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Frequently asked questions

Incompatibility between airframe and engine related tasks in the maintenance programme.

A properly developed maintenance programme should not contain inconsistencies in the performance of tasks required for airframe and engine continuing airworthiness.

One of the characteristics of a proper maintenance programme is its adaptation to operating times and shutdowns in order to carry out scheduled maintenance without impairing continued airworthiness.

In the EASA environment the engine TC Holder must establish the engine ICAs. Each TC Holder must do the ICAs that correspond to him, so there should be no incompatibilities between airframe and engine ICAs, and in case of doubt, the instructions of both TC Holders (or the most critical one) should be complied with, unless the airframe TC Holder demonstrates that EASA has authorised otherwise.

In NON-EASA environments, aircraft can be found without an engine TC, in which the engine TC was considered as just another piece of equipment when certifying the aircraft type, so each case would have to be analysed.

How should the NR (National Requirements) note in the documentation provided by the manufacturer, e.g. in the MPD, be treated?

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.

Questions related to PRESERVATION: 1. If an aircraft is to be preserved, for whatever reason, is it mandatory to amend the maintenance programme and incorporate preservation tasks into it, or is it not necessary and once preservation is completed the aircraft continues to apply its maintenance programme as normal? 2. During the preservation period, is the aircraft airworthy or not? 3. While the aircraft is under preservation, can it continue to be included in the list of registrations managed by the organisation or should the CAMO remove it from its CAME? 4. And in case an aircraft does not follow its maintenance programme and is not preserved either, is the way to put the aircraft back into service by contacting the manufacturer for instructions?

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.

Who can develop and submit the Maintenance Programme for private aircraft, which do not have commercial operation and are not complex motor-powered?

We must differentiate whether the aircraft in question is Part-M or Part-ML affected, therefore:

A) For Part M affected aircraft requiring EASA approval (see following table with all possibilities):

  • B. For Part-ML affected aircraft, from 24/03/2020 maintenance programme approvals will not be carried out by EASA (see Part-ML).

A summary of the provisions of Part-ML and its reliefs from ML.A.201, ML.A.302, ML.A.801 and M.L.A.901 is provided in Part-ML paragraph GM1 ML.A.201 'Responsibilities'.

Can measures banning operations be applied as a result of findings at an Inspectorate in Rampa?

In some cases, where the findings detected during the inspection on an aircraft prove to be major or serious breaches for operational safety, the different Participating States may decide to revoke the entry permit of that aircraft. In such a situation, the aircraft or all of the aircraft forming part of the operator, as the case may be, shall not be able to operate or fly in the airspace of Spain. If the ban is imposed only on the inspected aircraft, it may not operate in any other State, since it cannot leave Spanish airspace. This prohibition may be lifted if the aircraft operator demonstrates that the problems have been properly addressed and corrected in accordance with the instructions required by the authority. Therefore, the revocations of the operating permit can, and are usually, temporary in nature.

With regard to these prohibitions and their subsequent lifting, participating States which are also members of the European Union shall act in accordance with the provisions laid down in Regulation (EC) No 2111/2005 on the establishment of a Community list of air carriers subject to an operating ban within the Union.

In accordance with the requirement set out in Commission Regulation (EU) No 965/2012, ARO.RAMP.145 Reports, Participating States are also including information from the centralised database on their monitoring measures. This information makes it possible to assess the ability and willingness of operators to rectify the findings identified during ramp inspections and is used in subsequent analyses of the generated data.

What does denial of withdrawal mean?

In the event that a request needs to be remedied, due to lack of documentation or any other reason, it must be answered within 10 working days. After the deadline, no documentation has been provided, it is considered that the application has been withdrawn.

The reason why we refuse authorisation in this case is because Law 39/2015 on the Common Administrative Procedure of Public Administrations (LPACAP) requires AESA to reply within a certain period.

In the event of a refusal of this kind, the procedure may be re-opened without any problems. In addition, the documentation submitted in the rejected application will continue to be taken into account in the event that it has not become invalid.

I will work with a license from a third ICAO country and the Aeronautical Authority requires a verification of my FCL license. How should I proceed?

In connection with the verification of the FCL licence, the aeronautical authority of the ICAO Third Country may request it by sending your request to the following email address licpiloto.aesa@seguridadaerea.es

 

 

I want to request an information note of my FCL license How should I proceed?

The information note contains the content in force of the FCL license You can request an information note via AESA’s Electronic Headquarters or by application request

What is the difference between revalidating and renewing a rating?
  • Revalidation involves carrying out the procedure to maintain the vigor of the exercise of flight privileges. The revalidation procedure is always carried out before the rating expires.
  • Renewal means that the authorisation has expired and that the revalidation procedure has not been carried out in time and form. In this case, if you want to put your rating into force again, it will be renewed through an authorised training centre.
Can I exercise attributions of a rating that is expired?

Ratings have a period of validity during which the flight privileges of the licence may be exercised provided that you additionally have in force the aeronautical medical certificate associated with your licence and the language proficiency in force at least one language recognised by the Aeronautical Authority

Remember if the rating is expired you can't exercise flight privileges until it’s in force again on your FCL license