European Aviation Safety Agency

04 July 2007 M-005 Limited pilot owner maintenance 1 Slide

 M-005: Limited Pilot
owner maintenance

EASA workshop
04 July 2007
[email protected]

04 July 2007 EASA Cologne

 European Aviation Safety Agency

Current Part M.A.803

Pilot-owner authorisation
(a) The pilot-owner is the person who owns or jointly owns
the aircraft being maintained and holds a valid pilot licence
with the appropriate type or class rating.
(b) For any privately operated aircraft of simple design
with a maximum take-off mass of less than 2730 kg, glider
and balloon, the pilot-owner may issue the certificate of
release to service after limited pilot owner maintenance
listed in Appendix VIII.
(c) Limited pilot owner maintenance shall be defined in the
M.A.302 aircraft maintenance programme.
(d) The certificate of release to service must be entered in
the logbooks and contain basic details of the maintenance
carried out, the date such maintenance was completed and
the identity and pilot licence number of the pilot-owner
issuing such a certificate.

04 July 2007 M-005 Limited pilot owner maintenance 3 Slide

 European Aviation Safety Agency

Current AMC M.A.803

Pilot-owner authorisation
AMC M.A.803 Pilot-owner authorisation
1. The pilot–owner should hold a valid pilot
license issued or validated by a member state for
the aircraft type being maintained.
2. Privately operated means the aircraft is not
operated pursuant to M.A.201 (h) and (i).
i.e means not involved in “commercial” activities or
‘operational” activities requiring an AOC IAW the
national rules
3. A pilot owner should only issue a certificate of
release to service for maintenance performed by
the pilot owner and after demonstrating the
competence to carry out such maintenance tasks.
04 July 2007 M-005 Limited pilot owner maintenance 4 Slide
 European Aviation Safety Agency

History / need for such a

working group
JAA times: non complex and light
aircraft not involved in commercial
activities were not taken into account
When the EASA was created, it became
urgent, according to the remit of
activities, to develop a regulation for non
complex and light aircraft not involved in
commercial activities.
EASA Appendix VIII was based on
FAR43 appendix A part (c) that
needed to be updated.

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 European Aviation Safety Agency

History / need for such a

working group
Part M was published in 2003 (regulation
2042)
NPA 07-2005 gave the opportunity to
comment Part M (impact for non
commercial aircraft)
Appendix VIII was found too limitative. It was
furthermore proposed re-evaluating the applicability of
each task in Appendix VIII to gliders, balloons, airships
and light aircraft.
EASA decided that paragraph M.A.803 and Appendix
VIII should be subject to further re-evaluation.

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 European Aviation Safety Agency

History / need for such a

working group
Creation of rulemaking task M.005.
Comments arising from NPA 07-2005 have
been considered and liaison with M-017 and
MDM-032 was performed
Composition of group M-005:
 a balance between experts from Industry (representing
flying associations as AEI, EAS, OAPA) and NAAs
 Experts in the field of the General Aviation (Powered
aircraft, glider, balloon, helicopter) + liaison with some TC
holders, associations
 The group started to work on July 2006. 7 meetings

04 July 2007 M-005 Limited pilot owner maintenance 7 Slide

 European Aviation Safety Agency

M-005 Pilot owner

maintenance

What the new

Appendix VIII will say
…

04 July 2007 M-005 Limited pilot owner maintenance 8 Slide

 European Aviation Safety Agency

M-005 Pilot owner

maintenance
Several criteria / basic principles:
MTOW limit: kept as it is (2730 kg)
You must be a pilot holding a valid license
You must be the owner of the aircraft
 In the case of collectively owned aircraft, see next slides
The pilot will issue the CRS in the logbook
 identity and pilot licence number of the pilot-owner issuing such a
certificate
The controlled environment is kept.
The tasks are not critical for safety
No competency check but self assessment
 The tasks shall be defined in the M.A.302 aircraft maintenance
programme.
 Possible consequence in case of exportation (next slide)

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 European Aviation Safety Agency

M-005 Pilot owner maintenance:

Competency check
ICAO Annex 6, Part II, Chapter 8.1.3
(maintenance for general aviation): when
the maintenance release is not issued by
an approved Mmaintenance organisation,
the person signing the CRS shall be
licensed in accordance with ICAO Annex I.
ICAO Annex I. Annex I (Personnel
licensing) Chapter 4 : an applicant for any
licence or rating shall demonstrate in a
manner determined by the Licensing
Authority, such requirements in respect of
knowledge and skill that are specified for
that licence or rating.

04 July 2007 M-005 Limited pilot owner maintenance 10 Slide

 European Aviation Safety Agency

M-005 Pilot owner maintenance:

Competency check
A signatory shall not be less than 18
years of age and shall have demonstrated
a level of knowledge relevant to the
privileges to be granted and appropriate to
the responsibilities of an aircraft
maintenance licence holder in at least air
law and maintenance requirements as well
as other subjects.
Additionally, sub-chapter 4.2.4 authorises
an approved maintenance organisation to
appoint non-licensed personnel to exercise
Certificate of Release to Service privileges
provided that the above criteria are met.

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 European Aviation Safety Agency

M-005 Pilot owner maintenance:

Competency check
Thus, an aircraft which has undergone
pilot owner maintenance IAW Part M
appendix VIII may need to have additional
maintenance carried out to ensure full
compliance with ICAO requirements, for
example on export from the EU

(Sum up) no competency check but there are

3 filters:
Tasks are not critical for safety
Tasks listed in the Maintenance programme
(NAA/CAMO approved)
ARC review on a yearly basis

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 European Aviation Safety Agency

M-005 Pilot owner

maintenance
New structure: Appendix VIII is now split in four
lists aligned to ATA classification:
Aeroplane (below 1000kg and between 1000 and
2730kg) / Sailplanes and powered sailplanes / Hot air
ships, hot air and gas balloons / Rotorcraft – single
engine (Part A to D)

Most of the existing Appendix VIII with its proposed

amendment from NPA 2005-7 was retained.
Except item 41 (minor scheduled maintenance required
at 50h/6months or less for piston-engine aeroplane or
helicopters, gliders, balloons or airships (see further
explanations)
In fact the new lists are less restrictive, more flexible,
more accurate than the existing one and adapted to the
technology.

04 July 2007 M-005 Limited pilot owner maintenance 13 Slide

 European Aviation Safety Agency

Proposal Appendix VIII: 10

principles
10 basic principles are to be complied with before
any task is carried out under the terms of pilot owner
maintenance:
1 Before carrying out any maintenance tasks as
listed in this appendix, the pilot owner must satisfy
himself that he is competent to do the task. It is the
responsibility of pilot owners to familiarize
themselves with the standard maintenance practices
for their aircraft and with the aircraft maintenance
programme.
2 The maintenance instructions of the TC holder
as expressed in the maintenance manual and
instructions for continuing airworthiness are to be
considered in developing the maintenance
programme; however, these requirements cannot
override the generic lists in Part “A” to “D”.

04 July 2007 M-005 Limited pilot owner maintenance 14 Slide

 European Aviation Safety Agency

Proposal Appendix VIII: 10

principles
3 The maintenance data as specified in
M.A.401 must be always available during the
conduct of pilot owner maintenance. Details
of the data referred to in the conduct of pilot
owner maintenance must be included in the
Certificate of Release to Service IAW
M.A.803(d).
4. The need to use special tools, carry out
special testing (e.g. NDT) or any
unscheduled special inspections (e.g. heavy
landing check) prevents the task from being
carried out as pilot owner maintenance.

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 European Aviation Safety Agency

Proposal Appendix VIII: 10

principles
5 Any task described in the aircraft flight manual
as preparing the aircraft for flight (Example:
assembling the glider wings or pre-flight), is
considered to be a pilot task and is not considered
pilot owner maintenance and therefore does not
require a Certificate of Release to Service.
6 Any task related to an Airworthiness Directive
is not considered as pilot owner maintenance, unless
specifically allowed in the AD.
7. The pilot owner must inform the M.A. Subpart
G Continuing Airworthiness Management
Organisation (if applicable) not later than 30 days
after completion of the pilot owner maintenance task
IAW M.A 305 (a).

04 July 2007 M-005 Limited pilot owner maintenance 16 Slide

 European Aviation Safety Agency

Proposal Appendix VIII: 10

principles

8 Inspection tasks/checks of any periodicity

included in an approved maintenance programme
can be carried out providing that the specified tasks
are included in the generic lists at Parts A to D of
Appendix VIII.

9 In addition to the generic lists in Parts “A” to

“D”, the pilot-owner may carry out very simple visual
inspections for general condition and obvious
damage of the airframe, engines and components as
long as the task does not involve the removal of any
component or element.

04 July 2007 M-005 Limited pilot owner maintenance 17 Slide

 European Aviation Safety Agency

Proposal Appendix VIII: AMC

to principles n°8 and 9
AMC to Appendix VIII “Limited Pilot Owner
Maintenance” regarding Basic principles N°8 and
N°9
The content of periodic inspections/checks as well
as their periodicity is not regulated or standardized
in an aviation specification. It is the decision of the
manufacturer/Type Certificate Holder (TCH) to
recommend a schedule for each specific type of
inspection/check.
For an inspection/check with the same periodicity
for different TCHs, the content may differ, and in
some cases may be critically safety related and may
need the use of special tools or knowledge and thus
would not qualify for pilot owner maintenance.
Therefore the maintenance carried out by the pilot
owner cannot be generalised to specific inspections
such as 50 Hrs, 100 Hrs or 6 Month periodicity.

04 July 2007 M-005 Limited pilot owner maintenance 18 Slide

 European Aviation Safety Agency

Proposal Appendix VIII: AMC

to principles n°8 and 9
AMC to Appendix VIII “Limited Pilot Owner
Maintenance” regarding Basic principles N° 8 and N°
9 (…continuation)

The Inspections to be carried out are limited to

those areas and tasks listed in the Appendix; this
allows flexibility in the development of the
maintenance programme and does not limit the
inspection to certain specific periodic inspections. A
50 Hrs /6 Month periodic inspection for a fixed wing
aeroplane as well as the one-year inspection on a
glider may normally be covered in the maintenance
programme.

04 July 2007 M-005 Limited pilot owner maintenance 19 Slide

 European Aviation Safety Agency

Proposal Appendix VIII: 10

principles

10 . Tasks in Appendix VIII Table A

shown with ** exclude IFR operations
following pilot owner maintenance.
For these aircraft to operate under
IFR operations, these tasks must be
certified by an appropriate licensed
engineer.

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 European Aviation Safety Agency

M-005 Pilot owner maintenance

Pilot owner maintenance versus

collectively owned aircraft…..

04 July 2007 M-005 Limited pilot owner maintenance 21 Slide

 European Aviation Safety Agency

Pilot owner maintenance versus

collectively owned aircraft

One comment arising from NPA 2005/07

was the definition of “pilot owner” in the
case of collectively owned aircraft.
Existing AMC M.A.803
Is it applicable to associations representing
flying clubs, training schools? Can we allow
pilots in flying clubs for instance to carry out
pilot owner maintenance?
Rulemaking tasks M-010 created by the agency.
M-005 took into account the concern about a
« flying association / club » where members share
the property of the aircraft (task M-010).
04 July 2007 M-005 Limited pilot owner maintenance 22 Slide
 European Aviation Safety Agency

Pilot owner maintenance versus

collectively owned aircraft

Clarification of “joint ownership”: an

aircraft is either owned by a natural person
or jointly owned by a group of natural
persons, by a limited liability company or
by a legal entity, accepted as the registered
owner by the Member State of registry,
irrespective of whether these owners are
part of a non profit association, flying
club/association, training schools etc.

Only the registered owner is authorised to

perform pilot owner maintenance: this
excludes legal owners that are not in the
document for the registration of aircraft.
04 July 2007 M-005 Limited pilot owner maintenance 23 Slide
 European Aviation Safety Agency

Pilot owner maintenance versus

collectively owned aircraft
Only a natural person can possess a pilot licence.
The pilot must hold a current licence, which must be
valid for the aeroplane type concerned.
Consequently, a company or a legal entity cannot
hold a pilot licence and should designate the pilot
authorised to perform limited pilot owner
maintenance.
The current Part M does not regulate this situation,
the reason for which this proposal has been made.

Ultimately, only the pilot owner or the pilot

designated by the company or the legal entity as
mentioned above is authorized to issue a CRS for
the maintenance tasks he/she has performed.

04 July 2007 M-005 Limited pilot owner maintenance 24 Slide

 European Aviation Safety Agency

Pilot owner maintenance versus

collectively owned aircraft

EASA is not committed to regulate

the registration process (state of
registry).
What is enforceable is under the
national rules.
The national rules will apply. Refer to
your national system whereby you
are recognized as the “owner” of the
aircraft.

04 July 2007 M-005 Limited pilot owner maintenance 25 Slide

 European Aviation Safety Agency

Pilot owner maintenance versus

collectively owned aircraft

Paragraph M.A.803 (a) is proposed to

be amended as follows:
(a) The pilot-owner is the person who
owns or jointly owns the aircraft being
maintained and holds a valid pilot license
issued or validated by a Member State for
the aircraft type or class rating with the
appropriate type or class rating.

04 July 2007 M-005 Limited pilot owner maintenance 26 Slide

 European Aviation Safety Agency

Pilot owner maintenance versus

collectively owned aircraft

Paragraph M.A.803 (a) (…continuation)

1. An aircraft, as referred to above paragraph (a)
may be jointly owned by:
 (i) a number of natural persons on the registration form, or
 (ii) a limited liability company or a legal entity accepted as
registered owner under the applicable national laws pertaining to
the registration of aircraft.
2. Pilot owner maintenance shall be performed by:
 (i) the pilot owner or,
 (ii) in the case of joint ownership, the pilot owners designated by
the registered owners of the aircraft being maintained or
 (iii) where the joint owner is a limited liability company or a legal
entity, by a pilot who is a member of, and designated by, that
company or legal entity.

04 July 2007 M-005 Limited pilot owner maintenance 27 Slide

 European Aviation Safety Agency

Pilot owner maintenance versus

collectively owned aircraft

Amendment to AMC M.A.803 Pilot-owner

authorisation
1. Privately operated means the aircraft is not operated
pursuant to M.A.201 (h) and (i).
2. A pilot owner may only issue a certificate of release to
service for maintenance he/she has performed.

3. In the case of a jointly owned aircraft,

the maintenance program should list the
names of all pilots designated to perform
pilot owner maintenance and the limited
maintenance tasks they may perform.

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 European Aviation Safety Agency

Pilot-owner maintenance

Paragraph M.A.803 (d) is proposed to

be amended as follows:
(b) For any privately operated aircraft of simple design
with a maximum take-off mass of less than 2730 kg, glider
and balloon, the pilot-owner may issue the certificate of
release to service after limited pilot owner maintenance
listed in Appendix VIII.
(c) Limited pilot owner maintenance shall be defined in
the M.A.302 aircraft maintenance programme.
(d) The certificate of release to service must be entered
in the logbooks and contain basic details of the
maintenance carried out, the maintenance data used, the
date such maintenance was completed and the identity and
pilot licence number of the pilot-owner issuing such a
certificate.

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 European Aviation Safety Agency

End

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