Sofema Aviation Services (SAS) www.sassofia.com considers key changes which will impact a number of regulatory requirements between the UK CAA, EASA & the FAA.
Introduction
The UK Civil Aviation Authority (CAA) and European Union Aviation Safety Agency (EASA) have concluded negotiations on the Technical Implementation Procedures (the TIP), which was signed today (17 May 2021).
The TIP gives both the CAA and EASA oversight of the Air Safety Agreement that was signed between the UK and EU in December, and sets out the measures the aerospace sector must take in order to design and produce new aerospace parts moving between the UK and the EU.
Technical Implementation Procedures for Airworthiness and Environmental Certification
The Civil Aviation Authority of the UK & the European Union Aviation Safety Agency.
The TIP will provide specific procedures to facilitate the implementation of Airworthiness and Environment Certification, namely:
- Airworthiness certificates and monitoring of civil aeronautical products;
- Environmental certificates and testing of civil aeronautical products;
- Design and production certificates; and
- Monitoring of design and production organisations.
Certificates of Airworthiness (C of A) and Airworthiness Review Certificates (ARC)
The UK CAA issued a non-expiring C of A, a National Airworthiness Review Certificate (National ARC), and a noise certificate (if required) for each aircraft. After receipt of your non-expiring C of A and initial National ARC, the National ARC can be extended for two years, after which time a full airworthiness review will be required prior to a new National ARC being issued.
UK CAA has issued guidance that new C of As and ARCs are not required for UK operators following the Withdrawal Date, and that current certificates issued by EASA will continue to be recognized by the CAA until expiration.
Replacement C of A’s will be issued during 2021 and ARCs will be updated at the next issue of the certificate.
For a used non-Part 21 craft being imported into the UK a check flight is required to support the airworthiness review.
Non-military State aircraft, those used for commercial air transport, or public transport are to be managed by an A8-25 (CAMO) and maintained by an A8-23 (M1) organisation.
Remaining C of A aircraft may have their continuing airworthiness managed by an A8-25 (CAMO) or they can have an annual review performed by an A8-25 (CAMO). For those aircraft below 2730kg the annual review can also be carried out by an appropriately licensed engineer.
For aircraft below 2730kg MTOW, maintenance may be performed by an A8-24 (M1), (M2) or independent certifying staff.
- UK CAA have issued a letter to be carried on each aircraft confirming that any references to EASA on the certificates should be deemed to be references to the CAA. The letter states that “Until the UK CAA replaces all certificates with a CAA form number, existing certificates with EASA form numbers remain valid in accordance with UK Law.“
EASA Form 1
All EASA certificates, approvals and licenses in effect on the Withdrawal Date for use in the UK aviation system and on UK-registered aircraft will be recognized by the CAA for up to two years.
Previously, EASA Form 1s were issued by UK organisations to confirm that a product, part or component was manufactured in accordance with approved design data. Following the Withdrawal Date, CAA-approved organisations will now issue a CAA Form 1 in place of an EASA Form 1.
A CAA Form 1 is similar in both content and layout to the EASA Form 1 The CAA adopted the new form effective January 1, 2021.
Export Certificate of Airworthiness (Export C of A)
UK registered aircraft being exported to the EU will need an Export C of A and not just a Certificate of Registration, C of A and ARC.
The Trade and Cooperation Agreement (TCA) provide for a mutual recognition of Export C of A’s.
You need an Export Certificate of Airworthiness (E C of A) to certify that your aircraft conforms to the described type certificate data sheet (TCDS) and is in a condition for safe operation.
The Export C of A does not mean you can fly. You still need a valid C of A, Permit to Fly, or other airworthiness document.
FAA – CAA Implementation Procedures for Airworthiness
Implementation Procedures (IPA) concern the Agreement between the FAA & UK CAA for the Promotion of Aviation Safety, dated December 20, 1995, also known as the Bilateral Aviation Safety Agreement (BASA), or “BASA Executive Agreement.”
The Federal Aviation Administration (FAA) and the Civil Aviation Authority (CAA) have determined that the aircraft certification systems of each Authority for the design approval, production approval, airworthiness approval, and continuing airworthiness of the civil aeronautical products and articles identified in this document are sufficiently equivalent or compatible in structure and performance to support these Implementation Procedures.
FAA – CAA Maintenance Annex Guidance (MAG)
The Federal Aviation Administration (FAA) and the Civil Aviation Authority (CAA)have agreed to cooperate and provide technical support in evaluating and accepting each other’s approved maintenance organization systems.
- This Maintenance Agreement Guidance (U.S.-UK MAG) contains the respective responsibilities and procedures for recommendations for FAA certification, renewal of certification, certificate amendments, and continued monitoring of maintenance and alteration or modification facilities located in the UK.
- The U.S.-UK MAG also describes the actions required of applicants located in the United States seeking Maintenance Organisation Approval under Commission Regulation (EU) No. 2018/1139, as applicable in the UK legal system by virtue of the European Union (Withdrawal) Act 2018.
Next Steps
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aviation, CAMO, Civil Aviation Authority, EASA, continuing airworthiness, FAA, SAS blogs, Airworthiness Review Certificates (ARC), UK CAA, Technical Implementation Procedures (TIP), Certificates of Airworthiness, MTOW
