1. European Aviation Safety Agency
Workshop EASA Part-M (aircraft not involved in Commercial Air Transport)
Cologne
1 December 2006
Juan Anton
Cologne

2. 1. General
Cologne

3. REGULATION ORGANISATIONAL STRUCTURE
Cologne
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4. EASA: Rulemaking Status of EASA texts
Applicability; basic principles and essential requirements:
Binding; adopted by the legislator under co-decision; included in Regulation
Implementing Rules:
Binding; will be adopted by the Commission following an Opinion from the Agency
Guidance Material:
Not binding; adopted by the Agency.
Cologne
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5. 2. Part-M
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6. Regulation 2042/2003 Annex I (Part-M) Entry into Force
Article 7(3)(a) to Commission Regulation 2042/2003 establishes that, Member States may elect not to apply the provisions of Annex I (Part-M) to aircraft not involved in commercial air transport, until 28 September 2008.
See Opt-Out table: ( Rulemaking, Opt-outs to regulation)
Cologne

7. Structure of Annex I (Part-M) to Regulation 2042/2003 Sections A&B
Part-M Section A
This section establishes the measures to be taken to ensure that airworthiness is maintained. It specifies the conditions to be met by persons or organisations involved in such continuing airworthiness management or maintenance organizations for general aviation.
Part-M Section B
This section establishes Administrative requirements to by followed by the competent authorities in charge of the application and enforcement of Section A.
Cologne

8. Who is the Competent Authority (Paragraph M.1)
For the purpose of Part-M, the competent authority shall be:
For the oversight of the continuing airworthiness of individual aircraft and the issue of airworthiness review certificates the authority designated by the Member State of Registry.
For the approval of maintenance programmes, the authority designated by the Member State of Registry.
For the approval and oversight of maintenance organisations (Subpart F) and CAMO (Subpart G and I) the authority designated by the Member State where they are located, except those based in a third country. In this case, it will be EASA.
Cologne

9. Responsabilities of the owner and Subcontracting (M.A.201)
The owner is responsible for the continuing airworthiness of the aircraft and shall ensure that:
The aircraft is maintained in an airworthy condition;
Any operational and emergency equipment fitted is correctly installed and serviceable;
The airworthiness certificate remains valid;
The maintenance of the aircraft is performed in accordance with the approved maintenance programme.
The owner is responsible for granting the competent authority access to the aircraft to determine continuing compliance with Part-M.
Cologne

10. Responsabilities of the owner and Subcontracting (M.A.201) cont’d.
The owner may contract:
The tasks associated with continuing airworthiness to an approved continuing airworthiness management organisation (CAMO) . In this case, the CAMO assumes responsibility for the proper accomplishment of these tasks.
The maintenance to an approved maintenance organisation
However, for large aircraft and for operators requiring an operational certificate (other than Commercial Air Transport), the contract with the CAMO and with an approved maintenance organisation is mandatory.
The Contract with the CAMO will comply with Appendix I.
Cologne

11. Responsibilities of the pilot in command (M.A.201)
The pilot in command shall be responsible for the satisfactory accomplishment of the “pre-flight inspection”. The inspection must be carried out by the pilot or another qualified person but need not be carried out by an approved maintenance organisation or by a Part-66 certifying staff.
Pre-flight inspection is intended to mean all the actions necessary to ensure that the aircraft is fit to make the intended flight (see AMC M.A.301-1).
Cologne

12. Maintenance Programme (M.A.302)
Every aircraft shall be maintained in accordance with a “maintenance programme” approved by the competent authority. It must be reviewed and amended accordingly.
When the aircraft continuing airworthiness is managed by a CAMO the maintenance programme and its amendments may be approved through a maintenance programme procedure established by such organisation (indirect approval). The procedure must be approved by the authority.
Cologne

13. Maintenance Programme (M.A.302)
The maintenance programme must be established in compliance with:
TC holder recommendation
This only requires copying TC holder information but could induce extra costs.
NAA recommendations
This will allow all existing national practices to continue, such as LAMS (Light Aircraft Maintenance Schedule) in the UK or AC extending piston engine overhaul limits.
Instructions defined by the owner
The owner may define himself other time limits acceptable to the NAA. This will allow practices in force in certain countries to continue in a more formalised manner.
Cologne

14. Modifications and Repairs (M.A.304)
Modifications and repairs must be approved according to Part-21.
EASA will work on publishing standards practices manuals that will alleviate this requirement for the simple cases. These documents will initially be based on FAA AC
Cologne

15. Aircraft continuing airworthiness records (M.A.305)
For general aviation the existing system of log books satisfies the intent of this paragraph, as far as the airworthiness records are concerned.
Cologne

16. Maintenance Standards/Maintenance Data (M.A.401)
The person or organisation maintaining the aircraft shall have access to and use only applicable maintenance data in the performance of maintenance including modifications and repairs.
Maintenance data is:
Any applicable requirement, procedure, standard or information issued by the competent authority or the Agency. This allows national systems to continue and enable EASA to produce standards.
Any applicable airworthiness directive;
Applicable instructions for continuing airworthiness, issued by type certificate holders, STC holders and any other organisation that issues data in accordance with Part 21.
Cologne

17. Maintenance Standards/Performance of Maintenance (M.A.402)
All maintenance shall be performed by qualified personnel, following the methods, techniques, standards and instructions specified in the Maintenance data.
PART-66 LICENCE IS NOT ALWAYS NEEDED
All maintenance shall be performed using the tools, equipment and material specified in the maintenance data.
OWNERSHIP OF THE TOOLS IS NOT NEEDED
The area in which maintenance is carried out shall be well organised and clean in respect of dirt and contaminations.
OWNERSHIP OF A HANGAR IS NOT NEEDED
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18. Subpart E Components
A Decision is very close to publication to declare as standards parts all non required equipment on gliders.
Non salvageable parts must be mutilated beyond repair before they are disposed of. This is important to limit the number of bogus parts.
Maintenance on components must be performed by Subpart F or Part 145 organisations. However, certifying staff qualified in accordance with M.A.801(b)(2) may perform maintenance on components while they are installed on the aircraft.
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19. Subpart F Maintenance Organisation
A maintenance organisation may maintain any aircraft and or component which it is approved at the locations specified in the approval certificate.
Alleviations for general aviation:
No quality system. Organisational Reviews are allowed per M.A.616.
No ownership of tools, data and facilities.
Cologne

20. Subpart G Continuing Airworthiness Management Organisation (CAMO)
An approved continuing airworthiness management organisation may manage the continuing airworthiness of non-commercial air transport aircraft as listed on the approval certificate. The CAMO may be authorised to approved the maintenance programme itself. The CAMO may be approved to issue the airworthiness review certificate.
Alleviations for general aviation:
No quality system needed if no ARC privilege is held (for small organisations)
No ownership of data and facilities
Cologne

21. Certificate of Release to Service (CRS) M.A.801
A certificate of release to service shall be issued before flight at the completion of any maintenance by:
A Part-145 organisation;
A Subpart F organisation;
A Part-66 licensed engineer for non-complex tasks (see Appendix VII), excluding components off the aircraft; For gliders and ballons this means a national license.
A Pilot-owner (per Appendix VIII)
Tasks included in the AFM are not considered “maintenance tasks”, except in those cases where there is an attachment to the AFM showing the maintenance schedule.
Cologne

22. Certificate of Release to Service (CRS) by the pilot-owner (M.A.803)
The pilot-owner is the person who owns or jointly owns the aircraft being maintained and holds a valid pilot license with the appropriate type or class rating.
For any privately operated aircraft of simple design with a maximum take-off mass of less than 2730 Kg, glider and balloon, the pilot-owner may issue the certificate of release to service after limited pilot owner maintenance listed in Appendix VIII to Part-M.
The limited pilot-owner maintenance shall be defined in the aircraft maintenance programme.
Cologne

23. Certificate of Release to Service (CRS) by the pilot-owner (M. A
Certificate of Release to Service (CRS) by the pilot-owner (M.A.803) cont’d
For a pilot-owner a certificate of release to service should contain the following statement:
« Certifies that the limited pilot-owner maintenance except as otherwise specified was carried out in accordance with Part-M and in respect to that work the aircraft is considered ready for release to service »
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24. Airworthiness Review Certificate (ARC)
To ensure the continued airworthiness of an aircraft an airworthiness review must be carried out periodically. This airworthiness review includes a review of technical documentation and the physical survey of the aircraft.
When an aircraft is continuously managed and maintained by approved organisations this activity is carried out without the intervention of the NAA.
When an aircraft is not in the above case the ARC is issued by the NAA based on a recommendation from a CAMO, every year.
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25. 3. Significant Rulemaking Tasks
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26. M.005: Pilot Owner Maintenance
Re-evaluation of M.A.803 and Appendix VIII.
Evaluate interface between Appendix VIII „Limited Pilot Owner Maintenance“ and Appendix VII „Complex Maintenance Tasks“.
Will incorporate the intent of Task M.010 regarding Pilot Owner Maintenance in the case of collectively owned aircrafts in flying clubs.
NPA to be published by 2Q 2007.
Opinion / Decision to be published by 2Q 2008.
Cologne

27. M.007: Part M amendment for non-commercial air transport.
Regulatory Impact Assessment performed by Air EuroSafe to evaluate the impact of Part M.
Concern was limited to non-commercial air transport.
NPA07/2005 published on June 2005, with 5 months consultation period.
CRD and Opinion / Decision will be issued by M.017 Task.
Cologne

28. M.017: EC2042/2003 amendment for non-complex non-commercial aircrafts.
Takes over the review of comments from NPA07/2005 (M.007).
Implements the necessary changes to EC2042/2003 as a result of MDM.032. Includes changes not only to Part-M but to other Annexes (Part-66).
NPA to be published by 1Q 2007.
Opinion / Decision to be published by 1Q 2008.
Cologne

29. MDM.032: A concept for better regulation in General Aviation
Implies changes to regulations related to Initial Airworthiness, Continuing Airworthiness and Maintenance, Air Operations and Pilot Licensing.
Changes to Continuing Airworthiness and Maintenance are handled by M.017 group.
Cologne

30. THANK YOU FOR YOUR ATTENTION.
(new address)
Cologne
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