AEA European Regulatory Update
December 2010

As 2010 comes to an end, it is appropriate to report advances in three important areas for AEA Europe members. AEA’s Vice President of Government and Industry Affairs, Ric Peri recently completed a two-week European trip in support of AEA Europe members. Highlights of that trip are as follows:

  1. Dual Release of components by foreign AMOs,
  2. The B-2L (formerly B-4) license, and
  3. Availability of B-2 aircraft type training. 

Aircraft Type Training
Since the establishment of EASA, the AEA has been working with EASA and the industry to find a viable solution for the 100-plus aircraft type ratings that are required by the AMC to Part 66.  While EASA has made significant strides in redefining the aircraft type rating requirements for B-2 engineers, the basic issue of type ratings for large and complex aircraft is a high hurdle to cross. 

For nearly two years, the AEA has been in discussions with the European Aviation Maintenance Training Committee (EAMTC), an organization of European Part 147 training organizations, regarding the type training challenge.  Following a November meeting with a Part 147 training provider, the AEA has a plan moving forward to facilitate B-2 type training. 

During January, the AEA will be surveying our European members to define the scope of B-2 engineers, the current rating they hold, and the ratings they most desire over the next few years.  Following the survey, the AEA will plan a discussion session during the annual 2011 AEA Europe Regional Meeting scheduled in Copenhagen in May.  If the type training needs support the development of a program, the first type transition training could be available as early as the 2012 AEA Europe Regional Meeting.

B-2L License
The EASA working group on the development of the B-2L license is finishing its proposal.  This EASA rulemaking working group is chaired by AEA’s Vice President of Government and Industry Affairs, Ric Peri and also supported by AEA European Director, Garry Joyce.

The final product proposes a license that recognizes avionics technology and is both task- and type-rated, but allows for an optional progressive approach to accomplishing the entire B-2 license.  There are some significant limitations to this proposal, but generally, the B-2L would be able to Return-to-Service all non-complex aircraft limited to the specific systems that they have been approved for.  The final proposal should be submitted to EASA early in 2011 with a NPA published late in 2011. If approved, a final rule should be published sometime in 2012.

Dual Release of components by foreign AMOs
Following this issue being raised at the 2010 AEA European meeting last June, the AEA has been working with EASA as well as the FAA to identify the regulations and requirements for a dual release of components for import into Europe.  As many of you know, the FAA regulations for overhaul is slightly different than that of EASA, as well as the FAA regulations for making minor changes to TSO’d articles by repair stations.  The issue is not nearly as clear as it initially appeared to be.  Initially, the limitations on the changes to ETSO components seemed to clarify the issue. However, for FAA TSO’d components maintained by an EASA 145 located in the U.S. and covered under the EASA – FAA agreements and operated under the EASA MIP-G document, it appears that the U.S.-based EASA 145 may be able to make minor changes to components.

AEA will continue to raise this issue at every opportunity until a clear answer is obtained from EASA.

As always, we welcome and appreciate member comments. If you have any questions about these three issues, please do not hesitate to contact Ric Peri at

Also, please note the dates and location for the upcoming AEA International Convention & Trade Show: March 22-25, 2011, at the Grand Sierra Resort in Reno, Nev. Your attendance is encouraged. For complete convention details, visit:

Contact Ric Peri, AEA vice president of government and industry affairs, by email at or by phone at 202-589-1144.