EASA Part 145 and the Performance of Airworthiness Review Certificates (ARC)

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Introducing 145.A.37 (Forthcoming regulation NPA 2019-05 (C))

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Why should 145 Organisations be involved with the issuance of Airworthiness Review Certificates?

The answer is basically to fill a niche; the approval is quite restricted and is only applicable to small “none AOC” aircraft, namely.

The Certificate that is used to provide the ARC is EASA Form 15C.

What is ML.1?

a) This Part applies to the following aircraft when they are not listed in the air operator certificate of an air carrier licensed in accordance with Regulation (EC) No 1008/2008 and not classified as complex motor-powered aircraft: 

1. Aeroplanes of 2 730 kg maximum take-off mass (MTOM) or less
2. Rotorcraft of 1 200 kg MTOM or less certified for a maximum of up to 4 occupants
3. Other ELA2 aircraft

ML.A.901 Aircraft Airworthiness Review

To ensure the validity of the ARC, an airworthiness review of the aircraft and a review of its continuing-airworthiness records shall be carried out periodically.

a) An ARC valid for 1 year, using the EASA Form 15c described in Appendix IV to this Part, is issued upon completion of a satisfactory airworthiness review.
b) The airworthiness review and the issuance of the ARC shall be performed in accordance with ML.A.903 by:

1) The competent authority
2) An appropriately approved CAMO or CAO
3) The approved maintenance organisation performing the 100-h/annual inspection contained in the AMP
4) For aircraft operated under Part-NCO, the independent certifying staff performing the 100-h/annual inspection contained in the AMP, when holding:

i. A Part-66 licence rated for the corresponding aircraft or, if Part-66 is not applicable to the particular aircraft, a national certifying-staff qualification valid for that aircraft
ii. An authorisation issued by:

A. The competent authority who issued the Part-66 licence
B. If Part-66 is not applicable, the competent authority responsible for the national certifying-staff qualification

Independent certifying staff holding a Part-66 licence can perform airworthiness reviews and issue the ARC for aircraft registered in any Member State. 

145.A.37 Airworthiness Review Staff

a) In order to be approved to carry out airworthiness reviews, a Part-145 organisation shall have appropriate airworthiness review staff who comply with all of the following requirements: 

1. They have acquired experience in continuing airworthiness of at least 1 year for sailplanes and balloons and of at least 3 years for all other aircraft
2. They hold an appropriate licence issued in accordance with Annex III (Part-66) or a nationally recognised maintenance personnel qualification appropriate to the aircraft category (when Article 5(6) refers to national rules) or an aeronautical degree or equivalent, or they have acquired experience in continuing airworthiness in addition to that referred to in point (1) of at least 2 years for sailplanes and balloons and at least 4 years for all other aircraft
3. They have acquired appropriate aeronautical-maintenance training

b) Before the organisation issues an airworthiness review authorisation, the organisation shall nominate the person who will perform an airworthiness review of an aircraft under supervision of the competent authority or already authorised airworthiness review staff of the organisation. If this supervision is satisfactory, the competent authority shall formally accept that person to become airworthiness review staff.
c) The Part-145 organisation shall ensure that the airworthiness review staff can demonstrate appropriate recent continuing airworthiness experience. 

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