Part-M: General

Maintenance for each type of aircraft/operation

 

 

 

MAINTENANCE

Commercial operations

Licenced air carriers [1]

Maintenance to be performed by Part-145 organisations

Commercial specialised operations or CAT other than licenced air carriers or commercial ATOs

Complex motor-powered aircraft [2]

Maintenance to be performed by Part-145 organisations

Other than complex motor-powered aircraft (CMPA)

Maintenance to be performed by:

  • Part-M Subpart-F organisations; or,
  • Part-145 organisations.

Other than commercial operations

CMPA

Maintenance to be performed by part-145 organisations

Other than CMPA and limited operations [3]

Maintenance may be performed by:

  • Part-145 organisations,
  • Part-M Subpart-F organisations,
  • Independent certifying staff, or,
  • Pilot-owner maintenance [4]

[1] Licensed air carriers are EU air carriers holding an operating licence in accordance with Regulation (EC) 1008/2008

[2] Twin turboprop aeroplanes of 5 700 kg MTOM and below can be exempted by the Member State from complying with any requirements applicable to CMPA and shall instead comply with the requirements applicable to other than CMPA.

[3] Limited operations are defined in Regulation (EU) 1312/2014 Article 2(p)

[4] Only limited to non-CMPA of 2730 kg MTOM and below

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Continuing airworthiness management for each type of operator/ aircraft

    CONTINUING AIRWORTHINESS MANAGEMENT

Commercial operations

Licenced air carriers [1]

Continuing airworthiness shall be performed by a CAMO. Operator shall be CAMO approved (CAMO linked to the AOC).

Commercial specialised operations or CAT operations other than licensed air carriers or commercial ATOs

Continuing airworthiness shall be performed by a CAMO. Operator shall obtain CAMO approval, or operator shall contract a CAMO

Other than commercial operations Complex motor-powered aircraft [2] Continuing airworthiness shall be performed by a CAMO. Owner shall contract a CAMO
Other than complex motor-powered aircraft (CMPA) and limited operations [3]

Continuing airworthiness management may be performed by the owner. CAMO is not required.

 [1] Licenced air carriers are EU air carriers holding an operating licence in accordance with Regulation (EC) 1008/2008

[2] Twin turboprop aeroplanes of 5 700 kg MTOM and below can be exempted by the Member State from complying with any requirements applicable to CMPA and shall instead comply with the requirements applicable to other than CMPA.

[3] Limited operations are defined in Regulation (EU) 1312/2014 Article 2(p).

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Can an independent certifying staff maintain ELA1 aircraft used for commercial operations (such as ATO)?

No, ELA1 aircraft used for commercial operations cannot be maintained by independent certifying staff because in accordance with M.A.201(i) commercial operations require maintenance release by an organisation (part-M subpart-F or part-145 approved).

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Which are the correct statements to be written in block 11 of EASA Form 1 after maintenance?

Appendix II to part-M describes the following 4 permissible entries in block 11 of EASA Form 1:

  • Overhauled,
  • Repaired
  • Inspected/tested
  • Modified

The meaning of “Inspected/Tested” status is inspected and/or, if applicable, tested as it described in provisions of part-M/part-145.  Besides that, block 12 in the EASA Form 1 should contain the detailed information on the status/work described in block 11.

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Can a licenced pilot without a valid medical certificate perform pilot-owner maintenance?

This question arises because of the different understandings of license validity in Commission Regulation (EU) No 1178/2011 (Aircrew) and No 1321/2014 (Continuing Airworthiness).

In Reg. (EU) 1321/2014, the pilot-owner authorisation described in M.A.803 assumes that a pilot has sufficient technical knowledge to perform certain maintenance tasks. While exercising such pilot-owner authorisation, the pilot-owner even further develops his/her competency in maintenance. Hence, in the case where the medical examination has not been conducted or not been passed and the licence has therefore lost its validity, it is the intent of the rule to allow the pilot-owner to continue using this authorisation as long as he/she still considers himself/herself physically fit (including good visual acuity) and competent to carry out such maintenance (ref. point (a)(2) of Appendix VIII to Part-M).

This is the reason why a new point (5) was introduced in AMC M.A.803 in 2016 (ED Decision 2016/011/R) stating: “not holding a valid medical examination does not invalidate the pilot licence (or equivalent) required for the purpose of the pilot-owner authorisation”.

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What are the responsibilities relevant to pre-flight inspection?

The pre-flight inspection forms part of the essential requirements for air operation, as required in Annex V (point 6.2) of the ‘Basic Regulation’ (Regulation (EU) 2018/1139). Being relevant to the aircraft’s fitness for the intended flight, this essential requirement is implemented by the Commission Regulation (EU) 1321/2014 for continuing airworthiness in the following way:

Reference

Obligation

Who

Remark

M.A.201(d)

Carry out pre-flight inspection satisfactorily

Pilot-in-command or, in case of Licensed Air Carrier, a qualified staff under the responsibility of the operator (e.g. maintenance staff - see note)

 

M.A.301(1)

Ensure pre-flight inspection is carried out

Owner or CAMO (according to M.A.201)

 

Ensure pre-flight inspection includes the actions necessary to ensure that the aircraft is fit to carry out the intended flight

AMC M.A.301(1) point(1) and (2) elaborates those actions

If a/c managed by CAMO: Provide training to ensure that pre-flight inspection is carried out adequately [AMC M.A.301(1) point (3)]

CAMO

Pre-flight inspection training described in the CAME in part 1.11 [‘Appendix V to AMC M.A.704’]

Additional information:

 

M.A.712(b)

If a/c managed by CAMO:
Ensure pre-flight inspection is subject to the quality system
[AMC M.A.301(1) point (3)]

CAMO

This is important because the pre-flight inspection contributes in feeding the process of aircraft continuing airworthiness

 

Note:
As per the definition of ‘maintenance’ in article 2 point(h) of Commission Regulation (EU) 1321/2014, ‘pre-flight inspection’ (as defined in article 2(j)) is not considered maintenance. Therefore it does not require a certificate of release to service [M.A.201(d)].

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What are the plans of EASA concerning the Continuing Airworthiness of aircraft operated under the new Part-DTO (Annex VIII to Reg. (EU) No 1178/2011 as amended)?

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). This amendment of Aircrew Regulation requires also an amendment of Part-M, which has not been adopted to date but will be reflected in the next amendment of Reg. (EU) 1321/2014.
The intent is to specify that commercial training organisations, whether ATO or DTO, will have the same Continuing Airworthiness obligations.

This amendment of Part-M will, in particular, clarify the following:

  Complex motor-powered aircraft                                             Other than complex motor-powered aircraft                                              

Commercial DTO             

M.A.201(f) applicable
CAMO required
M.A.201(h) applicable
CAMO* is required
Non-commercial DTO                 M.A.201(g) applicable
CAMO required
M.A.201(i) applicable
CAMO* not required

NOTE: With adoption of Part-ML (Opinion 05/2016), CAMO* will not be required for organisations that operate Part-ML aircraft under Part-NCO. That means any DTO organisation operating Part-ML aircraft under Part-NCO will not be required to contract (or be approved as) a CAMO*.

* or CAO organisation with continuing airworthiness management privilege, once Opinion 05/2016 is adopted

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