Part-ML, Part-CAO, Part-CAMO and new structure of the Regulation

Juan AntonMaintenance Regulations Section ManagerFlight Standards DirectorateEASAE&M Sub-SSCC11 May 2016

TE.GEN.00409-001

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New structure of the Regulation

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Part-M GA Task Force (Phase II)

CURRENT RULE STRUCTURE Non-CAT CAT

Non-CMPA CMPA Non-CMPA CMPA

Part-M Applicable

Subpart F Applicable N/A N/A N/A

Subpart G

(CAMO)

Applicable

Part-145 Applicable

Part-66 Applicable

Part-147 Applicable

Part-T (Third country aircraft

dry-leased by EU AOC holders)

N/A N/A Applicable Applicable

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Part-M GA Task Force (Phase II)

PROPOSED RULE STRUCTURE Non-CAT CAT

Non-CMPA CMPA Non-CMPA CMPA

Part-M Applicable only to non-

Light aircraft (Light

aircraft must follow

Part-ML)

Applicable

Subpart F May still be used for 2

years after new

Regulation. It

disappears later.

N/A N/A N/A

Subpart G (CAMO) Disappears (transferred to Part-CAMO)

Part-145 Applicable

Part-66 Applicable

Part-147 Applicable

Part-T (Third country aircraft dry-

leased by EU AOC holders)

N/A N/A Applicable Applicable

Part-ML Applicable to Light

aircraft

N/A N/A N/A

Part-CAMO (with SMS) Applicable

Part-CAO (without SMS) Applicable N/A N/A N/A

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Coordination between Part-M GA task force and SMS (phase I)

Part-M GA Task Force Phase II

New Part-ML

New Part-CAO (no SMS)

Opinion 05/2016 published on 13 April 2016

SMS (Phase I) for CAMOs

New Part-CAMO with SMS and management system for NAAs

Changes to Part-M (from both tasks)

NOTE: Management system for NAAs in other areas will be addressed in SMS (Phase II)

Opinions expected in May 2016.

Part-M GA Task Force (Phase II)

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Light Part-M (Part-ML)

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Applicable to:

aeroplanes up to 2730 Kg,

other ELA2 aircraft and

helicopters up to 4 occupants and 1200 Kg.

Applicable to private and commercial operations but not to Commercial Air Transport (in the sense of licensed air carriers per (EC)1008/2008).

NOTE: This means that Part-ML covers all sailplanes and balloons, even if the carry passengers (balloons and sailplanes are excluded from 1008/2008)

Light Part-M (Part-ML)

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Part-ML is the only option for this category of aircraft.

All other aircraft (including all aircraft involved in CAT) must follow Part-M.

If an aircraft moves from Part-ML to Part-M (because it changes to CAT operations):

The maintenance programme must be approved by the NAA. Additional maintenance maybe needed to comply with it.

An airworthiness review by a CAMO or NAA and a new ARC issued.

Light Part-M (Part-ML)

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Declaration/approval of the Maintenance Programm (AMP):

Not possible to have the AMP approved by the NAA:

For aircraft managed by a CAMO or CAO:

The CAMO or CAO approves the AMP with justifications to any deviations from DAH recommendations.

For aircraft not managed by a CAMO or CAO:

The AMP is declared by the owner (no justification for deviations needed)

Part-ML includes a “default” AMP to be used by owners if:

The data from the manufacturer is used.

All the recommendations are followed (with no deviations).

No repairs/modifications (with maintenance requirements), life-limited components, repetitive ADs, etc exist for the aircraft.

In this case, no need to declare/approve the AMP

Light Part-M (Part-ML)

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Independent certifying staff can perform airworthiness reviews and issue the ARC together with the 100h/annual inspection (for aircraft operated under NCO)

The staff needs to be approved by the NAA, as follows:

The person must hold a Part-66 licence or national qualification.

The authorisation must be requested to the NAA responsible for such licence or qualification.

The NAA has to assess the knowledge on airworthiness reviews and Part-ML.

1 airworthiness review under supervision of the NAA.

Authorisation valid for 5 years.

This authorisation is mutually recognised by all Member States if based on a Part-66 licence (can issue ARCs on any EU registered aircraft)

If the authorisation is based on a national qualification, they can only issue ARCs on aircraft registered in that country.

Light Part-M (Part-ML)

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Possibility for maintenance organisations to perform airworthiness reviews and issue the ARC together with the 100h/annual inspection.

Minimum Inspection Programmes:

Can be used instead of manufacturer data.

If manufacturer data is used, the declared/approved AMP cannot go below the Minimum Inspection Programme.

Template for the AMP:

In order to facilitate and standardise the development of the AMP.

Deferment of defects by the pilot (for aircraft operated under NCO):

Possible for the pilot to defer defects with the agreement of the owner.

ARC document:

Part-ML contains only the Form 15c.

Part-M contains the Forms 15a and 15b.

Light Part-M (Part-ML)

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“Combined Organisation Approval” (Part-CAO)

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Proposes a new “Combined Airworthiness Organisation” (Part-CAO) for General Aviation:

Applicable to non-complex non-CAT aircraft (some aircraft will follow Part-M and others Part-ML)

Combines the privileges of a Subpart-F maintenance organisation and a CAMO.

No SMS: They will continue with the current Quality System (or organisational reviews if the organisation is small).

Introduces simplified requirements.

Part-CAO

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Organisations already holding CAMO, Part-145 or Subpart Fapprovals will be issued a Part-CAO approval uponapplication, with 2 years to correct any findings (mostlylinked to the need to amend the exposition).

Limitations will be introduced to maintain the currentscope of work.

Limitations can be removed (if desired) when complyingwith the corresponding differences and including thecorresponding procedures in the exposition.

Organisations can keep the current CAMO or Part-145approval (still needed for complex aircraft and CAT)

Part-CAO

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NAAs can still issue Subpart F approvals for 1 year afterapplicability of the new rule.

Existing Subpart F approvals will be valid only until 2years after applicability of the new rule. After that,Part-CAO will be needed.

Part-CAO

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Simplifications introduced:

Combined privileges for maintenance, continuing airworthinessmanagement, airworthiness reviews and permit to fly.

Single exposition for all activities.

The approval certificate has been simplified, with no indication ofaircraft types, just aircraft categories.

More privileges for the organisation to manage changes in theorganisation and in the scope of work.

Only for aeroplanes above 2730Kg, for helicopters of more than1200 Kg or 4 occupants and for workshop maintenance ofcomplete turbine engines, there will be a need to have approvalfrom the NAA. Other aircraft and components can be introducedin the scope of work by the organisation (with an approvedprocedure).

Changes to facilities, tooling, equipment, procedures, etc, canbe managed by the organisation.

Part-CAO