PtF Permit to Fly. European Aviation Safety Agency PtF Slide 2 Permit to Fly - Some major principles of the new rules - Frequently asked questions - Discussion

PtF

Permit to Fly

PtF Slide 2

European Aviation Safety Agency

Permit to Fly

- Some major principles of the new rules

- Frequently asked questions

- Discussion / Questions

PtF Slide 3


Old rules

Permit to Fly Until 28 March 2007 21A.174(d) Application21A.185 Issue of permits to fly

NAA issue PtF after:Agency found that aircraft can perform safe flight (with restrictions)

But: 1702/2003 article 2.11: NAA makes findings until 28-3-07

PtF Slide 4


Permit to Fly

Some important principles:Different types of PtF all covered by one ruleshared responsibility: Agency – NAAOld national PtF grandfatheredApplicable to EU registered aircraftValid in all member statesPrivileges for DOA and POA Maintenance rules in flight conditionsSeparate Subpart P: Permit to Fly

PtF Slide 5


Different types of PtF all in one rule

Complicating factor for drafting Existing (R) C of A temporarily invalid

unapproved changeUnrepaired damage(long) due maintenance

Pre C of ATC not yet issued (Production) Flight testing

C of A or Restricted C of A not appropriate or not possible

Air racing / record breakingSome orphan aircraft

PtF Slide 6


Shared responsibility Agency-NAA

Complicating factor for drafting: shared responsibility: Agency – NAA

Agency: All design issues

NAA: Conformity (production) C of A issuance and oversight Permit to Fly issuance Implementation of maintenance rules

Permit to Fly: often deviation from approved design: Agency involvement

PtF Slide 7


PtF Grandfathering

Principle:All PtF or other certificate grandfathered until first expiry date or 28-3-08 maximumFor “permanent” PtF: flight conditions are grandfathered indefinitely (until need for change),unless Agency determines insufficient level of safety

(Reg 1702/2003 art. 2.e)

PtF Slide 8


PtF applicability

PtF rules applicable only to aircraft registered in EU; orUnregistered when identification marking prescribed by MS

(Reg 1702/2003 art. 2.2)

Result: PtF rules do not cover validation of foreign PtF: use national rulesUnder new BR need to develop IR for this

PtF Slide 9


PtF validity

PtF issued in accordance with new rules are valid in all Member States:No additional national conditions / limitations Holder must comply with other local operational rules outside scope of PtFNational rules should not obstruct free circulation

PtF Slide 10


DOA/POA privileges

DOA (possible) privileges:Approve flight conditions for all PtF except 21A.701(a)(15)Issue PtF when configuration controlled by DOA

POA (possible) privileges:Approve flight conditions and issue PtF for aircraft it produced when design is approved

In previous draft: privilege for CAMO: this is subject of Opinion 4/2007

PtF Slide 11


Maintenance rules for PtF

According to 2042/2003 art. 3.3 aircraft under PtF are exempted from Part MIn stead: maintenance rules are defined in the flight conditionsIn most cases they can refer to Part M

PtF Slide 12


Separate Subpart P

Initial drafts were amendments to Subpart H (airworthiness certificates)Due to complexity decided to create new subpartAs a consequence all references to PtF are deleted from subpart H

PtF Slide 13


FAQ

Q: Must a PtF be applied for when one of the purposes mentioned in 21A.701 is applicable?A: No, only when the (R-) CoA is invalid or not yet issued

PtF Slide 14


FAQ

Q: Can an aircraft on a PtF do commercial operationsUnder EU-OPS it is impossible (without exemption)For the future IR-OPS it is not excluded by definition but in practice most PtF will have the limitation that no passengers may be carried

PtF Slide 15


FAQ

Q: where is the PtF validA: the PtF is valid in all EU within the limitations on the PtF. Outside EU there is a need to ask for validation of the PtF by the countries overflown

PtF Slide 16


FAQ

Q: Does EASA have 24/7 service for approval of flight conditions?A: No, however NAAs have the Agency emergency phone number.NAAs can always use article 14.4 for urgent operational needs

PtF Slide 17


FAQ

Q: Who is the holder of the PtFA: The applicant will become the holder when the PtF is issuedE.g. If a modifier uses the aircraft of an operator to demonstrate compliance this modifier is expected to apply for the necessary PtF; and will also be the holder

PtF Slide 18


FAQ

Q: can a PtF be applied for using approved flight conditions which were not applied for by the same applicant?A: Yes, the applicant for PtF and applicant for approval of flight conditions do not necessarily have to be the same person

PtF Slide 19


FAQ

Q: can the DOA privilege be used for aircraft that are not under the control of the DOA?A: Yes, the privilege to approve flight conditions can be used for any aircraft; as long as it is within the scope of the approvalThe privilege to issue PtF is limited to aircraft under the control of the DOA

PtF Slide 20


FAQ

Q: if the approval of flight conditions contains design and not-design related issues, who should the approve the flight conditions?A: An interpretation could be that you would need approval by the Agency of the design related and by the NAA of the non-design related; however to avoid undue burden the Agency will accept to approve both as one package

PtF Slide 21


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PtF Permit to Fly. European Aviation Safety Agency PtF Slide 2 Permit to Fly - Some major principles of the new rules - Frequently asked questions - Discussion