Do declared training organisations (DTO) need a CAMO/CAO and approved maintenance organisations?
Answer
Regulation (EU) No 1178/2011 was amended in July 2018 to introduce Part-DTO as regards to declared training organisations (ref. Reg. (EU) 2018/1119). Regulation (EU) No 1321/2014 was therefore amended and aligned the Continuing Airworthiness obligations of ATO with those of DTO.
This means:
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Complex motor-powered aircraft |
Other than complex motor-powered aircraft |
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Commercial DTO |
Applicable requirement |
M.A.201(f) is applicable |
M.A.201(h) or, for aircraft specified in Article 3(2), ML.A.201(e) are applicable |
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Continuing airworthiness management |
CAMO is required
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CAO (with continuing airworthiness management privilege) or CAMO is required |
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Maintenance |
Part-145 organisation is required |
CAO (with maintenance privilege) or Part-145 or Part-M Subpart F organisation is required |
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Non-Commercial DTO |
Applicable requirement |
M.A.201(g) is applicable |
M.A.201(i) or, for aircraft specified in Article 3(2), ML.A.201(f) are applicable |
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Continuing airworthiness management |
CAMO is required
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CAMO is not required CAO (with continuing airworthiness management privilege) is not required
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Maintenance |
Part-145 organisation is required |
With the exception of complex maintenance tasks under Part-M: CAO (with maintenance privilege) is not required Part-145 organisation not required Part-M Subpart F organisation is not required
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Please also refer to GM1 ML.A.201(e) which provides examples of aircraft not considered to be operated by a commercial ATO or a commercial DTO.