wp.squawkd.com

Tag: aircraft maintenance programme

  • 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

  • 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

    Image search: light aircraft maintenance hangar inspection