Denmark

1
NPA 2007-08Amendment to Part-M for aircraft not
used in Commercial Air Transport

• Juan AntonFrederic Knecht

2
Current requirements

• On 20 November 2003 the European Commission
  adopted Regulation (EC) 2042/2003, on the
  continuing airworthiness of aircraft and
  aeronautical products, parts and appliances, and
  on the approval of organisations and personnel
  involved in these tasks.
• This Regulation includes Implementing Rules
  (Part-M, 145, 66 and 147). In particular, Part-M
  introduces measures to be taken to ensure that
  airworthiness is maintained, included
  maintenance.

3
Current requirements

• For aircraft involved in Commercial Air
  Transport, most of the Part-M requirements have
  been mandatory since 28 September 2005.
• For aircraft not involved in Commercial Air
  Transport, Part-M requirements are not applicable
  yet (for countries that have opted-out), but its
  implementation can not be postponed further than
  28 September 2008.

4
Part-M Regulatory Impact Assessment and NPA
07/2005

• Article 7(6) of (EC) No 2042/2003 required the
  Agency to make an evaluation of the implications
  of the provisions of Part-M.
• Such evaluation was performed through NPA
  07/2005, and the resulting CRD 07/2005 was
  published on April 30th, 2007.

5
Further changes to those proposed by NPA 07/2005

• Since Industry and NAAs had requested further
  changes to Part-M (in addition to those from NPA
  07/2005) in order to alleviate the requirements
  imposed in non-commercial air transport
  operations, especially on light aircraft, and
  since it was necessary to develop Acceptable
  Means of Compliance (AMCs) and Guidance Material,
  the Agency created Working Group M.017. This
  group was also tasked to evaluate the comments
  received through NPA 07/2005 and to develop CRD
  07/2005, as well as to evaluate maintenance
  related comments received from MDM.032 A better
  concept for General Aviation.

6
Further changes to those proposed by NPA 07/2005

• In addition to Working Group M.017, Working Group
  M.005 was also created in order to address the
  issue of Pilot Owner Maintenance and to produce
  a revised Appendix VIII that would better adapt
  the needs of non-complex aircraft not involved in
  commercial air transport. The concept of jointly
  owning an aircraft has also been addressed.
• THE RESULT OF THE WORK PERFORMED BY M.017 AND
  M.005 IS THE NPA 2007-08 THAT HAS BEEN PUBLISHED
  AT THE END OF JUNE 2007.

7
Further changes to those proposed by NPA 07/2005

• During the work performed by Working Groups M.017
  and MDM.032, it was found necessary to study the
  possibility of creating an aircraft maintenance
  licence specific for light aircraft, the
  so-called "B3 aircraft maintenance licence".
• This task (called 66.022) has been undertaken by
  a sub-group of M.017 and is currently under
  discussion.

8
Envisaged calendar

• NPA 2007-08 has been published on 25 June 2007.
• The comment period for CRD 07/2005 finished on 26
  June 2007.
• However, since some of the changes introduced
  have been further developed by NPA 2007-08 (ARC
  issuance conditions, Pilot Owner Maintenance.),
  it is the intention of the Agency not to publish
  an Opinion following CRD 07/2005, and publish a
  single Opinion by the 1st quarter 2008 covering
  both CRD 07/2005 and NPA 2007-08.
• Consultation for NPA 2007-08 finishes by on 13
  October 2007.
• CRD expected to be published by December 2007,
  ending the consultation period by February 2008.
• Opinion (for CRD 07/2005 and NPA 2007-08) by
  March 2008.
• Approval by the Commission hoped before June
  2008, with Decision on AMC and Guidance Material
  adopted immediately.

9
Transitional measures

• In view of the envisaged schedule
• Organisations will likely withhold their
  application for M.A. Subpart F, Subpart G and
  Subpart I approval until the envisaged changes
  are approved by the Commission.
• Competent Authorities will probably not be able
  to complete the corresponding investigations and
  issue the approval certificates before 28
  September 2008.
• There will be a need to consider some
  transitional arrangements which may include
• Possible grandfathering measure to facilitate
  issuing of approvals to organisations already
  performing similar tasks under national
  regulations, and/or
• Postponing the entry into force of those
  provisions that can not be reasonably implemented
  before 28 September 2008.
• Such arrangements can not be elaborated until
  there is a better view of the implementation
  difficulties.

10
Transitional measures

• As a consequence, the Agency has strongly
  encouraged the Competent Authorities not to
  introduce provisions in their national
  regulations that force the organisations to
  comply with current Part-M requirements that are
  very likely to be amended.
• This is further supported by the fact that both
  CRD 07/2005 and NPA 2007-08 envisage the removal
  of the 12 month in a controlled environment
  requirement before a CAMO can issue an ARC (after
  a full airworthiness review).

11
Transitional measures

• It is not the intention of EASA to propose
  postponing the entry into force of the whole
  Part-M as a block as it is likely that more
  proportionate measures may be a better way to
  address the necessary transition from the
  national systems to Part M
• Such measures may include a phased introduction
  of particular provisions of Part-M, based on
  supporting evidence from the analysis of the
  comments received during the consultation of NPA
  2007-08
• They may also include grand-fathering provisions
  such as the grant of Part M Subpart F
  (maintenance organisation) and/or Subpart G
  (CAMO) and/or Subpart I (ARC privileges)
  approvals to all organisations that have been
  granted a similar approval under national rules,
  subject to some transitional conditions (see the
  precedents in Regulations 1702/2003 and
  2042/2003).

12
Transitional measures

• We therefore encourage regulated persons and
  competent authorities to provide comments in
  relation to the particular areas that may pose an
  implementation problem, together with
  substantiation and proposals.
• In order to accelerate the process, the Agency
  will review all comments received as soon as
  possible, so the areas requiring appropriate
  transitioning can be identified before the end of
  2007.
• We will also examine with National Aviation
  Authorities the possibility to incorporate under
  national regulations provisions of Part-M,
  Subparts F, G and I, together with the changes
  proposed by NPA 2007-08, permitting voluntary
  organisations to start the transition process
  without waiting for publication of the amended
  regulation in the official journal.

13
NPA/CRD 07/2005NPA2007-08 (related to M.017)

• Changes introduced in
• NPA/CRD 07/2005, and
• NPA 2007-08 (related to M.017)

14
Revision of Part-M versus Light Part-M

• Feedback from Industry showed a preference for a
  separate Light Part-M.
• However, EASA did not find enough justification
  in doing so because of the following reasons
• Most of the paragraphs of the current Part-M
  remain unchanged. There is no need for
  duplication.
• This duplication would have meant more
  inconsistencies and duplicated work when keeping
  both documents updated (including approval from
  the Commission).
• Owners/operators trying to move from non
  commercial air transport to commercial air
  transport would have needed to learn two separate
  regulations, trying to identify the differences
  between each other. This difference is much more
  evident having a single regulation with some
  articles split in commercial and non-commercial
  air transport (with an appropriate weight limit).

15
Changes not adopted (FAA AC 43-13)

• Acceptance of FAA AC 43-13
• AC 43-13 states that its material can only be
  used for minor repairs (no major repairs).
• However, the decision (minor / major) has to be
  adopted by a Part-21 design organisation (the
  outcome of MDM.032 may facilitate it)
• As a consequence, currently there is no legal
  basis to accept the proposal.
• A rulemaking task is going to start in 2008 to
  develop and approve a document similar to AC
  43-13.

16
Changes not adopted (FAA 8130-3 issued by
non-Part-145 Repair Stations)

• Acceptance of FAA 8130-3 issued by FAA Repair
  Stations not approved in accordance with
  Part-145
• Components maintained prior to 28 September 2008
  may be issued a Form 1 (under the conditions of
  AMC M.A.613(a)).
• Components maintained afterwards are not
  acceptable (not allowed by the corresponding
  bilateral agreements).
• The following considerations may reduce the
  impact
• Reduce the number of components requiring a Form
  1 or equivalent, and also allow the owner to
  fabricate certain non critical parts (under
  study by MDM.032).
• Such maintenance may also be performed by
  Part-145 organisations (which in many cases
  already exist).
• FAA repair stations may see a business case with
  the new General Aviation market and get the
  Part-145 approval. It is fairly easy and
  inexpensive (bilateral agreement)

17
What is a "competent authority"

• New AMC M.1
• A competent authority may be a ministry, an
  aviation national authority or any aviation body
  designated by the Member State.
• A Member State may designate more than one
  competent authority to cover different areas of
  responsibility (no overlap of responsibilities).

18
"Indirect Approval Procedure" of maintenance
programmes

• Current Rule M.A.302(e)
• The maintenance programme and its amendments may
  be approved through an "indirect approval
  procedure" established by the CAMO responsible
  for the management of the aircraft.
• CRD 07/2005 clarifies what is an "indirect
  approval procedure" (M.A.302(b)
• It is a procedure established by the CAMO,
  included in the exposition and approved by the
  competent authority (the one responsible for the
  oversight of the CAMO.
• In this case, the maintenance programme and its
  amendments are formally approved by the CAMO (no
  need for competent authority endorsement).

19
"Indirect Approval Procedure" of maintenance
programmes

• NPA 2007-08 addresses the case where the State of
  Registry is not the State responsible for the
  oversight of the CAMO. (M.1 and M.A.302(b))
• Usually, the Member State of Registry is
  responsible for the approval of Maintenance
  Programmes.
• The "indirect approval procedure" is a procedure
  approved by the competent authority responsible
  for the CAMO.
• If they are different Member States, the
  responsibility falls on the State of Registry,
  unless there is an agreement between both
  countries. If there is no agreement, the
  "indirect approval procedure" can not be used on
  that particular aircraft.

20
Maintenance programmes not linked to an operator
(independent CAMOs)

• NPA 2007-08 introduces in M.A.302(c) the concept
  of BASELINE and GENERIC maintenance programmes
• Purpose permit the approval of the CAMO without
  having any customer.
• Only for aircraft not involved in Commercial Air
  Transport.
• Based on the maintenance programme recommended by
  the TC holder.
• "Baseline" for a particular aircraft type.
• "Generic" to cover several similar aircraft
  types.

21
Maintenance programmes not linked to an operator
(independent CAMOs)

• AMC M.A.302 revised to include
• UK-LAMS is an example of "Generic" maintenance
  programme.
• "Baseline" and/or "generic" maintenance
  programmes are not applicable to a particular
  "registration mark".
• Should be available to the competent authority
  prior to the CAMO approval and will be listed in
  Form 14.
• After the approval of the CAMO, these programmes
  shall be revised to include specific tasks for
  each customer (for each registration mark).
• May be revised through the "indirect approval
  procedure".

22
Reliability Programmes

• CRD 07/2005 clarifies in M.A.302(e) that a
  Reliability Programme is not required for other
  than large aircraft.

23
Operators Technical Log

• CRD 07/2005 clarifies in M.A.305(b) that the
  Operators Technical Log is only required for
  Commercial Air Transport and when required by the
  Member State in accordance with M.A.201(i).

24
What is a work card / worksheet

• Current Rule M.A.401(c)
• The person or organisation maintaining an
  aircraft shall establish a work card or worksheet
  system to be used and shall either transcribe
  accurately the maintenance data onto such work
  cards or worksheets or make precise reference to
  the particular maintenance task or tasks
  contained in such maintenance data.
• NPA 2007-08 amends AMC M.A.401(c)
• For aircraft 2730 Kg MTOM and below these
  systems may take the form of
• A format where the mechanic writes the defect,
  action and maintenance data used,
• An aircraft log book with the defect, action and
  maintenance data used,
• For maintenance checks, the checklist issued by
  the manufacturer (i.e. 100h checklist).

25
Component maintenance

• NPA 2007-08 modifies M.A.502(b) and introduces
  new AMC M.A.502 and AMC M.A.502(b) to clarify the
  following
• Component removal and installation from an
  aircraft is not considered component maintenance,
  but aircraft maintenance.
• The normal requirement is that component
  maintenance must be performed by approved
  organisations (C rated organisations).
• Nevertheless, component maintenance may be
  performed by independent certifying staff or A
  rated organisations when
• Maintenance in the component is performed in
  accordance with aircraft maintenance data, and
• The component stays installed on the aircraft, or
  the aircraft maintenance data describes or
  permits the removal of such component.
• In this case, the component can not be released
  with a Form 1, but in accordance with the
  aircraft release procedures.

26
Control of unserviceable components

• Current Rule M.A.504(b) and AMC material
• Unserviceable components shall be identified and
  stored in a secure location under the control of
  the M.A.502 approved maintenance organisation
  until a decision is made on the future status of
  the component.
• M.A.801(b)(2) certifying staff performing
  aircraft maintenance should send, with the
  agreement of the aircraft owner/lessee, any
  unserviceable component to an approve maintenance
  organisation for controlled storage.
• NPA 2007-08 amends AMC M.A.504(b) to clarify
  that
• A secure location may be any location described
  in the procedures of the approved maintenance
  organisation for which the organisation is
  responsible, and may include locations away from
  the main maintenance facilities.
• The purpose is to facilitate access to those
  locations to the M.A.801(b)(2) certifying staff
  removing the component.

27
Requirements for continued experience of
certifying staff

• For certifying staff in Subpart F maintenance
  organisations, the 6 months experience
  requirement in every 2 years period has been
  changed to refer to the experience requirements
  of Part-66, which in the case of sailplanes and
  balloons refer to national rules.
• This change also aligns with the requirement of
  M.A.801(b)(2) that requires independent
  certifying staff to be in compliance with the
  requirements of Part-66.

28
What is a work order

• Current Rule M.A.610
• Before the commencement of maintenance a written
  work order shall be agreed between the
  organisation and the customer to clearly
  establish the maintenance to be carried out.
• M.A.610 has been revised in CRD 07/2005 to
  replace "customer" by "the organisation
  requesting maintenance". "Organisation" includes
  natural persons.
• A new AMC M.A.610 has been added in NPA 2007-08
  to clarify that a "written work order " may be a
  formal document or a form specifying the work to
  be carried out. This form may be provided by the
  CAMO managing the aircraft, by the maintenance
  organisation undertaking the work or by the
  owner/operator himself.
• An entry in the aircraft log book specifying the
  defect that needs to be corrected also qualifies
  as a work order.

29
Subcontracting of specialised services (for
Subpart F organisations)

• Current Rule
• Subpart F maintenance organisations do not have
  the privilege of subcontracting maintenance
  tasks. May be justified by the fact that they are
  not formally required to have a Quality System.
• NPA 2007-08 introduces in M.A.615 and associated
  AMC the privilege of subcontracting but limited
  to specialised services (NDT, welding, heat
  treatment....). Conditions
• The specialised service provider must be
  appropriately qualified.
• Under the control of the Subpart F organisation
• Procedures documented in the MOM.
• Coverage by the applicable Organisational
  Reviews.

30
Qualification requirements of CAMO nominated
persons (and competent authority personnel)

• NPA 2007-08 amends AMC M.A.706 to clarify that
  the training on aircraft types for the nominated
  persons in a CAMO should be at least at Level 1
  General Familiarization as specified in
  Part-66, Appendix III and should cover at least
  one aircraft type for each subcategory (i.e.
  helicopter piston, helicopter turbine, aeroplane
  piston, aeroplane turbine) and for each type of
  turbine propulsion system (turbofan, turboprop).
• NOTE Similar provision has been included in AMC
  M.B.102 for the staff involved in Part-M
  activities within the Competent Authority.

31
Airworthiness Review Staff qualification
requirements for CAMOs (and Competent Authorities)

• NPA 2007-08 introduces in M.A.707 alleviated
  requirements for organisations managing aircraft
  of 2730 Kg MTOM and below not involved in
  commercial air transport
• at least three years experience in continuing
  airworthiness, and
• an appropriate Part 66 licence, or a nationally
  recognized maintenance personnel qualification
  appropriate to the aircraft category (when
  Part-66 refers to national rules) or an
  aeronautical degree or equivalent, and
• appropriate aeronautical maintenance training,
  and
• a position within the approved organisation with
  appropriate responsibilities
• NOTE Similar provision has been included in
  M.B.902 for the staff involved in Airworthiness
  Reviews within the Competent Authority.

32
Airworthiness Review Staff qualification
requirements for CAMOs (and Competent Authorities)

• NPA 2007-08 introduces AMC material in order to
  clarify the following terms
• experience in continuing airworthiness
• to hold a position with the appropriate
  responsibilities, including
• Independence from the airworthiness management
  process
• Overall authority on the airworthiness management
  process.
• formal aeronautical maintenance training
• appropriate aeronautical maintenance training
• performance of an airworthiness review under
  supervision
• continuing experience needed to keep the validity
  of an airworthiness review authorisation
• minimum content of the airworthiness review staff
  records.

33
Airworthiness Review Staff qualification
requirements for CAMOs (and Competent Authorities)

• Experience in continuing airworthiness means
  (AMC M.A.707(a))
• Experience in tasks related to aircraft
  maintenance and/or maintenance management
  (engineering) and/or surveillance of such tasks,
  which may be combined.
• NOTE Similar provision has been included in AMC
  M.B.902(b) for the staff involved in
  Airworthiness Reviews within the Competent
  Authority.

34
Airworthiness Review Staff qualification
requirements for CAMOs

• Independence from the airworthiness management
  process may be achieved by (AMC M.A.707(a))
• Having authorisation to perform airworthiness
  reviews only on aircraft which have not been
  managed by that person. For example, performing
  airworthiness reviews on a specific model line,
  while being involved in the management of a
  different model line.
• In the case of organisations with Subpart F,
  Subpart G and Subpart I approval, maintenance
  personnel from the Subpart F organisation may be
  nominated as airworthiness review staff, as long
  as they are only involved in the maintenance of
  the aircraft but not involved in its maintenance
  management.
• Nominating as airworthiness review staff
  personnel from the Quality Department of the
  continuing airworthiness management organisation.

35
Airworthiness Review Staff qualification
requirements for CAMOs

• Overall authority on the airworthiness
  management process of complete aircraft may be
  achieved by (AMC M.A.707(a))
• Nominating as airworthiness review staff the
  Accountable Manager or the Maintenance
  Postholder.
• Having authorisation to perform airworthiness
  reviews only on those particular aircrafts for
  which the person is responsible for the complete
  continuing airworthiness management process.
• In the case of one-man organisation, this person
  has always overall authority. This means that
  this person can be nominated as airworthiness
  review staff.

36
Airworthiness Review Staff qualification
requirements for CAMOs

• For aircraft used in commercial air transport and
  aircraft above 2730 kg MTOM, formal aeronautical
  maintenance training means training (internal or
  external) supported by evidence on the following
  subjects (AMC M.A.707(a)(1))
• Relevant parts of continuing airworthiness
  regulations.
• The operators Operations Specifications when
  applicable.
• Relevant parts of the operators Operations
  Manual.
• Relevant parts of operational requirements and
  procedures.
• The organisations continuing airworthiness
  management exposition.
• Knowledge of a relevant sample of the type(s) of
  aircraft gained through a formalised training
  course. These courses should be at least at the
  Level 1 as specified in Part-66, Appendix III and
  should cover at least one aircraft type for each
  subcategory (i.e. helicopter piston, helicopter
  turbine, aeroplane piston, aeroplane turbine) and
  for each type of turbine propulsion system
  (turbofan, turboprop).
• Maintenance methods.

37
Airworthiness Review Staff qualification
requirements for CAMOs

• For aircraft of 2730 Kg MTOM and below, not used
  in commercial air transport (AMC M.A.707(a)(2))
• experience in continuing airworthiness can be
  full time or part-time, either as professional or
  on a voluntary basis.
• Appropriate aeronautical maintenance training may
  be demonstrated by documented evidence or by an
  assessment performed by the competent authority
  or by other airworthiness review staff already
  authorised within the organisation. This
  assessment should be recorded.

38
Airworthiness Review Staff qualification
requirements for CAMOs

• AMC M.A.707(b)
• An airworthiness review under supervision means
  under the supervision of the competent authority.
  If the organisation already has properly
  authorised airworthiness review staff, the
  competent authority may accept that the
  supervision be performed by this existing
  airworthiness review staff in accordance with an
  approved procedure. In such case, evidence of the
  airworthiness review performed under supervision
  should be provided to the competent authority
  together with the EASA Form 4.

39
Airworthiness Review Staff qualification
requirements for CAMOs

• AMC M.A.707(c)
• In order to keep the validity of the
  airworthiness review staff authorisation, the
  airworthiness review staff should have either
• been involved in continuing airworthiness
  management activities for at least six months in
  every two year period for each subcategory (i.e.
  helicopter piston, helicopter turbine,
  rotorcraft, aeroplane piston, aeroplane turbine,
  gliders and balloons), or,
• conducted at least one airworthiness review in
  the last twelve month period.
• In order to restore the validity of the
  authorisation, the airworthiness review staff
  should conduct at a satisfactory level an
  airworthiness review under the supervision of the
  competent authority or, if accepted by the
  competent authority, under the supervision of
  another currently valid authorised airworthiness
  review staff of the concerned continuing
  airworthiness management organisation in
  accordance with an approved procedure.

40
Airworthiness Review Staff qualification
requirements for CAMOs

• AMC M.A.707(e)
• The minimum content of the airworthiness review
  staff record should be
• Name,
• Date of Birth,
• Basic Education,
• Experience,
• Aeronautical Degree and/or part-66-qualification
  and/or nationally-recognized maintenance
  personnel qualification,
• Initial Training received,
• Type of Training received,
• Continuation Training received,
• Experience in continuing airworthiness and within
  the organisation,
• Responsibilities of current role in the
  organisation.

41
Availability of maintenance data in a CAMO

• NPA 2007-08 has revised M.A.709 to indicate
• The approved continuing airworthiness management
  organisation shall hold and use applicable
  current M.A.401 maintenance data in the
  performance of M.A.708 continuing airworthiness
  tasks. In the case of customer provided
  maintenance data, it is only necessary to have
  such data when there is a contract with such a
  customer, with the exception of the need to
  comply with M.A.714.

42
Anticipation of the Airworthiness Review

• M.A.710 allows the anticipation of the
  airworthiness review by a maximum of 90 days
  without the loss of continuity of the
  airworthiness review pattern, to allow the
  physical review to take place during a
  maintenance check.
• NPA 2007-08 has introduced new AMC M.A.710 to
  clarify that
• Without loss of continuity of the airworthiness
  review pattern means that the new expiration
  date is set up one year after the previous
  expiration date.
• Renewal of the ARC must be for 1 year at least
  (even if the ARC was expired)

43
Privileges of the CAMO (removal of
recommendations)

• M.A.711
• For aircraft of 2730 Kg MTOM and below , which
  are not used in commercial air transport, CRD
  07/2005 has removed the concept of
  recommendations except for the import of an
  aircraft.
• NOTE For this type of aircraft, changes
  introduced in M.A.901 allow the CAMO to issue the
  ARC even if the aircraft has not been in a
  controlled environment.

44
Need for a Quality System

• M.A.712
• The possibility has been added to have
  organisational reviews even for organisations
  issuing ARCs for aircraft of 2730 Kg and below.
  (CRD 07/2005)
• M.A.712(f) has been aligned with M.A.712(e),
  making clear that organisational reviews are not
  possible when managing aircraft involved in
  commercial air transport. (NPA 2007-08).
• It has been stated that contracting continuing
  airworthiness management tasks is not possible
  without a Quality System. (NPA 2007-08)

45
Need for a Quality System

• AMC M.A.712(f)
• The criteria to qualify as a small organisation
  (eligible for organisational reviews) has been
  changed from managing 5 large aircraft (10 small)
  to have up to 5 persons in the CAMO (including
  M.A.706 and M.A.707 personnel). (NPA 2007-08)
• A new Appendix XII to the AMC has been created to
  give guidelines on the content of the
  organisational reviews. (NPA 2007-08)

46
Record-keeping

• AMC M.A.714
• The M.A. Subpart G organisation should ensure
  that it always receives a complete CRS from the
  approved maintenance organisation and/or from the
  pilot owner such that the required records can be
  retained. The system to keep the continuing
  airworthiness records should be described in the
  organisation continuing airworthiness management
  exposition. (NPA 2007-08)

47
Release authorisation in case of AOG

• CRD 07/2005 removed this provision from M.A.607
  and transferred it, with some modifications, to
  M.A.801
• In case of AOG, the owner may authorise any
  person, with not less than 3 years maintenance
  experience and holding the proper qualifications,
  to maintain according to the standards set out in
  subpart D and release the aircraft, provided
  there is no organisation appropriately approved
  under this Part or Part 145 at that location.
• This is valid for non-large aircraft not used in
  commercial air transport (those not required to
  go to a Part-145 organisation).

48
Release authorisation in case of AOG

• In the cases mentioned in the previous page, the
  owner shall
• obtain and keep in the aircraft records details
  of all the work carried out and of the
  qualifications held by that person issuing the
  certification, and
• ensure that any such maintenance is rechecked and
  released by an appropriately authorised
  M.A.801(b) person or a Subpart F organisation or
  a Part-145 organisation at the earliest
  opportunity but within a period not exceeding 7
  days, and
• notify the contracted CAMO, or the competent
  authority in the absence of such a contract,
  within 7 days of the issuance of such
  certification authorisation.

49
Release authorisation in case of AOG

• AMC M.A.801(c)
• 3 years maintenance experience means 3 years
  working in an aircraft maintenance environment on
  at least some of the aircraft type systems
  corresponding to the aircrafts endorsed on the
  aircraft maintenance license or certifying staff
  authorisation that the person holds.
• Holding the proper qualifications means holding
  either
• a valid ICAO compliant maintenance license for
  the aircraft type requiring certification, or
• a certifying staff authorisation valid for the
  work requiring certification, issued by a
  maintenance organisation approved in accordance
  with ICAO Annex 6, Part II, paragraph 8.1.3.

50
M.A.901 Aircraft Airworthiness Review

• Revised for aircraft of 2730 Kg MTOM and below
  which are not used in commercial air transport.
  (CRD 07/2005 and NPA 2007-08)
• Possibility for the owner to choose between a
  CAMO or the Competent Authority.
• Any CAMO appropriately approved (Subpart I) may
  be contracted to issue the ARC (with full
  airworthiness review), even if the aircraft has
  not stayed in a controlled environment for the
  previous 12 months. So
• The 12 month requirement has been removed.
• Maintenance can also be performed by
  M.A.801(b)(2) certifying staff (except complex
  tasks per Appendix VII)
• However, controlled environment still required
  for ARC extension (without full airworthiness
  review).

51
Part-M, Appendix I Continuing Airworthiness
Arrangement

• Included in Appendix I Continuing Airworthiness
  Arrangement, the obligation of the owner to
  inform the CAMO about the flying hours and any
  other utilization data, as agreed with the CAMO.
  (CRD 07/2005)

52
Part-M, Appendix II EASA Form 1

• Instructions have been revised to include some
  missing information regarding the Release to
  Service (CRD 07/2005)

53
Part-M, Appendix III Airworthiness Review
Certificate

• NPA 2007-08
• Form 15a has been amended to align with Form 15b.
• Now, both certificates show
• is considered to be airworthy at the time of the
  review

54
Part-M, Appendix VII Complex Maintenance Tasks

• NPA 2007-08
• Appendix VII has been revised to incorporate
  complex maintenance tasks related to piston
  engines.
• The purpose of Appendix VII is to provide those
  tasks that need to be performed in an approved
  maintenance organisation because they are likely
  to involve the use of special tooling, equipment
  and facilities.

55
Other provisions related to Part-M, Section B
(Competent Authorities)

• NPA 2007-08
• AMC material has been created to give flexibility
  to the competent authority when creating the
  airworthiness survey programme for aircraft for
  which it delivers the airworthiness review
  certificate.
• M.B.606, M.B.706 and AMC aligned with Part-145
  (145.B.35) regarding changes.
• Editorial correction in AMC 704(b) regarding the
  time where back credit for specific item audits
  can be granted (11 12 months replaced by 23
  24 months).