On the deferrement of defects

With the entry in force of Regulation (EU) No 1321/2014 (revised by 2019/1383 and 2019/1384) on the 24th of March this year, there is a welcoming and significant difference between Parts M and ML - thank you EASA for the effort you are putting in in alleviating the requirements for GA!

Specifically, I find the difference in M.A.403 and ML.A.403 on who can defer defects particularly interesting:

1. M.A.403: “Only the authorized certifying staff, according to points M.A.801(b)1, M.A.801(b)2, M.A.801(c), M.A.801(d) or Annex II (Part-145) can decide, using M.A.401 maintenance data […]”
2. ML.A.403: “the appropriately qualified certifying staff in respect of other defects than those referred to in points […]”

The term maintenance data is nowhere in ML.A.403 which indicates that appropriate certifying staff can now defer defects based on their own judgment (on what seriously endangers flight safety) rather than specific data that has never existed for GA aircraft (e.g. SRM, PDS, MRB/MPD/OMP, etc.).

The only reference to maintenance data is in AMC1 ML.A.403(d) which relates to the time of rectification of deferred defects.

This has been an issue of contention with the NAAs for years as the lack of any supporting documentation from GA aircraft TCHs made it almost impossible to defer any defects. As a real-life example, defects like "scratched lens on recognition light" or "bits of paint missing around screws" could not be deferred as there was no "maintenance data" to support it!

I can't thank EASA enough and can only applaud the road they are taking regarding GA as it reflects the true difference in available TCH support and documentation between an A320 and a DA20.

Can't wait for Part 21L and keep up the great work!