Requirements for maintenance staff for non-EASA aircraft

The pilot-owner authorisation is limited to scheduled maintenance and repairs of minor defects and damage for which the type-approval holder or manufacturer of the aircraft or equipment attached to it has given instructions or for which there are generally approved or Traficom-issued maintenance instructions.

Pilot-owners may carry out simple visual inspections or operations to check for the general condition, obvious damage and normal operation of the airframe, engines, systems and components. They are not allowed to issue certificates of release to service in connection with annual inspections.

In the case of type-approved non-EASA motor gliders or non-EASA aircraft that are type-approved and non-motor-powered or operate under a permit to fly, pilot-owners have a wider authorisation for independent maintenance of the above-mentioned aircraft if they have sufficient training, experience and skills for the aircraft group, maintenance operation, structural material or equipment in question and hold (or have held) a pilot licence for the group of aircraft being maintained.

For more information on pilot-owner maintenance of aircraft within the scope of the EASA Basic Regulation, please see the Continuing Airworthiness Regulation point M.A.803 onwards.

At present, the maintenance of EASA-approved ELA1 (MTOM < 1,200 kg) gliders, motor gliders and hot air balloons is governed by the national Aviation Regulation PEL M3-4 on licensing. The extended pilot-owner authorisations for the maintenance of these aircraft are governed by the national Aviation Regulation AIR M1-5. The provisions of these two regulations apply until 1 October 2020.

After that, only personnel with a Part-66 licence issued in accordance with the Continuing Airworthiness Regulation may issue certificates of release to service for any ELA1 aircraft maintenance operations that go beyond pilot-owner maintenance. National maintenance privileges will be converted into Part-66 licences in accordance with the conversion report prepared by Traficom. Conversions will begin on 1 October 2019.

The maintenance of Annex I aircraft that are subject to national regulation will continue as before. Their maintenance personnel and operations are subject to the provisions of the national Aviation Regulations PEL M3-4 and AIR M1-5.

Conversion of national privileges

In accordance with the conversion report prepared by Traficom, national maintenance privileges can be converted to a Part-66 licence in the subcategory L1 (sailplanes), L2 (powered sailplanes) or L3H (hot-air balloons) with corresponding privileges. In this context, national maintenance privileges refer to extended pilot-owner authorisations under section 2.4.3 of AIR M1-5 or the aircraft maintenance mechanic’s or general aircraft mechanic’s licence under PEL M3-4.
The conversion of extended pilot-owner authorisations requires the applicant to demonstrate that they meet the training requirements laid down in AIR M1-5 and to act as one of the owners of an aircraft or as a maintenance person appointed by an organisation for recreational aviation.

The licences of professional mechanics holding a Part-66 licence in subcategory B1.2 (or B3) and a Group 3 type rating will be automatically extended to include corresponding privileges in subcategories L1 and L2 in connection with the next reissue of the licence.

New Part-66 licences

To qualify for a new Part-66 licence you must complete theoretical knowledge examinations in each subcategory and demonstrate the required supervised work experience with a logbook. Traficom is preparing to organise theoretical examinations during autumn 2019 by drafting the examination questions in collaboration with recreational organisations.

For EASA-approved ELA1 aeroplanes and helicopters, maintenance operations that go beyond pilot-owner maintenance are governed by the requirements of the Continuing Airworthiness Regulation. Such operations require a Part-66 licence.

To apply for the licence, you must meet the following requirements:

• 80 hours of maintenance training
  • for motor-powered aircraft, an additional 20 hours of training on the scheduled maintenance of aircraft engines
• sufficient knowledge of at least the following:
  • aviation legislation on maintenance
  • annual inspections
  • weighing of aircraft
  • at least one group of structural materials
• maintenance experience of at least two years and 500 working hours

To apply for the licence, you must meet the following requirements:

• successful completion of training for an aircraft maintenance mechanic licence provided by a maintenance personnel training organisation in compliance with the ICAO manual or a more advanced training
• at least two years’ experience of aeroplane and helicopter maintenance as main occupation