Sofema Aviation Services (www.sassofia.com) looks at the common issues and considers the merits of various solutions.
The Development of an EASA 147 Third Country Approval
1/ Essentially this is not a contentious area as it is straightforward (relatively) moreover there is a significant amount of guidance material to support you to develop your Maintenance Training Organisation Exposition (MTOE).
2/ The Issue of Module Certificates – Once approved your module Certificates are of equal value to any other 147 organisations either within or outside of the EU.
What happens with the Module Certificates for “Successfully Passed” Modules?
1/ They can be used in an application for an EASA Part 66 Aircraft Maintenance Engineers.
2/ The application can be made to any European Member State Regulatory Authority (Competent Authority) – with one exception if any modules have been issued by a Competent Authority Directly – It is only they who can issue the license.
So what’s the Problem?
1/ The problem is to become an “active” Licences Aircraft Engineer (LAE) you MUST complete Structured On the Job Training (SOJT) – Such training Must be performed with the direct control of either an EASA approved Part 145 Organisation. (May also be possible within an FAA-approved 145 Organisation – subject to oversite.)
Does the Structured On the Job Training need to be approved by the EU Competent Authority CA?
1/ The short answer is yes, in addition, it needs to be in the 145 MOE as an approved program.
2/ Clearly then there is a logistics challenge if the CA who issued the license is different from the CA of the EASA 145 where you are proposing to do the SOJT – This frustration affects many people who cannot effectively comply with the objectives.
3/ The SOJT Program will need to be repeated for each Group.
Is there a way forward?
1/ Well yes – The first comment is that to be able to deliver EASA Part 66 Module Certificates under an EASA Third Country Approval is a significant milestone of attainment.
2/ Moreover, it is often acceptable to the local regulatory authority as a method of obtaining a Part 66 license of the state of the operator.
3/ Consider also that with such a license (local issue) you can certify EASA Aircraft under Third Country Approval Authorisation.
Please consider the purpose of your proposed EASA Third Country Part 147 approval – if it is in support of a local license program it can be a perfect solution.
If it is to provide a qualification for a person who wishes to hold an EASA Part 66 Aircraft Maintenance Engineers Licence – You should seriously consider the SOJT and to choose wisely the Regulatory Authority.
Is There an Alternative Solution?
Many People choose to go down the A license route as this delivers a working document and avoids the challenge of SOJT.
With the A license, it is easier to obtain approval based on an approved Task Training Program.
In Addition, by working as a physical person with a European 145 you can build up the experience to support the SOJT (note this will be extremely difficult in a line only environment).
This is only a very brief summary for a detailed consultancy please discuss your issues with SAS through the following email firstname.lastname@example.org