Sir - Andreas Georgiades, president of Aircraft Engineers International, wrote on the Joint Aviation Authorities' (JAA) requirement JAR 65 (Flight International, 6-12 September, Letters, P43).
I would like to point out that the views and facts in David Learmount's original article (Flight International, 26 July - 1 August) were based on the JAR 65 Notice of Proposed Amendment (NPA), which provides the basis for industry consultation.
The document does not represent a completed requirement, since a particular request was made for comment on some key issues on which policy needed to be finalised.
Mr Georgiades specifies two items which I believe are worthy of further comment, to prevent any misunderstanding.
First, the Category A certificator is very limited in his or her capacity to certificate. This situation is deliberate, and reflects the fact that these personnel will not be able to troubleshoot defects, but only be able to replace certain agreed items, the condition of which can be readily determined as unserviceable. Their familiarity with an aircraft type will probably extend beyond the detailed task knowledge they need for their limited authority, but in view of their role, there cannot be any real justification for insisting on complete training for the particular aircraft type.
I would emphasise that the JAR 65 proposals with respect to Category C certificating privileges are essentially the same as the current provisions under the UK Air Navigation Order (ANO). Under the latter system (and proposed in the current JAR 65 document), the legal requirement is that a Certificate of Release to Service (CRS) is only given at the time of releasing an aircraft back to service. The certification effectively signs off all work carried out on the check.
All contributory work also needs to be signed off, but a CRS certification is not now a legal requirement under the ANO.
Confusion arises because, in the UK and many other countries, it has become common practice to use the wording of the legally-required CRS at the bottom of each page of the work packs.
J C McKENNA
Head of licensing standards division
UK Civil Aviation Authority, Gatwick Airport South, UK
Source: Flight International
