Frequently asked questions

Relevant training serves to reduce the basic experience requirement to obtain a Part 66 LMA license.

Relevant training shall be considered:

• Higher-grade vocational training courses in the following specialties:
  • Superior Technician in Aeromechanical Maintenance (for B1).
  • Superior Aviation Maintenance Technician (for B2).
     
• Higher grade training courses in maintenance of the following specialties:
  • Aeromechanical turbine engine aircraft (for B1.1).
  • Aeromechanical of piston-engine aircraft (for B1.2).
  • Aeromechanical turbine engine helicopters (for B1.3).
  • Aeromechanical of piston-engine helicopters (for B1.4).
  • Electronic and avionic systems in aircraft (for B2).
     
• Training corresponding to a basic training course in a subcategory of B1 other than that requested in an organisation Part 147.

However, the consideration of relevant training does not exempt from passing the examinations corresponding to the basic training modules of Part 66 of the category or subcategory of the licence that is intended to be obtained.

Operational aircraft experience means the following:

• That obtained in the performance of maintenance tasks on aircraft being operated by aircraft operators, air taxi organisations, owners, etc.
• The experience should comprise a broad spectrum of tasks in complexity, quantity and variety and have to be performed in a Part-145 or Part-CAO environment.
• For L licences, it is acceptable for maintenance experience to be gained only during weekends and public holidays, provided that the level corresponding to the category/subcategory being sought is attained.

The formats to be used to document the experience records are available on the website:

LMA maintenance technician licence management (Part 66)

LIC-P66-P01-F02 Record of basic experience. You must complete at least one form for each subcategory you are applying for.

Regulation (EU) 1321/2014 lays down in Appendix I to Part 66 the modules that need to be passed in order to access a particular category. Those modules that are common to two categories, may be used to obtain different categories or subcategories, if the module that has been passed in a certain category or subcategory has the same content with a level equal to or higher than in the other categories or subcategories to be obtained.

There is no process for validating aircraft maintenance licenses obtained outside the EASA environment. EASA only recognises for the issue of LMA Part 66, the training obtained and passed as set out in Annex III (Part-66) to Regulation (EU) 1321/2014. 
 
You can find information about the application for licenses in Spain in the “User Guide” at the following link.

In order to speed up the processing of the application, there is the possibility of submitting a telematic application through the catalogue of procedures and services of the EASA Electronic Headquarters under the name "LMA Part-66 Maintenance Technician Licence Management", in the section "Licences and Aeronautical Medicine":

LMA maintenance technician licence management (Part 66)

If submitted on paper, applications may be handed in at any official registry of the State administration (Art. 16 of Law 39/2015). And it must be addressed to the Service of Licensing and Training of Maintenance Technicians of the Aircraft Safety Directorate of AESA:

Maintenance Technician Licensing and Training Service
Aircraft Safety Directorate
STATE AVIATION SAFETY AGENCY
Paseo de la Castellana, 112
28046 Madrid
Telephone: +34.91.396.87.18

In addition to the application, you must also provide all the documentation required for the procedure you are applying for.It is not possible to provide documentation by e-mail, as it is not a valid official record. Any application sent by e-mail will not be evaluated.

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.

RESPUESTA DE EASA

The following aspects to be taken in consideration:

• it is possible to release component maintenance on an internal release document (IRD) when this component will be installed on an aircraft by the same maintenance organisation (145.A.50(d));
• The CAMO/operator of the aircraft should be in agreement; and 
• all the information normally required for an EASA Form 1 should be adequately detailed in the IRD (and in MOE procedure). In this case the IRD is considered to be equivalent to an EASA Form 1 for 145.A.42 purpose

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.