The Future of Maintenance in General Aviation The perspective from the European sailplane manufacturers by Werner Scholz, Spokesman of the European Sailplane Manufacturers

Contents: Introduction Basic comments regarding Part M Comparison of Part M with old status Summary and assessment of Part M

Introduction „Who are we - whom do we represent?“ The European sailplane manufacturers are represented by two associations: Verband deutscher Segelflugzeughersteller, Germany European Glider Manufacturers and Suppliers association, East Europe Together they include 13 companies (representing more than 1000 employees) in Austria, Czech Republic, Germany, Lithuania, Slovenia. Further members of the sailplane “industry”: other European sailplane manufacturers manufacturers of glider-typical avionics manufacturers of trailers and equipment glider maintenance facilities

Introduction „Who are we - whom do we represent?“ In total the European sailplane industry represents: more than 20 sailplane manufacturers more than 30 manufacturers of gliding equipment more than 90% of world-wide sailplane production (over 400 new aircraft per year) more than 3000 employees at the manufacturers and associated companies

Introduction „Who are we - whom do we represent?“ The European sailplane maintenance industry sector represents: much more than 100 sailplane maintenance shops (perhaps even more than 200 - no central association existent) certainly hundreds of employees several hundred approved inspectors according to national rules conducting airworthiness reviews on a honorary basis (in their free time) within the national gliding federations The European gliding community in Europe includes: more than 20.000 registered sailplanes more than 70.000 pilots flying gliders and powered sailplanes

Introduction „Who are we - whom do we represent?“ The European sailplane manufacturers do not claim that they can represent all stakeholders of the gliding community in Europe. BUT: the manufacturers know “their market” (= the operators & the maintenance sector) very well since more than 50 years they know how continuing airworthiness is been handled until now as some work also as maintenance organisations they know as TC holders that there is no general safety problem due to a lack of proper maintenance they know that more complicated regulations will lead towards loss of much more pilots due to frustration and increased costs they already experience the effects of a slowly shrinking “gliding scene”

Basic comments regarding Part M „Motivation of Part M“ Obviously the basic idea of Part M is to have a common regulation for continuing airworthiness within all EASA member states. The claimed benefits for stakeholders should be: standardised rules valid in all member states common safety standards regarding maintenance procedures common minimum standards regarding maintenance personnel avoidance of duplication at national / European level facilitation of a “free movement of goods and services” within Europe (= to alleviate the selling of aircraft between member states and to ease cross-border maintenance of aircraft) promotion of cost-efficiency in the regulatory process So how does this all fit to the gliding community? - See later.....

Basic comments regarding Part M „Part M is a very complex regulation“ Part M is by far too complex and difficult to read and understand. This regulation will be a “must read” at least for all maintenance organisations & manufacturers & inspectors (= many persons not having a legal / academic background). format with many cross-references within Part M and towards other regulations language with many abbreviations partition into regulation and AMC material This problem is even made worse as the official translations offered by the authorities are sometimes wrong and/or not directly fitting to the English original wording.

Basic comments regarding Part M „Part M will not allow simple continuation“ EASA officials have verified that Part M is introduced not to cure a pressing safety deficit but to standardise maintenance in Europe with the idea that basically most national maintenance procedures within light aviation should be possible to be continued. Nevertheless the competent authorities (= the NAA responsible now to implement Part M in the member states) have already started to change rules regarding continuing airworthiness to implement Part M. This is definitively not a continuation of well established maintenance procedures!

Comparison of Part M with old status „Basis of the comparison“ Based on the experience in the member states of more than 50 years of sailplane maintenance, a comparison between the “old status quo” and the new Part M procedures has been made. Data for this comparison has been accumulated by the European sailplane manufacturers the European Gliding Union (EGU) representing the gliding sectors of the national sporting federations by a large number of European maintenance organisations (traditional repair shops and also federations / clubs conducting glider maintenance) This comparison is primary valid for gliding but organisation within light aviation (e.g. ballooning, small aeroplanes) have already signalled similar conclusions!

Comparison of Part M with old status „Regular physical survey / issuance of ARC“ The fundamental cornerstone of glider maintenance until now: A physical survey of the aircraft on a regular basis directly resulting into issuance of the ARC for continuing flight operations until the next survey (or a maintenance/repair event). This might be likened to a basic “maintenance philosophy” similar to the operation of a private owned car: maintenance is been conducted on a “on need basis” the showing of “streetworthiness” is only required in certain intervals and/or after special maintenance/repair events operations of the car allowed immediately after completion of the physical survey without further “registration/certification” by authorities

Comparison of Part M with old status „Regular physical survey / issuance of ARC“ Within Part M this will be in the future: A physical survey of the aircraft on a regular basis resulting into issuance of the ARC either by the competent authority or a CAMO+ and introduction of a certificate of release to service after every maintenance event. This certainly stems from the “maintenance philosophy” of the maintenance and operation of commercial air transport airplanes: maintenance is been conducted on a “procedural basis” the aircraft “is owned by” the technical/maintenance organisation and can only operated after a release to service maintenance operations only possible with consent of the authorities based on regulated procedures and approved personnel

Comparison of Part M with old status „Regular physical survey / issuance of ARC“ The introduction of the additional step for the issuance of the ARC by the competent authority / CAMO+ and the obligatory release to service certificate will: increase the number of administrative “steps” until the glider will be back in service this translates into time delays (remember: more than 20.000 gliders!) this also means increased costs for the owners this does nothing to improve the actual physical survey this does therefore also not increase safety

Comparison of Part M with old status „Airworthiness survey & introduction of maintenance programs“ Until now the check of the technical documentation for each particular glider was made parallel to the physical survey and typically included: review of the logbook of the glider / engine / propeller review of the findings report for this glider before start of the maintenance check against procedures described in the maintenance manual issued by the manufacturer check against existing service bulletins / airworthiness directives entry of all findings during the physical review against a check list provided by the maintenance manual or (if not provided) against a check list suitable for gliders / motor gliders All was done together with the inspector during the physical survey.

Comparison of Part M with old status „Airworthiness survey & introduction of maintenance programs“ Now the check of the technical documentation will be THE central point for the airworthiness review of each particular glider and is not necessarily coupled to the physical survey. Additionally now every individual aircraft needs to have an maintenance program with an approval of the competent authority. These maintenance programs will in most cases not give more information than the already existing information supplied by the manufacturer as (contrary to commercial air transport) the maintenance organisations do typically not develop own procedures. Even this “standard maintenance program” now will need approval! Issuance of the ARC will be done typically by persons not seeing the actual aircraft but based on the accompanying paperwork!

Comparison of Part M with old status „Airworthiness survey & introduction of maintenance programs“ This new system can only work if ALL participating partners are familiar with the new administrative procedures (this implies the need for training thousands of persons) have suitable background (excluding the experienced “worker-type” maintenance people) have the additional time for the new additional administrative steps (making the work for the honorary / free-time inspectors even more difficult as their time per glider inspection is limited) Therefore the following results seem to be (again) time delays cost increase loss of maintenance workforce with resulting degradation of safety....

Comparison of Part M with old status „Maintenance personnel - certifying staff“ Until now the maintenance personnel in gliding consisted of: the owners/operators conducting the lion share of typical regular maintenance tasks (often referred to as “winter overhaul”) the inspectors within the gliding federations conducting the regular airworthiness reviews on a honorary basis (in their free time) or at least on a “at cost price” the personnel within maintenance organisations and/or the manufacturers with detailed knowledge for special systems and/or repairs and major maintenance tasks Typically some form of approval was required for inspectors - this was granted under supervision / directly from the NAA. BUT: Besides the minimum technical expertise required the maintenance personnel was not excessively regulated.

Comparison of Part M with old status „Maintenance personnel - certifying staff“ Regarding maintenance personnel and inspectors (now identified as certifying staff) the situation will be more complicated after introduction of Part M: regarding certifying staff Part M refers to Part 66 Part 66 defines categories of qualifications for aeroplanes and helicopters and components (excluding gliders) for all other aircraft (e.g. sailplanes) Part 66 refers to relevant member states regulations (resulting into a return to existing systems regarding maintenance personnel/certifying staff This raises two questions: why this complicated introduction if nothing changes? what happens if some NAA will simply delete their national regulation in favour of Part M / Part 66 thereby “forgetting” gliders?

Comparison of Part M with old status „Maintenance organisations approvals“ Until now a typical maintenance organisation typically had to show: compliance to national rules written in the national language and based on the particular local experience some form of certification for the organisation audited by the local authorities some minimum requirements regarding the qualification of the workers some approved qualification for the inspectors (issued directly or under supervision by the NAA) Normally this meant: one single approval for the maintenance organisation individual approvals for the inspectors

Comparison of Part M with old status „Maintenance organisations approvals“ Now a typical maintenance organisation needs: compliance to EASA rules written in a complicated language (sometimes not improved by the official translation) plus additional national rules fitting more or less to Part M one certification for the maintenance tasks (Subpart F) one certification for the inspections tasks (Subpart G) - now referred to as Continuing Airworthiness Management Organisation (CAMO) compliance - if applicable - with Part 66 / Part 145 if the tasks performed fall outside the pure glider world / outside of Part M still a regular auditing by the competent authority but now based on a much more complicated regulation system introduction of quality assurance systems into their organisations as the new organisations approvals require

Comparison of Part M with old status „Maintenance organisations approvals“ This already means: small maintenance organisations (read: repair shops) do not know if approval under Subpart F and G will be feasible for them some existing maintenance workforce will be lost as they cannot afford this step towards the new approvals air-sport federations acting as maintenance organisations face new and unfamiliar approval processes (mainly with managers working in their free time and/or under quite limited working time constrains) manufacturers offering maintenance tasks beside their production process face additional approval processes to continue these maintenance tasks the owner will finally pay for all this application processes without any safety benefit for his glider and his personal flying....

Summary and assessment of Part M „Motivation of Part M - revisited“ Obviously the basic idea of Part M is to have a common regulation for continuing airworthiness within all EASA member states. The claimed benefits for stakeholders should be: standardised rules valid in all member states common safety standards regarding maintenance procedures common minimum standards regarding maintenance personnel avoidance of duplication at national / European level Especially for gliders the rules about maintenance / certifying staff will still be based on national rules. This does not necessarily needs to be a disadvantage as those rules already work very good. BUT the additionally regulations / administrative procedures as required by Part M will make maintenance in gliders much more complicated and expensive .... without discernible safety benefit!

Summary and assessment of Part M „ Motivation of Part M - revisited“ Obviously the basic idea of Part M is to have a common regulation for continuing airworthiness within all EASA member states. The claimed benefits for stakeholders should be: facilitation of a “free movement of goods and services” within Europe (= to alleviate the selling of aircraft between member states and to ease cross-border maintenance of aircraft) promotion of cost-efficiency in the regulatory process The alleviation regarding selling a glider in Europe will only work if the NAA will be accepting the rules by the other NAA - which was historically not the case until now - so why should this function now? Therefore cross-border maintenance still will be difficult. And within the gliding community no one has been heard to foresee ANY cost benefit due to the introduction of Part M ......

Summary and assessment of Part M „ Where are we standing now?“ The concept “one regulation that fits all sectors of aviation” is not working regarding maintenance of gliders. Either Part M needs some fundamental changes or extensive changes are needed in the AMC material of Part M / Part 66. The basic idea of rulemaking task MDM.032 has been claimed to be “simple regulations for light aviation” - this is of course linked to Part M and directly influences future of maintenance for GA. (But ONLY for non-commercial activities!!) The tasks M.005 (pilot-owner maintenance) and M.017 (review of NPA 7/2005 after Part M regulatory impact assessment) must result into important changes very fast (in order to stay within the time scale as EU 2042/2003 gives 28.9.2008 as final introduction date).

Summary and assessment of Part M „ Where to go?“ Today there is no one claiming a basic safety problem regarding maintenance / continuing airworthiness for gliders (or for General Aviation). Therefore: only change when there is a need for change! If a common regulation is really envisaged then a simpler regulation is needed than Part M (and Part 66) and then it really must be standardised in all member states. If the Agency / EU commission / EU parliament feels national regulation to be sufficient then make a “mini Part M” only approving existing national regulations (as existing now) as valid in all member states. Therefore: a clear decision between European / national rules! And: Extend the time schedule to avoid “quick fixes” and chaos!

Thank you - any questions?