Frequently asked questions

A B1 can perform transponder check tasks, as long as: 

• Use automated testing equipment (which does not require previous calibrations)
• Test results are GO/NO GO 
• Be trained in the use of such equipment.

A) Preflight inspection vs “preflight” interval maintenance inspection
Some TCH (usually helicopters) include in the maintenance documentation inspections with interval “preflight” or “before the first flight-BFF”. The content of these inspections is usually similar to the content of the pre-flight inspection included in the aircraft flight manual (AFM). The criterion to be applied in order to register its completion is:

In cases where the maintenance documentation (SMM, AMM, etc.) and the flight manual (AFM) include identical tasks, it is considered acceptable for the pilot to carry out inspections under the operation umbrella (signing the pre-flight inspection section) without having to perform a Maintenance “Release”. Normally this will not happen, as there are usually modifications incorporated into the aircraft that include pre-flight inspections linked to the Maintenance Manual.

B) Pilot-certifiers in approved line stations
Here are some criteria on how to deal with pilot-certifiers when certifying tasks in approved line stations (lines included in the MOE):

• There needs to be a Part 66 certifier assigned to the line.
• The availability of the Part 66 certifier to attend the facilities should be clearly identified in the production plan when necessary.
• The pilot-certifier can only certify simple tasks (mainly ALF, BFF, TA) to perform tasks according to 145.A.30 j) 4) since the certifier is not full time in the installation (at the moment the installation would be treated as “not supported”)

The following link to the EASA website  is included as an additional reference.

There is no limitation in the standard or in the EASA guides that prevent a certifier from performing critical tasks in its first year.  
However, the organisation may add additional requirements in its maintenance organisation manual.

• Prior to carrying out the ATPL skill test, the applicant must meet and certify the prerequisites and experience as laid down in Regulation (EU) 1178/2011 in the relevant aircraft category and hold the corresponding ATPL certificate of prior requirements and experience issued by COPAC or EASA
  The examiner with whom it intends to carry out the ATPL skill test must be expressly authorised to do so, by means of an authorisation letter issued by AESA at the request of the examiner. 
  The ATPL skill test shall be carried out under valid EASA means.

The presentation of the responsible declaration by e-mail will not be accepted in any case.   

For all those interested with obligation to interact with the administration in a telematic way (legal persons, representatives of legal persons, and natural persons who choose it) can carry out the procedure from the electronic headquarters of AESA

For those interested who have the option to carry out the procedure in person (at AESA’s own headquarters or at any registration assistance office) or by postal mail, essentially natural persons and their representatives in the case of being also natural persons, the form of presentation of the declaration must be downloaded from the procedure itself, complete it and address it to “AESA — Directorate of Airports and Security of Civil Aviation (DASAC), Paseo de la Castellana 112, 18046 Madrid”:

• You can deliver it personally to our headquarters.
• You can direct it by post, note that in this case you must ask the company that makes the shipment information on how to obtain the receipt, since it is not sent from AESA.
• You can submit it to any registration assistance office.

On the AESA website:
https://www.seguridadaerea.gob.es/Organisations/Training Organisations/Maintenance Training Organisations (Part 147)

Information on the approval procedure can be found in the Applicant Information Guide FOR-P147-P01-GU01.

Technical requirements on the Organisation Manual can be found in the FOR-P147-P01-DT01 guide.

In the guide FOR-P147-P01-DT04 you can find the technical requirements on the personnel of the organization

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).

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.

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.