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The JAR 66 Requirement
JAR 66 is a new JAA rule introducing qualification requirements for Certifying Staff. Certifying Staff are those personnel authorised to release an aircraft to service after maintenance work in a JAR 145 Approved Maintenance Organisation (AMO).
Currently, JAR 66 only applies to the release to service of aircraft with a maximum certificated take-off mass of 5700kg or above. It is intended to further expand JAR 66 to include light aircraft and components at a later stage.
JAR 66 has been effective since 1 June 1998, but compliance with JAR 66 will be mandatory after 1 June 2001.
JAR 66 introduces four categories of certifying staff, and includes related qualification requirements in term of basic knowledge, maintenance experience, task or type training.
The A category, corresponds to the line maintenance mechanic certifying staff, it means the person authorised to release an aircraft to service in the line maintenance environment after simple maintenance tasks (e.g. a wheel change, minor cabin maintenance, weekly check, etc..).
The B1 and B2 categories correspond to the line maintenance certifying technicians, respectively in the mechanical and avionics speciality. Together the B1 and B2 licences cover all possible line maintenance works, which the category A does not.
Finally the C category corresponds to the base maintenance certifying engineer, authorised to release an aircraft to service after base maintenance works.
A JAR 66 Aircraft Maintenance License itself does not confer any certification privileges. Certification privileges are granted by the JAR 145 Approved Maintenance Organisation. The JAR 66 license is only a prerequisite to the qualification as certifying staff; JAR 145 includes additional requirements for certifying staff such like the need to demonstrate current maintenance experience, to undergo continuation training and the requirement for the employer to assess any potential certifying staff for their competence, qualification and capability.
JAR 145 also specifies that so called "base maintenance support staff", it means those base maintenance personnel supporting -from a technical point of view- the base maintenance certifying staff during the release to service process must be qualified in accordance with JAR 66, in the B1 or B2 category.
Other maintenance personnel such as the line or base maintenance non-certifying mechanics or technicians do not have to comply with JAR 66. Obviously, this does not mean that no qualification standard is applicable to them. The applicable standard is in all cases JAR 145, which requires that the AMO employ competent personnel and specifies that the qualification standard for all maintenance personnel must be accepted by the Authority.
The need for JAR 66
The introduction of JAR 66 corresponds with the need to achieve a common high safety standard in European maintenance. The process started in the early 90's with the implementation of JAR 145. Although the uniform application of JAR 145 itself was not questioned, the absence of a unified qualification standard for certifying staff was deemed to result in some variations in the National maintenance standards. Clearly, a unified maintenance standard including the qualification requirement for certifying staff, is necessary to strengthen the mutual confidence between JAA National Aviation Authorities that they can accept each other's maintenance.
JAR 66 was also introduced to improve the level playing field between JAR 145 Approved Maintenance Organisations. There is indeed a general perception that significant variations in the qualifying process of certifying staff for aircraft throughout the JAA member States may result in appreciable variations in maintenance costs.
In summary, the JAA objectives are to ensure common high levels of aviation standards and to contribute, through the uniform application of common standards, to fair and equal competition within the member states, hence the need to complete the harmonisation of maintenance rules by JAR 66.
"Grandfather rights", or "protected rights"
The introduction of JAR 66 on 1 June 2001 does not mean however that all certifying staff would be immediately affected by the JAR 66 qualification standard.
JAR 66 includes an important provision known as "protected rights" or "grandfather rights". This provision stipulates that any person exercising certifying staff privileges before 1 June 2001 will be authorised to exercise his privileges after 1 June 2001 without the need to demonstrate compliance with the JAR 66 standard. This very pragmatic approach is based upon the fact that due to good safety records, there is no reason for the JAA to question the qualification background and experience of existing certifying staff.
In practice, the protected rights approach consists of concurrently accepting and "freezing" existing certifying staff authorisations. This means that a member of certifying staff with "grandfather rights" willing to extend the scope of their privileges after 1 June 2001 to add for instance the "Avionics" qualification to an existing "Mechanical" qualification will have to comply with the JAR 66 standard for the additional "avionics" qualification. However adding a type qualification within the existing "Mechanical" authorisation can still be done under the pre-JAR 66 National qualification requirement.
The conversion process
Before the implementation of JAR 66, there was generally no automatic recognition of Aircraft Maintenance Licenses across JAA countries. Accordingly those personnel who benefit from "protected rights" will only remain accepted in their own country. For these personnel, the way to mutual recognition is the "conversion process".
The conversion process consists in granting a JAR 66 license to all "protected rights" certifying staff. This JAR 66 license will be issued in the category that corresponds to the existing scope of work of the person and will include limitations to reflect any difference between the existing scope of the authorisation and the corresponding JAR 66 category.
A "converted" JAR 66 license will be issued without any examination. An examination would only be needed when the person wishes to remove a limitation.
The conversion process by the JAA Member States must be completed on 1 June 2011 the latest. This 10 years period takes into account the need to convert about 50 000 existing certifying staff throughout the JAA countries.
JAR 66 implementation
All JAA countries are currently working on the implementation of JAR 66: this is a very complex task, which involves the national Aviation Authorities, the Maintenance Organisations, and the Aircraft Maintenance Training Schools.
A majority of JAA Authorities will be in a position to issue JAR 66 licenses on 1 June 2001, but a minority will still need a few more months to get fully ready. This is not seen as a problem, because in practice during the months following June 2001, a very limited number of applications for new licenses should be received. In fact, the vast majority of personnel concerned by JAR 66 in this period will be those covered by "protected rights", who can continue to exercise their privileges without a JAR 66 license. Therefore the Industry should not be penalised if not all JAR 66 applications can be immediately processed on June 2001
Like any JAA approval, JAR 66 licenses are issued by the JAA National Aviation Authorities (JAA-NAA). A JAR 66 licence issued by any JAA full member Authority is automatically recognised by all other JAA full member Authorities. In order to establish mutual confidence across the JAA members, the Central JAA has operated since February 1999 the so-called "JAR 66 Review Board".
The purpose of this Review Board is to audit the JAA-NAA in order to ensure that the JAR 66 licences will be issued in accordance with the correct standard. The JAR 66 Review Board focuses on the examination standard and the conversion process.
No JAA-NAA may issue a JAR 66 licence unless it has successfully passed the JAR 66 Review Board.
Next amendment to JAR 66
A Notice of Proposed Amendment, NPA 66-1, has been published in December 2000. This NPA will extend JAR 66 to cover aircraft below 5700 kg. NPA 66-1 proposes to introduce a new category "B3" for simple light aeroplane; other aircraft would be covered by existing A, B1, B2 and C categories. The NPA also introduces the possibility to have "group ratings" instead of "type ratings" for the light aircraft. Comments on NPA 66-1 are being reviewed but it is too early to establish any trend from the comments received so far.
Another amendment covering component maintenance certifying staff is under development. At this stage the main concepts of the rule change are being discussed with the JAA-NAAs and Industry representatives.
JAR 145 contains an exemption to the effect that certifying staff working in non JAA based approved maintenance organisations will not be required to comply with JAR 66. This exemption is based on the fact that it is impractical to impose a complex standard like JAR 66, with all its social and educational implications to countries who already have their own qualification system.
However, in order to ensure equivalent standards and fair competition, JAR 145 required the foreign JAR 145 organisations to demonstrate that their qualification system is comparable to JAR 66. If it is not comparable, then the JAA will impose and publish additional conditions to ensure equivalence.
It should be noted that an increasing number of non-JAA countries are adopting JAR 66 as their national qualification standard for certifying staff. This of course will facilitate the demonstration of equivalence.
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The JAR 147 requirement
JAR 147 is the requirement dealing with the approval of aviation maintenance training organisations. It has been effective since 1 June 1998, but compliance is mandatory after 1 June 2001.
To be approved in accordance with JAR 147, an organisation has to comply with a series of requirements dealing with facilities, personnel, documentation, records, examinations, quality monitoring, etc.
A JAR 147 organisation may be approved to conduct basic training, type training, or both. An organisation approved in accordance with JAR 147 to conduct basic or type training is also entitled to conduct related examinations on behalf of the Authority.
The standard for basic training and type training is mainly included in JAR 66 but JAR 147 includes additional elements. For instance JAR 66 includes the basic examination syllabus, on which the training syllabus is based, but JAR 147 includes the required duration for each training courses. For type training, JAR 66 specifies that the standard for B1 and B2 categories is ATA 104 level III.
The need for a JAR 147 approval: basic training
JAR 66 does not require an applicant for a JAR 66 licence to be trained by a JAR 147 training school: This is in fact an option. In reality JAR 66 requires the applicants to demonstrate by examination that they comply with the JAR 66 examination requirement. In order to prepare for the examination, an applicant for a JAR 66 license may choose to self-train, be trained by a non-approved organisation, or be trained by a JAR 147 approved organisation.
For a student, the advantage of undergoing JAR 147 basic training is that he would benefit from experience credit (less maintenance experience is required from students trained by JAR 147 organisations), and also the JAR 147 "label" gives him the assurance that the training content complies with the JAR 66 examination requirement.
For a training organisation, the advantage of being JAR 147 approved is that it gives a competitive advantage (the JAR 147 "label") and allows to organise basic examinations on behalf of the Authority.
In summary we can see that while JAR 147 approval is not required for basic training, the advantages of being JAR 147 approved are such that most maintenance training organisations in Europe have applied or will apply for a JAR 147 approval.
The need for a JAR 147 approval: type training
JAR 66 requires B1&B2 type training to comply with ATA Spec 104 level III, plus additional elements such as the duration of practical training. It further specifies that the type training course may be either directly approved by the JAA Authority, or approved through a JAR 147 approval covering the whole organisation. This in fact provides two options for the type training schools:
The first option is to be JAR 147 approved: the organisation is approved to conduct a series of type courses under an approval that is automatically recognised by all JAA countries.
Under the second option, which consists in having type courses approved individually by a JAA Authority, the organisation would not have to undergo the full JAR 147 approval process, but the type courses are then only recognised by the Authority that approved it: there is indeed no mutual recognition by other JAA countries, as mutual recognition can only be based upon a JAA approval, in other words a JAR 147 approval. This means, the type course approval exercise has to be repeated by every JAA Authority concerned. For a training school having potential customers in a number of JAA countries, the best option is then probably to opt of the JAR 147 approval
JAR 147 outside the JAA territories
Non JAA based maintenance training organisations may only be granted a JAR 147 approval if the JAA Authorities are satisfied that there is a need for such an approval. The need must be expressed by an organisation located in the JAA territory, and may e.g. be in the form of a letter of intent by a JAR 145 approved organisation to use the training school to train their personnel.
This provision was put in the requirement not as a trade-barrier but as a tool to allocate first the JAA work resources to the needs of the European Industry.
JAR 147 implementation
The approval of all applicants for a JAR 147 approval is a long process and for obvious reasons, the JAA elected to first concentrate its resources on the European scene.
This will result in most foreign applicants for a JAR 147 Type Training Organisation approval not being approved by 1 June 2001.
This is not viewed as a critical issue by the JAA because, as we have seen above, an organisation that is not yet JAR 147 approved always have the interim possibility to get an approval for individual type courses from the concerned JAA Authority.
I have mentioned foreign basic training JAR 147 approval, as so far only applications for foreign type training have been received. Obviously, while it is reasonable for a type training organisation to envisage attracting European customers for a 4-week type training course, it is less probable to expect attracting foreign students for a 2-year basic training course. The need for foreign basic JAR 147 approval will therefore remain limited.
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