Frequently asked questions

No, as their independence would not be guaranteed.

AMC1 CAMO.A.310(a), paragraph (e), of independence of the PRA from the airworthiness management process. 

A CAMO with a maintenance organisation approval may nominate personnel from its maintenance organisation as airworthiness review personnel as long as they have not been involved in managing the airworthiness of the aircraft. In order to avoid a conflict of interest, these personnel should not have participated in the commissioning of the aircraft in question (except for maintenance performed during the physical inspection of the aircraft or carried out as a result of discrepancies found during such physical inspection).

NOTE: This independence requirement does not exist in the CAO Party, so the certifying staff of a CAO organisation could.

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.

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: 

1. Controlled environment conditions, M.A.901(b) or ML.A.901(c) 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.

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.

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.

Applicants who complete basic training at an approved Part 147 organisation and then pass the examinations in another approved Party 147 organisation, will be granted full basic course consideration and, therefore, the reduction of the basic experience requirement will be maximum, eventually remaining within 1 or 2 years. 

The combination of Certificates of Recognition (only complete basic training + examination of modules) will be sufficient for the competent authority to recognise that the basic training course has been successfully ‘completed’. 
 
See also AMC of Appendix III to Part 147 "Certificates of recognition referred to in Annex IV (Part 147) – EASA Format 148

Regulation (EU) No 1321/2014 provides in paragraph (b) of 66.A.25 that basic training courses and examinations shall be conducted within the 10 years preceding the application for an aircraft maintenance licence or the addition of a category or subcategory to that licence.

Those modules that have passed 10 years will need to be re-examined if the syllabus of these modules has changed since it was approved until the date on which the license is requested. If the agenda of those modules had not changed, it would not have to be reconsidered.

The appointment must be made in writing by the quality manager of the organisation, which is prior to the start of the OJT. There must also be a signature of “received” by the data subject (evaluator or supervisor) in order to justify that he is aware of his or her role. There is no established format for such appointments.

In accordance with current regulations, it is the responsibility of the owner/operator that the flight manual is updated. 
The FM and its supplements should reflect the configuration of the aircraft at the time of inspection, and only applicable supplements should be carried on board. If it is decided to carry all supplements on board, it must be possible to demonstrate which supplements are applicable to the current configuration.

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: 

• 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 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).