AEA addresses issues related to design, certification and airworthiness in its Engineering & Maintenance Sub-Committee. The aim is to optimise engineering and maintenance measures to improve safety and productivity.
AEA supports the highest standards of safety. However, engineering and maintenance safety rules must strike a fair balance between the need to optimise safety and the need to avoid unduly burdening Maintenance, Repair and Overhaul shops (MROs) with extensive obligations and related implementation costs.
AEA is pro-actively involved in EASA’s work through the EASA Advisory Board, EASA Safety Standards Consultative Committee (SSCC), Rule-Making Tasks and specific Committees to ensure that the interests of the airlines are taken into account. AEA also contributes to the ongoing process of revising the EASA Basic Regulation.
In recent years Original Equipment Manufacturers (OEMs), in particular in the field of engines and components, have become increasingly aggressive in order to capture a bigger part of the Maintenance, Repair and Overhaul (MRO) market. Engine and Component OEMs are more and more in direct competition with airline and independent MROs which rely on the same OEMs for access to technical documentation, spare parts and test equipment. In the longer term there is a risk that the MRO market will be dominated by OEM monopolies, restricting the airlines’ choice of provider. This would lead to increased costs for all airlines and for consumers.
Action must be taken by the Commission to safeguard competition within the aircraft MRO market so that airline MROs, independent MROs and OEM MROs can compete on a level playing field. The Commission must also ensure that the EU internal market functions efficiently, for the benefit of both consumers and aircraft operators.
The new EU Regulation (No 1907/2006) on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) entered into force in 2007 with the purpose of managing all chemicals manufactured, imported or used in Europe. Under REACH, the so-called Substances of Very High Concern (SVHC) cannot be placed on the market or used without prior authorisation after a certain sunset date. These substances are often used by the aviation industry to fulfil stringent safety requirements. There are many unknowns related to the REACH authorisation procedure for SVHC and even if authorisations are granted there is no guarantee that there will be continued supply within the EU. Not only would this lead to substantial income and job losses, but the work would continue to be done anyway, at facilities outside the EU.
The aviation industry is committed to the objectives set out in the REACH legislation, but in its current form REACH will create an unacceptable burden for the aviation industry and jeopardise European competitiveness. AEA therefore calls upon EU decision-makers to adjust the REACH implementation process in order to guarantee the economic viability of European MRO.