Name: Mladen Hanevaki
Title:
Continuing Airworthiness Rulemaking Officer
Date: 21/22 May 2013
Outline
EASA Regulation structure EASA Rulemaking Procedure
21/22 May 2013
EAMTC Instructor Seminar RMT.0281
Outline
EASA regulation structure EASA Rulemaking Procedure
21/22 May 2013
EAMTC Instructor Seminar
EASA rulemaking organisation structure
21/22 May 2013
EAMTC Instructor Seminar
EASA Rulemaking Structure
EASA rulemaking procedure
Continuing airworthiness regulation
RMT.0281 (MDM.082)
21/22 May 2013
EAMTC Instructor Seminar
Outline
EASA regulation structure EASA Rulemaking Procedure
21/22 May 2013
EAMTC Instructor Seminar
EASA Rulemaking Procedure Overview
Phase 1: Programming
4-year Rule making Programme
Phase 2: Rule development
Decision
Opinion
What to do when?
How to do it?
21/22 May 2013
EAMTC Instructor Seminar
Inputs to rulemaking
European Aviation Safety Plan
ICAO EASA country NAAs
Safety Recommendations
Industry
Third Country NAAs
European Institutions
Rulemaking Proposal
Agency processes: R, E, S and C
A large number of proposals from a wide variety of sources What to do when?
21/22 May 2013 EAMTC Instructor Seminar 8
Rulemaking Procedure Phase 1: Programming overview
Initial review
Develop Pre-RIA
Consult Drafting RAG/TAG Rulemaking /SSCC Programme
Consult Final RAG/TAG revision /SSCC
4-year Rule making Programme
21/22 May 2013
EAMTC Instructor Seminar
Rulemaking Procedure Phase 1: Internal consultation
Internal consultation with C, S and E focal points, who propose experts
Initial review
C Develop S ISC Pre-RIA E
Consult Drafting RAG/TAG Rulemaking ISC /SSCC Programme
Consult Final RAG/TAG revision /SSCC
4-year Rule making Programme
Internal Safety Committee consultation
21/22 May 2013
EAMTC Instructor Seminar
10
Rulemaking Procedure Phase 1: Programming timeline
2013
Feb Mar Apr May Jun Jul Aug Sep
Continuous process Initial Develop as soon as review Pre-RIA Pre-RIAs are ready
Consult Drafting RAG/TAG Rulemaking /SSCC Programme
Consult Final RAG/TAG revision /SSCC
4-year Rule making Programme
Submission of latest Pre-RIAs to RAG/TAG/SSCC
21/22 May 2013
EAMTC Instructor Seminar
11
Rulemaking Procedure Phase 1: Programming timeline
2013
Feb Mar Apr May Jun Jul Aug Sep
Continuous process Initial Develop as soon as review Pre-RIA Pre-RIAs are ready
Consult Drafting RAG/TAG Rulemaking /SSCC Programme
Consult Final RAG/TAG revision /SSCC
4-year Rule making Programme
End of technical consultation on Pre-RIAs
21/22 May 2013
EAMTC Instructor Seminar
12
Rulemaking Procedure Phase 1: Programming
2013
Feb Mar Apr May Jun Jul Aug Sep
Continuous process Initial Develop as soon as review Pre-RIA Pre-RIAs are ready
Consult Drafting RAG/TAG Rulemaking /SSCC Programme
Consult Final RAG/TAG revision /SSCC
4-year Rule making Programme
Start of consultation on draft Rulemaking Programme
21/22 May 2013
EAMTC Instructor Seminar
13
Rulemaking Procedure Phase 2: Rule development
4-year Rule Task making initiation Programme
Decision Analyse with CRD issue Phase Draft 2:NPA Public Draft Public Final ToR RIA CRD and Consult Edit Rule (RIA) Consult CRD Rule development develop Opinion Draft RIA with CRD
21/22 May 2013
EAMTC Instructor Seminar
14
Rulemaking Procedure Phase 2: Rule development
NEW: Optional consultation of a concept paper
Concept Paper
Decision
with CRD
Consult 4-year RAG/ ToR Rule Task making initiation TAG/ GC Programme SSCC
Draft ToR
Opinion
with CRD
21/22 May 2013
EAMTC Instructor Seminar
15
Rulemaking Procedure Phase 2: Rule development
Analyse Consult 4-year RAG/ ToR issue Rule Task and making initiation TAG/ GC develop Programme SSCC Draft RIA
Decision
with CRD
RIA
Draft Rule
NPA
(RIA)
Opinion
with CRD
21/22 May 2013
EAMTC Instructor Seminar
16
Rulemaking Procedure Phase 2: Rule development
Analyse Consult 4-year RAG/ ToR issue Rule Task and making initiation TAG/ GC develop Programme SSCC Draft RIA
Decision
with CRD
RIA
Draft Rule
NPA
(RIA)
Opinion
with CRD
Regulatory Impact Assessment for evidence-based decision-making
The Notice of Proposed Amendment with the RIA to describe and explain the proposal to the public
21/22 May 2013
EAMTC Instructor Seminar
17
Rulemaking Procedure Phase 2: Rule development
Analyse Consult 4-year RAG/ ToR issue Rule Task and GC making initiation TAG develop Programme SSCC Draft RIA
Decision
RIA
Draft Rule
NPA
(RIA)
Public Consult
CRD drafting and final review
with CRD
Opinion
with CRD
http://hub.easa.europa.eu/crt/
21/22 May 2013
EAMTC Instructor Seminar
18
New template: The layout
NPA CRD Decision Opinion
Amended rules in the Explanatory note, not on the front page
21/22 May 2013
EAMTC Instructor Seminar
19
Rulemaking Procedure Phase 2: Rule development
Timing
01/ 13
KO
02/ 13
03/ 13
1.op tion
04/ 13
05/ 13
RIA
06/ 13
07 /13
08/ 13
09/ 13
1. NPA
10/ 13
11/ 13
2. NPA
12/ 13
01/ 14
02/ 14
3. NPA
03/ 14
04/ 14
05/ 14
06/ 14
NPA Pub
2-6 months
3-18 months
1-3 months
2-6 months
Decision
with CRD CRD drafting and final review Opinion with CRD
Analyse Consult 4-year RAG/ ToR issue Rule Task and GC making initiation TAG develop Programme SSCC Draft RIA
RIA
Draft Rule
NPA
(RIA)
Public Consult
Total time for rule development: 8-33 months
21/22 May 2013 EAMTC Instructor Seminar 20
[email protected]