M.A.901
To ensure the validity of the aircraft airworthiness certificate, an airworthiness review of the aircraft and its continuing airworthiness records shall be carried out periodically.
M.A.901(a) ARC validity
(a) An airworthiness review certificate is issued in accordance with Appendix III (EASA Form 15a or 15b) to this Annex upon completion of a satisfactory airworthiness review. The airworthiness review certificate shall be valid for 1 year;
GM M.A.901(a) ARC Forms
EASA Form 15a is issued by competent authorities while EASA Form 15b is issued by a CAMO or CAO organisation.
M.A.901(b) Controlled environment
(b) An aircraft in a controlled environment is an aircraft which, during the preceding 12 months:
1. has had its airworthiness continuously managed by a unique CAMO or CAO;
2. has been maintained by a maintenance organisation approved in accordance with Subpart F of this Annex, Annex II (Part-145) or Annex Vd (Part-CAO), including the cases when maintenance tasks referred to in point (b) of point M.A.803 are carried out and released to service in accordance with point (b)(1) or (b)(2) of point M.A.801 of this Annex.
AMC M.A.901(b) Controlled environment
1. If the continuing airworthiness of the aircraft is not managed according to an Appendix I Continuing airworthiness contract, the aircraft should be considered to be outside a controlled environment. Nevertheless, such contract is not necessary when the operator and the CAMO are the same organisation.
2. The fact that limited pilot-owner maintenance as defined in M.A.803(b) is not carried out and released by an approved maintenance organisation does not change the status of an aircraft in a controlled environment providing the CAMO under contract has been informed of any such maintenance carried out.
M.A.901(c) Organisation responsibilities (AOC, MTOM>2730kg)
(c) For all aircraft used by air carriers licensed in accordance with Regulation (EC) No 1008/2008, and for aircraft above 2 730 kg MTOM that are in a controlled environment, the organisation referred to in point (b)(1) managing the continuing airworthiness of the aircraft may in accordance with CAMO.A.125(e) of Annex Vc or point M.A.711(b) of this Annex or point CAO.A.095(c)(1) of Annex Vd, as applicable, and subject to compliance with point (j):
1. issue an airworthiness review certificate in accordance with point M.A.901;
2. extend at most twice the validity of the airworthiness review certificate it has issued, for a period of 1 year each time, where the aircraft concerned has remained within a controlled environment.
M.A.901(d) Competent authority responsibilities
(d) The airworthiness review certificate shall be issued by the competent authority upon a satisfactory assessment based on a recommendation made by a CAMO or CAO, sent together with the application from the owner or operator for all aircraft used by air carriers licensed in accordance with Regulation (EC) No 1008/2008, and for aircraft above 2 730 kg MTOM that complies with the following alternative conditions:
1. they are not in a controlled environment;
2. their continuing airworthiness is managed by an organisation that does not hold the privilege to carry out airworthiness reviews.
The recommendation referred to in the first subparagraph shall be based on an airworthiness review carried out in accordance with point M.A.901.
AMC M.A.901(d) Airworthiness review
The recommendation sent by a CAMO or CAO to the competent authority of the Member State of registry should be, at least, in English when the Member State of registry is different from the CAMO/CAO’s Member State. Otherwise, it can be completed in the official language(s) of the CAMO/CAO’s Member State.
The recommendation sent to the competent authority should contain at least the items described below:
(a) General information
— CAMO information
— owner/lessee information
— date and place where the document review and the aircraft survey were carried out
— period and place the aircraft can be seen if required by the competent authority
(b) Aircraft information
— registration
— type
— manufacturer
— serial number
— flight manual reference
— weight and centre of gravity data
— maintenance programme reference
(c) Documents accompanying the recommendation
— copy of registration papers
— copy of the owners request for a new airworthiness review certificate
(d) Aircraft status
— aircraft total time and cycles
— list of persons or organisations having carried out continuing airworthiness activities including maintenance tasks on the aircraft and its components since the last airworthiness review certificate
(e) Aircraft survey
— a precise list of the areas of the aircraft that were surveyed and their status
(f) Findings
— a list of all the findings made during the airworthiness review with the corrective action carried out
(g) Statement
A statement signed by the airworthiness review staff recommending the issue of an airworthiness review certificate.
The statement should confirm that the aircraft in its current configuration complies with the following:
— airworthiness directives up to the latest published issue, and;
— type certificate datasheet;
— maintenance programme;
— limitation for life-limited parts and time-controlled components;
— the valid weight and centre of gravity schedule reflecting the current configuration of the aircraft;
— Part-21 for all modifications and repairs;
— the current flight manual including supplements, and;
— operational requirements.
The above items should clearly state the exact reference of the data used in establishing compliance; for instance the number and issue of the type certificate data sheet used should be stated.
The statement should also confirm that all of the above is properly entered and certified in the aircraft continuing airworthiness record system and/or in the operator’s technical log.
M.A.901(e) ARC issuance (MTOM<2730kg, not listed in AOC)
(e) For aircraft not used by air carriers licensed in accordance with Regulation (EC) No 1008/2008, and for aircraft of 2 730 kg MTOM and below, any CAMO or CAO chosen by the owner or operator may in accordance with CAMO.A.125(e) of Annex Vc or point M.A.711(b) of this Annex or CAO.A.095(c) of Annex Vd, as applicable, and subject to compliance with point (j):
1. issue the airworthiness review certificate in accordance with point M.A.901;
2. extend at most twice the validity of the airworthiness review certificate it has issued, for a period of 1 year each time, where the aircraft has remained within a controlled environment under its management.
M.A.901(f) ARC extension
(f) By derogation from points (c)(2) and (e)(2) of point M.A.901, for aircraft that are in a controlled environment, the organisation referred to in point (b)(1) managing the continuing airworthiness of the aircraft, may, subject to compliance with point (j), extend at most twice the validity of an airworthiness review certificate that the competent authority or another CAMO or CAO has issued, for a period of 1 year each time.
AMC M.A.901(c)2, (e)2 and (f) ARC extension
When the aircraft has remained within a controlled environment, the extension of the validity of the airworthiness review certificate does not require an airworthiness review but only a verification of the continuous compliance with M.A.901(b).
It is acceptable to anticipate the extension of the airworthiness review certificate by a maximum of 30 days without a loss of continuity of the airworthiness review pattern, which means that the new expiration date is set up one year after the previous expiration date. This anticipation of up to 30 days also applies to the 12 month requirements shown in M.A.901(b), meaning that the aircraft is still considered as being in a controlled environment if it has been continuously managed by a single organisation and maintained by appropriately approved organisations, as stated in M.A.901(b), from the date when the last airworthiness review certificate was issued until the date when the extension is performed (this can be up to 30 days less than 12 months).
It is also acceptable to perform the extension of an airworthiness review certificate after its expiration date, as long as all the conditions for the extension are met. However, this means the following:
— The aircraft could not fly since the airworthiness review certificate expired until it is extended, and
— The new expiration date (after extension) is set one year after the previous expiration date (not one year after the extension is performed).
Can the airworthiness review certificate (ARC) of the Part-M aircraft be extended during the extensive maintenance/long term storage?
An ARC extension could be performed as long as:
1. the conditions established for controlled environment (M.A.901 (b)) are met. This means:
1. continuously managed during the previous 12 months by a unique CAMO or CAO, and
2. maintained for the previous 12 months by Part-145, Part-M Subpart F or Part-CAO organisations.
AND
2. there is no evidence or reason to believe that the aircraft is not airworthy, as stated in M.A.901(j).
Thus, the procedure for the extension established in the CAMO or CAO has to address verification of the compliance with 3 above mentioned conditions. An aircraft going through the lengthy maintenance/modification or long-term storage is not considered to meet the condition number 2.
M.A.901(g) ARC by the competent authority
(g) Whenever circumstances reveal the existence of a potential risk to aviation safety, the competent authority shall carry out the airworthiness review and issue the airworthiness review certificate itself.
M.A.901(h) ARC by the competent authority
(h) Without prejudice to point (g), the competent authority may carry out the airworthiness review and issue the airworthiness review certificate itself in the following cases:
1. when the continuing airworthiness of the aircraft is managed by a CAMO or CAO which has its principal place of business located in a third country;
2. for any other aircraft of 2 730 kg MTOM and below, if the owner so requests.
M.A.901(i) Owner, operator responsibilities
(i) Where the competent authority issues the airworthiness review certificate itself in accordance with points (g) or (h) or after assessing the recommendation in accordance with point M.B.901, the owner or operator of the aircraft shall, where necessary for those purposes, provide the competent authority with:
1. any documentation required by the competent authority;
2. suitable accommodation at the appropriate location for its personnel;
3. the support of the certifying staff
AMC M.A.901(i) Suitable accommodation
Suitable accommodation should include:
(a) an office with normal office equipment such as desks, telephones, photocopying machines etc. whereby the continuing airworthiness records can be reviewed.
(b) a hangar when needed for the physical survey.
The support of personnel appropriately qualified in accordance with Part-66 is necessary when the competent authority’s airworthiness review staff is not appropriately qualified.
M.A.901 (j) ARC
(j) An airworthiness review certificate shall not be issued, nor extended if there is evidence or indications that the aircraft is not airworthy.
M.A.901(k) Documented review
(k) The airworthiness review of the aircraft shall include a full documented review of the aircraft records establishing that the following requirements have been met:
1. airframe, engine and propeller flying hours and associated flight cycles have been properly recorded;
2. the flight manual is applicable to the aircraft configuration and reflects the latest revision status;
3. all the maintenance due on the aircraft pursuant to the approved AMP has been carried out;
4. all known defects have been corrected or, when applicable, carried forward in a controlled manner in accordance with M.A.403;
5. all applicable ADs have been applied and properly registered;
6. all modifications and repairs applied to the aircraft have been registered and are in compliance with point M.A.304;
7. all life-limited parts and time-controlled components installed on the aircraft are properly identified, registered and have not exceeded their limitation;
8. all maintenance has been carried out in accordance with this Annex;
9. the current mass and balance statement reflects the current configuration of the aircraft and is valid;
10. the aircraft complies with the latest revision of its type design approved by the Agency;
11. if required, the aircraft holds a noise certificate corresponding to the current configuration of the aircraft in compliance with Subpart I of Annex I (Part-21) to Regulation (EU) No 748/2012.
AMC M.A.901(k) Full documented review
1. A full documented review is a check of at least the following categories of documents:
— registration papers;
— M.A.305 aircraft continuing airworthiness record system;
— M.A.306 aircraft technical log system;
— list of deferred defects, minimum equipment list and configuration deviation, list if applicable;
— aircraft flight manual including aircraft configuration;
— aircraft maintenance programme;
— maintenance data;
— relevant work packages;
— AD status;
— modification and SB status;
— modification and repair approval sheets;
— status of life-limited parts and time-controlled components;
— relevant EASA Form 1 or equivalent;
— mass and balance report and equipment list;
— aircraft, engine and propeller TC data sheets.
As a minimum, sample checks within each document category should be carried out.
2. The CAMO or CAO should develop procedures for the airworthiness review staff to produce a compliance report that confirms the above have been reviewed and found in compliance with Part-M.
M.A.901(l) Physical survey
(l) The airworthiness review of the aircraft shall include a physical survey of the aircraft. For that survey, airworthiness review staff not appropriately qualified in accordance with Annex III (Part-66) shall be assisted by such qualified staff.
M.A.901(m) Physical survey requirements
(m) Through the physical survey of the aircraft, the airworthiness review staff shall ensure that:
1. all required markings and placards are properly installed;
2. the aircraft complies with its approved flight manual;
3. the aircraft configuration complies with the approved documentation;
4. no evident defect can be found that has not been addressed in accordance with point M.A.403;
5. no inconsistencies can be found between the aircraft and the documented review of records referred to in point (k).
AMC M.A.901(l) and (m) Physical survey
1. The physical survey could require actions categorised as maintenance (e.g. operational tests, tests of emergency equipment, visual inspections requiring panel opening, etc.). In this case, after the airworthiness review, a release to service should be issued.
2. When the airworthiness review staff are not appropriately qualified as per Part-66 in order to release such maintenance, M.A.901(l) requires them to be assisted by such qualified personnel. However, the function of such Part-66 personnel is limited to performing and releasing the maintenance actions requested by the airworthiness review staff, it not being their function to perform the physical survey of the aircraft.
3. This means that the airworthiness review staff who is going to sign the airworthiness review certificate or the recommendation should be the one performing both the documented review and the physical survey of the aircraft. It is not the intent of the rule to delegate the survey to Part-66 personnel who are not airworthiness review staff. Furthermore, the provision of M.A.901(n) that allows a 90-day anticipation for the physical survey provides enough flexibility to ensure that the airworthiness review staff (ARS) are present.
4. The physical survey may include verifications to be carried out during flight.
5. The CAMO or CAO should develop procedures for the ARS to produce a compliance report that confirms that the physical survey has been carried out and found satisfactory.
6. To ensure compliance, the physical survey may include relevant sample checks of items.
M.A.901(n) ARC anticipation
(n) By derogation from point (a), the airworthiness review may be anticipated by a maximum period of 90 days without loss of continuity of the airworthiness review pattern, so as to allow for the physical review to take place during a maintenance check.
AMC M.A.901(n) Anticipation period
‘Without loss of continuity of the airworthiness review pattern’ means that the new expiration date is set up 1 year after the previous expiration date. As a consequence, when the airworthiness review is anticipated, the validity or the airworthiness review certificate is longer than 1 year (up to 90 days longer).
This anticipation of up to 90 days also applies to the 12-month requirements shown in M.A.901(b), which means that the aircraft is still considered as being in a controlled environment if it has been continuously managed by a single organisation and maintained by appropriately approved organisations, as stated in M.A.901(b), from the date when the last airworthiness review certificate was issued until the date when the new airworthiness review is performed (this can be up to 90 days less than 12 months).
Can the extension of an ARC be anticipated more than 30 days?
Assuming the aircraft satisfies the conditions for extension established in M.A.901 or ML.A.901, 30 days is the maximum allowed period for which the ARC extension can be anticipated without losing the continuity of the airworthiness review pattern. This means that the new expiration date is established as one year after the previous expiration date (AMC M.A.901(c)2, (e)2 and (f), ML.A.901(d)). If the extension is anticipated by more than 30 days, the new expiration date will be established as one year after the date of extension.
Is an aircraft considered to be in controlled environment at the end of the ARC validity when that aircraft was received by the CA(M)O during the 90/30 days anticipation of the ARC issue/extension performed by the preceding CA(M)O?
CA(M)O 1 uses the anticipation when performing the airworthiness review or extension for 90 or 30 days correspondingly. After the issue or extension of the ARC, the aircraft is transferred during the anticipation period from CA(M)O 1 to CA(M)O 2. As the consequence CA(M)O 2 has solely continuously managed the aircraft for more than 12 months due to the term of the validity of the ARC accordingly being more than 12 months. Are the requirements of the M.A.901(b) point 1 satisfied? The intent of the point M.A.901(b) point 1 is to define the ‘controlled environment’ (see also ML.A.901(c)(1)) by indicating that the aircraft must be managed during last 12 months by unique CA(M)O, which indirectly refers to a standard term of validity of the ARC. Therefore, if the aircraft has been managed by more than one CA(M)O since the date of issue of the last ARC or the date of issue of the ARC extension, it actually indicates that controlled environment was discontinued. In addition, in accordance with M.A.901(n) or ML.A.903(d) the 90 days anticipation for the ARC issue shall be used to allow the physical review to be performed during a maintenance check. Hence the intention of the rule is not to address the transfer of the aircraft within those 90 days with the purpose of avoiding the forthcoming airworthiness review. Concerning the ARC extension and its 30 days anticipation, point M.A.901(f) [AMC M.A.901(c)2, (e)2 and (f)] or ML.A.901(d) are intended for 2 consecutive extensions by the same CA(M)O managing the continuing airworthiness of the aircraft from the date of issue of the ARC. Therefore, an ARC extended for the first time by an organisation cannot be extended a 2nd time by another organisation, because this constitutes a ‘breach’ in controlled environment.
M.A.901(o) ARC Forms
(o) The airworthiness review certificate (EASA Form 15b) or the recommendation for the issue of the airworthiness review certificate (EASA Form 15a) referred to in Appendix III to this Annex can only be issued:
1. by authorised airworthiness review staff on behalf of the approved organisation;
2. if the airworthiness review has been completely carried out.
AMC M.A.901(o) ARC documentation
A copy of both the physical survey and document review compliance reports stated above should be sent to the competent authority together with any recommendation issued.
M.A.901(p) ARC documentation
(p) A copy of any airworthiness review certificate issued or extended for an aircraft shall be sent to the Member State of registry of the aircraft concerned within 10 days.
M.A.901(q) Airworthiness tasks
(q) Airworthiness review tasks shall not be subcontracted.
M.A.901(r) Inclusive airworthiness review
(r) Should the outcome of the airworthiness review be inconclusive, the organisation having carried out the review shall inform the competent authority as soon as possible and in any case within 72 hours from the moment the organisation identifies the reason for which the airworthiness review is inconclusive.
M.A.901(s) ARC findings
(s) The airworthiness review certificate shall not be issued until all findings have been closed.