Jan. 15, 2019
NBAA has submitted written comments to the European Aviation Safety Agency (EASA) in response to proposed rule changes for foreign-aircraft ramp inspections.
Brian Koester, NBAA’s senior manager for flight operations and regulations, said the comments will ensure that EASA and its Safety Assessment of Foreign Aircraft (SAFA) program are fully aware of association members’ concerns.
“As EASA revises its Authority Requirements for Air Operations, Ramp Inspection Manual, and Inspecting Instructions & Pre-Described Findings, it is important that regulators understand that non-commercial and foreign-registered operators have unique operations compared to large scheduled air carriers,” Koester said.
“These unique operating characteristics require special attention when developing guidance and regulation, or it can result in a lack of clarity for operators and inspectors,” he added. “As a recent example, U.S.-registered operators are facing difficulty during ramp inspections in Europe due to differences in EASA’s and the FAA’s Minimum Equipment List approval process.”
One NBAA comment addresses ramp inspection manuals. While EASA has a manual that explains how inspectors should conduct ramp inspections, the document is designed for inspecting commercial operations. Since many international and national requirements for non-commercial operators differ from those for commercial operators, NBAA encouraged EASA to develop a separate manual for non-commercial operations.
Another NBAA comment focused on disagreements between inspectors and operators. While NBAA agrees with EASA that such disputes are rare, it said specific language is needed for handling a situation that may easily escalate. NBAA recommended that EASA formulate instructions for how an operator can appeal a safety finding or the category of a finding.
NBAA opposed a proposal that would give inspectors unrestricted access to an aircraft they are inspecting. The association wrote in comments that the pilot-in-command should retain final authority over an aircraft, that the crew should have the right to be present during an inspection and that no inspector should have unrestricted access to an aircraft without crew consent. NBAA would support language clarifying that inspectors have unrestricted access to the parking area where an aircraft is being inspected.
NBAA developed and submitted its comments in collaboration with the General Aviation Manufacturers Association.