EUROPEAN GLIDING UNION ______

Representative Organisation of European Glider Pilots

Draft Part Management Systems – AMC and GM – for EASA internal consultation August 2008.

Comments by Roland Stuck 22 August 2008

AMC and GM

General comment

The structure of this document could be improved by drawing the distinction between a ‘small organisation’ and ‘other organisation’ at the beginning of the document (and indeed in the introductory paragraphs of the draft IRs), because the requirements for a small organisation should be clearly separated from ‘other organisation’ throughout the documents, rather than being intermingled.

This distinction is only provided on page 25 of the AMC under the heading ‘AMC to MS.ATO.010’

Why is it that EASA keeps insisting on drafting documents where the requirements of different sectors of aviation are combined? It would make life so much easier for the ‘end users’ (and NAAs, we suspect) if rules etc were drafted in discrete documents which apply to a particular category, sector or activity. This document (MS) is a prime example where it would be far better to draft a document specifically for gliding training organisations, and consult genuinely with the people who really know how gliding training works – that is the gliding associations and EGU. We have stated this consistently in working groups and other forums since 2002; air sports are not commercial air transport. They should be treated separately and rules written specific to the activities, and not be a by-product of commercial air transport, as the risk factors are quite different.

The comments below are in the order of the document, except the first comment which is fundamental to the overall view taken.

AMC 3 to MS.ATO.010:

“employment” of less than 20 FI = “small”, more than 20 FI = “other”

 the use of the word “employ” implies “on the payroll” so this does not fit for clubs where all or the vast majority of FI are volunteers. Indeed, there some clubs which employ full time staff to run the club, but when a FI is employed – usually by very large clubs – s/he has to do a lot of other jobs as well, outside the core flying and safety related activities, to ensure the club is viable.

1/4 Also the other sections which regulate Small Organisations are clearly drafted for professional flight schools and cannot be considered adequate for small clubs providing training on a volunteer basis as is the case in gliding.

A lot may be gained if ‘small’ is defined as less than 20 full-time equivalent Fl.

 This distinction is hopeless for gliding. This could mean that every club has to obtain his own approval – thus structure, documents, process, audit and therefore COST.

Fees will be fixed by the NAA of every member state. Or in the case where we want to continue as “a federation”, the federation will be classified automatically as an “other organisation” with requirements that can not be fulfilled…

 All the requirements drafted for the “small” organisation are much higher than the actual requirements for the “Registered Facilities” in the JAR-system. So what is the safety case for this increase in requirements? Where is the evidence?

AMC to MS.GEN.200(a)(1) Management System

2.b Suggest use ‘personnel’ rather than ‘staff’ as the word ‘staff’ implies paid employees.

AMC 1 to MS.GEN.200(a)(2) Management System – Small Organisations

1. Suggest replace ‘in a rudimentary manner’ with ‘be proportional to the size of the organisation and complexity of the activity’ (as in AMC to MS.GEN.200(a)(3) paragraph 1 c.

AMC 1 to MS.GEN.200(a)(4) Management System – Small Organisations

1.c Suggest replace ‘in a rudimentary manner’ with ‘be proportional to the size of the organisation and complexity of the activity’ (as in AMC to MS.GEN.200(a)(3) paragraph 1 c.

AMC 1 to MS.GEN.200(a)(5) Management System – Small Organisations

1. a. and 2.a.i Suggest use ‘personnel’ rather than ‘staff’ as the word ‘staff’ implies paid employees.

AMC 2 to MS.GEN.200(a)(8) Management System – Small Organisations

1.c. Concur with the last sentence

6.b. Periodicity of audits. On what basis has the 12 months been selected? It could be very challenging for a volunteer organisation.

6.d. Audit report within 3 days. This requirement would be particularly challenging where the work is performed by volunteers, who have other things to do most days of the week. It takes some time after an audit to draft and consider a report. 3 days is not always feasible.

AMC 2 to MS.GEN.200(b) Management System

1. As there are no quantum parameters, will there be consistency in interpretation between member states, and indeed within member states?

2. Is the definition of an ‘activity’ clear? Please clarify with example(s).

2/4 AMC to MS.GEN.215 Facilities

Again, these requirements are drafted with professional training schools for aeroplane licences in mind. A simple gliding club can’t fulfil all these requirements, nor should it be expected to. In particular, small gliding clubs do not always have the property facilities to comply with these proposals, and for them to invest in such facilities would probably result in closure.

1.a. Gliding operations are controlled from the flying field, not from an ‘operations room’ !! Likewise ballooning.

1.b.v Gliding by its nature, does not have ‘standard cross country routes’. (Nor does ballooning, if you think about it!)

1.c. “Furnished crew room(s) for instructors and students.” Whilst perhaps desirable, this is totally unrealistic for many gliding clubs. Maybe ‘suitable rest areas, where appropriate to the training task’ as an alternative.

2.c. “A radiotelephony training and testing facility”. Gliding in many countries does not require a radio licence for VFR. Those glider pilots who do have and use radios, and use them solely on dedicated gliding frequencies, do not require a radio licence in at least some member states. Therefore this requirement, for gliding training organisations, is unnecessary. Further, even where glider pilots are trained for a state-issued radio licence, to enable use on non-gliding frequencies, often this training is done at another training establishment.

AMC to MS.GEN.220(b) Record keeping

3. The requirement for backup of computer records within 24 hours of new entries is impractical for most volunteer gliding clubs, which may only operate at weekends on a voluntary basis. The last thing the duty instructor is going to remember to do after putting all the gliders away in the hangar (if the club is wealthy enough to have a hangar) at the end of the day, and before opening the bar, is to back up a computer system. Please, let’s have a reality check!

Subpart ATO – General

AMC to MS.ATO.010 Management System

Please see comments at the beginning of this commentary.

General comment

Much of what is drafted here, for a small organisation, is unrealistic in terms of effort. It is far too bureaucratic, without any objectively determined safety case.

AMC to MS.ATO.030 Aerodromes

1.d ATC-service required.

Gliding sites do not generally have an Air Traffic Control service, as generally interpreted. Clubs normally have a base radio operating on the dedicated gliding frequency for the site.

This paragraph should be prefaced by ‘except in the case of gliding- only training aerodromes….’ Otherwise most gliding training aerodromes will simply be unable to comply and will be unable to invest in such a

3/4 facility.

4/4