Europe's safety regulator is already preparing retaliatory action to be taken if the US Senate passes the controversial US FAA reauthorisation bill, which would require the FAA to inspect Part 145-certificated foreign repair stations at least twice a year.
In a letter to European air transport director Daniel Calleja, European Aviation Safety Agency chief Patrick Goudou writes that the bill's inspection requirements "contravene the confidence built in the regulatory oversight" carried out by the FAA and EASA, currently harmonised by the bilateral EU-US aviation safety agreement signed in June 2008.
Goudou adds: "Measures should be put in place to make sure that the European side will act in a reciprocal manner if the above-mentioned act is finally adopted."
These measures, he says, would involve EASA's carrying out oversight of all 1,233 US repair stations that have been granted an EASA type 145 approval, and are currently surveilled by the FAA.
EASA is already preparing an invitation to tender for a study to define "the most efficient way" to carry out such oversight, writes Goudou, who suggests that surveyors could be based initially in Europe and later, once "legal prerequisites" are met, in the USA.
Negation of the US-EU bilateral agreement would impose higher costs on US maintenance organisations. Under EASA rules, organisations covered by bilateral agreements are charged €1,500 ($2,100) for new Part 145/147-equivalent approvals and €750 for renewals. However, those which are not covered by bilaterals are required to seek full maintenance organisation approval, for which charges are imposed on a sliding scale based on employee numbers. An organisation with at least 1,000 employees would face a €53,000 approval fee and a €43,000 surveillance fee.
Goudou says EASA will write to all 1,233 of its approved US maintenance organisations this month, requesting information on their employee numbers and on the technical ratings they would seek if their status changed from "bilateral accepted approval" to full EASA Part 145 approval. This communique "would serve the purpose of informing all maintenance organisations on the negative impact of the envisaged change, and this will trigger most probably some reactions in the repair station community", he writes.
The study on how best to carry out oversight will be launched this month and conclude in September, with a choice of option to follow in October.
Deployment would take place between November and June 2010, according to the timetable set out in Goudou's letter to Calleja, who had previously written to EASA to stress the "urgent need" for the agency to draw up draft measures.