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The Royal Belgian Aeroclub comments to EASA NPA 2007/1
Dear Sir,
For electronic reasons, we cannot answer NPA 2007/08 using your new tool Comment-Response Tool (CRT), therefore please accept by this e-mail our comments below
But first a precision: any e-mail sent to : berger.louis@swing.be OR lou.berger@skynet.be will arrive directly to me.
COMMENTS.
Introduction : The Royal Belgian Aero Club is the co-ordinating body of the national federations of 8 different air sports, 3 of which fall under community rules : aeroplanes, gliders, balloons. Each of these three federations will make their specific and technical comments through their respective European Unions and Europe Air Sports. Therefore the Royal Belgian Aero Club, in co-ordination with its federations will voluntarily stay general.
1. About the calendar. Presented during the very good Juan Aton briefing in Cologne last July, the calendar seems to be unrealistic to the Royal Belgian Aero Club : Even if after the consultation period (13 October 2007) EASA will be able to send its opinion to the Commission by March 2008 and hoping that the regulation will be approved by the Commission in June 2008, we do not see how it will be possible to be ready for implementation in all countries for the 28 September 2008. This time scale, in our view, will create confusion.
2. Preference for a separate “Light Part M”. The Sport and Recreational aviation we represent, always wanted to have a simple regulation on Light Part M, separated from a regulation applicable to transport aviation. It cost us a lot of money to be able sending experts through Europe Air Supports, to help EASA to understand this problematic. It seems that this has not been understood. We do not accept the argument by which owners/operators trying to move from non-commercial aviation to commercial air transport would need to learn two separate regulations. How many owners/operators would be in this case? This is seen as making from the exceptions the general rule!
3. Language used and translation. If it can be admitted that professional in aviation must have a good level in English, however this is not the case in non professional world and in particular in Sport and Recreational aviation (S&R aviation). Therefore a document of 144 pages written in a very difficult English, is discouraging the consulted stakeholders, the pilot owner making its own maintenance or the volunteers making the maintenance of the gliders of their club or clubs.
4. Real benefit for safety ? We do not think that the multiplicity of detailed, and separate, approvals required on all involved in maintaining and managing light aircraft under Part M will bring more benefit to safety, compared with the existing system that up to now have been proven as adequate. There is a very well known saying “ too much regulation kills safety”, this is in particular true in S & R aviation. It is statically proven that accidents in those three disciplines are practically never due to bad maintenance. It is not an increase in paper work that will help safety.
5. Proposal : The Royal Belgian Aero Club believes that EASA in light of the outcome of NPA 2007/08 should request the Commission to delay the application of Part M until such a time that MDM 032 working Group has completed its works, so that the S & R aviation world involved in “non complex non commercial” outside annex II of 1592, will have a joined and coherent regulatory approach of the entire issue: airworthiness, continuous airworthiness, pilot licensing and operations. Such a coherent regulation, short and simple should be completely separate from Commercial Air Transport regulation, because their environment and the goal are different. Was Working Group MDM 032 not created for this purpose ? This reason is however clearly explained in its ToR.
Louis BERGER
Vice-President of the
Royal Belgian Aero Club
For electronic reasons, we cannot answer NPA 2007/08 using your new tool Comment-Response Tool (CRT), therefore please accept by this e-mail our comments below
But first a precision: any e-mail sent to : berger.louis@swing.be OR lou.berger@skynet.be will arrive directly to me.
COMMENTS.
Introduction : The Royal Belgian Aero Club is the co-ordinating body of the national federations of 8 different air sports, 3 of which fall under community rules : aeroplanes, gliders, balloons. Each of these three federations will make their specific and technical comments through their respective European Unions and Europe Air Sports. Therefore the Royal Belgian Aero Club, in co-ordination with its federations will voluntarily stay general.
1. About the calendar. Presented during the very good Juan Aton briefing in Cologne last July, the calendar seems to be unrealistic to the Royal Belgian Aero Club : Even if after the consultation period (13 October 2007) EASA will be able to send its opinion to the Commission by March 2008 and hoping that the regulation will be approved by the Commission in June 2008, we do not see how it will be possible to be ready for implementation in all countries for the 28 September 2008. This time scale, in our view, will create confusion.
2. Preference for a separate “Light Part M”. The Sport and Recreational aviation we represent, always wanted to have a simple regulation on Light Part M, separated from a regulation applicable to transport aviation. It cost us a lot of money to be able sending experts through Europe Air Supports, to help EASA to understand this problematic. It seems that this has not been understood. We do not accept the argument by which owners/operators trying to move from non-commercial aviation to commercial air transport would need to learn two separate regulations. How many owners/operators would be in this case? This is seen as making from the exceptions the general rule!
3. Language used and translation. If it can be admitted that professional in aviation must have a good level in English, however this is not the case in non professional world and in particular in Sport and Recreational aviation (S&R aviation). Therefore a document of 144 pages written in a very difficult English, is discouraging the consulted stakeholders, the pilot owner making its own maintenance or the volunteers making the maintenance of the gliders of their club or clubs.
4. Real benefit for safety ? We do not think that the multiplicity of detailed, and separate, approvals required on all involved in maintaining and managing light aircraft under Part M will bring more benefit to safety, compared with the existing system that up to now have been proven as adequate. There is a very well known saying “ too much regulation kills safety”, this is in particular true in S & R aviation. It is statically proven that accidents in those three disciplines are practically never due to bad maintenance. It is not an increase in paper work that will help safety.
5. Proposal : The Royal Belgian Aero Club believes that EASA in light of the outcome of NPA 2007/08 should request the Commission to delay the application of Part M until such a time that MDM 032 working Group has completed its works, so that the S & R aviation world involved in “non complex non commercial” outside annex II of 1592, will have a joined and coherent regulatory approach of the entire issue: airworthiness, continuous airworthiness, pilot licensing and operations. Such a coherent regulation, short and simple should be completely separate from Commercial Air Transport regulation, because their environment and the goal are different. Was Working Group MDM 032 not created for this purpose ? This reason is however clearly explained in its ToR.
Louis BERGER
Vice-President of the
Royal Belgian Aero Club
EASA recognises specific needs for Airsports
