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EASA presents new approach to GA at AERO

here

I wonder what the difference between the established approach (“kill it”) and the new one is going to be. A good sign though and they really have delivered on the CB-IFR and E-IFR, have a pragmatic opinion on the Cessna SIDs, applied the very liberal German cost sharing rules to all of Europe etc. I’m starting to like them and focus my anger on our CAA

Last Edited by achimha at 08 Apr 09:48

The problem is the “kill it” approach (using EASA FCL to wipe out much of Europe’s IFR GA community) is actually law, which means that a prudent position is to obey it literally (from the insurance POV, at least) while any benefits that EASA brings, in theory, reading its texts, are open to whatever job-protection / job-creation interpretation the local CAA applies to it.

So the negatives are “totally negative” and become thus immediately, while the positives may or may not filter through, and while one could take legal action locally against one’s local CAA, in practice virtually nobody is going to do that.

A private pilot doing it is just going to piss off his CAA whose enforcement department is prob99 staffed with police-type individuals who (like the police) tend to “pay attention to known individuals” so you don’t really want to piss off your local CAA. The organisation that ought to be doing this is AOPA but they are not going to get aggressive because they badly need a good working relationship. Even doing an FOIA request on the local CAA is not going to go down well if you then have to sit across a table with them.

The only good thing EASA has actually delivered so far was the 2003 grandfathering of certification, so that CAA-approved mods anywhere in the EU become usable anywhere in the EU. And, to the limited extent that one can actually find these “precedent” mods, this does actually work and has not AFAIK been locally obstructed.

The CB IR and the EIR will be good – but what is the net benefit after trashing most of the existing IFR community which is N-reg? We will see a small increase in the # of private pilots doing the IR but much of the existing bunch will probably chuck it in.

Administrator
Shoreham EGKA, United Kingdom

so that CAA-approved mods anywhere in the EU become usable anywhere in the EU

Many of these approvals have been for a single airframe S/N, so what’s the benefit of this?

LSZK, Switzerland

Now……. who would do such an approval (a completely outrageous practice) and who exactly stands to profit from that?

Administrator
Shoreham EGKA, United Kingdom

The whole concept of minor mods is a completely outrageous practice.

Unlike STCs, no-one is keeping a database of the minor mods approved. ABCD Aero Engineering could obtain approval for the installation of a blodgett in a TB20 spending a few thousands on time and cost of the application fee to EASA. XYZ Aviation might want to make exactly the same mod to the same type but are forced to spend more money and make the same application as they will not know such a minor mod (sorry, minor change in ESA speak) has already been approved, even by the same NAA.

The old grandfathered CAA minor mod approvals and AANs (Airworthiness Approval Notes) do cause problems. If you use the AAN to fit a different engine in a Cessna 172, do you have the agreement of the person who first applied for the AAN? When Cabair was alive and kicking, it held some CAA AANs and the approval for many more minor modifications so, with the demise of that company, the chance to use the AANs or minor mods they held has disappeared with them.

If EASA want to deregulate, then acceptance of FAA approved STCs and Field Approvals must be high on the list. Quite why EASA accept the FAA STC for Garmin GTN units but then insist on each installation being individually approved is beyond me.

Be honest guys. Who in their right mind would have thought the new IR rules even a remote possibilty 2-3 years ago? I did not believe them before I saw them!

Fact is, the former EASA boss was totally anti GA, something which has changed apparently with the current one. Fact is further, a lot of national CAA’s have in recent years given a clear indication to EASA that they disagree and have problems with the GA overregulation. France was a forerunner by simply taking law into their own hands (which led amongst other things to the renewed IR).

Personally, I am ready to give EASA the benefit of doubt that they may indeed try to rectify the situation. The IR is one significant step towards that. Let’s see with what else they come up with.

However, I’d say it might be wise to “make haste slowly” rather than to now basically demand of them to “right now” change everything. The IR took time, took lobbying and pressure. So will the rest.

For me, the STC question is one on the forefront, likewise the requirements on paperwork for changes/avionic upgrades/CAMO e.t.c. need to be reviewed and gotten into perspective. If EASA REALLY want to change, their goal should be to be an attractive and pro-active regulator rather than what they were up to now. Further, if they want the “N-Reg Problem” to go away, they need to become more attractive. I think the new boss has realized this and is trying to move in this way.

I’ll be there and talk to them on the Aero.

LSZH, Switzerland

When one has been threatened with death the prospect of a beating becomes acceptable.

Darley Moor, Gamston (UK)

They are talking about an approach and we all know that it can end up in a go around.
Minimums are not met for sure.

EGBE - Coventry, United Kingdom

If you use the AAN to fit a different engine in a Cessna 172, do you have the agreement of the person who first applied for the AAN?

Is there an explicit intellectual property involved?

AFAIK, the CAA AANs have been widely used to get approvals, without anybody asking the party whose application generated the original AAN.

With STCs there is an explicit IP principle involved.

When Cabair was alive and kicking, it held some CAA AANs and the approval for many more minor modifications so, with the demise of that company, the chance to use the AANs or minor mods they held has disappeared with them.

Why would they disappear?

Assuming that there is IP involved in making use of an AAN, when a company holding the IP goes bust, the asset is now owned by the administrator, who should be happy to take money off somebody who wants to use it

More practically, if the IP holder has vanished, nobody is going to care anyway.

Is there any history of problems here i.e. the alleged IP holder going after somebody who referenced the AAN?

I find it hard to believe the CAA would be stupid enough to set up the AAN database (which ran for many years, up to c. 2003) without getting the applicant to sign some small print releasing any IP. Otherwise, such a database would open up the CAA to litigation – because most people using the approvals will be doing it in ignorance of the issue.

You probably know my view on this, KevinC but I think most of this “IP” stuff is way overcooked, because the content of most avionics approvals (including most STCs) is nothing more than pages copied out of the back of installation manuals, with some standard phrases chucked in to wrap it all up, and somebody’s time in pushing the wad of paper through the regulatory sausage machine. There is almost never any “IP”, in the traditional sense (e.g. copyright in some kind of unique design).

IMHO, EASA is not accepting FAA STCs because they have recruited a pile of ex EASA 21 people who are now looking after their old mates Acceptance of FAA STCs would undermine the EASA 21 business, especially with avionics.

Last Edited by Peter at 08 Apr 15:58
Administrator
Shoreham EGKA, United Kingdom

Is there any history of problems here i.e. the alleged IP holder going after somebody who referenced the AAN?

Not the IP holder but the CAA asking for proof that the STC was obtained from the STC holder in the USA with the consent of the UK company who made the original application for the AAN.

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