If you have an enquiry relating to Part M and how it may affect the maintenance of your aircraft please contact Jason Kettlewell either on 01832 280984 or e mail to [email protected] and we will do our best to answer it.
Part M of EU Regulation 2042/2003 has come into force and now applies to all light aircraft under 5700kg. It was introduced to control the Continuing Airworthiness Management of all E.A.S.A., light aircraft, throughout the EU, which fall in to one of two categories as far as the future of their ongoing maintenance is concerned.
In simple terms aircraft that come into Annex I are those types that are supported by either the manufacturer themselves, or an organisation approved by the authorities to provide an appropriate level of support, and include most of the popular types of Piper, Robin, Cessna, Grumman etc. etc.
Aircraft listed in Annex II include almost all other types requiring a C of A (including those operated on a Permit to Fly) and are not affected by the new regulations
Under Part M regulations Annex I aircraft are issued with a non-expiring C of A, but this will only remain valid when a current Airworthiness Review Certificate (ARC) is in place. The ARC has to be renewed every year.
Part M allows for two alternative scenarios for light aircraft operators:
The Controlled Environment, or
The Uncontrolled Environment.
In a Controlled Environment the operator must agree a contract with a Subpart G Continuing Aircraft Maintenance Organisation (CAMO) who then becomes responsible for the Continuing Airworthiness of the aircraft.
The responsibility includes:-
- Keeping the aircraft documentation up to date.
- Developing a maintenance programme.
- Ensuring all Airworthiness Directives and Service Bulletins are complied with.
- Making sure all modifications and repairs are carried out correctly
- Being satisfied that all scheduled maintenance is carried out at a Subpart F approved organisation, (or a Part 145 organisation).
- Ensuring the aircraft mass and balance report is correct.
Issuing the ARC.
It is necessary to carry out an initial airworthiness review to ensure that all the airworthiness matters noted above are up to date.
The Subpart F approved organisation can then carry out the actual maintenance needed to meet these requirements.
Following this, a Subpart I approved organisation is able to issue the ARC that will be valid for one year. It can be extended for a further year but after three years the ARC will be renewed following a further Airworthiness Review, which will be not dissimilar to the old “star annual”.
If, for any reason, an owner changes his/her CAMO the cycle goes back to the start and the whole process will need to begin again from scratch.
In an Uncontrolled Environment the owner retains the responsibility for the Continuing Airworthiness of his aircraft and is required to carry out ALL the activities required of a CAMO.
A Part 66 Licensed Engineer can then certify maintenance but complex tasks must be carried out at a Subpart F or Part 145 approved organisation.
However an Airworthiness Review will be required each year, which has to be carried out by a CAMO or the CAA .
In practice this is like having to carry out a star annual every year with the attendant costs, and will require the owner to keep up to date with all the ADs, SBs etc.
Under Part M a range of Pilot Owner Maintenance Tasks, for aircraft up to 2730kg, are allowed and are detailed in Part M Appendix VII. However, the range of these tasks must be agreed with the CAMO when preparing the maintenance programme and a degree of competence will need to be demonstrated by the owner before agreement can be reached.
Aircraft that fall into Annex II will be maintained much as before i.e. 50hr – 100hr – 150hr – annual, - star annual or 50hr/182day check – annual – star annual,
the maintenance being carried out by either an existing M3 approved organisation or a Part M, subpart F as we have become.
Whilst there is no official requirement to agree a formal contract with a CAMO, owners of aircraft in this category would, hopefully, feel that such an arrangement as detailed for Annex I aircraft would be beneficial, and offer the same peace of mind that they will enjoy. The reorganisation that an M3 approved organisation making the move to Part M subparts G and F will have gone through to achieve the standard required, will be of benefit to all concerned if a similar, formal arrangement can be put in place, rather than running two differing systems side by side.
What as the aircraft owner/operator, do you do now?