EASA Part-NCC

As of the 25th of August 2016, all Part-NCC operations must be included in the oversight programme of the competent National Aviation Authority (NAA). This also means announced and unannounced inspections, in addition to the existing ramp inspections led by various authorities (e.g., SACA for EU community operators, or SAFA for third-country operators).

How will your operation satisfy the authority? How can Aerodit support the important decisions you must take? We provide you with clarity and peace of mind by preparing you to this new framework. Five different options are available:

  •  Before any EASA Part-NCC implementation:
    • Part-NCC Quick Check: a one-day on-site assessment to broadly check the essentials, for a flat fee.
    • Part-NCC Gap Analysis: how long and arduous is the road to EASA Part-NCC compliance, and which strategic decisions should you take? Let’s find out together and precisely identify what needs to be done.
  • During or after the EASA Part-NCC implementation:
    • Part-NCC Desktop Evaluation: documentary review of your Operations Manual(s) against the EASA requirements applicable to your operations, including a compliance checklist;
    • Part-NCC Evaluation: documentary review, compliance checklist and on-site audit against the EASA requirements applicable to your operations;
    • Dual Evaluation (IS-BAO + EASA Part-NCC): as a service to the industry, IBAC produced several documents to facilitate the implementation of EASA Part-NCC through IS-BAO (including a compliance tool and an EASA Part-NCC Generic Operations Manual). For just one extra day on top of any IS-BAO audit we will assess your operation against both standards.

Why should you have an evaluation performed by Aerodit? Reasonable and responsible organisations that value the benefits of an independent, expert opinion will want to validate the compliance and efficiency of the systems, processes and procedures put in place. In other words these services prove particularly useful to:

  1. Operators that implemented EASA Part-NCC requirements without any external help, and aiming to ensure that they’re on the right tracks;
  2. Operators using third-party services to achieve compliance (e.g., manuals, software, consulting, AOC) and interested in assessing the effectiveness and efficiency of those services;
  3. Corporate and private operators wishing to better evaluate their options before deciding whether they should place their aircraft in a commercial structure or upgrade their own to EASA Part-NCC;
  4. Lessors, banks and insurers wondering about a customer’s ability to manage risks and achieve regulatory compliance in Europe.

Contact us with your company details and receive a free quote for your EASA Part-NCC evaluation.

 

Q&A: the essentials of EASA Part-NCC in 7 questions and answers

1. What’s EASA Part-NCC? Who needs to comply?

Part-NCC is the most commonly used name for what is actually a combination of EU regulatory requirements applicable to non-commercial operations of complex motor-powered aircraft. In a nutshell, these requirements apply to any individual or organisation operating an aircraft regarded as ‘complex’ if it meets the following:

  • Registered in an EU/EASA member state; or
  • Based in Europe (read below or contact us if you need clarifications);
  • Having a maximum take-off mass above 5.7 tons; or
  • Powered by at least one turbojet engine; or
  • Powered by at least two turboprop engines; or
  • Having 19 seats or more; or
  • Powered by motors mounted on rotating engine pods (i.e., tiltrotors); 

Regarding rotary-wing aircraft specifically, the following criteria define a helicopter as ‘complex':

  • A maximum take-off mass above 3.175 kg; or
  • Requiring a crew of at least 2 pilots; or
  • Powered by at least one turbojet engine; or 
  • Powered by at least two turboprop engines; or 
  • Having 9 seats or more.

Reminder: in a fairly recent development EASA accepted to exclude twin turboprops with a MTOM below 5.7 tons (i.e., most King Airs, etc.). For those, Part-NCO will apply rather than Part-NCC.

2. We’re conducting our flight operations from within Europe but our aircraft is not registered in an EU/EASA member state. Does Part-NCC apply and does that mean double oversight?

There’s little doubt left if your operations remain mostly within Europe: Part-NCC will likely apply (but read on). In other cases, the EU regulations leave some room for interpretation. It would be sensible to query the competent authority of the countries overseeing your operations to determine your principle place of business and whether Part-NCC applies or not. Concerning the issue of double oversight, EASA acknowledges the problem and wants to avoid unnecessary duplication if the state of registry complies with ICAO Annex 6 Part II. EU-based operators of aircraft registered in such territories as the Isle of Man, Bermuda or Cayman Islands are therefore very likely to be released from implementing Part-NCC. At present EU-based operators of N-registered aircraft won’t be able to dodge Part-NCC and some form of double oversight.

3. We’re frequently flying in and out and into Europe, but are neither based nor registered in an EU/EASA member state (e.g., FAA Part-91K, FAA Part-135 operator). Does EASA Part-NCC apply to us?

Most likely not, but let’s make sure by reviewing the details of your operations.

4. What’s expected in practice?

NCC operators must have a controlled Operations Manual, a Safety Management System, a system to monitor compliance with regulatory requirements, Standard Operating Procedures, an approved MEL (if applicable), appropriate training for all staff, and any approval pertinent to the aircraft type and operation. Moreover Part-NCC operators need to either set-up or contract a Continuing Airworthiness Management Organization (CAMO) to manage the airworthiness of their complex aircraft. Operators must also declare themselves to their competent authority, but they don’t need to submit their manuals for approval.

5. Is it another piece of superfluous regulation exclusive to Europe?

EASA Part-NCC closes the gap between commercial and non-commercial operators by raising the bar for many business/general aviation operators. The purpose is to align Europe with ICAO expectations and with the latest amendments to Annex 6 in particular. Certain questions may remain on the fine-print, however Part-NCC  finally creates a common regulatory framework for an entire aviation sector that wasn’t always accustomed to legal certainty.

6. Why not simply wait for an aviation authority to identify any non-conformity?

Your NAA can go as far as grounding your wonderful aircraft or taking similarly restrictive measures until you fix the non-conformities. Aerodit is there to assist you avoiding all that in a proactive manner since Part-NCC may be quite challenging to implement. Prevention remains the best cure: overall it’s cheaper… and safer for you and those you care about.

7. My operation falls under EASA Part-NCC but I’ll wait for clear guidance and instructions from the competent authority before doing anything…

All the opt-outs and possible postponements have already been used by all EU/EASA member states. August 2016 was the final deadline. Any Part-NCC-type of operation conducted without meeting the associated requirements would obviously be illegal. In case of problem, even the tiniest, an operator would in effect completely subject itself to the good will and leniency of its competent authority, insurer, bank, customers, etc. No words could possibly describe how hazardous and uncomfortable this situation would be for the continuity of an operator.