- A CAMO 1 uses the 90-day advance notice to perform an airworthiness review or uses the 30-day advance notice for an extension. After issuing the ARC or the extension, the aircraft is transferred during the advance period from “CAMO 1” to a “CA(M)O 2”. As a consequence, the “CA(M)O 2” manages the aircraft for a period of time longer than 12 months. Could the ARC be extended on the understanding that the requirements of M.A.901(b)(1) are met?
No, you couldn't.
The purpose of paragraph M.A.901(b)(1) is to define a part of the concept “controlled environment”, stating that the aircraft must be managed over the last 12 months by a single CAMO or CAO with regard to the validity of an ARC.
In the case described, although the “CA(M)O 2” may have been managing the airworthiness of the aircraft for a period of more than 12 months, such as the CA(M)O that issued the ARC or the previous extension, the aircraft shall be deemed to have been managed by more than one CAMO or CAO since the date of issuance of the last ARC or the last extension, implying that the condition “controlled environment” is not met.
This is to prevent the transfer of the aircraft within the 90-day advance period (ARC) or 30 days (extensions) with the intention of avoiding the completion of a complete airworthiness review at the time of expiry of the airworthiness review certificate.
This does not apply to Part ML aircraft, as referred to in paragraph (c) of point ML.A.901, the CA(M)O may extend the ARC regardless of who issued the original ARC.
- Can the Airworthiness Review Certificate (ARC) be extended during extensive maintenance/long-term storage?
- Controlled environment conditions, M.A.901(b) or ML.A.901(c) are met.
The CA(M)O that could issue the extension of the airworthiness review certificate should, inter alia, verify that the following two conditions are met:
An aircraft in a controlled environment is an aircraft:
a) the airworthiness of which has been managed continuously over the last 12 months by a single CAMO or CAO;
b) the maintenance of which has been carried out during the last 12 months by a maintenance organisation approved in accordance with Part 145 or the EAC Party.For aircraft under Part M, this maintenance includes the maintenance tasks referred to in point M.A.803(b) performed and declared fit for service in accordance with points M.A.801(b)1 or M.A.801(b)2.
In the case of aircraft under Part ML, the maintenance tasks of the pilot-owner performed and declared fit for service by the pilot-owner or by independent certifying personnel are included.
2. There is no evidence or reason to believe that the aircraft is not airworthy, according to M.A.901(k) or ML.A.901(c)3.
In the case of an aircraft that is undergoing long-term maintenance/modification or is stored for a long period of time, condition 2 is not met and an extension of ARC should not be issued.
- Can an extension of an ARC be anticipated for more than 30 days?
Yes, you can, but you lose the time pattern of revisions.
AMC M.A.901(c)2, (e)2 and (f):
It is acceptable to anticipate the extension of the ARC for a maximum of 30 days without loss of the temporary standard of revisions of the certificate of airworthiness, which means that the new expiry date would be set one year after the previous expiry date.
In case the ARC extension is anticipated more than 30 days, the continuity of the temporary airworthiness review pattern would be lost, the next expiration date being one year after the extension date.
ML.A.901(d):
[...] the extension of the airworthiness review certificate may be anticipated for a maximum period of 30 days without loss of continuity of the airworthiness review pattern, so that the aircraft is available for the purpose of placing the original airworthiness review certificate on board.
- Can an Airworthiness Review Certificate (ARC)/Airworthiness Review Recommendation be issued with open incidents?
No, it is not possible to issue either an ARC or a recommendation with open incidents.
Each incident requires at least one corrective action before issuing an ARC or recommendation. Corrective actions should be appropriate for open incidence.
Corrective actions should be carried out and airworthiness review staff (PRA) must accept the closure of incidents prior to the issuance or recommendation of the ARC.
- Can an airworthiness review certificate issuance recommendation be issued for an aircraft under Part ML? Who issues the Airworthiness Review Certificate for a Part ML aircraft imported from a third country?
- In the case of a new aircraft, the issuance of the ARC by the competent authority of the Member State of registry shall be requested.
- In the case of a used aircraft, it shall be the CA(M)O, the maintenance organisation or the personnel conducting the airworthiness review, as provided in ML.A.901(b), which shall issue the ARC and submit a copy to the competent authority of the Member State of registry.
No, the standard does not provide for the possibility of issuing airworthiness review recommendations for aircraft under Part ML.
In the case of importing an aircraft from a third country or from a regulatory system where Regulation (EU) 2018/1139 does not apply:
The ARC shall not be valid until the Certificate of Airworthiness is also issued by the competent authority of the Member State of registration.
- If the ARC date pattern is to be maintained, can the airworthiness review be initiated within 90 days of expiry, and can the physical inspection and signature of the ARC be carried out within the deadline?
No, you can't.
If you want to maintain a date pattern, the airworthiness review can only be started 90 days in advance, according to the M.A.901(n) or the ML.A.903(d).
This advance period applies to both the physical review and the documentary of the aircraft.
- Does Part ML Aircraft Apply Event Analysis and Tracking (Follow-Up)? And to ML aircraft whose airworthiness is managed by the owner/individual?
- Individuals: they are exempted from the requirements of having databases, performing analyses, etc. In summary, they are only required to notify.
- Organisation: the full follow-up concept is applied to them.
The occurrence reporting applies to all ML aircraft (according to ML.A.202 and AMC 1 ML.A.202), but in terms of analysis and monitoring of events (follow-up), we will have to differentiate between aircraft managed by:
The occurrences of mandatory reporting for an individual and an organisation are different.
In the following link is the section of the AESA website for the Analysis and Tracking of Events (Follow-Up), including the Guide to the Analysis and Monitoring of Events (Follow Up).
- What should be indicated in the CAME Registration Schedule if an aircraft has an EASA type certificate, is managed by a CAMO and performs mixed operation (COE and an EASA operation)? And in the case of aircraft that do not perform EASA or COE operation (e.g. police)?
- In the annex of registrations of SIPA, the COE operation and the rest of the EASA operations that could be carried out shall be marked.
- If correctly defined in the SIPA registration annex, this information shall not be required to be included in CAME itself.
- In relation to the ACAM program, they will enter the program since they are considered mixed operation, and the equipment of the most demanding EASA operation that they can perform in terms of equipment will be reviewed.
According to point TAE.AER.GEN.100 of Royal Decree 750/2014, of 5 September, regulating aerial firefighting and search and rescue activities and laying down airworthiness and licensing requirements for other aeronautical activities, those aircraft that have an EASA type certificate, and do not exclusively perform COE operations, must comply at all times with Regulation (EU) 1321/2014.
These aircraft must be included in the SIPA registration annex, which is a part of the CAME that has been allowed to be taken out of the manual to speed up administrative procedures when modifying them. It shall always be up-to-date and reflect the speed or scope of operation for which the aircraft are intended.
The selection of the type of operation within the registration annex can be multiple, e.g. if an aircraft can make COE and at another time NCO, both boxes must be ticked. Even if an aircraft is stationary at a certain time, it shall be considered in flight for the purpose of operation. That is, as many operations as you could perform at that time or in the future will be marked.The case of an aircraft with EASA type certificate operating COE most of the time, although it is considered mixed because it could perform some EASA operation, will be treated as follows:
In the case of non-EASA and non-COE operation, as the corresponding column does not exist in SIPA, no boxes shall be ticked in the SIPA operation type columns and the information on the operation shall be entered in the CA(M)E manual itself.
A summary of the different possibilities is included on the next page.
- A. Will the ARC of a Part ML aircraft issued by a 15c form remain valid if that aircraft becomes Part M by being listed on an operating AOC certificate under Regulation (EC) 1008/2008? B. And conversely, if an aircraft has an ARC issued on a Form 15a/15b (Part M), it meets the conditions of Article 3(2)(a), (b) or (c) of Regulation (EU) 1321/1014 and will cease to be listed on an operating AOC certificate under Regulation (EC) 1008/2008 and become a Part-ML, is its ARC still valid?
A. No, the ARC will cease to be valid. An airworthiness review should be carried out and a new ARC 15a or 15b format issued. See Article 3(3)(c) of Regulation (EU) 1321/2014.
B. Yes, the ARC issued in a 15a/15b format shall remain valid until the end of its validity period and shall not be issued as a new 15c format.
At the time of the extension of ARC following the transfer from Part M to Part ML, this must be made on a 15c form due to the ML.A.901(c) declaration of compliance. A 15c format must be generated and the data transferred from the original 15a/15b format.
Since the SIPA system does not allow this action to be carried out at the time of the extension, the 15c format must be issued outside it, with a valid electronic signature, and send its copy to the competent authority within 10 days, according to ML.A.903(f).
- Can the airworthiness review be carried out by more than one person? For example, one PRA performs the documentary inspection and another PRA performs the physical inspection.
The intention of AMC M.A.901(l) and (m) is that it is the same person who shall carry out the documentary inspection and physical inspection.
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