European Aviation Safety Agency

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European Aviation Safety Agency

• Workshop EASA Part-M (aircraft not involved in
  Commercial Air Transport)
• Cologne
• 1 December 2006
• Juan Anton

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1. General
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REGULATION ORGANISATIONAL STRUCTURE

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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.

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2. Part-M
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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 (http//www.easa.europa.eu,
  Rulemaking, Opt-outs to regulation)

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Structure of Annex I (Part-M) to Regulation
2042/2003 Sections AB

• 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.

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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.

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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.

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Responsabilities of the owner and Subcontracting
(M.A.201) contd.

• 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.

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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).

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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.

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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.

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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 43. 13.

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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.

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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.

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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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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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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.

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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

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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.

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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.

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Certificate of Release to Service (CRS) by the
pilot-owner (M.A.803) contd

• 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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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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3. Significant Rulemaking Tasks
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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.

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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.

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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.

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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.

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• THANK YOU FOR YOUR
• ATTENTION.
• www.easa.europa.eu
• (new address)