SOUTH ASIA REGIONAL INITIATIVE 2 nd SARI 66 & 147 WG meeting Prepared by: ED Karachi, 1 to 3 March 2011 MEETING PARTICIPANTS CAD Maldives CAA Nepal CAA Sri Lanka CAA Pakistan PIA Air blue CAA International SARI Absence from COSCAP, CAA Bangladesh and DGCA India were regretted. Refer to the list of participant given in annex 1 SUMMARY The Agenda is given in annex 2 The following topics were reviewed or discussed during the meeting: 1. Reminder on the SARI 66 & 147 Working Group (WG) objectives; 2. Objectives of the second SARI 66 & 147 WG objectives; 3. Reminder on the first meeting outcomes; 4. Identification of possible CAAP variants on draft Part 66 Section a & b (regulation only); 5. Completion of SARI Part 66 preliminary draft (AMC & GM Section A and B); 6. Conversion Report Review 7. Actions to be completed before next meeting. 1. The WG confirmed its objective to release the first complete draft SARI Part 66 and SARI Part 147 no later than January 2012. The list of SARI 66 & 147 WG members will be amended to include additional member from Pakistan that will be nominated shortly by PCAA. The SARI Coordinator will also seek confirmation from the SARI CAA of the members already nominated before the 15 th of March 2011 (Action: PCAA and SARI Coordinator) 2. The SARI 66 and 147 TOR have been slightly amended to reflect the decisions of the last Steering Committee. These TOR will be distributed to the SARI 66 & 147 WG members SARI 66 & 147 WG-2 nd meeting Summary Final issue 1 / 7
for comment and / or approval before the 15 th of March 2011. (Action: SARI Coordinator) SARI reminded the role of the European Technical Advisor (Eric Mills) selected by EASA and encouraged the WG members to contact him through the coordinator for any issue relevant to 66 and 147 paragraphs interpretation. (Action: SARI WG members) 3. Despite the decision of the last SARI Steering Committee meeting to switch from the National Variants (NV) concept to the opt-out concept it was agreed to continue to use NV in the development of SARI Part 66 which is recognised as a difficult regulation where full harmonisation will not be achieved shortly. 4. In addition to the NV identified during the 1 st WG meeting and listed in paragraph 5 of the meeting summary the following NV were recorded: 66.A.25(a) : NV for CAA SL (Examination to be conducted by the DGCA) ; 66.A.25(e): NV for CAA SL (To include military experience) May be transferred in AMC (tbc); 66.A.40(a): NV for PCAA due to existing Rules (Two years license validity); NV for CAA SL (One year validity) ; 66.A.45: NV for PCAA (One year experience required by PCAA for type endorsement on the license on top or required approved type training); 66.A.45(g): NV for CAA SL (Competent Authority to be replaced by approved Training Organisation or DGCA); 66.B.200(a) : NV for CAA SL, CAAP (due to existing Rules), CAAN and DGCA I- 2 years instead of 5 years; AMC 66.A.30(d): Potential NV for Sri Lanka regarding the 6 months for military experience. No other NV was identified in the AMC and in GM section A. The review of GM Section B was not completed during the meeting. It was recognised that NV in the regulation may also generate NV in the AMC or the GM. 5. The following information and explanations were provided during the meeting: 66.A.30(a)(5): interpretation of representative selection of tasks ; 66.A.30(a)(5): Experience requirements for cat C; 66.A.30(a)(5): interpretation of Civil aircraft environment ; 66.B.200 and appendix 2: Essay (refer to Appendix 1, modules 7, 9 and 10). Non inclusion of essay should be considered as a significant deviation from the EASA Part 66 concept. Absence of essay should be compensated by alternative examination tool. AMC 66.A.20(a): Definition of line and base maintenance to be harmonised with the definition of SARI Part 145; AMC 66.A.20(b)(2): 6 months /100 days to be deleted. Changes are expected with the introduction by EASA of B3 Retain the initial wording of EASA Part 66 for the first SARI Part 66 issue; AMC 66.A.30(a): CAA SL to review the wording ( 4 months/ 2 weeks) AMC 66.A.30(e)(2): Workshop experience not acceptable. AMC 66.A.45(e): OJT to be required in the next ED for first type rating. SARI 66 & 147 WG-2 nd meeting Summary Final issue 2 / 7
AMC 66.A.45(d): Comparable construction Each NAA to publish a guideline but no detailed criteria. AMC 66.A.45 (g): Aircraft types representative of a group and Group Rating- EASA recommended to build the SARI Part 66 Group Rating List using the EASA corresponding list as a reference- A list will be reviewed during the 3 rd WG meeting; AMC 66.A.30(e)(2) or in aircraft manufacturing : A wording will be drafted before the 3WG meeting; AMC 66.B.105: to be deleted No licence issued via a 145 organisation. AMC 66.B.100 to 115: The next ED will transfer this AMC into the regulation. Follow the EASA change when published; Annex 1 Module 6.3.2 and 6.3.3 will be transferred to B3 category when the next ED will be published Review the issue before publication of the first draft SARI Part 66 end of 2011 and follow EASA Annex1 content. (This transfer of 6.3.2 and 6.3.3 to B3 has not happened in the next issue of EASAPart-66 due for release in June/July 2011.) 6. Other significant issues: As it was the case during the 1 st SARI 66 & 147 WG meeting, some of the SARI partners were tempted to compare EASA PART 66 to their existing National regulation forgetting that the ultimate goal of the WG was to build a harmonised regulation acceptable by all the SARI partners and not to measure how far from EASA Part 66 their National regulation was. SARI will take action at the highest level possible to overcome this difficulty during the next meetings. (Action SARI Coordinator). Some of the SARI partners are showing difficulties to follow key EASA Part 66 principles such as imposing requirement for English language (not required by EASA), not including essay in the examination process (Essay are required by EASA for several modules listed in Annex 1), experience requirement on top of type training required for type endorsement (no experience requirement for EASA), etc... If not resolved these difficulties may stall the harmonisation process of Part 66. Using EASA Part 66 as a reference does not impose SARI to adopt EASA Part 66 in full. Significant difference may be acceptable however the EASA Part 66 concepts should be followed. The concept of issuance of the authorisation by the Part 145 or by the Part M Subpart F organisation and its consequence in the EASA Part 66 system remains not perfectly understood. 7. Actions before the 3 rd SARI 66 & 147 WG meeting. The 3 rd SARI 66 & 147 WG meeting will be held in Male from 4 to 7 July 2011 (4 days). 2 days will be allocated to the completion and fine tuning of SARI Part 66. The remaining 2 days will be dedicated to start the harmonisation work on SARI Part 147. Before the meeting the following action should be completed as indicated: Summary of 2 nd WG meeting to be drafted, commented and released before the SARI 66 & 147 WG-2 nd meeting Summary Final issue 3 / 7
15 th of March (Action: All WG members); Compilation of preliminary draft Part 66 including GM Section A to be released before the 20 th of March 2011 (Action: SARI Coordinator) WG members to comment preliminary draft and draft NV before the end of April 2011 (Action: All WG members); WG members to review and provide position on item listed in paragraphs 4 and 5 above and to require possible clarification on paragraph interpretations before the end of May 2011 (Action: WG members); Confirmation of the names of the WG members to be provided before end of March 2011. (Action: CAA SARI National CAA Coordinator) ************* SARI 66 & 147 WG-2 nd meeting Summary Final issue 4 / 7
Annex 1 Country Participant Organisation / Title Pakistan Mr. Nayyar Faruqui PCAA Pakistan Mr. Malik Sanaullah PCAA Pakistan Mr. Khan Younus PIA Pakistan Mr. Muhammad Ali Jafri PIA Nepal Mr. Raju Shrestha CAAN Nepal Mr. U.L. Shrestha Nepal Airlines Sri Lanka Mr. Chaminda Wimalrathne CAA Sri Lanka Sri Lanka Mrs. Malka Pathirana CAA Sri Lanka Maldives Ahmed Somith CAD Maldives Maldives Adam Mufassir CAD Maldives Europe Eric Mills CAA UK Europe Eric Dormoy SARI Non Working Group Members Pakistan Engr. M Zahid Bhatti PCAA Pakistan Engr. Massod Mahfooz PCAA Pakistan Engr Amir Hussain PCAA Pakistan Mr Yasin Reza Hamani PCAA SARI 66 & 147 WG-2 nd meeting Summary Final issue 5 / 7
Pakistan Aslam Tariq PIA Pakistan Mumtaz Ahsan Zubairi PIA Pakistan M A K Rana AIRBLUE Pakistan Yousaf Bhayat AIRBLUE Pakistan Mohammad Abdullah SOA Pakistan Afzal Khan Pakistan Aviation Training School Pakistan Mohd Waqar Ashfaq ATS Training Institute SARI 66 & 147 WG-2 nd meeting Summary Final issue 6 / 7
Annex 2 SARI 66 & 147 WORKING GROUP SECOND MEETING Karachi 1 to 3 March 2011 DAY 1 Agenda - Introduction - Reminder on the working group procedures and objectives - Reminder on the 1 st meeting outcomes - Review of the National Variants resulting from the 1 st meeting -Completion of the regulation review (section B) -Conversion reports (1 to 2 hours discussion on this specific topic RRI Part 66 - SARI-02) DAY 2 (tbc depending on day 1 achievements) -AMC & GM review DAY 3 -AMC & GM review - Continuation of day 2 agenda -Wrap-up on the achievements of the 3 days meeting -Plan of actions to be completed between the 2 nd and 3 rd WG meeting -Agreement on work sharing and target dates for completion of these actions. ******** The meeting will start every day at 9 am and will finish no later than 5 pm SARI 66 & 147 WG-2 nd meeting Summary Final issue 7 / 7