Frequently asked questions

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.

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.

The CAMO Party does not impose a “basic” or “generic” maintenance program; however, in Chapter 1.2 of the CAME the organisation must describe how it will develop the aircraft maintenance program (AMP). 

The Part-CAMO is based more on performance than the former part M Subpart G, the organisation has to demonstrate that it is competent for the work to be done. Certain elements such as the “IT tool” for AMP or the experience of staff with AMP can contribute to this goal.

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.

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).