Repair/Alteration Data Developed by JAA-Maintenance Organizations by Werner Luehmann, Lufthansa Technik, Germany

1. Repair/Alteration Data Developed by JAA-Maintenance Organizationsby Werner Luehmann, Lufthansa Technik, Germany Members of AEA: Adria Airways, Aer Lingus, Air France, Air Malta, Alitalia, Austrian Airlines, British Airways plc, BMI British Midland, Cargolux Airlines International, Croatia Airlines, CSA Czech Airlines, Cyprus Airways, Finnair, Iberia, Icelandair, JAT Yugoslav Airlines, KLM Royal Dutch Airlines, Deutsche Lufthansa AG, Luxair, Malev Hungarian Airlines, Meridiana, Olympic Airways, SAS- Scandinavian Airlines System, Spanair, SWISS, TAP Air Portugal, Tarom, Turkish Airlines 19 th FAA/JAA International Conference

2. The Data • Supplemental Type Certificates-> major alterations/modifications/repairs for JAA and FAA • JAA-minor changes/modifications/alterations • classified as FAA-major, or • classified as FAA-minor • JAA-minor repairs • classified as FAA-major, or • classified as FAA-minor • FAA-DER approved modification/repair data-> acceptable to JAA authorities ? 19 th FAA/JAA International Conference

3. Two Systems - One Goal 19 th FAA/JAA International Conference

4. The Problem (1) • Airplanes move from one register to another • Overhauled/repaired components cross borders • 10+ years after the original approval of the data • Mostly not covered by existing bilateral agreements • Additional approvals cause are waste of resources, beause of • duplication of effort and cost • loss of aircraft utilization • no „added value“ 19 th FAA/JAA International Conference

5. The Problem (2) • Unsolved differences in the definition of „major/minor“ • classification between Certification and Maintenance (FAA): (1) Major: FAR-1.1 FAR-21.93(a) = JAR-21.91  FAR-43, Appendix A (2) Minor: FAR-43.13 (a) and (b)  „NOT (1)“ ? • In terms of performing maintenance JAA does neither make a distinction between „major“ and „minor“ (only in JAR-21), nor between „approved“ and „accepted“ 19 th FAA/JAA International Conference

6. Where do we stand? • Slow (if at all) mutual FAA / JAA acceptance progress • JAA adoption of NPA 21-8 and 21- 17 and publication under JAR-21, Subpart M per 1 May 2002, includes extensive ACJ material • US-German BASA IPA STC process for almost three years can be considered essentially mature • We have a set of approval concepts in both systems with • DER/DAS + FAA in the US and • DOA + JAA-NAA in the Europe • FAA’s position to AEA is not clear 19 th FAA/JAA International Conference

7. The Solution (1) • A commitment is needed to proceed for data for ”minor changes/repairs” (majority of of cases) • We need reciprocal acceptance of each others concepts, because • a reciprocal acceptance looks more realistic and less time consuming than full harmonization • of experience from large airplane certification discussions • Maintenance MIPs and Certification IPAs with several European countries are a good example 19 th FAA/JAA International Conference

8. The Solution (2) • Documentation issues (e.g. use of FAA Form 337 for ”FAA-majors”) have to be solved • We need a simple and quick validation procedures for import of used products • Day to day problems of operators and maintenance organizations doing international business demand a quick, economical solution Let‘s start NOW. 19 th FAA/JAA International Conference