# Presentation: 840308

## Maintenance

**Notes:**
Wednesday, June 3, 2008
Workshop Series 3, 10:30 AM – 12:00 PM

Moderator:  Yasuhisa Tani, Director of Engineering Department, JCAB

Presentation Panel:  
Robert Reich, FAA
Mark Sinclair, CASA Australia
Yves Morier, EASA
Nancy Graham, ICAO

## Major Discussion Points

_**Pending FAA Authorization**_
- Done every 5 years  (House completed actions, Senate has not – versions not aligned)
- House Bill HR 2881
- requires foreign repair stations to be inspected 2 times/year
- Senate Bill 1300 (more favorable to industry and FAA)
- No increased inspections
- Impacts:
- 	Not supported by safety data
- 	Strain on FAA resources
- 	Other countries may take similar actions

## Major Discussion Points

_**Contract Maintenance**_
- OIG reports 2003 and 2005  -  FAA working to improve oversight of repair stations and air carrier use of maintenance vendors
- FAA Actions:
- 	Enhanced Repair Station Oversight System (launched in 	September 2005)
- 	Quarterly Utilization Report
- 	FAA focused team inspections
- 	Proposed Rulemaking on Air carrier manuals
- 	Proposed rulemaking on repair stations (ratings 	structure/quality system/)
- 	Inspector outsource maintenance training program (prototype 	completed)
- Owner/operator is responsible for airworthiness.

**Notes:**
The EASA approach is different from the FAA and to some extend from what ICAO had originally proposed in its September 2007 State Letter.

EASA split out ETOPS from LROPS:
 due to the regulatory impact assessment (regulatory impact not demonstrated) and
 the confirmation by diversion statistics for 3 or more engined airplanes of European register involved in commercial air transport.

## Major Discussion Points

_**Proposed line maintenance authorization**_
- Article 4 of the Maintenance Annex: Implementation
**	**Covers all additional fixed locations within EU member states
- 	Requires appropriate FAA annex to EASA form 6
- 	Line maintenance in Europe has Special Conditions (Appendix 1)
- 	Line Stations outside the EU do not fall under the agreement
- Proposed Agreement does not allow EASA line stations to exist outside of US territories (EASA side of approval) under new agreement.  Current MIPS with Germany, France, Ireland allow this today
- Transition from old to new agreement
- To assist, both FAA/EASA put together training modules describing:
- How EASA and FAA work together
- How a US repair station gets EASA certification
- How an EASA repair stations gets US certification

## Reaction from the Floor

- Concerns with FAA based EASA repair stations and the alignment of privileges of certificate ratings
- EASA repair stations outside the EU held to same standards as EASA repair stations outside the EU (Certificated as foreign repair stations by EASA)
- Concerned with FAA rule changes (14 CFR Part 145 – ratings and quality systems) and their impact on the upcoming US/EU agreement.  Authorities did consider the impact as part of the Special Conditions
- Authorities need to consider impact of allowing U.S. based EASA repair stations to perform “EASA release only” on EASA based type design products when not on U.S. repair station capability list.

**Notes:**
FAA and CASA were generally congratulated for completing their rulemaking projects.
FAA/JAA had ETOPS as an original harmonization item in the FAA/JAA Harmonization Work Program (HWP) from 1992 until the HWP was ceased to be published after 2004.  It was noted that both FAA and JAA had convened public groups that had  worked the issues for several years, and it was noted as disappointing that harmonization had not be achieved – with FAA now publishing its final rules (addressing 2, 3,  and 4 engine aircraft) and EASA now addressing 2 engine airplanes only.
European Cockpit Association expressed disappointment that some of the regulations, such as the FAA regulations, did not address cargo operations, noting that a high level of safety should apply to all operations.
European Cockpit Association expressed concerns that adequate consideration had been given to conditions as alternate airports, such as weather conditions, and the impact on passengers arriving at such alternates that are identified for extended range operations, especially those in polar areas.

## Outcomes/Additional Ideas

- Industry personnel want the Authorities to continue to have dialogue with them on their concerns in order to minimize the impact on their operations when the transition to the new agreement comes to fruition

**Notes:**
The ICAO representative stressed that a new approach was needed and that ICAO will “start” with a clean sheet as it begins its work.

No further work between the Authorities is planned at this time.