NPA 2018-13 Appendix I to AMC to Annex III (Part-66) can be commented

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Dear all,

NPA 2018-13 Appendix I to AMC to Annex III (Part-66) Aircraft type ratings for Part-66 aircraft maintenance licences RMT.0541 (66.024) has been published and can be commented until 5 March 2019.

NPA 2018-13

Please review and send your comments to our president  <>  before March 1st 2019 for a consolidated EAMTC feedback. Additionally you can also comment for your organisation by using the EASA Comment-Response Tool (CRT) available at

In addition to commenting the content, EAMTC has also received a request to complete a survey on the quality of the rulemaking. You can respond to this as well and send your comments to the president before March 1st 2019.

Here are the questions:

  1. Technical quality of the (draft) legal text – assesses the extent to which the rule (proposal) achieves its objectives in a cost-effective manner.
  2. Clarity and simplicity of the (draft) legal text – measures if the text is written in an understandable way.
  3. Clarity and linguistic quality of the Explanatory Note – measures the user-friendliness of the format, layout and structure of the documents; the linguistic quality (clarity and readability), the level of details and easy use of the document.
  4. Quality of the impact assessment – measures how credible and sound the regulatory impact analysis is (e.g. based on reliable data which is analysed in a valid and objective manner) and whether it is written in an understandable way.
  5. Application of performance-based principles – evaluates to which extent the proposed rules apply EASA’s performance-based principles and PBR policy.

With best wishes for the New Year

Harald Strehling

EC Secretary

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