Frequently asked questions

EASA's response:

1. Appendix B:
   • When the programme is based on the DAH ICAs, Appendix B is to include the additional tasks to those ICAs. In case it is based on an IPM Appendix B is used to include:
     • Certain tasks of the DAH ICAs (e.g. maintenance due to components with limiting life).
     • Other supplementary tasks (e.g. due to aircraft operation).

The intervals in the right hand column should be as defined in the AMP.

1. Appendix C:

If "YES" is ticked in section 5 of the format, you must list any alternative maintenance tasks to the DAH ICAs taking the MIP as a reference

Normally, this note is included by the manufacturer in the repository document, Maintenance Planning Document, a basic tool for the operator to draw up the maintenance programme.

It usually refers to regulations or legal requirements, usually non-aeronautical, i.e. industrial or occupational safety requirements at European or national level.

Examples could be: inspection intervals of pressurised gas cylinders, buoyancy of lifejackets, expiry of certain capabilities related to heat protection, impact, ingestion of harmful gases, etc.

If any NR is provided for in the manufacturer's documentation, it should be considered whether such a national requirement exists and, if so, it should be included.

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.

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.

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: 

• 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.  

The ARC shall not be valid until the Certificate of Airworthiness is also issued by the competent authority of the Member State of registration.

EASA Response:

If the Authority responsible for the approval of the aircraft maintenance programme remains the same, i.e. the authority of the State of registry of the aircraft, the CAMO may continue to use the programme, unless the programme needs to be modified due to changing operating environments, operation, utilisation, etc.

If the Authority responsible for the approval of the maintenance programme becomes the Authority of another member state, because an agreement is established between Authorities to do so, then it is necessary for the new Authority responsible for the approval of the programme to re-approve the maintenance programme for administrative and legal reasons.

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 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.

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.

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.

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).

Answers:

1. there is no requirement to amend the maintenance programme to include preservation.
2. During preservation as such the aircraft will not be airworthy, after completion of the preservation phase with all the tasks marked by the manufacturer for preservation and after completion of all additional maintenance tasks according to M.A.301, the aircraft can be considered airworthy again.
3. Yes, it shall remain included in the organisation's manual as during preservation it continues to be managed by the organisation, despite being un-airworthy.
4. In general, the organisation should consult with the manufacturer and follow their instructions.