several members approached me with queries to the implementation schedule and details to this regulation. After a meeting on September 25th with EASA where I voiced our concerns and requests for clarification I received the following replies:
- “Basic training courses or any part thereof” refers only to the approved 2400 hrs course any other combination of training and examination is not recognized by EASA as course. In this case they are only considering this as “approved examinations” which have to be amended according to the new regulation before June 12. 2024.
- If the approved basic training course is conducted by a national school or college, the start of the training is considered the first day a Part-66 relevant subject is taught.
- EASA discussed the deadline for the implementation (12. June 2024) with all member states (not industry) and they did have no objections.
- EASA might produce a better explanation for the implementation in the GM to assist standardization in the member states.
- Regarding the short time to amend training materials, MTOE and examinations EASA cannot see a problem since all changes in the syllabus in Appendix I are seen as minor or in case of new topics such as i.e. additive manufacturing and electric-hybrid engines the level being low enough to produce the necessary materials in due time.
- The still missing AMC’s and GM will be provided by end of October and can be commented by us.
- Meanwhile, it was suggested to use the Appendix I as shown in NPA 2020-12 as a guide to prepare the training materials as the changes in the AMC’s, GM will be minor…..
- With the exception of the German LBA, they did not get any negative feedback from other NAA’s regarding the implementation schedule.
with best regards,
Harald – EC Secretary