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PtF Permit to Fly
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European Aviation Safety Agency PtF Slide 2 Permit to Fly - Some major principles of the new rules - Frequently asked questions - Discussion / Questions
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European Aviation Safety Agency PtF Slide 3 Old rules Permit to Fly Until 28 March 2007 21A.174(d) Application 21A.185 Issue of permits to fly NAA issue PtF after: Agency found that aircraft can perform safe flight (with restrictions) But: 1702/2003 article 2.11: NAA makes findings until 28-3-07
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European Aviation Safety Agency PtF Slide 4 Permit to Fly Some important principles: Different types of PtF all covered by one rule shared responsibility: Agency – NAA Old national PtF grandfathered Applicable to EU registered aircraft Valid in all member states Privileges for DOA and POA Maintenance rules in flight conditions Separate Subpart P: Permit to Fly
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European Aviation Safety Agency PtF Slide 5 Different types of PtF all in one rule Complicating factor for drafting Existing (R) C of A temporarily invalid unapproved change Unrepaired damage (long) due maintenance Pre C of A TC not yet issued (Production) Flight testing C of A or Restricted C of A not appropriate or not possible Air racing / record breaking Some orphan aircraft
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European Aviation Safety Agency PtF Slide 6 Shared responsibility Agency-NAA Complicating factor for drafting: shared responsibility: Agency – NAA Agency: All design issues NAA: Conformity (production) C of A issuance and oversight Permit to Fly issuance Implementation of maintenance rules Permit to Fly: often deviation from approved design: Agency involvement
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European Aviation Safety Agency PtF Slide 7 PtF Grandfathering Principle: All PtF or other certificate grandfathered until first expiry date or 28-3-08 maximum For “permanent” PtF: flight conditions are grandfathered indefinitely (until need for change), unless Agency determines insufficient level of safety (Reg 1702/2003 art. 2.e)
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European Aviation Safety Agency PtF Slide 8 PtF applicability PtF rules applicable only to aircraft registered in EU; or Unregistered when identification marking prescribed by MS (Reg 1702/2003 art. 2.2) Result: PtF rules do not cover validation of foreign PtF: use national rules Under new BR need to develop IR for this
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European Aviation Safety Agency PtF Slide 9 PtF validity PtF issued in accordance with new rules are valid in all Member States: No additional national conditions / limitations Holder must comply with other local operational rules outside scope of PtF National rules should not obstruct free circulation
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European Aviation Safety Agency PtF Slide 10 DOA/POA privileges DOA (possible) privileges: Approve flight conditions for all PtF except 21A.701(a)(15) Issue PtF when configuration controlled by DOA POA (possible) privileges: Approve flight conditions and issue PtF for aircraft it produced when design is approved In previous draft: privilege for CAMO: this is subject of Opinion 4/2007
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European Aviation Safety Agency PtF Slide 11 Maintenance rules for PtF According to 2042/2003 art. 3.3 aircraft under PtF are exempted from Part M In stead: maintenance rules are defined in the flight conditions In most cases they can refer to Part M
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European Aviation Safety Agency PtF Slide 12 Separate Subpart P Initial drafts were amendments to Subpart H (airworthiness certificates) Due to complexity decided to create new subpart As a consequence all references to PtF are deleted from subpart H
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European Aviation Safety Agency PtF Slide 13 FAQ Q: Must a PtF be applied for when one of the purposes mentioned in 21A.701 is applicable? A: No, only when the (R-) CoA is invalid or not yet issued
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European Aviation Safety Agency PtF Slide 14 FAQ Q: Can an aircraft on a PtF do commercial operations Under EU-OPS it is impossible (without exemption) For the future IR-OPS it is not excluded by definition but in practice most PtF will have the limitation that no passengers may be carried
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European Aviation Safety Agency PtF Slide 15 FAQ Q: where is the PtF valid A: the PtF is valid in all EU within the limitations on the PtF. Outside EU there is a need to ask for validation of the PtF by the countries overflown
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European Aviation Safety Agency PtF Slide 16 FAQ Q: Does EASA have 24/7 service for approval of flight conditions? A: No, however NAAs have the Agency emergency phone number. NAAs can always use article 14.4 for urgent operational needs
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European Aviation Safety Agency PtF Slide 17 FAQ Q: Who is the holder of the PtF A: The applicant will become the holder when the PtF is issued E.g. If a modifier uses the aircraft of an operator to demonstrate compliance this modifier is expected to apply for the necessary PtF; and will also be the holder
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European Aviation Safety Agency PtF Slide 18 FAQ Q: can a PtF be applied for using approved flight conditions which were not applied for by the same applicant? A: Yes, the applicant for PtF and applicant for approval of flight conditions do not necessarily have to be the same person
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European Aviation Safety Agency PtF Slide 19 FAQ Q: can the DOA privilege be used for aircraft that are not under the control of the DOA? A: Yes, the privilege to approve flight conditions can be used for any aircraft; as long as it is within the scope of the approval The privilege to issue PtF is limited to aircraft under the control of the DOA
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European Aviation Safety Agency PtF Slide 20 FAQ Q: if the approval of flight conditions contains design and not-design related issues, who should the approve the flight conditions? A: An interpretation could be that you would need approval by the Agency of the design related and by the NAA of the non-design related; however to avoid undue burden the Agency will accept to approve both as one package
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European Aviation Safety Agency PtF Slide 21 END
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