Maintenance Regulations Project

1. Maintenance Regulations Project NARTOCoP Melbourne 12 June 2008

2. Why NARTOCoP? A forum for open two way communication and information sharing. CASA values the feedback provided as an integral element of our industry consultation.

3. NARTOCoP Presentation • Project Changes • Progress overview since last NARTOCoP • Recap on Firm policies • Update on specific Parts • CAO 100.66 • B3 licence • Implementation lessons • RPL/RCC

4. Team Members • GA representative (Industry) • Continuing Airworthiness (CASA) • Team leader (CASA) • Maintenance licensing (CASA) • MRO Representative (Industry) • RPT operator representative (Industry) • Maintenance Sub-committee representative (industry) • Training representative (Industry)

5. Progress since November 2007 • Part 66 first draft 75% complete • Part 147 first consultation draft provided to MSC (February 2008) • Part 42 drafting on hold • Part 145 drafting on hold • Detailed policies on Part 42 virtually finalised • CAO 100.66 ongoing applications now routine business • Amendment 2 to facilitate transition • Ongoing liaison with EASA • B3 licence structure completed

6. Firm Policies • Large aircraft definition is a direct mirror of EASA • Part 145 organisations will require a SMS • Part 66 licence holders can operate independently • A, B1, B2 and C Licenses are the same as EASA • The B3 license is specific for small aircraft and not EASA-like • Flexibility in decisions on complex aircraft/ratings • Maintenance requirements integrated with Classification of Activities and Operational regulations

7. Integration with other CASA policy - Classification of Activities

8. ICAO vs. Australia – Current Situation ICAO • Commercial Air Transport Operation – An aircraft operation involving the transport of passengers, cargo or mail for remuneration or hire. It includes scheduled services, unscheduled services using chartered aircraft and small scale operations such as air taxis. • Aerial Work Operation – An aircraft operation in which an aircraft is used for specialised services such as agriculture, construction, photography, surveying, observation and patrol, search and rescue, aerial advertising, etc. • General Aviation Operation – An aircraft operation other than a commercial air transport operation or an aerial work operation, but includes paid flight instruction. Australia • Australia currently has four classifications defined in CAR 2 (7): • regular public transport (RPT) operation • charter operation • aerial work operation, and • private operation. • unclassified — Informal fifth classification covers activities that do not fit into the above four. Eg. flying displays and passenger-carrying in CAR 262AM (7) operations.

9. Proposed new classification scheme • The first class (Passenger Transport) comprises passenger carriage activities that: • are conducted in large and small aircraft which are certified in the transport, commuter and normal category; and • involve the carriage of passengers who have limited or no knowledge of the risks they are exposed to and have little or no control over the risks (other than choosing not to fly). • The Passenger Transport class includes, but is not limited to, passenger operations in scheduled and non-scheduled air services provided to the public. • Activities in Passenger Transport require an Air Operator’s Certificate (AOC) — full or graduated.

10. Proposed new classification scheme • The second class (Aerial Work) comprises activities in which: • the aircraft is being used for specialised in-flight purposes; and • the activity presents elevated operational and/or organisational risks, or the potential for significant consequences if there is an accident (by virtue of the number of persons carried on board and/or the area of operation). • The activities in the Aerial Work class are very diverse. Some may require a full AOC, graduated AOC, or some other permission subject to operating limitations. • Note: AOCs are one of the many tools and NOT the only tool that CASA can utilise to deal with operational and/or organisational risks.

11. Proposed new classification scheme • The third class (General and Freight-onlyActivities) comprises: • activities involving the carriage of “participants” — individuals who are adequately informed and have explicitly accepted the risks they are exposed to. Note: limits will establish the maximum number of “participants” that can be involved before an activity triggers increased regulatory oversight. • freight-only activities; and • any other aviation activities (e.g. crew-only) that do not fall into one of the other two classes. • Some activities in General and Freight-onlyActivities, e.g. freight-only activities in large aeroplanes, will require a full Part 121 AOC.

12. Classification of Activities and Maintenance Part 119 AOC -121 (Inc. Large Freight) -135 -133A Part 145 MRO Including AMC for all sizes of organisation from biggest to smallest LargeAircraft +Components Small Aircraft in PT + Components Includes CAMO Other AOC -132 -133B -136 -137 May include or contract a CAMO Small Aircraft not in PT + Components Sub part F Small Aircraft with no AOC Appendix VII Independent LAME Appendix VIII Small Aircraft not in PT (with restrictions) Pilot

13. Part 42 • Drafting of Subparts A to E ongoing • Drafting Instructions for Sub Part F (small maintenance organisation) and H (CRS) provided to OLDP. • Subparts G (CAMO) and Subpart I (Annual Review) to be provided to OLDP

14. Part 42 • Early introduction of Subpart F concept via CAO not viable • High level policy framework set and detailed technical work commencing on: • Airworthiness review small aircraft (non-Passenger) • Role of CAMO for small aircraft (non-Passenger) • Generic Maintenance Programs (Schedule 5) • De-couple annual/100 hourly • Independent LAME limitations (Schedule 7) • Pilot Maintenance (Schedule 8)

15. Part 145 • Drafting instructions with OLDP • Drafting commenced • First early draft received • Fundamental concept of ‘carrying out’ misunderstood has major consequences in Parts 42 and 66 • Work underway to review competencies for workshop personnel also applies to Subpart F • No outstanding policy issues related to drafting

16. Part 66 • Drafting currently ceased • First consultation draft about 75% complete • Working with DEEWR and TRA via Department

17. CAO 100.66 EASA like Maintenance Authorities • CAO 100.66 Amendment 2 issued • Will allow issue of licenses with ‘limitations’ to effect transitional outcomes of B1 and B2 licences • B3 license structure ‘decoupled’ from this amendment • CAO 100.66 continues to gain good voluntary use by industry

18. Part 147 • First consultation draft finalised • Lessons from CAO implementation incorporated into draft • Draft provided to MSC for comment • Only comment received from AMROBA • No comments from MSC since February

19. EASA Changes and liaison • Recent discussion held with EASA on Notices of Proposed Amendment (NPA) to their rules covering; • Certificate of Release to Service (CRS) • Part 66 licence scope, primarily B2 changes • Changes for implementation of regulations by GA • CRD to be published shortly • Application of Part M to GA will be deferred till 2009 in some instances • EASA are very interested in our initiatives on GA • Changes will be incorporated in draft Regulations Parts

20. EASA Changes and liaison • EASA is currently undertaking work in relation to Subpart G (CAMO) approvals in relation to ‘virtual airlines’. They anticipate issuing an NPA in the next three months. • Changes to EASA basic regulation will include some definition changes. Scope expansion also brings air operators and flight crew licensing under EASA (due for publication now).

21. EASA- CASA Arrangement Overview • The arrangement will be based on an assessment of CASA’s regulations, oversight capability and working practices in relation to EASA Part 145 and 147 organisations located in Australia. • To meet this requirement CASA must perform the oversight of the EASA Part 145 and 147 organisations according to EASA rules and procedures. The accreditation of CASA as equivalent to an EASA competent authority would be conducted according to EASA standardisation procedures.

22. Maintenance Regulations Project CAO 100.66 and Certification discussion

23. CAO 100.66 Update • Total B1 issued - 64 Total B2 issued - 44 • Total sub entitlements - 426 • EMB 170/190 • Airbus A380 (RR Trent 900) training being conducted (B1 and B2 – theory/practical) • Conversions of CAR31 ratings

24. CAO 100.66 Update Recognised Organisations for the Conduct of Category and Subcategory Training • Aviation Australia • Padstow TAFE

25. CAO 100.66 Update Recognised Organisations for the Conduct of Type Training • Qantas Airways LTD -A380 • Alteon Training LLC -B737-6/7/8/900 • Swiss Aviation Training -EMB/Saab/BAe146

26. CAO 100.66 Update Limited B1 • CAO 100.66 update issued 14 May 2008 as a result of EASA NPA 2007-07 proposal to expand scope of the B2

27. CAO 100.66 Update Limited B1 CASA has sent out the provided letter to explain the scope.

28. Certifications for Maintenance • Two required levels of Certification for Maintenance: • Maintenance Certification • Certificate of Release to Service

29. Maintenance Certification • This is the level of certification for tasks, that certifies that the maintenance was carried out correctly and in accordance with applicable Maintenance Data. • Maintenance Certifications made by: • Part 66 LAME working Independently under Pt 42; • AMO Authorised person: • Pt 66 LAME; • Specialist Services Qualified Person (EG NDT); • who either carried out or supervised the maintenance. • Appropriately Licensed Pilots, only for their own maintenance as authorised.

30. Certification of Release to Service (CRS) • This is a certification that all required maintenance has been completed and that with respect to that maintenance, the aircraft is airworthy or the aeronautical product is serviceable. • CRS will be made by: • Part 66 LAME: • Working Independently under Part 42 Authority for Aircraft Maint. • Category B1, B2 or B3 LAME with a Part 42 Sub-Part F AMO Authorisation for Small Aircraft Line or Base Maintenance. • Category A, B1 or B2 LAME with a Part 145 AMO Authorisation for Line Maint of Large Aircraft. • Category C LAME with a Part 145 AMO Authorisation in Base Maint of Large Aircraft. • AMO Authorised person for Aeronautical Products (ARC). • Appropriately Licensed Pilots, only for their own maintenance as authorised.

31. Privileges & Responsibilities Who Can Do What?

32. Notes on Certification • Certificate of Release to Service: • CRS is a Certification that all maintenance required (or ordered such as in a works order) is complete and that with respect to that maintenance, the aircraft is airworthy or the aeronautical product is serviceable. • This means that for multiple organisations that may be involved in a maintenance check or visit (such as other contracted AMO’s) a separate CRS may be issued, that would relate to the maintenance covered by the works order issued to that contractor. • Where an AMO sub-contracts an organisation that is not an AMO, the sub-contractor would have to carry out the maintenance ordered under the authorisation and Quality Assurance/ Control of the contracting AMO. The Contracting AMO would then be required to issue the CRS under its approval. • An AMO may wish to utilise a further level of Coordination Certification to assist the final CRS Certifier in coming to an informed decision as to the completeness of the maintenance. The regulatory outcomes are not intended to preclude the AMO designing an internal Certification structure that complements the required levels of Certification. The provisions would need to be detailed in the exposition and directly approved by CASA.

33. Maintenance Regulations Project B3 NPRM 0804MS

34. Expositions • Outcome–based Regulations • Acceptable Means of Compliance • Guidance Material • More flexibility for industry • Emphasis on managing risk

35. Expositions • The AMC material must be related to a specific regulatory provision. • The AMC cannot impose a regulatory requirement. • The AMC contains material that will allow an applicant to satisfy CASA of the related regulatory requirement if they follow the AMC material. • Material which is not regulatory in nature and does not address a means of compliance MAY be suitable for guidance material.

36. Expositions • An applicant can propose alternative means of meeting the regulation and this if approved by CASA (after removal of IP or commercially sensitive information) could be made into another AMC • If you come across material which is the ONLY way an applicant can comply then this is not suitable for an AMC. This will either become regulation or an Appendix to the regulation. • The AMC is effectively binding on CASA

37. Expositions Why have an exposition? Outcome based regulations generally prescribe the desired safety outcome and not the methods or means of compliance with the outcome. The organisation’s exposition provides the vehicle for an organisation to describe the process and procedures it intends to utilise to meet the required regulatory outcomes.

38. Expositions What other uses does an exposition have? • Application approval • To describe systems the organisation is developing or proposing • organisation to manage non-significant change • ongoing oversight

39. Expositions The exposition is designed to be a document that the organisation and its employees use as a matter of normal day to day business. Therefore it needs to be tailored to reflect the actual way that specific business operates and maintains compliance with the desired regulatory safety outcomes.

40. Extract from UK CAA CAP768 – Guidance Material 1 Purpose and Scope of an Operations Manual 1.1 It is a statutory requirement that an operations manual shall contain 'all such information and instructions as may be necessary to enable the operating staff to perform their duties'. 1.2 The form and scope of manuals will vary considerably with the nature and complexity of the operator's organisation and types of aircraft in use. A 'manual' may comprise a number of separate volumes and may well include individual forms, such as prepared navigation flight plans, supplied by the operator to his crew. Instructions and information to particular groups of operating staff - e.g. traffic manuals, cabin crew manuals, crew rostering instructions and information on weight and balance supplied to handling agents - can all be regarded as part of the operations manual. Applicants will be required to lodge copies of their manuals and associated documents with the CAA, together with copies of all amendments and temporary instructions. The operations manual will be regarded by the CAA as a primary indication of the standards likely to be achieved by an operator.

41. Expositions Where does an exposition live in the regulatory structure? A generic exposition template is merely guidance to an organisation seeking an organisational approval and would be published in guidance material. CAO 100.66 as an interim method of delivering the outcomes projected for Parts 66 and 147 has published an exposition template as an information bulletin.

42. Implementation lessons • Remote Locations • Delivery and examination • Industry Knowledge levels • Interaction between CAR31 and CAO 100.66 • Assessment Expectations • International Licence Recognition • Transition and Grandfathering • 147 Type rating training

43. RPL Lessons • Discussion - Handout

44. Questions ?