Hello, excuse me for my late reply.
In regards to the RTM.0544, I would like to introduce the following items:
– 147.A.105 (f) experience and qualifications of instructors refer to the standards agreed by the competent authority.
Our suggestion is to standardize these criteria, so the requirements would be the same from one country to another, allowing instructors to work in MTOs from different countries with the same qualification and experience. The common requirement should not be aligned with the most restricted NAA´s requirement, that could damage current Part 147, but closer to the less demanding NAA, or to the most common requirements accepted by NAAs in EU.
In addition, for new aircraft (types), also as a common requirement and rule, it should be accepted as relevant the experience acquired in a production or design environment (design, production, flight test…) in the type (not only in maintenance environment) and a reduced amount of experience in the type.
– AMC 147.A.130(b) 1. “The independent audit procedure should ensure that all aspects of Part-147 compliance should be checked at least once in every 12 months…” but in the case of the audit is an inspection of an ongoing course regarding theoretical element/practical element/theoretical examination/ practical assessment, it is dependent of the courses planning, and sometimes it could not be possible to adjust inspections to this 12 months. Therefore this should be taken into account: “In the case of an ongoing course inspection audit, this requisite of 12 months could be adjusted depending on the courses planning, with the previous communication to the NAA”
– 147.A.100 i). From our point of view, the requirement of having a physical library should not be required anymore, as nowadays students can have access to the technical documentation through electronic means, not necessarily allocated in a library.
– And also, we would like to have some feed back from RTM.0544 meetings,
A clear view about which parts of the NPA2014-22 will be introduced in new Part 147 and which ones in Part 66, as well as which of them will be updated.
Confirmation if the Competence Based Training concepts will be finally introduced in Part 147, as some activities carried out could be impacted, as examinations/assessments (introduce examination different from those based on test: open books exercises…)
Thanks a lot for your support and good work.
Yours Sincerely
Roberto López
Examination Manager at ITC Seville (Airbus Defence and Space)
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