Recently released FAA policy, ongoing collaboration with EASA, and a new industry guide are coming together to help ease some of the stress of European ramp checks.
European ramp checks, known as EASA’s Safety Assessment for Foreign Aircraft (SAFA) program, had become an increasing concern for operators in the latter part of the 2010s over what they needed to demonstrate compliance. There were frustrations over a lack of harmonization and guidance for authorizations of their necessary documentation.
One of the bigger issues that would recur during these checks, said Doug Carr, senior vice president of safety, security, sustainability, and international operations for NBAA, involved operators that may have had incomplete maintenance and operations procedures, which are a requisite part of the minimum equipment list (MEL) that ramp inspectors would scour—or they might not have them at all. “That’s when the ugly stories would happen,” he said.
Brian Koester, director of flight operations and regulations for NBAA, said certain noncompliance findings would trigger an EASA notification to the FAA of the issue and require an operator to outline corrections. In certain instances, when a part that was excluded from the MEL may have been found broken on an aircraft, the operator would be grounded until it was fixed.
Compounding this for U.S. operators was a lack of clear guidance from the FAA on approvals for their MEL. However, that changed this past October when the agency released its policy in AC 91-67A—Minimum Equipment Requirements for General Aviation Operations Under 14 CFR Part 91, § 91.213 and notice N 8900.680 covering “MEL Approvals Under Part 91, § 91.213(a) and Issuance of LOAs [letters of authorization] D095 and D195.”
NBAA explains that the MEL is “the list of equipment that may be inoperative, yet still allow an aircraft to operate safely, per FAA regulations.” MELs are derived from a master minimum equipment list (MMEL) that the aircraft manufacturer provides and is approved by the FAA.
“The MMEL includes all equipment and accessories available for the aircraft model, while the MEL is created by the operator for your specific type of aircraft,” said Elaine Karabatsos, aviation maintenance director for Encompass Health, to NBAA members.
Koester noted that the FAA pulled previous approval guidance in the late 2010s as it worked on updates. “It was a significant period of time where operators were left without guidance from the FAA on how to properly execute an MEL,” he noted.
Not only has the industry welcomed the release of the guidance, but the guidance found a way to provide “a best of all worlds,” Koester said. It gives pathways to approvals for MELs and MMELs and simplifies it for noncommercial operators through a streamlined, time-saving process.
“The FAA provided a pathway for the thousands that don’t need to go to Europe,” Koester said. And for those that do: “They also have a pathway to demonstrate compliance.” This guidance and these pathways were critical because EASA and the FAA have differing views on these—the FAA would view an MMEL as a MEL meeting ICAO standards, while EASA looked at it differently..The big difference is the way MELs are tailored to aircraft types, he said.
But under the guidance, the FAA provides a pathway that EASA views as compliant. Officials from the FAA and EASA attended NBAA’s International Operators Conference (IOC) in late March to discuss this, their collaboration, and EASA’s acceptance of the pathways.
Also welcomed is the streamlined process afforded under the guidance. Koester noted that with the absence of guidance, the previous process—particularly for changes to MELs—was burdensome and time-consuming for both the operator and the FAA alike. “I’ve heard horror stories of up to two years,” he added.
Not only does the new policy simplify the process for those who do not fly internationally and can use the D095 letter of authorization, but the optional attestation letter will also “really expedite the process for the D195 authorization” for those who need the internationally accepted pathway. Further, what would take three inspectors now really just needs one.
NBAA remains involved in the process, including participating in EASA’s RAMP Industry Forum to discuss best practices and expectations.
To further help operators, NBAA during IOC released an International Flight Plan Format Guide to serve as a comprehensive resource that helps operators streamline and standardize the international flight plan to ensure compliance in international operations. “Using a standard format assures operators of compliance and expedites ramp inspections, allowing inspectors to quickly locate pertinent information,” the association said.
While the ramp inspections and approval processes have been evolving, operators have been learning how to navigate these changes to comply, Koester said. Even so, as requirements shift, this is an area that needs constant watching. Carr cited that one such shift in recent years is the addition of testing for alcohol consumption in these ramp checks.
Of the roughly 10,000 SAFA inspections a year, some 5 to 7 percent have involved general aviation operations.