SOUTH ASIA REGIONAL INITIATIVE

Transcription

1 SOUTH ASIA REGIONAL INITIATIVE 8 th SARI 21 WG meeting Prepared by: ED Kathmandu, 6 to 8 February 2018 MEETING PARTICIPANTS CAA Bangladesh CAA Maldives CAA Nepal Trans Maldivian Airways (1) Yeti Airlines (1) Air Dinasty Heli Services (1) Buddha Air (1) Mountain Helicopter (1) Manang Air (1) EASA SARI Refer to the list of participant given in annex 1. Absence of CAA Bhutan, DGCA India, CAA Pakistan and CAA Sri Lanka were regretted. Meeting agenda is attached as annex 2. SUMMARY 1. General: The draft agenda was modified to take into account the absence of CAAN in the previous meetings and the agenda of day 3 was replaced with study cases presented by the CAAM, CAAB, CAAN, the Nepalese operators and MAT. SARI reminded the participants that this 8 th SARI 21 WG should be the last one before the publication of SARI Part 21 issue 1. A SARI presentation summarizing the achievements of the 7 previous meetings and the objectives of the 8 th meeting was developed and delivered by the SARI Coordinator. The presentation emphasized the link between Part 21, Part M and Part 145 in particular. A presentation (EASA Part 21 rule making activities affecting Part 21) was delivered by the EASA expert who also highlighted the links between Initial and Continuing 1 / 10

2 Airworthiness. During the presentations the following questions were addressed: Is the DOA personnel holding licence: No licensing system to support Part 21 Subpart J. It is the responsibility of the design organization to define the level of competence their personnel needs, to train them and ensure maintenance of competence (Refer to 21.A.239 & 234). Can an aircraft delivered in kit be assembled by a Part 14 approved organisation : This aircraft is subject to Part 21 Subpart G (POA) and should not be assembled under Part 145 since after its assembly it will get its first CoA. EASA/SARI underlined that Part 145 organisation can only maintain an aircraft after this aircraft has received its C of A. 2. Development of SARI Part 21 subpart B, D, E and M 2.1 Subpart N The Subpart Part N concept was presented and the draft regulation reviewed. The following changes will be made to the issue dated 01/12/17: 21.N.3 (a)(2): delete in all MS 21.N.5: replace A by The and do the necessary adaptation in the whole paragraph. 21.N.41: check the concept 21.N.61: rewrite (a) major change to the type design of a product 21.N.63: keep (b)(2) but replace current ref with 21.N.63(b) 21.N.63(b)(1): delete et renumbered below 21.N.65: add (a) and (b) shall include the information..with the type certificate holder 21.N.67: modify (a) and delete comment 21.N.71: remove highlight 21.N.85: replace 21.N.63(b)(2) with 21.N.63(b) Besides the review of Subpart N, EASA: Clarified the difference between the intent of the Subpart-H 21.A.174(b)(3) Importing of an aircraft, and the intent of the Subpart-N to facilitate the validation/acceptance process of foreign certification approvals (linked to eventual importing of products for later registration in the importing State). Explained that this subpart is not in EASA Part-21 because the call for bilateral agreements or working arrangements is directly given by the EU Basic Regulation. Showed example of the WA between EASA and FATA (Working Arrangement on Airworthiness between EASA and FATA), available in the EASA internet webpage. 2.2 Introduction to SARI Part 21 The draft document including a foreword, the list of amendment, list of effective pages and a list of content follows the usual format of the SARI Parts. It will be completed before the end of 2018/Q2 2 / 10

3 2.2 Section A - Subpart A Add definition of principal place of business Check content of Articles 8, 9 and 12 in EASA Part 21 and if necessary reflect it in SARI Part 21 Revise Part 21.A.1E and change title to reflect the case where MS have Cof A with limited validity 21.A.3A: Replace title with Occurrence assessment and reporting 21.A.3(A)(B)2: Check character size 21.A.4: Delete reference to paragraphs related to Subpart F 2.3 Subpart J Extensive explanations on the concept of DAS were provided as well as on the interface between Subpart G and J organisations. The case of first issuance of an approval to a Design Organisation was explained 2.4 Subpart G Add gyroplane in the list of definition in Subpart A 2.5 Other Subparts Subpart-O about [SARI] TECHNICAL STANDARD ORDER AUTHORISATIONS will be included in SARI Part Study cases The following study cases raised by the SARI Member States were addressed: Case study-1: Maldives. FRA150L to FA150L, swap of engine/propeller installation from one A/C model to the other. It has to be done through STC. Case study-2: Maldives. STC for modification of cockpit instruments. The objective was to monitories engine parameter, and presented in digital form. Contracted to EASA DOA organisation, and coordinated with CAAM. Training programme was also articulated with Garmin for the use of the instruments. The EASA DOA shared only the technical publications with TMA and CAA Maldives (ICA and installation data), not the compliance demonstration data. The CAAM recognises that it could be complicated to get access to the compliance demonstration data. Contacting directly the EASA DOA organisation by the CAAM may be a way to have access to compliance data however the DOA might refuse data disclosure as there is not legal agreed framework between EASA and the CAAM to allow this. In future, if a WA is put in place between the authorities, it will facilitate the validation of approvals, through direct communication channel between authorities. 3 / 10

4 In the past, there were modifications developed by the TMA MCAR 145 organisation who requested CAAM approval. This practice is stopped, and the CAAM requires now systematically to have design changes / repairs approved by FAA or EASA system. Regarding repair designs nowadays TMA Part 145 approved organisation designs the repair scheme and a DOA organisation contracted by TMA evaluate and approve the airworthiness of the repair. Case study-3: Nepal. Bhuda Air. Development of a minor design change done by EASA DOA and finally endorsed by CAAN is common practice. Case study-4: Nepal. Bhuda Air. FAA STC to install engine-monitoring system. The STC was approved by CAAN but with no supporting compliance data. Should a working arrangement had been in place such approval would not have been necessary. The CAAN would only have approved the STC installation by a NCAR organisation. Case study-5: Nepal. Installation of external equipment in helicopters. CAAN only receives installation instructions. No compliance demonstration data was shared from the DAH with the operator / CAA. Case study-6: Bangladesh. Typically they face situations needing to develop and approve repair design solutions. The operator develops the solutions directly and applies to the CAAB for approval. In some cases a NTO from the TC Holder is attached but no compliance data provided. EASA and SARI reminded that NTO is not compliance data. Case study-7: Maldives. STC for life extension of the wings (and the aircraft). Coordinated with Viking (TCH), USA STC organisation (STCH for the life extension on the LLPs) and FAA (State of Design Authority for the STC). It has been validated by EASA and TCCA. Noteworthy aspect is what is happening today in Nepal regarding ultra light aircraft. Ultra light aircraft registration is growing in Nepal. However, per NCAR (Issue 05 March 2017), only ultra light aircraft certified by foreign systems (EASA, FAA, ASTM, others) are accepted for registration in Nepal. CAAN recognizes that they are not in a position to permit eventual case of local industry willing to design and certify a Nepalese ultra light aircraft because CAAN is not prepared to conduct the necessary technical investigation tasks today. This is clear showstopper for the local industry to develop. The ultra light aircraft case will be also address during the 7 th SARI WG meeting in Kathmandu from 26 to 28 of February Main outcomes of the practical cases: In most of the cases, design changes / repair solutions are developed by FAA / EASA design organisations, and later endorsed by CAAs. This ensures compliance with airworthiness standards today. Exception seems to be for Bangladesh where the operator develops directly the repair design (145 mind setting mainly), obtains and NTO from the TC holder then applies for direct CAAB approval. This practice should 4 / 10

5 be avoided, until having regulatory framework facilitating proper compliance demonstration articulation. Compliance demonstration data to the certification specifications is not shared, not visible to the operators neither to the CAAs. Authority to authority Working Arrangement(s) (WA) would facilitate relation and communication between authorities. In some cases, NTO from TC holder is enclosed. This is giving confidence to the operator / CAA. However NTO is not compliance data neither constitutes an approval of the design change / repair design by the TC holder. Local regulations today refer to technical data, to be provided as part of the documentation package to support the design change / repair design approval. However, EASA mentioned this wording is ambiguous. It should better refer to compliance demonstration data as instructions for installation of change / repair are also technical data. 4. Round table on the adoption of SARI Part 21 by SARI Member states! EASA and SARI coordinator asked the CAA participating in the meeting to expose their possible roadmap for the adoption and implementation of SARI Part 21. Overall end of 2020 was considered as a realistic objective (2019 for Maldives and 2020 for Bangladesh and Nepal provided SARI Part 21 issue 1 is published in 2018/Q2 or Q3). A draft roadmap was established during the meeting (refer to annex 3).! SARI pointed out that in case a SARI MS needs a dedicated ad hoc session on specific Part 21 issues during its adoption and implementation phase of SARI Part 21 this could be considered and arranged. 5. Conclusions: The development process of SARI Part 21 is now completed and not additional SARI 21 WG meeting will be necessary before the publication of SARI Part 21 issue 1. SARI Part 21 issue 1 will be distributed to the SARI MS as draft during 2018/Q2 after fine tuning of it introduction as well as Subpart A, E and N, correction of editorials, development of Subpart O and of all the forms supporting Part 21. SARI Part 21 issue 1 will be officially published end of 2018/Q2 beginning of 2018/Q3. CAA Bangladesh, CAA Maldives and CAA Nepal recognise the interest presented by Section N and the concept of working arrangement between the authority of the country of design and the CAA of the importing country. CAA Bangladesh, CAA Maldives and CAA Nepal agreed to adopt and implement SARI Part 21 issue 1 before the end of SARI will seek agreement from the other SARI MS when the draft SARI Part 21 issue 1 will be distributed. SARI will liaise with the South Asia Aviation Partnership Project (APP) to provision 5 / 10

6 between 2018 and 2020 training on CS 23 and 25 in particular on structure and cabin safety. SARI when requested by a SARI MS will support the development of Working Arrangements related to importing products, parts and appliance involving this MS. A SARI MS may ask SARI /EASA for specific support to address Part 21 issues during its adoption and implementation phase of SARI Part 21. SARI may provision in the 2019 SARI WP a seminar on specific issues identified by the SARI MS during their SARI Part 21 adoption / implementation process. No other SARI 21 WG meeting is considered necessary before the publication of SARI Part 21 at issue 1 at the end of 2018/Q2. ************* 6 / 10

7 Annex 1 Country( Participant( Member( ( Bangladesh! Mr.!Md!Saiful!Haque!Shah! CAAB! Saif_aeld@yahoo.com! Bangladesh! Mr.!Md!Ataullah!Hasmi! CAAB! ataullahh@yahoo.com! Maldives! Mr.!Suraj!Panda! TMA! suraj@transmaldivian.com! Maldives! Mr.!Ibrahim!Mohamed! CAAM! Ibrahim.mohamed@caa.gov.mv! Nepal! Mr.!Ritesh!Pant! CAAN! Ritesh.pant@hotmail.com! Nepal! Mr.!bidhan!Shrestha! CAAN! Bidanshrestha84@gmail.com! Nepal! Mr.!Samrat!Pradhan! CAAN! prd.samrat@gmail.com! Nepal! Mr.!H.K.!Dahal! CAAN! dkumar.hem@gmail.com! Nepal! Mr.!Jose!M.!Salgueiro! CAAN! Jose.salgueiro@iasafety.aero! Nepal! Mr.!Deepak!R.!Koirala! Mountain! Helicopters! Dkoirala1@gmail.com! Nepal! Mr.!Nagendra!Dev!Pant! Yeti!Airlines! ndpant@yahoo.com! Nepal! Mr.!Upendra!Lal!Shrestha! Buddha!Air! ulshrestha@buddhaair.com! Nepal! Mr.!Udaya!B.!Shrestha! Air!Dynasty!Heli! Services! Shrestha.ub@gmail.com! Nepal! D.P.!Rajabhandari! Manang!Air! Digamber50@gmail.com! Europe! Mr.!Javier!Castillo! EASA! javier.castillo@easa.europa.eu! SARI! Mr.!Eric!Dormoy! SARI! eric.dormoy@searifssari.org! 7 / 10

8 Annex 2 SARI 21 WORKING GROUP EIGHT MEETING Kathmandu 6 to 8 February 2018 DAY Opening (CAAN/ SARI) Introduction of the participants (All) Status of the draft SARI Part 21 issue dated December 2017 (SARI) Coffee break Presentation of Part 21 Subpart N (SARI/EASA) Review of Part 21 Subpart N (All) Lunch Review of Part 21 Subpart N (cont d) (All) Tea break Remaining task for completion of SARI Part 21 Subpart N (All) Wrap-up day 1 (SARI) 8 / 10

9 DAY Final review of SARI 21 Subpart A - Section A & B (All) Coffee break Final review of SARI Part 21 Subpart A - Section A & B (cont d) (All) Final review of SARI Part 21 Subpart D & E Section A (All) Lunch Final review of SARI Part 21 Subpart D & E (cont d) (All) Tea break Final review of SARI Part 21 Subpart J Section A (All) WG agreement on the other Subparts to be reviewed during Day 3 (All) Wrap-up day 2 DAY Final review of other SARI Part 21 Subparts (All) Coffee break Final review of other SARI Part 21 Subparts (cont d) (All) Lunch Identification of remaining tasks before publication of SARI Part 21 (SARI) Round table on the adoption of SARI Part 21 by SARI Member states!!! (Commitment time scale etc ) Tea break Wrap-up day 1, 2 and 3 and conclusions (SARI/EASA) ************ 9 / 10

10 Annex 3 " Overall'Roadmap' 'dra.'expecta2ons' 1/2"" 2018" Training"on"cer1fica1on"specifica1ons"to"be"arranged"in"parallel" to"deployment"process."" " 2/2" 2018" " Goal:"Authority"readiness"at"the"rule"effec1veness"date." 1/2" 2019" " 2/2" 2019" 1/2" 2020" " 2/2" 2020" SARI821' Published'by' SARI'coordinator' CAAM' 'review' and'comments.' Start'rulemaking' process' NPA'procedure' '16' months'maximun' CAAM' 'rulemaking' process' NPA'procedure'on8 going' CAAM' 'rule' adoted' Publica2on'of' NCAR821' CAAM' 'CAR821'to' become'effec2ve' CAAM' 'CAR821'to' become'effec2ve' Maldives' Nepal' Rulemaking'process' B8CAR21' publica2on'(end' 2018' 'Q1'2019)' 2'years' implementa2on' B'8CAR821'to' become' effec2ve' Bangladesh' 08/02/2018" SARI"21"8th"WG"mee1ng"4"NEPAL"4"" 1" 10 / 10