EASA Part NCO and Carriage of PLB and ELT Equipment

[SteveSlater]

There have been some concerns raised among LAA members regarding the mandatory fitment of ELT and PLB equipment. The LAA can confirm there are no CAA plans to mandate their fitment in LAA Permit aircraft.

EASA Part-NCO requirements only apply to EASA Certified aircraft and their operators. They also include a relatively small number of aircraft operating under EASA Permits to Fly. These are all outside the control of the LAA .

Annex II types, which are outside of direct EASA control, will continue to operate under the terms of the CAA Air Navigation Order. Effectively there will be no change to our operations as a result of this revised EASA regulation, although the CAA is currently working on changes to the ANO which will bring it in line with the new EASA regulations. These changes are due to be announced around October.

We have this week sought and received confirmation fro the GA Unit that the mandatory carriage of ELT/PLB equipment will not be included in the ANO revisions in the CAA change documents. It has been agreed that as there is no proven risk-based or financial case, the mandating of ELT/PLB in Permit aircraft would demonstrate unnecessary ‘gold plating’.

The only area where the new ANO changes may potentially affect owners of LAA Permit aircraft may be those who are using such types as glider tugs, as the main emphasis of the EASA document deals with aerial work. We have suggested to the CAA that this area, as it is directly linked with sport flying, is categorised as non-transport flying and therefore outside the terms of Air Operations Regulations.

Steve Slater
Light Aircraft Association

[John Brady]

Steve,
as many members own or fly CofA aircraft could you post the impact and any known alleviation on them?
John

[Cookie]

Part-NCO was implemented in EASA states during 2013. The UK CAA have already applied the maximum derogation permitted up to August 2016, so a further exemption to this is unlikely. LAA Permit to Fly aircraft will be required to comply with the requirements of the ANO, and not Part-NCO. The ANO Review has aligned some of the future ANO requirements with Part-NCO where simplification was desirable. However where EASA is more restrictive and there is no safety case in support of a more restrictive requirement, your representatives on the ANO Review (myself included) sought to retain the current requirements or amend them.

EASA Part-NCO requirements only apply to EASA Certified aircraft and their operators. They also include a relatively small number of aircraft operating under EASA Permits to Fly. These are all outside the control of the LAA .

Steve, this statement isn't actually correct. Of note is that some aircraft for which the continued airworthiness is administered by the LAA are actually EASA Permit to Fly aircraft, and would be required to comply with Part-NCO and the associated requirements.

Cookie

[Joseph Cullen]

I fly an ARV Super2 which is on an EASA permit administered by the LAA. Can somebody give me a definitive answer as to whether I need to carry a PLB or ELT after 1 August 2016? Given some of the places that I fly over, it may well be a good idea anyway but I'd like an authoritative answer to this.

[mikeblyth]

PLB not a problem and relatively cheap. I bought one for a trip to Belfast and now leave it in my
current plane. ELT another matter not cheap and requires paperwork.

[SteveSlater]

Hi Jo and Jon,

While the LAA administers EASA Permit to Fly aircraft on behalf of owners, the key difference is that we have, as I said earlier, no direct control of mods or exemptions. In the case of LAA Permit aicraft we can and do, ask the CAA to seek derogations which they can implement in the ANO. Jon has played a very active part in this (thank you!).

Unfortunately no similar mechanism seems to exist in the EASA world, although I will further query next week, whether there is any way EASA PtF types need to follow the same strictures as EASA Certified types. I must warn you I am not hugely optimistic though.

Steve Slater

[Joseph Cullen]

Am I correct in my interpretation that carrying a PLB will meet the requirement?

[Jeremy Liber]

Minor point; there is no such thing as an LAA Permit to Fly.

Most are LAA-administered CAA Permits, a few are LAA-administered EASA Permits.

[Joseph Cullen]

ORS4 No.1183: The Carriage of Emergency Locator Transmitters in Aircraft Flying for Purposes other than Public Transport or Commercial Air Transport dated 8 August - gives an exemption for UK registered aircraft as indicated.

[SteveSlater]

After receiving several explanations which proved as clear as mud, indebted to Mark Charlwood, Manager of GA Operations at the CAA, for this clarification of ORS4 1183:

All UK registered aircraft are regulated by the ANO 2009 until 25th August 2016 when the EASA Air Operations Regulations come into force. Under the ANO 2009 all aircraft are required to carry a PLB/ELT, however, an exemption has been in place for many years relieving aircraft operating for other than Public Transport or CAT from the requirement.

On 25th August 2016 the new ANO for Annex II aircraft will come into force and the requirement to carry a PLB/ELT has been removed from the equipment schedule for Annex II aircraft. This means that the exemption is no longer required.

For EASA aircraft the EASA Air Operations Regulations come into effect on 25th August 2016 so EASA aircraft will need to comply with those regulations and thus will need to carry and ELT/PLB as per NCO.IDE.A.170. The exemption will no longer apply because the CAA can only apply for an exemption from the requirement to comply with the regulations for a limited period of two months, in order to address an immediate safety issue. As this has been in law for 3 years, and the full derogation period was applied, no further extensions are possible.

In summary:
- On 25th August 2016 all EASA aircraft will have to carry a PLB or an ELT.
- On 25th August 2016 non-EASA will still not have to carry a PLB/ELT but an exemption is no longer required.


Don't forget though, if you take your LAA/CAA Permit aircraft overseas, the requirement to carry PLB/ELT will still apply!

Steve

[Ian Hoolahan]

Needing one for flying abroad we have just bought one for our group - saved over £50 buying from a marine supplier rather than an aviation one!