While you will be very familiar with the normal day-to-day operations, what about the more obscure activities that don’t happen so often? Things like delivery flights to the operator, moving aircraft from one operator to another at the end of a lease, or even flights after maintenance.
What are the more common types of operation that do not involve the carriage of passengers and/or cargo and under what regulations are they operated? This article will tell you everything you need to know about Maintenance Check Flights (MCF).
Also check out this podcast with Donal Young from Technical Flight Solutions will hopefully de-mystify this important topic.
When are they needed and who does them?
MCFs are required on aircraft in various circumstance such as after extensive maintenance, periods of storage period or when moving from one operator to another. Such flights can be as simple as testing the normal operation of the landing gear of an aircraft after a period of storage, or as complex as the In-Service Aircraft Technical Flight profile mandated by some manufacturers, where ground checks and air checks are conducted by specially trained crew on a dedicated flight.
Types of Maintenance Check Flights
Regulations covering the conduct of maintenance check flights are detailed in EASA Air Operations Annex VII (Part-SPO) regulations, specifically under Part SPO.SPEC.MCF. Under these regulations there are two types of maintenance check flights:
- A “Level A” maintenance check flight is one where the use of abnormal or emergency procedures, as defined in the aircraft flight manual, is expected, or where a flight is required to prove the functioning of a backup system or other safety devices.
- A “Level B” maintenance check flight may be required to check the normal operation of an aircraft where a “Level A” maintenance check flight is not needed.
Most Part-CAT operations comply with the regulatory requirements by having trained and current crew available to conduct level A and/or level B maintenance check flights. Additionally, Part NCC compliant operations (Non-Commercial Complex) with their principal place of business within an EASA member state, can also conduct maintenance check flights once they meet the requirements of both Part NCC and Part SPO.SPEC.MCF regulations.
Why the regulations are important?
Regulations on how to carry out maintenance check flights came into existence in 2019 following an extensive period of consultation with organisations and operators. The regulations were precipitated by an accident in 2008 involving an aircraft undergoing an acceptance flight after a period of maintenance, for validation of the airworthiness of the aircraft prior to hand-over to its owner.
“The Investigation noted that end-of-lease airworthiness check flights, although not exceptional, were not included in the list of non-revenue flights detailed in the EU-OPS 1.1045 and that there was no extant overall framework for non-revenue flights either within the EU or outside it which could be used to set constraints on these flights or establish the skills required of the pilots involved in them. It was noted that Operators therefore have to define for themselves the programme and operational conditions for these flights in their Operations Manual and may not have fully evaluated the specific risks that these flights may present.” (Skybrary, A320, vicinity Perpignan France, 2008).
The Part SPO.SPEC.MCF regulations have raised the standards in safety for maintenance check flights in the following ways:
- Flights must be conducted under the operational control of either a Part CAT or a Part NCC organisation.
- Part CAT and Part NCC organisations have management and safety systems in place to ensure correct oversight of maintenance check flights.
- Crew need to be trained and qualified to conduct maintenance check flights.
- Briefings must be completed between flight crew and maintenance staff before the flight takes place.
- Only flight crew or specific task specialists may be on board during the flight.
How do you conduct a maintenance check flight if you are not an airline?
If an aircraft is not under the control of an airline, i.e., not on an AOC, a check flight can be conducted under the control of a Part-NCC organisation. There are, however, several items to be considered before such an operation can take place.
Principles place of business
If a maintenance check flight is to be carried out on an aircraft where the operation falls outside the control of an airline, it may be conducted by an EASA Part NCC compliant organisation. The organisation conducting the check flight is required to maintain a head office or registered office in an EASA Member State where the principal financial functions and operational control of the operator are exercised.
The core operational control and financial functions need to be tangible, visible and, capable of being overseen and monitored by the competent national authority. The obligation under Principal Place of Business enables oversight of the operation by the national authority where the principal place of business lies.
An EASA Part-NCC operator must have a company structure consisting of an Accountable Manager, a Safety Manager, a Nominated Person Flight Operations (NPFO) and a Nominated Person Flight Training (NPFT) as a framework for the organisation with outlined roles, responsibilities, procedures, and policies.
Company manuals consisting of Ops Manual A, B, C, D, Safety Management Manual, Emergency Response Plan and MCF Operations Manual are needed to ensure safety and compliance with EASA regulatory standards. As part of safety management, the Operator is required to utilise a safety reporting system by encouraging and enabling incidents, safety concerns and hazards to be documented.
A Part NCC operator should consider the following before conducting a maintenance check flight, demonstration flight or delivery flight:
- An agreement needs to be in place with the owner of the aircraft giving permission to operate the aircraft.
- Insurance will be required to be in place for the flight.
- Crew should be trained, appropriate to the level of flight. The basic requirement is that an Operator’s Conversion Course has been completed to enable pilots to conduct flights on behalf of the specific operator. Annual recurrent training is also required.
- The organisation needs to have their own Maintenance Check Flight Operations Manual, giving details of crew requirements, briefings, and safety reporting considerations.
- A ‘Declaration’ needs to be filed with the national authority of the principal place of business of the operator detailing the operation that is to take place. The declaration is to acknowledge the organisation’s capability and means to discharge the responsibilities associated with the operation of the aircraft to the competent authority.
- A mechanism needs to be in place where specific approvals such as RVSM can be requested as per Part SPA of the regulations.
The intent of the Declaration is for the operator acknowledge its responsibilities under the applicable safety regulations and that it holds all necessary approvals, which will enable the competent authority to fulfil its oversight responsibilities in accordance with EASA regulation ARO.GEN.300 and 305.
Considerations for Pilots carrying out Maintenance Check Flights
Pilots engaged in non-commercial operations, such as maintenance check flights must be aware of the following:
- Pilots must have undergone an Operators Conversion Course specific to the operator.
- Be type rated with a valid medical certificate.
- If conducting a maintenance check flight or demonstration flight, be trained to the level required to conduct the check flight.
- Be aware of the requirements of Part SPO.SPEC.MCF regulations, specifically in relation to crew briefings and safety reporting.
Aircraft owners, lessors and maintenance organisation considerations
Aircraft owners and maintenance organisations also have obligations to ensure the flights are conducted safely:
- Appropriate aircraft insurance must be in place.
- Under EASA Continuing Airworthiness regulations (EU 1321/2014), any CAMO involved with the preparation of an aircraft should verify that any check flight is conducted in compliance with Part SPO.SPEC.MCF regulations.
- Aircraft owners/maintenance organisations should ensure that the operator and pilots are qualified and compliant to conduct the planned operation.
EASA Part NCC and Part SPO.SPEC.MCF regulations were introduced to increase safety standards in an area of aviation activity that has previously had limited oversight. As a result it is acknowledged that the complexities involved in maintenance check flights, demonstration flights and delivery flights are generally higher than those in ‘routine’ commercial operations.
The better you understand the Part NCC regulations, apply the relevant rules with trained and competent staff the greater the chance of a successful outcome.