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  • How to Declare Your Own Aircraft Maintenance Programme Under EASA Part-ML

    How to Declare Your Own Aircraft Maintenance Programme Under EASA Part-ML

    How to Declare Your Own Aircraft Maintenance Programme Under EASA Part-ML

    Meta description: Learn how to declare your own AMP under EASA Part-ML without a CAMO. Covers mandatory items, permitted deviations, and annual review requirements.

    You own a Cessna 172 or a Piper PA-28 in Europe. You fly privately, keep good records, and wonder why you need to pay a CAMO several hundred euros a year to manage paperwork you could handle yourself. Good news: you probably don’t. Since Part-ML came into force, owners of ELA1 and ELA2 aircraft operating non-commercially can declare their own Aircraft Maintenance Programme without any external approval. But “can” isn’t the same as “should know how.” This guide walks you through exactly what’s required.

    What Is an Aircraft Maintenance Programme and Why Does It Matter?

    An Aircraft Maintenance Programme is the document that defines every recurring maintenance task for your specific aircraft. It tells you what needs to be done, when it needs to be done, and what regulatory requirements drive each task.

    Without an AMP, there’s no structured way to ensure your aircraft remains airworthy. The Annual Review of Airworthiness (ARA) reviewer will check that one exists and that you’re complying with it. If you can’t produce a valid AMP, you won’t get your Airworthiness Review Certificate (ARC) renewed.

    The AMP covers three categories of tasks:

    1. Manufacturer-specified maintenance — the scheduled inspections and component replacements from your aircraft, engine, and propeller maintenance manuals
    2. Mandatory requirements — repetitive Airworthiness Directives and Airworthiness Limitations from the Type Certificate holder
    3. Additional tasks — anything you add based on operational experience, modifications installed, or specific equipment fitted

    For a typical ELA1 aircraft, the AMP might be ten pages. For a complex ELA2 twin, it could be forty. Either way, it’s the backbone of your continuing airworthiness management.

    Declaring vs. Approving: The Part-ML Distinction That Matters

    Here’s where Part-ML created genuine flexibility for private owners. Under the older Part-M framework, every AMP required approval from a CAMO or, in some cases, the competent authority. That meant paying someone else to review and stamp your programme.

    Part-ML changed this for non-commercial operations of ELA1 and ELA2 aircraft. Under ML.A.302, you have two options:

    Option 1: Approved AMP
    You contract a CAMO to develop and approve your AMP. They take responsibility for its content and compliance. You pay for the privilege.

    Option 2: Declared AMP (owner-declared)
    You develop your own AMP using an approved template as a basis, sign a declaration that it meets Part-ML requirements, and take full responsibility for its content. No external approval needed.

    The declaration route under ML.A.302(d) is specifically designed for owners who want to self-manage. You’re not asking permission. You’re stating that your AMP complies with the regulation and accepting the consequences if it doesn’t.

    The catch? “Owner-declared” doesn’t mean “owner-invented.” You must base your AMP on either:

    • The minimum inspection programme from Part-ML Appendix VII, or

    • A template published or accepted by your competent authority, or

    • The manufacturer’s recommended maintenance programme

    Most owners start with their national authority’s template (the UK CAA, EASA, and many NAAs publish these) and adapt it to their specific aircraft configuration.

    Mandatory Items: What You Cannot Omit or Defer

    Owner flexibility has hard limits. Certain items must appear in every AMP regardless of whether it’s declared or approved:

    Repetitive Airworthiness Directives
    Any AD that requires recurring inspections or actions must be incorporated into your AMP with the correct intervals. If AD 2019-0124 requires inspection of a fuel tank vent every 100 hours, that task must appear in your AMP at that interval or more frequently. You cannot extend AD intervals. Ever.

    Check your aircraft’s AD status using EASA’s Safety Publications Tool and cross-reference with any national ADs from your state of registry.

    Airworthiness Limitations (ALIs)
    These come from the Type Certificate holder and appear in Chapter 4 of the aircraft maintenance manual or in a separate Airworthiness Limitations document. ALIs include life-limited parts (replace the landing gear attach bolts at 12,000 hours regardless of condition) and mandatory inspection intervals.

    ALIs are not recommendations. They’re certification requirements. Under ML.A.302(c)(1), your AMP must include all ALIs without modification.

    Certification Maintenance Requirements (CMRs)
    Less common on GA aircraft, but if your type has CMRs defined in the Type Certificate Data Sheet, they’re mandatory inclusions.

    Modifications and Repairs
    If your aircraft carries an STC or has had a major repair, check whether that modification introduced its own maintenance requirements. An autopilot STC might require annual inspection of servo mounting bolts. A composite repair might require periodic NDT. These go in your AMP.

    The point: your declared AMP gives you flexibility on manufacturer-recommended tasks, not on regulatory requirements. Know the difference.

    Where You Have Flexibility: Deviating from Manufacturer Schedules

    Part-ML permits owners to adjust manufacturer-recommended maintenance intervals under specific conditions. This is codified in ML.A.302(c) and represents a genuine departure from the Part-M approach.

    Here’s what you can do:

    Extend or reduce inspection intervals
    If the manufacturer recommends a 100-hour inspection but you fly 30 hours a year, you might choose to perform it annually instead. Part-ML permits this provided you justify the deviation and it doesn’t conflict with mandatory requirements.

    Adjust task groupings
    Rather than following the manufacturer’s exact inspection schedule, you can reorganise tasks into a programme that suits your operation — perhaps combining items into a single annual inspection rather than spreading them across multiple calendar intervals.

    Omit non-applicable tasks
    If your aircraft doesn’t have a specific optional system fitted (no oxygen system, no de-icing equipment), you don’t include the related maintenance tasks.

    The critical phrase in ML.A.302(d) is that deviations are made “under the owner’s responsibility.” This isn’t bureaucratic boilerplate. It means:

    • You must document your reasoning

    • You accept liability if a deviation contributes to an incident

    • An ARA reviewer can question your decisions and refuse to issue an ARC if the justification is inadequate

    Practically speaking, conservative deviations (aligning to annual inspection when you fly well under 100 hours) are rarely challenged. Aggressive extensions without supporting data or experience will raise eyebrows.

    [VERIFY: ML.A.302(d) wording on deviation justification — confirm current AMC/GM guidance]

    The Annual Review Requirement Under ML.A.302(c)(9)

    Your AMP isn’t a document you create once and forget. ML.A.302(c)(9) requires an annual review of the AMP to ensure it remains current and effective.

    What does this review involve?

    AD currency check
    Have any new repetitive ADs been issued since your last review? If yes, incorporate them.

    Service Bulletin review
    Has the manufacturer issued any SBs that affect scheduled maintenance? While SBs aren’t mandatory, you should assess whether any affect airworthiness sufficiently to warrant inclusion.

    Effectiveness assessment
    Has your maintenance programme caught problems before they became failures? If you’ve had recurring discrepancies (persistent corrosion, repeated brake wear), should task intervals be shortened?

    Configuration changes
    Have you installed any new equipment or modifications that introduce maintenance requirements?

    Document the review. A simple signed statement with the date, a summary of changes made (or “no changes required”), and references to any new ADs incorporated is sufficient. Keep it with your aircraft records.

    This annual review typically happens before your ARC renewal. The ARA reviewer will expect to see evidence that it’s been done.

    How Squawkd Helps

    Squawkd tracks your AMP tasks alongside flight hours and calendar time, alerting you before items come due rather than after. When annual review time arrives, you can generate a current status report showing compliance across all tracked requirements — exactly what an ARA reviewer wants to see.

    Frequently Asked Questions

    Q: Can I use the manufacturer’s maintenance schedule directly as my AMP?

    You can base your AMP on the manufacturer’s schedule, but you need to supplement it with repetitive ADs and any requirements from installed modifications that aren’t covered. The manufacturer’s schedule alone won’t include ADs issued after publication or equipment you’ve added via STC. Most owners find it easier to start with a competent authority template and incorporate manufacturer task intervals rather than using the manufacturer document directly.

    Q: What happens if an ARA reviewer disagrees with a deviation I’ve made?

    The reviewer can refuse to issue an ARC if they believe your AMP doesn’t meet Part-ML requirements. In practice, they’ll usually discuss concerns with you first. If you’ve documented your reasoning clearly and it’s technically sound, you can defend your position. If you can’t justify a deviation, expect to revise your AMP and potentially perform overdue maintenance before the ARC is issued.

    Q: Do I need to notify my competent authority when I declare my AMP?

    Under Part-ML, a declared AMP doesn’t require submission to or approval from the authority. However, you must keep the AMP available for inspection. Some national authorities request that you send them a copy for their records — check your NAA’s specific requirements. The declaration itself (stating your AMP complies with Part-ML) should be retained with your aircraft records.

    Tags: EASA Part-ML, aircraft maintenance programme, owner-declared AMP, ELA1, ELA2, continuing airworthiness, ARC renewal

    Regulatory context: EASA

    Image search: light aircraft maintenance hangar inspection

  • FAA Aircraft Annual Inspection: What Part 91 Owners Must Know

    FAA Aircraft Annual Inspection: What Part 91 Owners Must Know

    FAA Aircraft Annual Inspection: What Part 91 Owners Must Know

    Meta description: FAA aircraft annual inspection explained: what it covers, who can perform it, how to prepare, and what the sign-off actually certifies legally.

    Every 12 calendar months, your aircraft needs an annual inspection or it doesn’t fly legally. Simple rule, but the details matter — who can sign it off, what they’re actually certifying, how to avoid surprises, and what happens when something fails. Get any of this wrong and you’re either grounded or, worse, flying an aircraft that isn’t legally airworthy. This guide covers what Part 91 private owners need to know to keep their aircraft legal and the inspection process efficient.

    What the Annual Inspection Covers — and What It Certifies

    The annual inspection is defined in 14 CFR §43.11 and Appendix D to Part 43. It’s a comprehensive examination of your aircraft’s airframe, engine, propeller, and all installed components and systems. The scope is specific: the inspector must check for conformity to type design and determine whether the aircraft is in condition for safe operation.

    Appendix D lists the minimum inspection items. For the airframe, this includes fuselage and hull surfaces, flight control systems, landing gear, cockpit and cabin components, engine mounts, and all structural elements. For powerplant, it covers the engine, exhaust, controls, fuel and oil systems, ignition, and accessories. Propellers get their own section covering blades, hubs, governors, and anti-ice components.

    Here’s what the annual inspection sign-off actually certifies: per §43.11, the IA (Inspection Authorization holder) is certifying that the required inspection was performed and the aircraft was found airworthy — or was not found airworthy, in which case it must be listed as such.

    Critical point: the signature does not mean the FAA has certified or approved anything. The FAA issues the type certificate and airworthiness certificate. The IA’s role is to inspect and attest. The legal responsibility for maintaining airworthiness sits with you, the owner, under §91.403(a). The IA certifies the inspection occurred and documents the findings. That’s it.

    Who Can Perform the Annual: A&P IA Aircraft Inspection Authority

    Not every mechanic can sign off an annual inspection. This is where many owners get confused.

    An A&P (Airframe and Powerplant) certificated mechanic can perform maintenance, preventive maintenance, and alterations. But to perform and sign off an annual inspection, you need either:

    1. A mechanic holding an Inspection Authorization (IA) under 14 CFR §65.91
    2. A manufacturer with a repair station certificate
    3. The aircraft manufacturer if they hold appropriate authority

    For most Part 91 owners, option one is the path: an A&P with IA authorization.

    The IA is issued by the FAA to experienced A&Ps who meet specific requirements: at least three years of certificated experience, current active engagement in maintenance, and completion of an IA refresher within the prior two years. The IA authorizes them to perform annual inspections, approve aircraft for return to service after major repairs or alterations, and perform the 100-hour inspection.

    You can hire an A&P without IA status to assist with the inspection — removing panels, cleaning, even diagnosing issues — but only the IA can approve the aircraft for return to service after the annual.

    When selecting an IA, look for experience with your aircraft type. A Bonanza specialist will inspect a Bonanza more thoroughly than a generalist unfamiliar with the type-specific AD history and known failure modes.

    How to Prepare Your Aircraft and Logbooks

    Preparation is where you save money and reduce downtime. Show up unprepared and you’re paying shop rates while someone searches through a box of loose papers.

    Logbook organization: Bring complete, organized maintenance records. This means airframe, engine, and propeller logbooks, plus any separate avionics logs. The IA needs to verify AD (Airworthiness Directive) compliance, life-limited component status, and previous inspection history. If you have digital records through a platform like Squawkd, export a complete summary. If you’re working from paper, tab the relevant entries.

    AD compliance list: Compile a current list of all applicable ADs with compliance status. This is your responsibility as owner under §91.403. Don’t make the IA hunt for it. Include one-time ADs with compliance dates and recurring ADs with next-due information.

    Aircraft preparation: Arrive with the aircraft clean. Seriously. Inspectors can’t see corrosion through grime. Remove interior panels if you’re able and willing — this can save an hour or more of shop time. Drain the sumps the night before so any water contamination is evident. Top off the oil so the inspector can verify oil consumption trends.

    Document known issues: If you know the right brake is weak or there’s a minor oil seep at the prop governor, tell the IA upfront. Surprises during inspection cost more than honest disclosure beforehand.

    Bring the aircraft’s equipment list and weight-and-balance data. The inspector needs to verify installed equipment matches documentation.

    What Commonly Gets Flagged

    Experienced IAs see the same issues repeatedly. Knowing these patterns helps you anticipate problems.

    Airworthiness Directive non-compliance: Either missed entirely or improperly documented. The AD was done but the logbook entry doesn’t include all required information — AD number, revision, method of compliance, date.

    Exhaust system cracks: Common on legacy aircraft. Inspect before the annual if you can; exhaust repairs take time and parts.

    Control cable wear and pulley issues: Often found at fairleads and turnbuckles. Cables fray where they bend.

    Corrosion: Particularly in battery boxes, around fuel tank fittings, and on steel components in coastal environments.

    Worn brake linings and leaking brake cylinders: Frequently deferred during the year but flagged at annual.

    Instrument markings: Faded or missing range markings on airspeed indicators, tachometers, manifold pressure gauges. Minor to fix but commonly noted.

    ELT battery expiration: The 406 MHz ELT battery has a replacement date. If it’s due within the next year, some IAs flag it.

    Seat track and stop condition: After several fatal accidents traced to seat slippage, inspectors scrutinize seat rail stops and locking mechanisms.

    Paperwork deficiencies: Weight and balance not updated after equipment changes. Missing 337 forms for previous alterations. Incomplete log entries.

    Annual vs. 100-Hour Inspection: Understanding the Difference

    The annual and the 100-hour inspection are identical in scope. Same checklist, same Appendix D requirements, same level of scrutiny. The difference is when each is required and who can sign it off.

    Annual inspection: Required every 12 calendar months for all aircraft under Part 91 (with limited exceptions for special categories). Can only be performed and approved by an IA, certified repair station, or manufacturer.

    100-hour inspection: Required only when the aircraft is operated for hire — flight instruction for hire, or carrying passengers or property for compensation. The 100-hour requirement sits on top of the annual requirement; it doesn’t replace it. An A&P without IA authorization can perform the 100-hour inspection.

    If you use your aircraft exclusively for personal transportation under Part 91, you have no 100-hour requirement. Annual only. If you rent your aircraft back to a flight school or provide any for-hire operations, you need both.

    One efficiency note: if a 100-hour inspection is due and performed by an IA, they can sign it off as an annual, resetting the 12-month clock. This avoids duplicative inspections.

    Return to Airworthy: What Happens When a Squawk Is Found

    When the inspection reveals a discrepancy, the aircraft is not airworthy until that item is corrected. The process is straightforward but must be documented properly.

    The IA cannot sign off the annual until all discrepancies are resolved or the owner chooses to leave items uncorrected. If you decline repairs, the IA must provide a signed, dated list of discrepancies. The aircraft cannot return to service until those items are addressed and signed off.

    For items that can be corrected: the repair or replacement is performed, then documented in the maintenance record with a return-to-service entry per §43.9. Only after all items are resolved can the IA make the annual inspection entry in the maintenance record.

    That entry must include: the type of inspection, the date, aircraft total time, the signature of the person approving the return to service, and their certificate type and number.

    If a major repair is required during the inspection — not just minor maintenance — a separate FAA Form 337 may be required. The IA determines whether the repair qualifies as major per Part 43 Appendix A.

    How Squawkd Helps

    Squawkd keeps your AD compliance status, component life tracking, and complete maintenance history in one place. When annual inspection time comes, you can generate a full maintenance summary that gives your IA exactly what they need to verify compliance quickly — no digging through boxes of paper.

    Frequently Asked Questions

    Q: Does a signed-off annual inspection mean the FAA has certified my aircraft is airworthy?

    No. The FAA issued your original airworthiness certificate when the aircraft was manufactured or imported. The annual inspection sign-off is the IA’s attestation that they performed the required inspection and found the aircraft in airworthy condition at that time. Continued airworthiness remains your responsibility as the owner under §91.403. The FAA does not review or approve annual inspection results.

    Q: Can I fly my aircraft to an IA for the annual inspection if it’s already overdue?

    Yes, with limitations. Under §91.409(e), you may operate an aircraft to a location where the inspection can be performed, but you cannot carry passengers and the flight must be the most direct route practical. This is sometimes called a “ferry permit” informally, though no formal permit is required for this specific situation.

    Q: What happens if my IA finds something during the annual but I can’t afford the repair right now?

    The IA cannot sign off the annual with known unairworthy conditions. Your options: complete the repair, have the IA provide a written list of discrepancies (the aircraft remains grounded until resolved), or in some cases, obtain a special flight permit under §21.197 to ferry the aircraft to a facility that can complete the work. Deferring required repairs indefinitely is not an option if you want to fly legally.

    Tags: Part 91 annual inspection, A&P IA aircraft inspection, aircraft airworthiness FAA, annual inspection preparation, AD compliance, FAA maintenance requirements, return to service

    Regulatory context: FAA

    Image search: aircraft maintenance hangar inspection

  • Aircraft Squawk List: What It Is, Why It Matters, and How to Manage Defects in Shared Aircraft

    Aircraft Squawk List: What It Is, Why It Matters, and How to Manage Defects in Shared Aircraft

    Aircraft Squawk List: What It Is, Why It Matters, and How to Manage Defects in Shared Aircraft

    Meta description: Learn what an aircraft squawk list is, how to manage maintenance defects under FAA and EASA rules, and why proper tracking matters for airworthiness.

    Every shared aircraft develops its quirks. A sticky trim wheel. An intermittent nav light. A door seal that whistles above 120 knots. The question isn’t whether defects will appear—it’s whether they get recorded, communicated, and resolved before they ground the aircraft or compromise safety. If you co-own or operate a GA aircraft with other pilots, a poorly managed aircraft squawk list creates real risk: missed defects, duplicated work, regulatory exposure, and the slow erosion of trust between partners.

    Two Meanings of “Squawk” — and Why It Matters

    The word “squawk” trips up even experienced pilots because it has two completely different meanings in aviation.

    The first meaning is the transponder code assigned by ATC. “Squawk 4521” means dial that code into your transponder. This usage comes from the early days of IFF (Identification Friend or Foe) systems and has nothing to do with maintenance.

    The second meaning—the one this article addresses—refers to a reported defect or discrepancy on an aircraft. When a pilot writes up a squawk, they’re documenting something wrong: a malfunction, damage, or abnormal behaviour observed during preflight or flight. This usage likely derives from the idea of the aircraft “complaining” about something.

    The confusion matters because when pilots discuss “squawks” without context, they may be talking past each other. In maintenance conversations, an aircraft maintenance squawk is a documented defect requiring evaluation and possible action before the next flight. That’s what belongs on your squawk sheet aviation log—not transponder codes.

    Throughout this article, “squawk” means a maintenance defect unless otherwise noted.

    What Belongs on a Squawk List

    A squawk list is a running record of known defects, discrepancies, and deferred maintenance items for a specific aircraft. It serves three functions: communication between pilots, documentation for maintenance, and evidence of airworthiness decision-making.

    Items that belong on a squawk list:

    • Malfunctions observed in flight (autopilot disconnect, rough mag, fuel gauge inaccuracy)
    • Damage found during preflight (dents, cracks, fluid leaks, tyre wear)
    • Inoperative equipment (landing light, intercom, one side of heated pitot)
    • Abnormal behaviours (high oil consumption, trim out of rig, unusual vibration)
    • Pending maintenance discovered by a shop but not yet completed
    • Discrepancies noted during annual or 100-hour inspections that were deferred

    Items that don’t belong:

    • Routine consumables tracking (oil changes, tyre replacements on schedule)
    • Cosmetic preferences (“interior looks dated”)
    • ATC-assigned transponder codes
    • Modifications you’d like to make but aren’t defects

    The purpose of a squawk list is reporting aircraft defects—things that deviate from the aircraft’s type design, approved data, or normal operation. If it’s working as designed, it’s not a squawk.

    Classifying Defects by Airworthiness Impact

    Not all squawks are equal. A burned-out courtesy light is not the same as a cracked exhaust stack. Effective squawk management requires classification by airworthiness impact—and this is where regulations provide structure.

    FAA framework (14 CFR Part 91)

    Under Part 91, the pilot in command is responsible for determining whether the aircraft is airworthy before flight. FAA regulations don’t prescribe a formal defect classification system for Part 91 operators, but they do establish clear boundaries:

    • Required equipment must be operative (per 91.205, 91.213, and the aircraft’s equipment list)
    • Known defects affecting airworthiness must be corrected before flight
    • Inoperative equipment may be deferred under 91.213 if it’s not required and is either removed or placarded

    Practically, this means you need to evaluate each squawk against the minimum equipment requirements. A Cessna 172 VFR day flight doesn’t require a working autopilot. It does require a working altimeter.

    EASA framework (Part-ML for ELA1/ELA2 aircraft)

    Part-ML provides more explicit guidance. Under ML.A.301, aircraft must be maintained in a condition of continuing airworthiness. Under ML.A.403, defects must be recorded in the continuing airworthiness records, and the pilot/owner must ensure defects are rectified by appropriately qualified persons.

    For aircraft under an AMP (Airworthiness Review Certificate programme), Part-ML.A.305 addresses the handling of defects. While owner-operators of simpler aircraft have some flexibility, the principle remains: known defects must be documented, assessed for airworthiness impact, and either rectified or appropriately deferred before flight.

    A practical classification system:

    1. Grounding defects — Aircraft cannot fly until rectified (e.g., cracked propeller blade, inoperative pitot heat for IMC flight)
    2. Deferrable items — Can be deferred under MEL/CDL or equivalent process (e.g., inoperative dome light)
    3. Monitor items — Not yet defective but trending (e.g., increasing oil consumption within limits)

    Every squawk should carry a classification. Without it, the next pilot has no basis for a go/no-go decision.

    Who Actions Squawks — and When

    In a single-owner operation, responsibility is simple: you find it, you own it. In shared aircraft, ambiguity kills.

    The pilot who discovers the defect is responsible for:

    • Recording it immediately with enough detail for the next pilot and the mechanic to understand
    • Making an initial airworthiness assessment (can this aircraft fly legally and safely?)
    • Communicating it to co-owners/operators without delay

    The owner or operator organisation is responsible for:

    • Ensuring the defect is evaluated by someone competent to assess airworthiness impact
    • Arranging maintenance action within an appropriate timeframe
    • Updating records when the defect is rectified
    • Making the entry in the aircraft’s technical log or equivalent

    Under FAA Part 91, the PIC has final authority and responsibility for each flight. Under EASA Part-ML, the owner bears continuing airworthiness responsibility but the pilot retains flight-by-flight authority.

    The failure mode in most partnerships isn’t hostility—it’s assumption. Pilot A assumes Pilot B saw the note. Pilot B assumes Pilot A is handling it. The defect persists unrectified through multiple flights.

    Why Group Chats and Sticky Notes Fail

    Most co-ownership groups start with informal systems: a WhatsApp thread, a shared Google Doc, a notepad in the aircraft. These work—until they don’t.

    Common failure modes:

    • Messages get buried. A squawk reported on Tuesday is invisible under Thursday’s fuel price discussion.
    • No audit trail. When did this defect first appear? Who reported it? Was it ever actioned? Group chats don’t answer these questions.
    • Ambiguous status. “I mentioned the mag drop to Dave” is not the same as a documented, classified, tracked defect.
    • No integration with maintenance records. The squawk list lives in one place; the logbooks live in another. Reconciliation requires manual effort that rarely happens.
    • Sticky notes disappear. Rain, wind, curious passengers, and time all destroy paper left in cockpits.

    A proper defect tracking system isn’t bureaucracy for its own sake. It’s the difference between “we have a maintenance culture” and “we have a maintenance crisis we don’t know about yet.”

    For airworthiness, what matters is demonstrable evidence that defects are identified, assessed, communicated, and resolved. Regulators auditing your records—and insurers investigating claims—won’t accept “we talked about it in the group chat.”

    What Happens If a Known Defect Isn’t Actioned

    Here’s where informal systems become legal exposure.

    Under FAA regulations, operating an aircraft with a known defect that renders it unairworthy violates 14 CFR 91.7: “No person may operate a civil aircraft unless it is in an airworthy condition.” The PIC who flew it bears primary responsibility, but owners can face enforcement action for failing to maintain airworthiness.

    Under EASA Part-ML, the registered owner or operator holds continuing airworthiness responsibility. Flying with a known unresolved defect affecting airworthiness can trigger certificate action, and in the event of an incident, both civil liability and potential criminal exposure.

    Insurance implications are equally serious. Most hull and liability policies contain airworthiness warranties. If an accident investigation reveals a known, unaddressed defect, underwriters may deny coverage entirely. “We knew about it but didn’t fix it” is among the worst possible findings.

    The legal standard isn’t “we planned to fix it.” It’s “was the aircraft airworthy at the time of operation.” A documented squawk that wasn’t actioned is evidence against you.

    How Squawkd Helps

    Squawkd’s defect tracking feature gives co-owners a single, auditable location for reporting aircraft defects—visible to all operators immediately, with status tracking from report through resolution. Each squawk is timestamped, attributed, and linked to the aircraft’s maintenance records, eliminating the ambiguity that informal systems create.

    Frequently Asked Questions

    Q: How long can a squawk remain open before it must be fixed?

    There’s no universal time limit. The determining factor is airworthiness impact. A grounding defect must be rectified before the next flight. A deferrable item—if properly documented under MEL procedures or equivalent—may remain open for a defined period or number of flights. A monitor item may persist indefinitely with appropriate tracking. What matters is that someone with appropriate authority has made a documented airworthiness determination, and that determination is communicated to all pilots before they fly.

    Q: Who is legally responsible if I fly with a known defect: the owner or the pilot?

    Both may bear responsibility, but for different things. Under FAA Part 91, the PIC is responsible for determining airworthiness before each flight and cannot delegate that responsibility. Under EASA Part-ML, the registered owner bears continuing airworthiness obligations. In practice, if you’re a co-owner who also flies the aircraft, you may be exposed on both fronts. This is precisely why documented defect tracking matters—it establishes who knew what and when.

    Q: Can I just placard something inoperative and keep flying?

    Under FAA 91.213, yes—if specific conditions are met. The item must not be required by the aircraft’s type certificate, the regulations (91.205), airworthiness directives, or the aircraft’s minimum equipment list or kinds of operations equipment list. It must then be either removed and the removal documented, or deactivated and placarded “Inoperative.” EASA has similar provisions under Part-ML, though owner-operators should confirm the specific procedures applicable to their aircraft category. Placarding without meeting these conditions does not render the aircraft airworthy.

    Tags: squawk list, aircraft defects, GA maintenance, co-ownership, airworthiness, EASA Part-ML, FAA Part 91

    Regulatory context: Both

    Image search: general aviation aircraft maintenance hangar

  • How to Find and Track Airworthiness Directives for Your Aircraft: A Step-by-Step Guide

    How to Find and Track Airworthiness Directives for Your Aircraft: A Step-by-Step Guide

    How to Find and Track Airworthiness Directives for Your Aircraft: A Step-by-Step Guide

    Meta description: Learn how to search FAA and EASA airworthiness directives for your aircraft by make, model, and serial number, plus track AD compliance effectively.

    You’re responsible for knowing which airworthiness directives apply to your aircraft. Miss one, and you’re flying an unairworthy aircraft—regardless of whether the oversight was innocent. The problem: ADs are scattered across multiple databases, issued by different authorities, and the applicability criteria can be buried in technical language. This guide walks you through the exact process for finding every AD that affects your aircraft and keeping track of compliance status over time.

    What Airworthiness Directives Are and Why They’re Mandatory

    Airworthiness directives are legally binding requirements issued when a safety defect is identified in a type-certificated product—aircraft, engine, propeller, or appliance. They’re not recommendations. Under FAA regulations (14 CFR 39.7), no person may operate a product to which an AD applies unless the requirements of that AD have been met. EASA takes the same position under Part-M, M.A.303: the aircraft is not airworthy if applicable ADs aren’t complied with.

    ADs typically require one of three actions: a one-time inspection, a repetitive inspection at specified intervals, or a modification that terminates the recurring requirement. Some ADs give you options—you might be able to install a superseding modification instead of continuing repetitive inspections.

    The critical point: AD applicability is determined by the type certificate holder’s design, but the compliance burden falls entirely on the owner/operator. Your maintenance organization will implement the AD, but you’re the one who needs to ensure it gets done. If you’re operating under owner-approved maintenance programs, this responsibility is even more direct.

    ADs aren’t retroactive in terms of timing—you don’t suddenly owe back-compliance when a new AD drops—but they apply immediately to aircraft that meet the applicability criteria. An AD issued today that applies to your aircraft serial number becomes a compliance requirement today, even if the underlying condition has existed since manufacture.

    How to Search the FAA Airworthiness Directive Database

    The FAA maintains its AD database through the Regulatory and Guidance Library at drs.faa.gov. Here’s the exact process for finding airworthiness directives aircraft owners need to track:

    Step 1: Access the correct search interface. Navigate to rgl.faa.gov, select “Airworthiness Directives” from the document types. You’ll see search options for aircraft, engine, propeller, and appliance ADs.

    Step 2: Search by type certificate data sheet (TCDS) criteria. For aircraft ADs, enter your make and model exactly as it appears on your TCDS—not the marketing name. A Cessna 172S is listed under “Cessna” (make) and “172S” (model), not “Skyhawk.” The database is literal.

    Step 3: Filter by applicability. Results will show all ADs ever issued for that type certificate. Many won’t apply to your specific aircraft because of serial number ranges, modification status, or component part numbers. Read the Applicability section of each AD carefully. An AD for “Model 172S aircraft, serial numbers 172S8001 through 172S9500” doesn’t apply to serial number 172S10200.

    Step 4: Check for superseding ADs. ADs can be amended or superseded. If AD 2019-15-06 was superseded by AD 2022-03-11, you comply with the newer one—but you need to verify whether previous compliance actions count or whether additional steps are required.

    Step 5: Don’t forget engine and propeller ADs. Your FAA airworthiness directive search must include the powerplant. Search separately for your engine type (e.g., Lycoming IO-360-L2A) and propeller (e.g., McCauley 1A170/GM8235). These ADs are filed under the engine or propeller manufacturer, not your aircraft manufacturer.

    Step 6: Document your search. Record the date you searched, the search parameters, and the results. If an AD doesn’t apply because of serial number exclusion, note that with the specific exclusion language. This documentation becomes part of your airworthiness argument.

    How to Search the EASA AD Portal for European Compliance

    EASA maintains a dedicated AD portal at ad.easa.europa.eu. The process differs from the FAA system:

    Step 1: Understand the dual-AD environment. EASA may issue its own ADs for products type-certificated in Europe, but it also mandates compliance with ADs from the State of Design. For a U.S.-manufactured aircraft operating on an EASA registration, you typically need to comply with both FAA ADs (as the State of Design authority) and any EASA ADs issued for that type.

    Step 2: Search by type certificate holder. The EASA portal organizes ADs by the TC holder name. For Cirrus aircraft, search under “Cirrus Design Corporation.” For older Cessna models, you may need to search historical TC holder names.

    Step 3: Use the advanced filtering options. The EASA portal allows filtering by aircraft model, AD status (current, superseded, cancelled), and publication date range. Use these to narrow results to currently effective ADs.

    Step 4: Check EASA AD status classifications. EASA ADs show applicability to aircraft on EU registries. If you’re operating a U.S.-manufactured aircraft on an EASA registry, verify whether the EASA AD adds requirements beyond the FAA AD or simply adopts it. Sometimes EASA sets different compliance timeframes.

    Step 5: Review the National Aviation Authority position. Some NAAs issue additional guidance on AD compliance. Your local authority (CAA, DGAC, LBA, etc.) may have specific interpretations or approved alternative methods of compliance. Check their publications alongside the EASA AD compliance requirements.

    Building Your AD Compliance List and Tracking Status

    Once you’ve identified all applicable ADs, you need a system to track compliance status. Here’s what that system must capture:

    For each applicable AD, document: the AD number, issue date, effective date, subject description, applicability statement (why it applies to your aircraft), compliance requirement (one-time, recurring, or terminated by modification), compliance status (open, complied, or not applicable), compliance evidence (work order, logbook entry, part number of installed modification), and next action due (for recurring requirements).

    Organize by compliance category. Group ADs into: complied one-time (no further action), complied recurring (track next due), open (action required before next flight or by calendar/hours deadline), and not applicable (document the exclusion reason).

    Review the list after any maintenance. When a component is replaced, check whether the new part changes AD applicability. Installing a replacement fuel pump with a different part number might bring new ADs into scope—or might comply with an AD terminating action.

    Cross-reference with Service Bulletins. Many ADs reference manufacturer Service Bulletins as the compliance method. Track SB status alongside AD status. Some SBs become mandatory via AD; others remain optional but affect AD applicability if accomplished. For more background on the relationship between these documents, see our overview of finding airworthiness directives.

    Audit before annual/100-hour inspections. Provide your IA or maintenance organization with your current AD list and compliance status before the inspection. This lets them verify your records against their search and flag any discrepancies. It also demonstrates you’re meeting your owner obligations under Part-91 or Part-ML.

    How Squawkd Helps

    Squawkd’s compliance tracker lets you import your aircraft’s AD list and set alerts for recurring inspection deadlines. The platform links compliance records directly to maintenance log entries, so you’re not reconciling spreadsheets against paper logbooks.

    Frequently Asked Questions

    Q: How often are new airworthiness directives issued for GA aircraft?

    The FAA issues roughly 300-400 ADs per year across all product categories, with a smaller subset affecting GA piston aircraft. EASA’s output varies but follows a similar pattern. New ADs can appear at any time—there’s no fixed schedule. Set up RSS feeds or email alerts from both rgl.faa.gov and ad.easa.europa.eu to catch new issuances relevant to your type. Checking monthly is a reasonable minimum for a GA owner.

    Q: What happens if I discover an AD wasn’t complied with before I bought the aircraft?

    The aircraft is technically unairworthy until the AD is complied with. You cannot legally fly it to maintenance—you’ll need to arrange compliance at the aircraft’s current location or obtain a ferry permit. For pre-purchase, this is why AD compliance verification is a standard part of any competent pre-buy inspection. If you missed it, address it now and document the correction in your maintenance records.

    Q: Can my mechanic sign off an AD compliance, or does it require an IA?

    Depends on the work required. If the AD calls for an inspection that doesn’t require disassembly beyond normal servicing, an A&P can perform and sign off the work under Part 43.3. If the AD requires an approval for return to service after a major repair or alteration, you’ll need an IA signoff. EASA rules differ—work must be performed under an approved maintenance organization structure as defined in your aircraft’s continuing airworthiness management arrangements.

    Tags: airworthiness directives, AD compliance, FAA AD search, EASA regulations, aircraft maintenance tracking, regulatory compliance, GA ownership

    Regulatory context: Both

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  • Aircraft Co-Ownership Costs: A Practical Guide to Splitting Expenses Fairly

    Aircraft Co-Ownership Costs: A Practical Guide to Splitting Expenses Fairly

    Aircraft Co-Ownership Costs: A Practical Guide to Splitting Expenses Fairly

    Meta description: Learn how to split aircraft co-ownership costs fairly using fixed/variable models, maintenance reserves, and written agreements that prevent disputes.

    You found a partner to share ownership of a Cessna 182 or a Piper Cherokee. The purchase price is sorted. Now comes the question that breaks more syndicates than mechanical failures ever will: who pays what, and when? Most co-ownership arrangements start with a handshake and end with a lawyer. The difference between the two outcomes is almost always a clear, written cost structure agreed upon before the first shared flight. This guide covers exactly how to build one.

    The Fixed vs. Variable Cost Model

    Aircraft expenses divide naturally into two categories. Understanding this split is the foundation of any fair shared aircraft expenses arrangement.

    Fixed costs exist whether the aircraft flies or not:

    • Hangar or tie-down fees
    • Hull and liability insurance premiums
    • Annual inspection labor (under FAA Part 91) or the ARC renewal and associated maintenance review (under EASA Part-ML)
    • Database subscriptions (charts, terrain, traffic)
    • Registration and airworthiness fees
    • Property taxes (jurisdiction-dependent)

    Variable costs scale with flight time:

    • Fuel
    • Oil
    • Engine reserve (toward overhaul)
    • Propeller reserve
    • Consumables (filters, brake pads, tires)

    The standard aircraft syndicate cost split works like this: fixed costs are divided equally among all owners regardless of hours flown. Variable costs are charged to whoever burned them.

    This model survives because it reflects economic reality. The hangar doesn’t cost less because you flew to Portland while your partner stayed home. The insurance premium doesn’t drop because one owner logged 80 hours last year and another logged 20.

    Why Equal Fixed Splits Make Sense

    Some new co-owners propose splitting everything by hours flown, including fixed costs. This creates problems:

    1. Unpredictability. You can’t budget monthly expenses when they depend on your partner’s flying habits.
    2. Perverse incentives. Owners who fly less start resenting those who fly more—even though higher utilization often benefits the aircraft mechanically.
    3. Administrative burden. Every month becomes an accounting exercise.

    Equal fixed splits, combined with per-hour variable charges, give each owner predictable baseline costs while ensuring heavy users pay their fair share of wear.

    The Maintenance Reserve Structure

    Here’s where most co-owner aircraft agreements fail to go deep enough. They’ll specify fuel is paid per hour but say nothing about the $30,000 engine overhaul that arrives at 2,000 hours.

    A maintenance reserve solves this by collecting funds incrementally. Each Hobbs hour flown triggers a contribution to a shared reserve account. When major maintenance comes due, the money is already there.

    Calculating Your Reserve Rate

    Start with expected overhaul and replacement costs, then divide by the relevant TBO or service life:

    | Component | Estimated Cost | Service Life | Reserve per Hour |
    |———–|—————-|————–|——————|
    | Engine overhaul | $30,000 | 2,000 hours | $15.00 |
    | Propeller overhaul | $4,000 | 2,000 hours | $2.00 |
    | Avionics refresh | $8,000 | 10 years (~500 hrs) | $16.00 |

    A typical four-seat piston single might run $25–$40 per Hobbs hour in reserves alone, on top of fuel and oil.

    Some syndicates maintain separate reserve accounts for engine, propeller, and avionics. Others pool everything. Either works if it’s documented. What doesn’t work: assuming everyone will simply contribute equally when the overhaul bill arrives. That’s when you discover one owner is between jobs and another thinks the engine “should easily make it to 2,400 hours.”

    Under EASA: AMP Considerations

    If you’re operating under EASA Part-ML, your Aircraft Maintenance Programme (AMP) dictates the inspection schedule. [VERIFY: Part-ML.A.302 — confirm AMP requirements for non-complex aircraft in current regulation] The AMP may call for additional scheduled maintenance beyond what a simple TBO-based reserve covers. Build your reserve model around your specific AMP, not generic assumptions.

    Under FAA: Annual Inspection Reality

    Part 91 aircraft require an annual inspection, but “annual” is a floor, not a ceiling. Any competent A&P will generate a squawk list. Budget $2,000–$5,000 annually for inspection labor plus discovered discrepancies on a well-maintained four-seat single. This should be a fixed cost split equally—everyone benefits from a maintained aircraft.

    When One Owner Flies More Than Others

    This is the scenario that generates the most resentment. Owner A flies 150 hours per year. Owner B flies 30. Both pay equal fixed costs. Is that fair?

    Yes—if your agreement was structured correctly from the start.

    Owner A is paying significantly more in total because they’re covering five times the fuel, oil, and reserve contributions. Owner B is paying a higher cost per hour, but that’s a consequence of their choice to fly less, not a flaw in the agreement.

    The friction arises when this isn’t explicit. Owner B thinks, “I’m paying $400 per month for an aircraft I barely use.” Owner A thinks, “The aircraft is cheaper for me because I fly a lot.” Both are correct. Neither understood the math before signing.

    Minimum Usage Fees: A Controversial Option

    Some syndicates implement minimum monthly hours. If you don’t fly at least 5 hours per month, you still pay the variable rate as if you did. This protects against partners who rarely fly but consume scheduling availability.

    The counterargument: minimum fees punish owners for weather, work travel, or family obligations. A better approach is honest discussion during formation. If someone intends to fly only 40 hours per year, everyone should know that before signing. It affects reserve accumulation, scheduling conflict frequency, and eventually, exit scenarios.

    Exit Provisions

    Speaking of exits: what happens when Owner B decides the cost-per-hour math doesn’t work for them? A good co-owner aircraft agreement specifies:

    • Right of first refusal for remaining owners
    • Valuation method (appraisal, agreed formula, or average of two independent valuations)
    • Timeline for buyout execution
    • What happens to reserve account balances (typically, departing owner is refunded their contributed share minus any outstanding obligations)

    Without these terms written down, you’re heading for a dispute that costs more than the aircraft is worth.

    Why Written Agreements Prevent Syndicate Breakdowns

    The absence of a written cost agreement is the single greatest predictor of syndicate failure. Not personality conflicts. Not scheduling disputes. The lack of a document that says exactly what happens when predictable scenarios occur.

    Every fractured syndicate has a story that sounds like this: “We agreed fuel was shared, but then he started doing touch-and-goes for three hours and I didn’t think I should pay for his practice.” Or: “The annual came in at $6,000 instead of $3,000 and nobody had the cash.” Or: “He sold his share to some guy I’d never fly with.”

    A written agreement doesn’t prevent disagreements. It provides a resolution mechanism that doesn’t involve litigation.

    Minimum Agreement Contents

    Your co-ownership agreement should specify, at minimum:

    1. Ownership percentages and how they affect voting on major decisions
    2. Fixed cost allocation and payment schedule
    3. Variable cost rates and how they’re calculated
    4. Reserve structure, target balances, and what happens if contributions fall behind
    5. Scheduling rules, including how conflicts are resolved
    6. Maintenance authority: who can authorize repairs and up to what dollar amount without group approval
    7. Insurance requirements, including minimum pilot qualifications for coverage
    8. Exit provisions as described above
    9. Dispute resolution mechanism (mediation before litigation is standard)
    10. Amendment process for changing the agreement itself

    Don’t rely on templates alone. Have an aviation attorney review your agreement. $500 in legal fees now prevents $15,000 in legal fees later.

    How Squawkd Helps

    Squawkd’s cost-sharing tools let co-owners track fixed and variable expenses against each partner’s usage automatically. When someone logs a flight, the system calculates their share of fuel, reserves, and consumables—then makes that visible to all owners. Transparent accounting reduces the conversations that become arguments.

    Frequently Asked Questions

    Q: How much should we budget per hour for maintenance reserves on a typical piston single?

    Plan for $25–$40 per Hobbs hour depending on your engine, propeller, and avionics stack. Continental and Lycoming overhauls run $25,000–$35,000 at TBO. Older airframes with aging avionics trend higher. Review your specific component times and condition before setting rates—a mid-time engine needs less reserve per hour than one approaching TBO.

    Q: Should insurance be split equally or based on flight hours?

    Split it equally. Insurance premiums are fixed costs that exist regardless of who flies. The premium is calculated based on hull value, coverage limits, and the pilot qualifications of all named insureds—not anticipated hours per owner. The owner who flies 100 hours doesn’t create more insurance cost than the owner who flies 25.

    Q: What happens if one co-owner can’t pay their share of an unexpected repair?

    This is exactly why your written agreement needs teeth. Common provisions include: a grace period (30 days) to pay, interest on overdue balances, suspension of flying privileges until current, and eventually forced sale of the non-paying owner’s share to remaining partners at a defined valuation. Decide this before it happens.

    Tags: aircraft co-ownership, syndicate cost sharing, maintenance reserves, co-owner agreements, partnership flying, shared aircraft expenses, aircraft operating costs

    Regulatory context: Both

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  • The EASA Airworthiness Review Certificate: What Private Owners Need to Know Before Renewal

    The EASA Airworthiness Review Certificate: What Private Owners Need to Know Before Renewal

    The EASA Airworthiness Review Certificate: What Private Owners Need to Know Before Renewal

    Meta description: Understand the EASA airworthiness review certificate renewal process, who can issue your ARC, and how to prepare for inspection.

    Your ARC expires in a few weeks. You’ve been flying all year, the aircraft feels fine, and now someone needs to confirm it’s still airworthy. But what exactly are they checking? What documents do you need ready? And what happens if they find something wrong? If you’ve been self-managing under Part-ML, the ARC renewal can feel like an exam you didn’t study for. This guide explains what the process involves, what trips owners up, and how to approach it prepared.

    What the Airworthiness Review Certificate Actually Is

    The Airworthiness Review Certificate is EASA’s mechanism for confirming that an aircraft remains in compliance with its approved maintenance programme and applicable airworthiness requirements. It’s not a one-time certification—it’s a recurring validation that your aircraft continues to meet the conditions under which it was originally certified.

    Under EASA Part-ML (which governs continuing airworthiness for most privately operated GA aircraft), the ARC serves as documented evidence that someone qualified has reviewed your aircraft’s airworthiness status within the required timeframe. Without a valid ARC, your aircraft cannot legally fly—even if every component is working perfectly.

    The certificate itself states the aircraft registration, the date of issue, and the expiry date. It confirms that on the date of review, the aircraft was found airworthy in accordance with the applicable regulations.

    Think of it as the aircraft equivalent of your medical certificate. The aircraft might be healthy, but you need the paperwork to prove someone qualified has checked.

    Who Can Issue an ARC and How Long It Lasts

    For aircraft operating under Part-ML, an ARC can be issued by:

    1. A Continuing Airworthiness Management Organisation (CAMO) — These are organisations approved under Part-CAMO or Part-CAO to manage continuing airworthiness. They can issue ARCs as part of their contracted management of your aircraft.

    2. Airworthiness review staff — Under Part-ML.A.903, qualified individuals who hold appropriate airworthiness review authorisation can conduct the review and issue the ARC. These are typically independent engineers or inspectors authorised by your National Aviation Authority (NAA).

    3. The competent authority itself — In some cases, your NAA can conduct the airworthiness review directly, though this is less common for routine renewals.

    An ARC is valid for 12 months from the date of issue. However, there’s an important nuance: if you complete your airworthiness review within the 90 days before your current ARC expires, the new certificate validity runs from the expiry date of the old one—not from the review date. This prevents you from losing months of validity by renewing early.

    The Two-Extension Rule

    Here’s where Part-ML differs from the older Part-M framework in an important way.

    Under Part-ML.A.901(c), if your aircraft is managed by a CAMO (or CAO with airworthiness review staff privileges), that organisation can extend your ARC twice, each time by 12 months, without requiring a full airworthiness review.

    This means a CAMO-managed aircraft could theoretically fly for up to three years on extensions before requiring a complete airworthiness review with physical inspection. The extensions are not automatic—the CAMO must still verify continuing airworthiness status through their management system—but they don’t require the full document review and physical survey that an initial issue or third renewal demands.

    Important limitation: If you’re self-managing under Part-ML (not using a CAMO), you cannot extend your own ARC. You must have a full airworthiness review conducted each year by authorised airworthiness review staff or your competent authority.

    This is one of the key decision points for owners: CAMO management adds cost but can simplify renewals. Self-management gives you control but requires annual reviews.

    What an Airworthiness Review Involves

    An airworthiness review has two components: a documentation review and a physical inspection of the aircraft.

    Documentation Review

    The reviewing staff will examine your aircraft records to verify:

    • Maintenance programme compliance — Has all maintenance required by your approved Aircraft Maintenance Programme (AMP) been completed? This includes scheduled inspections (annual, 50-hour, 100-hour, whatever your programme specifies), component life limits, and calendar-based tasks.
    • Airworthiness Directives (ADs) — Have all applicable ADs been complied with, either through completion or through an approved alternative means of compliance? The reviewer will check your AD status against the current applicable AD list for your aircraft type, engine, propeller, and installed equipment.
    • Service Bulletin status — While most SBs are not mandatory, some become mandatory through ADs or through your maintenance programme. The reviewer may check that you’re tracking these appropriately.
    • Weight and balance — Is your current weight and balance report accurate and up to date?
    • Modifications and repairs — Have all modifications been approved and documented correctly? Have repairs been signed off with appropriate release certificates?
    • Release to service documentation — Are your maintenance entries complete, legible, and signed by appropriately authorised personnel?
    • Component documentation — For life-limited or hard-time components, can you demonstrate traceability and remaining life?

    Physical Inspection

    The physical survey isn’t a full maintenance inspection—it’s a verification that the aircraft condition matches what the documentation claims. The reviewer will check:

    • General condition of the airframe, control surfaces, and visible structure
    • Evidence of damage, corrosion, or deterioration
    • Security of panels, cowlings, and access doors
    • Condition of tyres, brakes, and landing gear
    • Visible fluid leaks
    • Correct placards and markings
    • That the aircraft configuration matches the approved data (no undocumented modifications)

    The physical inspection typically takes one to three hours depending on aircraft complexity. The reviewer needs reasonable access—clean aircraft, panels accessible, logbooks available.

    Common Reasons an ARC Is Refused or Findings Are Raised

    ARC reviews don’t always go smoothly. Here are the issues that most commonly cause problems:

    Incomplete maintenance records — Missing signatures, illegible entries, maintenance performed but not properly documented. The work might have been done correctly, but if the paperwork doesn’t prove it, the reviewer cannot accept it.

    Overdue scheduled maintenance — Tasks in your AMP that have exceeded their interval. This is particularly common with calendar-based items that don’t correlate with flight hours.

    AD non-compliance — Either an AD wasn’t completed, wasn’t documented, or the documented compliance doesn’t match current requirements. AD statuses change—repeating inspections get superseded, new ADs get issued. Your AD tracking needs to be current.

    Configuration discrepancies — Equipment installed that isn’t on the approved equipment list, or modifications without proper approval documentation.

    Component life exceedances — Life-limited parts that have exceeded their approved life, or parts where the documentation can’t establish remaining life.

    Physical condition issues — Corrosion, damage, or wear that should have been addressed through maintenance but wasn’t.

    When findings are raised, you have options. Minor documentation issues can sometimes be resolved during the review. More significant findings require corrective action before the ARC can be issued. In some cases, you may need to complete maintenance before the aircraft can return to service.

    [VERIFY: Part-ML.A.903(a) — confirm current wording on findings resolution requirements]

    CAMO-Managed Versus Self-Managed: Which Approach Suits You?

    The choice between CAMO management and self-management under Part-ML is fundamentally about how much of the airworthiness management burden you want to carry yourself.

    Self-Managing Under Part-ML

    You’re responsible for:

    • Maintaining your own AMP (or using the Minimum Inspection Programme)

    • Tracking all scheduled maintenance, ADs, and component lives

    • Arranging annual airworthiness reviews with authorised staff

    • Maintaining complete and current aircraft records

    Advantages: Lower ongoing cost, direct control over your aircraft’s maintenance management, no dependency on a third party’s administrative processes.

    Disadvantages: Annual ARC reviews required (no extension option), all tracking responsibility falls on you, any gaps in your system become your problem at ARC time.

    CAMO Management

    The CAMO takes contractual responsibility for:

    • Monitoring your maintenance programme compliance

    • Tracking ADs and scheduling maintenance

    • Issuing ARC extensions (up to two consecutive years)

    • Maintaining airworthiness status oversight

    Advantages: ARC extensions reduce administrative burden, professional oversight catches issues before they become ARC problems, reduced owner workload.

    Disadvantages: Ongoing management fees, less direct control, dependent on CAMO’s responsiveness and accuracy.

    For owners who fly frequently, track their own maintenance meticulously, and are comfortable with regulatory requirements, self-management works well. For owners who want airworthiness management handled professionally—or who have complex aircraft with extensive tracking requirements—CAMO management may justify the cost.

    How Squawkd Helps

    Squawkd’s maintenance tracking automatically monitors your AMP compliance, AD status, and component life limits against your actual flight hours and calendar time. When your ARC review approaches, you can generate a complete airworthiness status summary showing exactly what’s been done and what’s coming due—giving your reviewer everything they need in one place.

    Frequently Asked Questions

    Q: Can I fly my aircraft if my ARC has expired?

    No. An aircraft without a valid ARC is not considered airworthy under EASA regulations, regardless of its physical condition or maintenance status. You must complete an airworthiness review and obtain a new ARC before flight. If your ARC lapses, the subsequent review may also require additional verification that no unauthorised flights occurred during the invalid period.

    Q: How early can I renew my ARC without losing validity time?

    If your airworthiness review is completed within 90 days before your current ARC expiry date, the new ARC validity period starts from your old expiry date rather than the review date. This means renewing up to three months early costs you nothing in terms of validity. Renewing earlier than 90 days out will result in a new 12-month validity starting from the review date.

    Q: What’s the difference between an ARC and a Certificate of Airworthiness?

    Your Certificate of Airworthiness (CofA) is the original certification that your aircraft meets type design standards—it’s issued once and remains valid indefinitely (for standard CofAs) as long as the aircraft remains airworthy. The ARC is the periodic verification that your aircraft continues to meet airworthiness requirements. Think of the CofA as proving the aircraft was built correctly; the ARC proves it’s been maintained correctly.

    Tags: ARC renewal, EASA Part-ML, airworthiness review, continuing airworthiness, aircraft maintenance programme, CAMO management, GA aircraft compliance

    Regulatory context: EASA

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  • EASA Airworthiness Review Certificate: The Complete Guide for Private Owners

    EASA Airworthiness Review Certificate: The Complete Guide for Private Owners

    EASA Airworthiness Review Certificate: The Complete Guide for Private Owners

    Meta description: Learn what the EASA airworthiness review certificate covers, how the ARC renewal process works, and what documents you need to prepare.

    Your ARC expires in eight weeks. You know the aircraft needs a review before you can legally fly it again, but the specifics are hazy. What exactly will the reviewing engineer inspect? Which documents do you need to have ready? And what happens if something in your maintenance records doesn’t add up? This guide covers exactly what private owners need to know about the EASA airworthiness review certificate—no padding, just the information you need to prepare properly.

    What the Airworthiness Review Certificate Actually Is

    The Airworthiness Review Certificate is the document that confirms your aircraft remains in compliance with its type design and is safe to operate. Without a valid ARC, your aircraft cannot fly under EASA regulations—full stop. It’s the regulatory mechanism that forces a periodic verification of your aircraft’s continuing airworthiness status.

    The ARC is governed primarily by Part-ML for aircraft used in non-commercial operations (which covers most private owners), specifically ML.A.901 through ML.A.905. For aircraft under Part-M (typically commercial or more complex operations), the equivalent requirements sit in M.A.901 and related sections.

    The certificate itself is EASA Form 15c for Part-ML aircraft. It states the aircraft registration, the date of issue, the expiry date, and confirms that at the time of review, the aircraft was found airworthy in accordance with the applicable requirements.

    One critical point: the ARC is not a maintenance release. It doesn’t replace the Certificate of Release to Service after maintenance work. It’s a separate, higher-level confirmation that looks at the complete airworthiness picture—maintenance records, modifications, ADs, life-limited components, and the physical condition of the aircraft.

    Who Can Issue an ARC and How Long It Lasts

    For private owners operating under Part-ML, two routes exist for ARC issuance and renewal:

    Route 1: CAMO or CAO
    A Continuing Airworthiness Management Organisation (CAMO) or Combined Airworthiness Organisation (CAO) with the appropriate privilege can issue and renew your ARC. They take responsibility for verifying the complete airworthiness status.

    Route 2: Appropriately Qualified Personnel
    Under Part-ML, certain licensed engineers can conduct airworthiness reviews and issue or extend ARCs. Specifically, ML.A.903 permits licensed certifying staff holding a Part-66 licence with appropriate type rating, or personnel specifically authorised by the competent authority, to perform this function for ELA1 and ELA2 aircraft. [VERIFY: ML.A.903(1) — confirm current scope of personnel privileges for ARC issuance]

    The validity period is straightforward: 12 months from the date of issue. The expiry date is printed on the certificate. Flying with an expired ARC means flying an aircraft that is not legally airworthy under EASA rules.

    The Two-Extension Rule

    Here’s where many owners get confused. An ARC can be extended twice—each extension adding 12 months—without requiring a full airworthiness review, provided certain conditions are met. After two extensions, a full review is mandatory.

    The conditions for extension under ML.A.901(c) include:

    • The aircraft has been maintained by an appropriately approved organisation or certifying staff

    • No airworthiness issues have been identified that would affect the aircraft’s continued airworthiness

    • The person extending the ARC has verified the maintenance records and confirmed compliance

    This means your ARC can theoretically cover three years (initial issue plus two extensions) before requiring another full physical inspection and documentation review. However, each extension still requires someone qualified to verify the records and confirm no issues exist. It’s not automatic.

    Practical tip: Many owners use the extension option to align ARC renewals with annual inspections or seasonal maintenance schedules. But don’t rely on extensions to avoid proper reviews—they exist for flexibility, not as a shortcut.

    What the ARC Engineer Actually Checks

    The airworthiness review is a two-part process: documentation review and physical survey. Understanding what’s checked helps you prepare properly.

    Documentation Review

    The reviewing engineer or organisation must verify:

    Maintenance records: Complete and continuous records showing all maintenance performed, including scheduled maintenance per your Aircraft Maintenance Programme (AMP), unscheduled maintenance, defect rectification, and component replacements.

    Airworthiness Directives: Evidence that all applicable ADs have been complied with. This means cross-referencing the current AD status for your aircraft type, engine, propeller, and any appliances against your maintenance records.

    Type Certificate and modifications: Confirmation that the aircraft conforms to its type design. Any modifications or repairs must be properly documented and approved (STC, EASA minor modification, etc.).

    Life-limited components: Verification that all components with life limits (calendar, hours, or cycles) are within limits and properly tracked.

    Weight and balance: Current weight and balance report reflecting the actual aircraft configuration.

    Flight manual: Correct and current version for your aircraft.

    Aircraft Maintenance Programme: Valid, current AMP appropriate for your aircraft and approved or declared in accordance with Part-ML.

    Certificate of Registration and CoA: Valid and matching the aircraft.

    Noise and emissions certificates: Where applicable.

    Physical Survey

    The physical inspection is not a full annual inspection—it’s a survey to verify the aircraft’s general condition matches what the paperwork suggests. The engineer will typically check:

    • General external condition: corrosion, damage, missing panels, security of fairings
    • Landing gear condition and tyre wear
    • Engine compartment: leaks, security, general condition
    • Propeller: damage, erosion, security
    • Control surfaces: freedom of movement, security, condition
    • Cockpit: instruments readable, placards present, required equipment installed
    • Safety equipment: fire extinguisher, first aid kit (where required), ELT status

    The physical survey must identify any obvious defects and verify the aircraft hasn’t been operated beyond limitations or with unresolved defects.

    Grounds for ARC Refusal or Suspension

    An ARC will be refused or suspended if the aircraft fails to meet airworthiness requirements. Common reasons include:

    Incomplete or inconsistent records: Gaps in the maintenance documentation, missing logbook entries, or records that don’t add up. If the engineer cannot verify continuous airworthiness, they cannot issue the ARC.

    Outstanding Airworthiness Directives: Non-compliance with mandatory ADs—especially repetitive ADs with expired intervals—is an automatic failure.

    Exceeded life limits: Any life-limited component found beyond its approved limit stops the process immediately.

    Unresolved defects: Known defects that haven’t been properly deferred or rectified.

    Invalid or expired AMP: Operating without a valid maintenance programme, or with one that doesn’t match your actual operations.

    Physical condition issues: Significant corrosion, obvious damage, or safety-critical defects found during the physical survey.

    Modifications without approval: Unapproved modifications or alterations to the aircraft.

    If the ARC is refused, you cannot fly the aircraft until the deficiencies are corrected and a new review confirms compliance. If your ARC is suspended (say, due to a newly discovered issue), the same applies—no flight operations until resolved.

    CAMO vs. Self-Managing Under Part-ML: What’s the Difference?

    Private owners under Part-ML have a choice: contract with a CAMO to manage continuing airworthiness, or self-manage.

    With a CAMO:
    The CAMO takes responsibility for managing your aircraft’s continuing airworthiness. They track maintenance due dates, AD compliance, life-limited components, and coordinate the ARC process. They can issue and renew your ARC directly. The owner still has legal obligations, but the CAMO handles the administrative complexity. This suits owners who want hands-off management or who operate more complex aircraft.

    Self-managing:
    You, as the owner, are responsible for ensuring continuing airworthiness. You must have a valid AMP (either the TCDS minimum inspection programme or a custom programme declared to your NAA), track all maintenance requirements, ensure AD compliance, and arrange for a qualified person to conduct airworthiness reviews. The owner declares their AMP under Part-ML rather than having it approved by a CAMO.

    Self-management works well for owners who are engaged with their aircraft’s maintenance and keep meticulous records. It requires more personal involvement but gives direct control over scheduling and costs.

    The ARC process itself is similar in both cases—the same documentation and physical survey requirements apply. The difference is who manages the ongoing tracking and who takes administrative responsibility for the airworthiness status between reviews.

    How Squawkd Helps

    Squawkd’s aircraft management tools track your ARC expiry alongside all your other airworthiness items—ADs, life-limited components, and scheduled maintenance tasks. When your ARC review approaches, you can pull the complete documentation package the reviewing engineer needs directly from the platform, eliminating last-minute scrambles through logbooks.

    Frequently Asked Questions

    Q: Can I fly while waiting for my ARC renewal appointment?
    No. Once your ARC expires, the aircraft is not legally airworthy under EASA regulations. You cannot fly it—even to reposition for the review—until a new ARC is issued or the existing one is extended. Plan your renewal timing so you’re not grounded waiting for an available slot.

    Q: What if my ARC engineer finds a minor discrepancy during the review?
    Minor discrepancies don’t necessarily mean automatic refusal. If an issue can be quickly resolved (a missing signature, a minor paperwork correction), many engineers will allow you to fix it during the review process. However, airworthiness-affecting issues must be resolved before the ARC can be issued. The engineer cannot sign off on an aircraft that doesn’t meet requirements, regardless of how inconvenient the timing.

    Q: Do I need a new ARC if I change my aircraft’s registration to another EASA state?
    Generally, yes. When you transfer registration between EASA member states, the receiving state’s competent authority will require verification of airworthiness status. This typically involves a new airworthiness review and ARC issuance under the new state’s oversight. The specific process varies by NAA, so contact the receiving state’s authority early in your transfer planning.

    Tags: EASA airworthiness review certificate, ARC renewal, Part-ML, continuing airworthiness, aircraft maintenance programme, private owner maintenance, CAMO

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  • How to Split Aircraft Co-Ownership Costs Fairly Between 2–5 Owners

    How to Split Aircraft Co-Ownership Costs Fairly Between 2–5 Owners

    How to Split Aircraft Co-Ownership Costs Fairly Between 2–5 Owners

    Meta description: Learn how to split aircraft co-ownership costs fairly. Covers fixed vs. variable expenses, maintenance reserves, and preventing disputes.

    Co-owning an aircraft makes GA affordable. It also creates arguments. The disputes rarely stem from bad intentions—they come from ambiguity. One owner flies 80 hours annually while another flies 20. Someone thinks they shouldn’t pay equally for an engine that’s wearing out under someone else’s use. The hangar fee comes due and no one remembers who paid last quarter. This article provides a practical framework for splitting costs that works whether you’re operating under FAA Part 91 or EASA Part-NCO. Get this right upfront, and you’ll preserve both the partnership and the friendship.

    Fixed vs. Variable: The Foundational Split

    Every aircraft expense falls into one of two categories. Understanding which is which prevents most cost-sharing disputes.

    Fixed costs exist whether the aircraft flies or not. These include:

    • Hangar or tie-down fees
    • Hull and liability insurance premiums
    • Annual inspection (Part 91) or Annual/100-hour equivalent under your AMP (EASA Part-ML)
    • Database subscriptions (navigation, charts, terrain)
    • Registration and airworthiness fees
    • Property taxes where applicable

    Split these equally among all owners, regardless of who flies more. The logic is straightforward: these costs secure the asset’s existence and legal airworthiness. Every owner benefits equally from the aircraft being hangared, insured, and legally flyable—even during months they don’t fly.

    Variable costs scale with use. These include:

    • Fuel and oil
    • Consumables (filters, brake pads, tires)
    • Hourly maintenance items driven by flight time
    • Landing and handling fees

    Split these by Hobbs time. The owner who flew the hours pays the proportional share. This is not about fairness in the abstract—it’s about causation. Running the engine burns fuel and accumulates wear. The person doing the running should bear that cost.

    Some groups use tach time instead of Hobbs. Either works if everyone agrees. Hobbs is simpler because it captures all engine-running time including taxi. Whatever you choose, document it in your co-ownership agreement and stick to it.

    The Maintenance Reserve Model

    Here’s where most informal arrangements fail. Two owners split an aircraft 50/50. After three years, the engine needs an overhaul. One owner has flown 400 hours; the other has flown 100. Who pays for the $30,000 overhaul?

    If you haven’t been reserving hourly, you’ll have a dispute. One owner will argue they shouldn’t subsidize wear they didn’t cause. The other will argue that TBO is a recommendation, not a guarantee, and ownership means shared risk. Both have a point. Neither will be happy.

    The maintenance reserve model solves this. Every flight hour triggers a contribution to a dedicated reserve fund. The rate depends on your engine and expected overhaul cost, but a typical piston single might reserve $15–25 per Hobbs hour for engine, $3–5 for propeller, and $5–10 for avionics/airframe contingencies.

    Calculate your own rates as follows:

    1. Estimate overhaul cost for your specific engine
    2. Divide by manufacturer’s recommended TBO
    3. Add a buffer of 10–15% for overhaul cost inflation

    Example: Continental IO-360 with estimated $28,000 overhaul cost and 2,000-hour TBO = $14/hour base rate. With buffer, reserve $16/hour.

    Do the same calculation for propeller overhaul and any other time-based maintenance requirements.

    The reserve account should be:

    • Jointly held with all owners as signatories
    • Separate from operating funds
    • Used only for major maintenance, not routine items

    When the engine goes out for overhaul, you pay from the reserve. If the aircraft sells before overhaul, the reserve is distributed proportionally based on each owner’s contributions, not ownership percentage. This rewards the owner who flew less while still protecting against unexpected failures.

    Under EASA Part-ML, your Continuing Airworthiness Management Organisation or self-managing owner group should account for these reserves when planning maintenance under the Aircraft Maintenance Programme. For FAA operations, there’s no regulatory requirement, but the principle is identical: plan for the cost of keeping the aircraft airworthy over its inspection cycle.

    When One Owner Flies Significantly More Than Others

    Unequal usage strains every co-ownership arrangement eventually. The pilot who flies 150 hours per year has different interests than the one who flies 30.

    The high-time owner may feel they’re subsidizing the low-time owner’s share of fixed costs. After all, if the partnership dissolved, the high-time owner would simply buy their own aircraft and pay 100% of fixed costs in exchange for 100% availability.

    The low-time owner may feel they’re being pushed out. They pay the same insurance and hangar as everyone else, but the aircraft is rarely available when they want it.

    Neither perspective is wrong. Address this with three mechanisms:

    1. Usage caps or minimums. Some groups set a maximum annual hours per owner (say, 150 hours in a 3-owner group) and a minimum (30 hours). Exceed the maximum and you owe a premium to compensate others for reduced availability. Fall below the minimum and you forfeit scheduling priority. These aren’t penalties—they’re prices that reflect the real tradeoffs.

    2. Adjusted ownership percentages. If usage consistently diverges, consider restructuring ownership. The high-time owner buys out a portion of a low-time owner’s share. Now fixed costs split 60/30/10 instead of 33/33/33, and scheduling priority shifts accordingly. This requires legal documentation and may trigger tax consequences, so involve an aviation attorney.

    3. Buyout provisions. Your co-ownership agreement should specify what happens when one owner wants out. Include a right of first refusal for remaining owners, a valuation method (typically average of two independent appraisals), and a timeline for payment. Without this, a departing owner can hold the group hostage or force a fire sale.

    The key principle: acknowledge that interests diverge over time and build mechanisms to adjust rather than expecting the original arrangement to last forever.

    Common Disputes and How to Prevent Them

    Even with good intentions, these specific issues generate conflict:

    Who pays for damage? If an owner damages the aircraft through pilot error—a prop strike, a gear-up landing—who covers the deductible and lost revenue during repairs? Best practice: the responsible pilot pays the insurance deductible; hull damage beyond deductible is an insurance claim; loss of use during repairs is absorbed by the group. Document this explicitly.

    Unscheduled maintenance timing. An owner returns the aircraft with a squawk. It needs repair before the next flight, but the next flight is scheduled for tomorrow with a different owner. Who decides if the repair can wait? Who pays if it delays the scheduled flight? Establish a decision protocol: safety-of-flight squawks ground the aircraft immediately; all else can wait if the next pilot accepts the condition; all owners are notified within 24 hours of any new squawk.

    Upgrades and modifications. One owner wants a panel upgrade. Others are happy with steam gauges. If the upgrade increases aircraft value, the upgrading owner might reasonably expect reimbursement on sale. If it’s purely preference, perhaps they bear the full cost. Define your policy for both mandatory compliance upgrades (ADS-B, for example) and elective improvements.

    Record-keeping disputes. Someone thinks they’ve paid more than their share. Without records, you’re guessing. Maintain a shared ledger—digital, accessible to all owners, updated within 48 hours of any expense or flight. This is also a regulatory issue: both FAA Part 91.417 and EASA Part-ML.A.305 require maintenance records be retained and accessible. Financial records should meet the same standard.

    The unifying theme: write it down before it matters. Every dispute above has a simple solution if the co-ownership agreement addresses it. Every one becomes partnership-ending if it doesn’t.

    How Squawkd Helps

    Squawkd tracks Hobbs time, calculates per-owner cost splits automatically, and maintains the maintenance reserve balances that keep overhaul funding transparent. When it’s time to reconcile expenses at month-end, every owner sees the same numbers—no spreadsheet version conflicts, no memory disagreements.

    Frequently Asked Questions

    Q: Should we form an LLC for aircraft co-ownership?

    An LLC can provide liability protection and simplify ownership transfers, but it adds administrative overhead and may affect your insurance options. Some insurers won’t cover LLC-owned aircraft on personal policies, requiring more expensive commercial coverage. Consult an aviation attorney and your insurance broker before structuring. For 2–3 owners with good personal liability coverage, an LLC may be unnecessary. For 4+ owners or if any owner has significant personal assets at risk, it’s worth serious consideration.

    Q: How do we handle insurance when one co-owner has less experience?

    Insurance premiums typically reflect the least-experienced pilot on the policy. If one owner has 200 hours and another has 2,000, you’ll pay for the 200-hour risk. Some groups address this by requiring the less-experienced owner to pay the premium differential until they reach a specified threshold. Others simply accept it as a cost of partnership. Either approach works if documented and agreed.

    Q: What happens to the maintenance reserve if we sell the aircraft?

    Distribute the reserve based on each owner’s contributions, not ownership percentage. If Owner A contributed $8,000 over three years and Owner B contributed $3,000, Owner A gets 72.7% of the reserve balance at sale. This incentivizes honest reserve contributions and fairly compensates the high-time owner who funded most of the engine life consumed.

    Tags: aircraft co-ownership costs, aircraft syndicate cost split, shared aircraft expenses, maintenance reserve, co-owner agreement, GA partnership, aircraft operating costs

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  • Owner Assisted Maintenance Under Part-ML: What Private Owners Can Actually Do

    Owner Assisted Maintenance Under Part-ML: What Private Owners Can Actually Do

    Owner Assisted Maintenance Under Part-ML: What Private Owners Can Actually Do

    Meta description: Owner assisted maintenance under Part-ML lets you work on your own aircraft legally. Here’s exactly what EASA allows and how to stay compliant.

    You bought an aircraft to fly it, not to watch it sit in a hangar waiting for an engineer’s schedule to clear. Part-ML opened real possibilities for private owners to perform certain maintenance tasks themselves—but the regulation is precise about what qualifies, who signs what off, and how you document it. Get this wrong and your aircraft’s airworthiness is compromised, not just on paper but potentially at your next ramp check. This guide covers exactly what owner assisted maintenance means under Part-ML, where the boundaries sit, and how to execute it without creating compliance headaches.

    What Part-ML Actually Says About Owner Assisted Maintenance

    Part-ML (Annex Vb to Regulation (EU) 2018/1139) governs continuing airworthiness for aircraft not used in commercial air transport. ML.A.803 specifically addresses pilot-owner maintenance, but the term “owner assisted maintenance” describes a related but distinct concept that trips up many owners.

    Pilot-owner maintenance under ML.A.803 allows the owner to perform limited maintenance tasks and release the aircraft to service themselves—no engineer required. Owner assisted maintenance is different: you’re working under the supervision of a licensed engineer who retains responsibility and ultimately releases the aircraft.

    The distinction matters for three reasons:

    1. Task scope. Pilot-owner maintenance is restricted to the task list in Appendix II to Part-ML. Owner assisted work, supervised by a certifying engineer, can extend beyond that list.

    2. Release authority. Under pilot-owner privileges, you sign the release. Under assisted maintenance, the supervising engineer signs.

    3. Record requirements. Both require documentation, but the chain of accountability differs.

    The regulation intentionally created flexibility here. EASA recognised that many private owners have genuine mechanical competence but lack formal licensing. Owner assisted maintenance provides a legal pathway to use that competence while maintaining the oversight structure that keeps aircraft safe.

    Which Tasks You Can Perform Yourself

    Appendix II to Part-ML lists the specific tasks a pilot-owner can perform independently without engineer supervision. These include:

    • Replacement of landing gear tyres, doors, seats, cowlings, and fairings
    • Simple fabric repairs not requiring rib stitching
    • Servicing of batteries, filters, and landing gear shock struts
    • Replacement of spark plugs, hoses, and elastic shock cords
    • Component replacements designed for rapid removal (safety wire, split pins, cotter keys)
    • Servicing operations such as lubrication, topping up fluids, and tyre pressure checks
    • Inspections and operational checks that don’t require disassembly beyond normal access covers

    These tasks share common characteristics: they’re maintenance items with established procedures, limited complexity, and low risk of consequential damage if performed incorrectly.

    For anything outside Appendix II, you have two options. First, you can simply hand the aircraft to a Part-145 organisation or independent certifying engineer and let them handle everything. Second—and this is where owner assisted maintenance becomes valuable—you can perform the work under an engineer’s direct supervision, with the engineer retaining release authority.

    The second option saves money without compromising airworthiness. You’re providing labour under expert oversight, reducing the engineer’s billable hours while they ensure the work meets standards.

    The Supervision Requirement: What “Assisted” Actually Means

    Owner assisted maintenance isn’t a loophole to perform major work and then ask an engineer to rubber-stamp it afterwards. The supervising engineer must be involved before, during, and after the work.

    Before the task: The engineer reviews the procedure, confirms the owner understands the steps, and ensures proper tooling and parts are available. This might happen in person or via detailed communication, depending on task complexity.

    During the task: The level of direct supervision varies. For straightforward work, the engineer might check in at key stages. For anything involving flight controls, engine internals, or structural components, expect continuous oversight.

    After the task: The engineer inspects the completed work, confirms compliance with the applicable maintenance data, and releases the aircraft. Their signature on the release confirms they accept responsibility for the work performed under their supervision.

    If an engineer is unwilling to supervise a particular task, that’s information worth respecting. Their licence is on the line. Push-back usually indicates either task complexity beyond reasonable assisted maintenance scope or concerns about the owner’s capability on that specific job.

    Some CAAs have issued additional guidance on supervision standards.

    Documentation Requirements You Cannot Skip

    Maintenance records under Part-ML aren’t optional paperwork—they’re the legal evidence that your aircraft is airworthy. ML.A.305 specifies what you must retain:

    Aircraft continuing airworthiness records must include the aircraft total time, current status of ADs, current inspection status, and details of modifications and repairs.

    Maintenance records must document the date, a description of the work, applicable maintenance data used, the person who performed the work, and the person who released it. For owner assisted maintenance, both names appear: yours as the person who did the work, the engineer’s as the person who supervised and released.

    The release to service entry must clearly state what was done, reference the applicable procedures or instructions, and confirm the aircraft is approved for return to service. ML.A.801 covers release requirements in detail.

    Sloppy records create real problems. A ramp inspection that finds maintenance entries without clear release authority can ground your aircraft on the spot. Worse, a maintenance-related incident with poor records history shifts liability in directions you don’t want.

    Keep your records current, organised, and accessible. If your system involves paper logbooks scattered across your hangar, office, and flight bag, you’re creating risk.

    Common Mistakes That Create Compliance Problems

    Having worked with owners navigating Part-ML, certain patterns emerge repeatedly:

    Performing tasks outside Appendix II and self-releasing. This is straightforward non-compliance. The task list exists for a reason. If the job isn’t listed, you don’t have pilot-owner release authority regardless of your skill level.

    Failing to use approved maintenance data. You can’t just watch a YouTube video and call it compliant. Maintenance must be performed in accordance with instructions from the type certificate holder, the aircraft manufacturer’s maintenance manual, or approved supplementary data. ML.A.302 is specific about data requirements.

    Incomplete record entries. “Changed oil” with a date and signature isn’t sufficient. The entry must reference the maintenance data used, oil type and quantity, and confirm return to service.

    Treating AMP optional items as truly optional. If your Aircraft Maintenance Programme includes a task, it’s not optional at that point—it’s your compliance schedule. You can propose AMP amendments through the proper process, but you can’t simply skip inconvenient tasks.

    Mixing up EASA and FAA standards. Owners with dual experience sometimes apply Part 91 Preventive Maintenance logic to Part-ML aircraft. The frameworks don’t align, and what’s legal under FAR 43 Appendix A doesn’t automatically transfer.

    Working With Engineers: Making Assisted Maintenance Practical

    Finding an engineer willing to supervise owner assisted maintenance requires trust in both directions. The engineer needs confidence that you’ll follow instructions, not cut corners, and accept their decision on what qualifies as owner-appropriate work.

    Build this relationship gradually. Start with straightforward Appendix II tasks performed independently, then discuss assisted work as they observe your competence. Many engineers prefer owners who ask questions over owners who assume.

    Agree on communication expectations upfront. Some engineers want photo documentation at each stage. Others prefer periodic check-ins. Clarify this before starting work, not after you’ve reassembled something incorrectly.

    Expect to pay for supervision time even when you’re doing the physical work. The engineer is reviewing procedures, monitoring your progress, and accepting liability for the release. That’s valuable, and pricing it appropriately keeps good engineers in the owner-assisted maintenance market.

    How Squawkd Helps

    Squawkd maintains your continuing airworthiness records in a format that satisfies ML.A.305 documentation requirements, tracking task status, inspection schedules, and release history. For co-ownership situations, it ensures every owner and any supervising engineers work from the same current maintenance status—eliminating the scattered logbook problem that creates compliance gaps.

    Frequently Asked Questions

    Can I change my aircraft’s brake pads under pilot-owner maintenance?
    Yes. Replacement of brake pads (including discs on certain types) appears in Appendix II to Part-ML as an approved pilot-owner task, provided you follow the aircraft maintenance manual procedures and document the work correctly.

    What happens if I perform a task outside the Appendix II list without engineer supervision?
    The release to service is invalid. Technically, your aircraft isn’t airworthy, regardless of whether the physical work was done correctly. A subsequent inspection revealing this creates immediate grounding and potential enforcement action.

    Does my engineer need to be physically present for all assisted maintenance?
    Part-ML doesn’t mandate continuous physical presence for every task, but the supervising engineer determines what level of oversight they require to accept release responsibility. For any work affecting flight safety systems, expect them on site.

    Tags: owner assisted maintenance, Part-ML, pilot-owner maintenance, EASA aircraft ownership, continuing airworthiness, ML.A.803, private aircraft maintenance