M-005: Limited Pilot owner maintenance

01 DEC 2006 Koeln

M-005: Limited Pilot owner maintenance

EASA workshop01 December 2006

JP Arnaud

01 Dec 2006 M-005 Limited pilot owner maintenance Slide 2

European Aviation Safety Agency

Part M.A.803Pilot-owner authorisation

(a) The pilot-owner is the person who owns or jointly owns the aircraft being maintained and holds a valid pilot licence with the appropriate type or class rating.(b) 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.(c) Limited pilot owner maintenance shall be defined in the M.A.302 aircraft maintenance programme.(d) The certificate of release to service must be entered in the logbooks and contain basic details of the maintenance carried out, the date such maintenance was completed and the identity and pilot licence number of the pilot-owner issuing such a certificate.



AMC M.A.803 Pilot-owner authorisation

AMC M.A.803 Pilot-owner authorisation1. The pilot–owner should hold a valid pilot license issued or validated by a member state for the aircraft type being maintained.2. Privately operated means the aircraft is not operated pursuant to M.A.201 (h) and (i).

i.e means “commercial activities” or ‘operational” activities requiring an AOC IAW the national rules

3. A pilot owner should only issue a certificate of release to service for maintenance performed by the pilot owner and after demonstrating the competence to carry out such maintenance tasks.



History / need for such a working group

JAA times: non complex and light aircraft not involved in commercial activities were not taken into account

When the EASA was created, it became urgent, according to the remit of activities, to develop a regulation for non complex and light aircraft not involved in commercial activities.

EASA Appendix VIII was based on FAR43 appendix A part (c)



History / need for such a working group

Part M was published in 2003 (regulation 2042)NPA 07-2005 gave the opportunity to comment part M (impact for non commercial aircraft)

The Appendix was found too limitative. It was furthermore proposed re-evaluating the applicability of each task in Appendix VIII to gliders, balloons, airships and light aircraft.EASA accepted that paragraph M.A.803 and Appendix VIII should be subject to further re-evaluation within the rulemaking task M.005.

Appendix VIII and M.A.801(b) has been updated.



5 - History / need for such a working group

Additionnaly, NPA 07-2005 gave birth to two working group

M-017: comment review and implementation of further changes to part M, AMC amendements following RIA

MDM-032: Regulation of aircraft other than complex motor powered aircraft when used in non-commercial activities

Comments from both groups about pilot owner maintenance will taken on board by M-005



Additional infoFuture new drafting groups

Working group M-010: definition of “pilot owner”

AMC M.A.803A problem was clearly demonstrated by associations representing flying clubs. Pilot owner maintenance in the case of collectively owned aircraft needs to be further developed to allow pilots in flying clubs for instance to carry out pilot owner maintenance

Work method: agencyNPA to be issued: 2008-04Opinion: 2009-04

PRERIA_M010_issue2.pdf

PRERIA_M010_issue2.pdf



Part M.A.803Pilot-owner authorisation

APPENDIXES VII (complex task) and VIII (pilot owner maintenance) has been reviewed (NPA 07/2005)

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State of the play

Kick off meeting and two meeting were held (July, Sept. and Nov. 2006)Next meeting: mid January 2007Composition of the group: a balance between experts from the General Aviation experts (representing flying associations as AEI, EAS, OAPA) and NAA’s.NPA to be published June 2007Opinion/Decision to be issued by June 2008



Pilot-owner maintenance

Decision already taken for a new structure:

AircraftGlidersBalloonsHelicopters

Example: Microsoft Word

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As from now, the next slides are only options that have not been accepted so far.




The concept for powered aircraft…

3 CRITERIAS

a) The weight (MTOW)b) How to demonstrate the competency?

c) How to adapt the list of tasks to the complexity of the aircraft?

(Flexibility)



Pilot-owner maintenance: general scheme

5700 kg 2000kg 850kg (To be defined IAW MDM032)

No competency checked

Self assessment from the pilot

List of tasks including the annual check and the 100 hour check

Full control of the competency by a subpart M/G organisation (controlled environment)

List of tasks included the 50h check

More restrictive list of tasks (smaller list)

Full control of the competency either by the NAA (uncontrolled environment) or a subpart M/G

organisation (controlled environment)

+ Additional /special module of training during the PPL

Full control of the competency by the NAA (uncontrolled environment)

Limited operations ?




A guidance could be given to the NAA or the Part M / Subpart G approved organisation to adapt the list of tasks (Appendixes VII and VIII) to:

Can the task be performed by a pilot owner?Complexity of the task: decision making

Microsoft Word Document

Microsoft Word Document



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M-005: Limited Pilot owner maintenance