Aerospace & Aviation
Volume 1 • Issue 3
Oceans Apart
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A Study by Purdue University Professors Analyzes the Gulf between FAA Regulations and JAA Requirements
On June 1, 2001 the gulf between European and American standards for aviation maintenance widened dramatically. On that day, Europe's Joint Aviation Authorities (JAA) required full compliance with JAR-66 Certifying Staff Maintenance and JAR-147 Approved Maintenance Training/Examinations.
JAR-66 and JAR-147 are two of JAA's three new Joint Aviation Requirements that address the maintenance needs of modern aircraft and avionics. The third requirement is JAR-145 Approved Maintenance Organizations, which became compulsory as of December 1994 for organizations providing commercial air transport maintenance. JAR-145 will eventually cover maintenance of all aircraft types.
While Europe's aviation technicians embark on a new chapter in aircraft maintenance, their U.S. counterparts are following standards mandated by regulations formulated in 1962, and minimally updated since. These regulations are Part 65 Certification: Airmen Other Than Flight Crewmembers, Part 145 Repair Stations and Part 147 Aviation Maintenance Technician Schools.
The contrast between JAA requirements and FAA regulations is noteworthy. European aviation technicians are honing their expertise on digital avionics and advanced materials while U.S. technicians are forced to learn little-used techniques, like airframe fabric repair and applying dope, but little to nothing about technology prevalent on today's aircraft.
FAA recognizes the dichotomy, and in 1998 it issued a notice of proposed rulemaking (NPRM) to update Parts 65 and 147. The opposition was so vitriolic that FAA withdrew the NPRM in 1999 and retreated to "study the issue internally."
FAA also issued an NPRM in June 1999 to rewrite Part 145. The proposal also encountered staunch resistance and remains mired in controversy.
A scholarly look
With the U.S.-European regulatory "gulf" widening, two professors at Purdue University, Michael Leasure and Ronald Sterkenburg, decided to analyze the differences between JAR-66 and Part 65. Both men teach aviation maintenance at Purdue's Department of Aviation Technology and each brought a different perspective to the analysis. Leasure gained his aviation maintenance certifications in the U.S., while Sterkenburg, a native of The Netherlands, began his aviation maintenance career in the Dutch military then acquired an A&P certificate in the U.S.
"We deal daily with Part 65 and Part 147 regulations and we want to see those regulations updated," Sterkenburg said. "One reason is because we still have to teach things no one really cares about anymore, but FAA requires it. Meanwhile, the airlines want mechanics who have more training in electronics and other advanced technology.
"The European regulations are new, so we looked at the differences between them and FAA regulations to see how we could use the differences to our advantage." Leasure and Sterkenburg presented their analysis in April at the annual Aviation Technician Education Council (ATEC) conference. The report's title is "A Comparison of the Licensing and Training Requirements of FAR Part 65 and JAR-66 and Their Impact on U.S. and European Air Carriers."
"Airlines are interested because their operations are increasingly global and a lot of their aircraft are being serviced abroad," Sterkenburg said. "Airlines want to know what kind of qualifications the technicians overseas have."
Of wider interest is the influence JAR-66 will play on future FAA regulations. The JAA and the FAA are working hard to harmonize their regulations and it is quite probable the FAA will use JAR-66 as a template for its next attempt to revise Part 65.
The key differences between JAR-66 and Part 65 are that JAR-66:
- Requires more training hours,
- Requires more training in specific technologies,
- Has more license categories,
- Requires aircraft-specific training and certification and,
- Requires recurrent training.
Training and syllabus
Both JAA requirements and FAA regulations stipulate two ways to obtain a maintenance certificate. One is through practical experience, which requires the certificate applicant to pass written and oral tests. The second is by graduating from an approved training program. However, the coursework and hours required by the FAA and the JAA vary greatly and depend on the certification pursued.
Regarding coursework, Part 65 does not stipulate training topics (leaving that to Part 147), while JAR-66 does. Furthermore, JAR-66's training modules are more pertinent to today's technology. For example, the FAA requires only a basic avionics knowledge, while JAR-66 not only dedicates a module to the topic, but also establishes an avionics certificate. The JAA also requires human factor training, which is absent in FAA regulations.
Training hours required by the FAA range from 1,150 hours to 1,900 hours. By comparison, the JAA requires 800 hours to 3,000 hours. This translates into a term of three to four years to acquire a JAR license, with the last year of training being an internship. Intriguingly, JAA license holders must also be at least 21 years old.
Certification categories
The disparity in training requirements between Part 65 and JAR-66 is related to the certification categories. The FAA has three certification categories: airframe, powerplant, and airframe and powerplant (A&P). Either of the first two categories require 1,150 hours, while the A&P requires 1,900 hours.
The FAA also issues inspection authorizations (IAs) to A&Ps who have three years' experience and pass written tests. An IA can return an aircraft to service after major repair and perform annual inspections, but the authorization generally applies only to general aviation aircraft.
For commercial aviation, inspection personnel holding only an A&P can return aircraft to service. However, Part 121 and 135 regulations require them to work under the supervision and control of an inspection unit, and they cannot inspect their own work.
The JAA has four certification categories:
- Category A-Requires minimum of 800 hours instruction and the technician can perform scheduled line maintenance and simple defect rectification.
- Category B1 (Mechanical rating)- Requires minimum of 2,400 hours instruction and the technician can perform maintenance on aircraft structure, powerplants and mechanical and electrical systems, as well as change out line-replaceable avionics units.
- Category B2 (Avionics rating)- Requires minimum of 2,400 hours instruction and the technician can perform maintenance on avionics and electrical systems.
- Category C (combines B1 and B2)-Requires minimum of 3,000 hours of instruction, and the technician can perform maintenance on all aircraft systems.
"The most significant difference is that JAR-66 requires aircraft-specific type training before the holder of an aircraft maintenance license can be issued a JAR-145 certification authorization to return an aircraft to service," the paper stated.
JAA adds another level of specialization to its license categories, with five subcategories: airplanes turbine, airplanes piston, helicopters turbine, helicopters piston and avionics. Students attending an approved training facility and completing the B1 category qualify for the first four subcategories; those completing the B2 category qualify for the avionics subcategory. Applicants receiving licenses based on prior experience are qualified only in subcategories in which they have experience.
Finally, the JAA requires recurrent training for all licensees. Furthermore, the license holder must receive recurrent training for every aircraft type for which he or she has a JAR-145 certification authorization. Part 65 only requires recurrent training for IAs, although it does mandate recent experience for A&Ps.
JAR-66 Training Modules
- Mathematics
- Physics
- Electrical Fundamentals
- Electronic Fundamentals
- Digital Techniques/Electronic Instrument Systems
- Material and Hardware
- Maintenance Practices
- Basic Aerodynamics
- Human Factors
- Aviation Legislation
- Airplane Aerodynamics, Structures and Systems
- Helicopter Aerodynamics, Structures and Systems
- Aircraft Aerodynamics, Structures and Systems
- Propulsion
- Turbine Engines
- Piston Engines
- Propellers
Airships
In closing, the analysis stated, "In the modern world of airlines and airline maintenance, it seems the JARs emphasis on advanced technology training would be the best solution. Also, the type certification of technicians for specific aircraft would certainly have merit as aircraft complexity increases. The requirement for recurrent or in-service training is also a big plus for the European method."
Pointing to the good safety record of U.S. carriers, which basically monitor their own maintenance practices, the paper's authors also said that a system "not quite so governed by a central agency" also had advantages.
Reprinted with permission.
July 2001 article in Aviation Maintenance, by Kathleen Kocks, Contributing Editor
Both JAA and FAA regulations are available through Global. See the Standards Section of this publication.