Frequently asked questions

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.

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.

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.

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.

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.

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.