Non EU EASA Part 66 License Holders
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This correspondence is initiated by international EASA Part 66 UK CAA License holders, who are unable to get their type endorsements due to the implementation of EASA Regulation EU NO. 1321/2014 Annex III Part 66, http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014R1321 which states On the Job Training (OJT) shall be approved by the competent authority who has issued the license.
It is widely understood that this regulation suits EU Residents/Citizens only and does not take into account the Non-EU members who are exercising their National license privileges under EASA recognized 145 organizations. The irony is that we are issuing Certificate of Release to Aircrafts that are even registered in EU regions and still we need to get OJT done.
We found more than 350 foreign EASA 145 (Non-Bilateral) organizations around the globe as published in http://www.easa.euorpa.eu for a rough calculation if we consider 1 applicant willing to get any EASA part 66 type rating then it is required to get the respective licensing authority to conduct audit to approve the SOJT procedure for each of the respective EASA Part 145 organization, whereas the applicant can exercise and give Certificate of Release to Service based on their local license as EASA 145 organizations located outside Europe does not require to have type rated EASA Part 66 License.
Currently National Regulatory Authorities globally, which have TECHNICAL COOPERATION ACTIVITY (TC) with EASA Agency, follow the regulation to get Type Ratings on the respective National License before the holder start exercising their privileges in EASA Part 145 approved Non EU organizations. This process is normally done within 3 years and for the first type rating and they do follow OJT procedures as mandated in the regulation.
UK CAA issued IN-2016/048
https://publicapps.caa.co.uk/docs/33/Information%20Notice%202016048.pdf require to produce Confirmation report & Compliance report from the EASA authority that approved the Part-145 OJT program to state that they have approved them. Our OJT programs are approved by our National Licensing Authorities. Now we only can produce the EASA approval reference and it is not practical for us the applicants to have such reports, as there is no open procedure.
OJT under direct approval method by conducting audit is not possible as we will have to do such audits for each type of aircrafts and the cost must be split between a number of applicants as our Organizations are approved by EASA Agency & does not require any such OJT approvals from any foreign agencies further.
It is impractical for us to take long vacation from our current employer to do the OJT from UK CAA approved organizations, above all the cost is very high for such programs and more over, programs are not yet designed for the latest aircraft like the A350/380 or B777/787.
Why is genuine current experience on releasing respective aircrafts in an EASA Part 145 approved organization not considered for Type endorsement by UK CAA or any other EU Member Licensing Authority?
Fact that OJT is required for the first rating alone, hints it is a biased decision favoring only EU members. Why not for subsequent type ratings?
Why is UK CAA conducting Part 66 License exams worldwide with charges amounting to 85£ per module which sums upto 85 x 15 = 1275£ and then 315£ for initial issue when the rules do not facilitate getting the license type endorsed?
1. The current certifying maintenance experience from EASA Part 145 should be considered for first type rating of NON-EU applicants having no approved OJT program by EU region Competent Authority. If not, publish OJT booklet following appendix 2 of the AMC to annex 3 of EU1321/2014 requirements like CAP 741 ‘Aircraft Maintenance Engineer’s Logbook’ which can be utilized in common for any type of Aircrafts so that we can purchase that booklet and get our own certifying experience to fulfill the OJT requirements.
2. The 3-year expiry for Non-EU applicants who have their Type Rating on their National License and are currently experienced on any such aircrafts applied for should be extended or removed.
3. As long as there is no open procedure for applicants to approach Competent Authority to verify any of the approvals given by such Authorities, it must be the responsibility of EU member Licensing Authority to verify directly with the concerned Competent Authority for any such requirements like Compliance Report and Confirmation Report.
4. Just like EASA Agency directly giving EASA Part-145/147 approvals for any Non-EU organizations why not EASA Part 66 Licensing for Non-EU applicants come directly under EASA Agency itself.
NOTE TO APPLICANTS: Kindly furnish your Name, Nationality, EASA License Number or EASA Reference Number, Email address in the comments when you make your signature for this online petition and forward to your known personal with same issue.
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