Frequently asked questions

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.

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.

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.

M.A.302(a) states that the maintenance of each aircraft shall be carried out in accordance with an aircraft maintenance programme.

The same aircraft, operated by the same operator and with the same type of operation may be included in the same maintenance programme.

The maintenance programme for a particular aircraft may have specific or particular tasks or modified in both content and interval of completion as a consequence of repairs, modifications carried out on that aircraft or inspection results. This is a certain type of "customisation" or particularisation.

M.A.302(d) states that the programme must comply with:

• Instructions issued by the aviation authority
• Instructions ensuring continued airworthiness, e.g. from type certificate holders, certification specifications, operator initiatives, owner, contracted CAMO, etc.

Justified acceptance of the above may lead to particularities of the maintenance programme of an aircraft or group of aircraft that constitute "customisation".

"To customise is to particularise for an operator or aircraft or type of operation the requirements for application of a maintenance programme to an aircraft or group of aircraft. The degree of customisation to be applied in each case shall be the maximum possible.

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'.

See EASA FAQ n. 19102.

If the TCH includes in its ICAs instructions for the calculation of the next completion, these should be followed. 

If not, the date of the next completion will be the expiry date prior to the extension or as agreed with the authority, the final decision must be made by the extension approver. 

For Part-ML regulated aircraft, the situation is different when the 1 month tolerance in ML.A.302(d) applies, the following interval will be calculated from the date of compliance (see ML.A.302(d)(1) and AMC1 ML.A.302(d)).

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.