11/21/2011 1 Prepared by EGAT EASA Part 66 & 147 Concerns
11/21/2011 1
Prepared by EGAT
EASA Part 66 & 147
Concerns
11/21/2011 2
Degrees Credited modules
Mechanical degree Module 1
(Mathematics)
Module 2
(Physics)
Aeronautical
engineering
Module 1
(Mathematics)
Module 2
(Physics)
Module 8
(Basic
aerodynamics)
Electrical or
Electronic
Module 1
(Mathematics)
Module 2
(Physics)
Module 3
(Electrical
Fundamentals)
Module 4
(Electronic
Fundamentals)
Avionics Module 1
(Mathematics)
Module 2
(Physics)
Module 3
(Electrical
Fundamentals)
Module 4
(Electronic
Fundamentals)
1. 66.A.25 Basic knowledge requirements
Recommendations for credited module:
Influences:
Unnecessary examinations cause a waste of time and resources.
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2. 66.A.30 Experience requirements
three years of practical maintenance experience on operating
aircraft and completion of training considered relevant by the
competent authority as a skilled worker, in a technical trade
for category B2 and subcategories B1.1 and B1.3:
Influences:
The new maintenance staff training conducted by the company will not gain
any experience reduction.
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3. 66.A.20 Privileges
• A category A aircraft maintenance license permits the holder
to issue certificates of release to service following minor
scheduled line maintenance and simple defect rectification
within the limits of tasks specifically endorsed on the
authorization. The certification privileges shall be restricted to
work that the license holder has personally performed in a
Part-145 organization.
Influences:
�International alignment�More maintenance cost for Taiwan aviation industry
compared to other countries adopted EASA Part 66 and Part 147.
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• Typical tasks permitted after appropriate task training to be carried out by the category A for the purpose of the category A issuing an aircraft certificate of release to service as specified in 145.A.50 as part of minor scheduled line maintenance or simple defect rectification are contained in the following list:
• a. Replacement of wheel assemblies.• b. Replacement of wheel brake units.• c. Replacement of emergency equipment .• d. Replacement of ovens, boilers and beverage makers.• e. Replacement of internal and external lights, filaments and flash tubes.• f. Replacement of windscreen wiper blades.• g. Replacement of passenger and cabin crew seats, seat belts and harnesses.• h. Closing of cowlings and refitment of quick access inspection panels.• i. Replacement of toilet system components but excluding gate valves.• j. Simple repairs and replacement of internal compartment doors and placards
but excluding doors forming part of a pressure structure.• k. Simple repairs and replacement of overhead storage compartment doors and
cabin furnishing items.• l. Replacement of static wicks.• m. Replacement of aircraft main and APU aircraft batteries.• n. Replacement of inflight entertainment system components but excluding public address.• o. Routine lubrication and replenishment of all system fluids and gases.• p. The de-activation only of sub-systems and aircraft components as permitted by• the operator's minimum equipment list where such de-activation is agreed by the competent authority as a simple
task.• q. Replacement of any other component as agreed by the Agency for a particular aircraft type only where it is
agreed that the task is simple.
• NOTE: This list will be periodically updated in the light of ongoing experience and technological changes.
AMC 145.A.30 (g) Personnel requirements
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4. Require 145 organization
• The release to service authorization is issued by a 145
organization. Current 06-02 A is based on the FAR 145.
• A lot of inconsistencies between Part-66 and the CAA 145.
Influences:
No release authorization will be issued due to current 145 without
mention of the privileges of the 145 organization and Category A, B1/B2
and C licenses are unrecognized by the Part 145.
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5. License conversion
• Some questions related to license conversion scenario still
open await discussion and reach a common consensus.
A
E
Av
A/E
A/Av
E/Av
A/E/Av
A, B1
N/A
B2
A, B1
A, B1 or B2
B2
B1, B2 or C
CAA Part-66
11/21/2011 8
• Questions like training and experience requirements for the
license conversion and the procedures and requirements for
endorsement of the type rating on the new license.
• Difficult to prepare for the license conversion.
Influences:
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6. AMC and GM
No AMC (Acceptable Means of Compliance) and GM (Guidance Materials) issued with the draft regulations.
Influences:
�Those materials provide the guidance for implementation of the new regulations.
�Difficult for airlines and MROs to implement the new regulations and the consistency of the new regulations implementation also affected..
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The End
Thank You!