While it is some distance to go from speech to reality, Theresa May has indicated that the UK intends to remain an EASA member. Of course nobody knows exactly which form it takes, but assuming it will be similar to Switzerland, this would mean that nothing changes, but also that the UK cannot enter its own bilateral agreements with others.
My specific point was that even if the UK remains in EASA the EU-USA bilateral will not apply as it is no longer an EU state. “Therefore the Agreement does not apply to Norway, Iceland, Switzerland and Liechtenstein, which are EASA Member States and Members of the EASA Management Board, but are not Member States of the European Union”. And (as you say) because we are in EASA we can’t agree our own bilateral.
We will be in “no man’s land” regarding the bilateral As Peter says this affects more than just light GA so something must be done, but I can’t see what – given the timescales and other priorities. I have lifed items that need replacing next April and in preparation was going to buy FAA single release 8130-3 parts but now I’m not sure I’ll be able to use them!
Ah well, we shall see…
Christopher wrote:
I have lifed items that need replacing next April and in preparation was going to buy FAA single release 8130-3 parts but now I’m not sure I’ll be able to use them!
For UK-registered non-EASA aircraft, the ability to use FAA 8130-3 new parts is permitted as shown in CAA CAP562 leaflet B-110 section 4. Below are the relevant extracts:
4.4 When received from a manufacturing source appropriately approved by the Federal Aviation Administration (FAA), which arranges for the release of the aircraft component, the Authorised Release Document will be FAA Form 8130-3, Authorised Release Certificate/Airworthiness Approval Tag for aircraft engines, propellers and all other new components including APUs. Further information regarding the use of FAA Form 8130-3 is contained in FAA Order 8130.21. As a result of the Common Release Certificate project between the JAA, FAA and Transport Canada, it has been accepted that inclusion of the word “Export” is not necessary on each authority’s respective forms. Inclusion of the word “Export” in Block 13 of a Form 8130-3 remains as an option to meet any existing bilateral agreement commitments. Where a Form 8130-3 has been raised under previous revisions of the FAA Order then an export statement is still required. The current issue of the Form may be recognised by its revision – Form 8130-3 (6-01). Form 8130-3 certifying conformity to the Export requirements of a specific country other than within the EU is not acceptable. Receiving organisations should ensure that where there are export requirements specific to the UK, these have been satisfied.
4.5 The CAA position regarding FAA-PMA parts is set out in EASA Decision No.2007/003/C which can be found at:
http://www.easa.europa.eu/ws_prod/g/rg_agency_desc_main.php.
My aircraft is a UK-registered C172 so it’s not a non-EASA aircraft.
I’m not really looking for a definite answer as the water is far too muddy for that at the moment. Just that “a trouble shared is a trouble halved”.
Anyone following this?
https://www.easa.europa.eu/document-library/notices-of-proposed-amendment/npa-2017-19
EASA:
I don’t see any practical benefits in GA from this:
DHs (design holders) need to classify every part that should benefit from this change as less critical. This sounds like a major effort for the DH (how to prove less criticality?). As the change would only affect maintenance, the DH would on the other hand not benefit from any such classification work – to the contrary it would allow maintenance facilities to source certain parts they currently have to buy from the DH as only qualified manufacturer in the future from alternative sources.
So as long as you do not buy new planes based own future maintenance cost (which commercial operators would do but not really GA owners), there’s an active disincentive for the DH to classify any part other than the most stringent CL.
Thanks for your analysis!
So my understanding is that this
The requirements proposed by this NPA may very positively impact on general aviation (GA), since often certain parts of the aircraft have not been designed with an aviation intent and not manufactured by a POA.
would only apply in the case of this
In certain cases, the possibility to assign CLs is also given to EASA.
Exactly! That’s at least my view…
Posts moved to existing thread on this EASA process.
I posted my views on the success of this further back The maintenance business has very little incentive to operate this.
A comment on a long ago point made repeatedly in this thread… FAA A&P mechanics IME fully understand that an 8130 is not required for parts. At the risk of overstating the point I think it is true that I have never even discussed such paperwork with any A&P concerned with my planes. Obviously when used parts and parts from overseas suppliers are a big part of the equation (as has often been the case for me) this is big factor – my planes would not have been maintainable if anybody started fussing around with 8130s and except for a few limited areas (e.g. people maintaining new factory production aircraft at very high cost) the entire light aviation scene would collapse if it were required under FAA regs.