CRD - NPA 13/2005 Comment Response Explanatory Note Paragraph - Add. info: Cmt. Aero Dordogne Service Item 1: “large aircraft” inchanged Not accepted. Item 2: “complex aircraft below 5700 Kg” (type rating) inchanged The group ratings were created just for this purpose. The table reflects Part- Item 3: Introduce “Aeroplane below 5700 Kg turbine engine aircraft” (group rating) 66.A.45(g)3. group ratings that were already in place in many Member States. (actuals groups 3 & 4) Having three representative aircraft in one group entitles for a group rating for all Item 4: cancelled aircraft in that group. Item 5: introduce “Aeroplane below 5700 Kg piston(s) engine(s) aircraft”(group Task 66.009 on the Agency's rulemaking inventory will address the issue of group rating)(actuals groups 5 to 10) ratings for light aircraft and experience requirements. The task is planned to start in Item 6 to 10: cancelled 2006. Your comment should be taken into acount when drafting the NPA. Item 11 & following: inchanged Justification Being too precise the sorting out is somehow not coherent ans will result in a rarefactionof mechanics having a valid licence to sign the CRS on general aviation aircraft. Paragraph - Add. info: ANNEX 1 APPENDIX 1“aircraft type ratings” Cmt. UEA Malibos Aviation Too much different types for all “small “aeroplanes piston engine below 5 700 kg. Not accepted. PROPOSED TEXT for aeroplanes piston engine below 5700 kg : The group ratings were created just for this purpose. The table reflects Part- - 1 TYPE for single/multiple piston engine – wooden structure 66.A.45(g)3. group ratings that were already in place in many Member States. - 1 TYPE for single/ multiple piston engine – metal structure Having three representative aircraft in one group entitles for a group rating for all - 1 TYPE for single/mutiple piston engine – composite structure aircraft in that group. Task 66.009 on the Agency's rulemaking inventory will address the issue of group ratings for light aircraft and experience requirements. The task is planned to start in 2006. Your comment should be taken into acount when drafting the NPA. Justification Those types of small aircraft very often fly less than 100 hours by year and it will be very difficult for mechanics to justify the '6 months experience' by type, if types are too precise. The work is not very diferent between a cessna 150 and a cessna 152 or SOCATA TB9 and TB10 or TB20 .... mechanics working on small non commercial aircrafts who are eligible to PART 66 license can justify experience and they are obliged to work following service maintenance manual of each aeroplane, to justify an experience by type of aircraft is unuseful. Being too precise on the types of small non commercial aeroplane will result on a rarefaction of mechanics having a valid license to sign the CRS. Certainly small aircraft wouldn’t be able to fly anymore if they can’t find mechanics or workshop in their vicinity. If you maintain too precise type ratings it will conduct workshop to be specialized by type of aircraft and it’s not reasonable for a small aircraft (for example a PIPER J3 !!!) to fly several hours to joign a worshop each 25 or 50 hours ! 20 December 2005 Page 1 of 53 Comment Response Paragraph - Add. info: Aircraft Type List 20 December 2005 Page 2 of 53 Comment Response Cmt. ACG Partially accepted. Please refer to the amended list. Please see below the comment to the aircraft type list: "Part 1" - the rating Cessna 550/560 (PW 530) should be corrected to: Cessna 560 (PW 535) - this is the correct engine acc. to TCDS and the Cessna 550 (PW 530) as already listed - Cessna 551 (JT15D) has a MTOM below 5700 kg, so should be transfered to "Part 2" and added to the type ratings Cessna 500/501 - so the new type rating there (in "Part- 2") is Cessna 500/501/551 (PWC JT15D) - Let 410/420 (MW M601) should read Let 410/420 (WM M601) "WM for Walter Minor" "Part 2" - we would suggest to transfer the types Piper PA 46 (Continental TSIO-520), Piper PA 46 (Lycoming TIO-540) to "Part 6" and Piper PA 60 Series (Lycoming TIO-540) to "Part 5" "Part 4" - we would suggest to transfer Pilatus PC-12 (PWC PT6) to "Part 2" "Part 6" the following aircraft types should be added: - Bölkow BO 208 (Continental O-200) - LBA Flugzeugkennblatt Nr: 644 - Piaggo P 149 D (Lycoming GO-480) - Robin HR 100.... different models and engines, detailed type ratings to be specified acc. to french TCDS N 131 - Siai Marchetti S.205..., S.208...,different models and engines, detailed type ratings to be specified acc.to italian TCDS A 131 - Avion NIPPER T-66 (Stamo 1400) french TCDS N 1 (it could be that this is an "Annex II" aircraft pls check) - Moravan Z 143 L (Lycoming O-540) CAA-CZ TCDS 94-08 - Moravan Z 326 (WM 6-III) CAA-CZ TCDS "Part 8" the following aircraft types should be added: - Aviamilano P.19 (Continental O-200) - Boeing 75 "Stearman" different models and engines, detailed type ratings to be specified acc. to FAA TCDS A-743 (it could be that this is an "Annex II" aircraft pls check) - CP 301 (Continental) - LBA TCDS L-642 und L-564a - Jodel D11, D111, D112 different models and engines, detailed type ratings to be specified acc. to french TCDS N 3 - Piper J3 , Piper PA-11 different models and engines, detailed type ratings to be specified acc. to FAA TCDS A-691 - Pitts S-1/S-2 different models and engines, detailed type ratings to be specified acc. to FAA TCDS A8SO - Robin DR 300/400 Series.... different models and engines, detailed type ratings to be specified acc. to french TCDS N 121 - Saab 91D Safir different models and engines, detailed type ratings to be specified acc. to swedish TCDS 9B 20 December 2005 Page 3 of 53 Comment Response Justification Paragraph - Add. info: ANNEX 1 APPENDIX 1, “AIRCRAFT TYPE RATINGS” Cmt. Troyes Aviation Item 1: “large aircraft” inchanged Not accepted. Item 2: “complex aircraft below 5700 Kg” (type rating) inchanged The group ratings were created just for this purpose. The table reflects Part- Item 3: Introduce “Aeroplane below 5700 Kg turbine engine aircraft” (group rating) 66.A.45(g)3. group ratings that were already in place in many Member States. (actuals groups 3 & 4) Having three representative aircraft in one group entitles for a group rating for all Item 4: cancelled aircraft in that group. Item 5: introduce “Aeroplane below 5700 Kg piston(s) engine(s) aircraft”(group Task 66.009 on the Agency's rulemaking inventory will address the issue of group rating)(actuals groups 5 to 10) ratings for light aircraft and experience requirements. The task is planned to start in Item 6 to 10: cancelled 2006. Your comment should be taken into acount when drafting the NPA. Item 11 & following: inchanged Justification Being too precise the sorting out is somehow not coherent ans will result in a rarefactionof mechanics having a valid licence to sign the CRS on general aviation aircraft. Cmt. AMO repair station Item 1: “large aircraft” inchanged Not accepted. Item 2: “complex aircraft below 5700 Kg” (type rating) inchanged The group ratings were created just for this purpose. The table reflects Part- Item 3: Introduce “Aeroplane below 5700 Kg turbine engine aircraft” (group rating) 66.A.45(g)3. group ratings that were already in place in many Member States. (actuals groups 3 & 4) Having three representative aircraft in one group entitles for a group rating for all Item 4: cancelled aircraft in that group. Item 5: introduce “Aeroplane below 5700 Kg piston(s) engine(s) aircraft”(group Task 66.009 on the Agency's rulemaking inventory will address the issue of group rating)(actuals groups 5 to 10) ratings for light aircraft and experience requirements. The task is planned to start in Item 6 to 10: cancelled 2006. Your comment should be taken into acount when drafting the NPA. Item 11 & following: inchanged Justification Being too precise the sorting out is somehow not coherent ans will result in a rarefactionof mechanics having a valid licence to sign the CRS on general aviation aircraft. 20 December 2005 Page 4 of 53 Comment Response Paragraph - Add. info: ANNEX 1 APPENDIX 1, “AIRCRAFT TYPE RATINGS” Cmt. MTA Aviation Item 1: “large aircraft” inchanged Not accepted. Item 2: “complex aircraft below 5700 Kg” (type rating) inchanged The group ratings were created just for this purpose. The table reflects Part- Item 3: Introduce “Aeroplane below 5700 Kg turbine engine aircraft” (group rating) (actuals 66.A.45(g)3. group ratings that were already in place in many Member States. groups 3 & 4) Having three representative aircraft in one group entitles for a group rating for all Item 4: cancelled aircraft in that group. Item 5: introduce “Aeroplane below 5700 Kg piston(s) engine(s) aircraft”(group Task 66.009 on the Agency's rulemaking inventory will address the issue of group rating)(actuals groups 5 to 10) ratings for light aircraft and experience requirements. The task is planned to start in Item 6 to 10: cancelled 2006. Your comment should be taken into acount when drafting the NPA. Item 11 & following: inchanged Justification Being too precise the sorting out is somehow not coherent ans will result in a rarefaction of mechanics having a valid licence to sign the CRS on general aviation aircraft. 20 December 2005 Page 5 of 53 Comment Response Paragraph - Add. info: Appendix I to Part-66 AMC (Aircraft Type Rating List) 20 December 2005 Page 6 of 53 Comment Response Cmt.