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Sat, Jul 19, 2003

AEA Comments On EASA Rulemaking

On The Record Regarding Part 66 And Part M

The Aircraft Electronics Association (AEA) has sent official comments to the European Aviation Safety Agency (EASA) on Implementing Rules (IRs) for Part 66 and Part M. Previously, AEA sent comments on EASA IR 145. AEA represents nearly 100 European aviation businesses.

Part 66

AEA does not support the proposed expansion of Part 66 to aircraft below 5700 kg.  The proposed licensing does not conform to the progressive career paths of aviation/avionics maintenance technicians, the proposal is cost prohibitive, the current licensing and oversight of technicians of light aircraft does not support an expedited implementation of a transitional regulations.  In addition, this proposal is cost prohibitive to the individual technicians and the small businesses that employ them.

The proposed regulation is also discriminatory in that it favors businesses located in countries that have state funded/state supported technical training schools while placing a significant financial burden on companies located in countries without state funded technical training programs.

Part M

AEA also  does not support the proposed expansion of Part M to aircraft below 5700 kg, saying the requirement to individually approve each and every aircraft's maintenance program is administratively burdensome to individual National Aviation Authorities; extremely costly to individual owners/operators; and will introduce a lack of standardization essential to the improving safety of general aviation maintenance and operations.

Furthermore, the proposed regulation will discourage growth in the ownership of general aviation aircraft.  The proposal will channel limited financial resources away from safety enhancing cockpit technology in order to develop maintenance work cards and maintenance management plans.  The administrative burden imposed by this proposal is not based on quantitative or qualitative analysis of any known problems but rather an arbitrary expansion of JAR-OPS criteria intended for commercial aircraft operations.

FMI: www.aea.net

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