AEA European Briefing from Ric Peri

SUMMARY: Following the discussions at this year's round tables at the AEA European Regional Meeting in Copenhagen, a number of questions have been answered as well as a number of initiatives to challenges raised during the meeting.

  1. The implementation schedule for repair stations impacted by the new Europe/U.S. Aviation Safety Agreement is "up to" two years.  The authorities have until May 2013 to complete the transition.  During this two-year phase-in period, personnel from each NAA must attend EASA training regarding the management and oversight of U.S. FAA 145 certificates. As a result, until notified by your NAA, you should continue communicating with your appropriate FAA International Field Office.
  2. The Aviation Safety Agreement only applies to EU countries. The FAA and EASA are currently in discussions on how to address non-EU EASA countries.      
  3. I attended the OSD (Operational Suitability Data) meeting in Cologne following the AEA meeting in Copenhagen. They have removed many of the "catch-up" provisions of the earlier proposals from the rule. Essentially, if the aircraft does not have an OSD, we will not be required to modify it. I raised numerous questions regarding avionics retrofit (modifications) that they had not considered. At the final out-briefing they acknowledged our questions and promised to consider them as they develop the guidance materials. What did come out of the meeting (if you read between the lines) is that the entire program is tied to the aircraft "type;" we don't change an aircraft "type" designation.     
  4. For the past number of years, I have raised the issue of type training and the lack of appropriate approved courses for avionics. At the Engineering and Maintenance (E&M) Subcommittee meeting of the SSCC this week, I again raised the issue of type training for legacy aircraft as well as making the same presentation I presented to the membership in Copenhagen. I received a very understanding response from the SSCC members as well as EASA. As a result, the AEA has been asked to host a series of meetings (similar to what we did for the B2L proposal) to make an "unsolicited" proposal on how to amend the type rating rules to provide for alternative approaches for legacy aircraft and present a proposal to the SSCC. This proposal will apply equally to B-1 and B-2 type ratings. Any solution will take rulemaking; however, they acknowledge that approved type training is likely not an option.     
  5. The SSCC has sanctioned a working group to evaluate the opportunity to streamline modifications for general aviation aircraft. 

At the past two SSCC meetings (November 2010 and May 2011), the AEA has asked that the definition of "major/minor" vested in AMC21.113 be re-evaluated for avionics modifications in order to foster the changes to new technology cockpit for general aviation aircraft as well as the equipment mandated by SESAR. The objective is to make the costs of the STCs or modifications more economical when meeting new communication, navigation and surveillance requirements.

While not strictly within the scope of E&M authority, we were able to brief the Design & Manufacturing Subcommittee resulting in an agreement to evaluate the AMC. The D&M chartered a working group to evaluate general aviation modifications and make recommendations to the SSCC at the November 2011 meeting. This working group is chaired by the D&M subcommittee with E&M participation. As the organization presenting the problem to the SSCC, the AEA will be participating in the working group.

Please Note: 

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