EASA eRules: Continuing Airworthiness

Easy Access Rules for Continuing Airworthiness 

(Regulation (EU) No 1321/2014) 

The new portions in the EASA Easy Access Rules for Continuing Airworthiness (Regulation (EU) No 1321/2014), particularly in the July 2024 edition, include several recent amendments and decisions that have been incorporated since previous versions. These updates focus on adapting to evolving aviation needs, such as:

1.    Introduction of More Proportionate Requirements for Aircraft Used in Sport and Recreational Aviation: This change (from Regulation (EU) 2022/1360 and ED Decision 2023/013/R) aims to simplify requirements for smaller aircraft used for leisure, reducing unnecessary complexity in managing their airworthiness.

2.    Information Security Risks: A new focus on managing information security risks (Regulation (EU) 2023/203 and ED Decision 2023/010/R) addresses the increasing importance of cyber resilience in aviation. Organizations are now required to manage security risks that could potentially impact aviation safety.

3.    Review of Part-66 and New Training Methods: New teaching technologies and training methods have been introduced to keep up with modern instructional approaches (Regulation (EU) 2023/989, ED Decision 2023/019/R). This ensures that personnel receive up-to-date training in line with the latest industry developments.

Why EASA Issued the eRules:

EASA issued the eRules to make aviation regulations more accessible, easier to navigate, and up to date for stakeholders in the aviation industry. The eRules system provides a consolidated, user-friendly platform that combines EU regulations with the related EASA Executive Director Decisions. The goal is to enhance safety, efficiency, and compliance by offering stakeholders a single source for all aviation safety rules that is regularly updated and easy to reference. This system is particularly beneficial for ensuring consistent compliance across member states and for aviation organizations globally ​(ICAO_SR_2024).

The table (p. 34) in the "Summary of Applicability" from the EASA Easy Access Rules for Continuing Airworthiness (Regulation (EU) No 1321/2014), provides an overview of the applicability of various regulatory annexes to different types of operations concerning continuing airworthiness requirements.

• Part-M (Annex I) is mandatory for licensed air carriers, particularly for commercial operations involving complex motor-powered aircraft (CMPA). Non-licensed air carriers are exempt unless operating commercial non-complex aircraft.
• Part-ML (Annex Vb) applies to non-commercial aircraft, particularly for light aircraft (e.g., aeroplanes up to 2,730 kg MTOM or rotorcraft up to 1,200 kg MTOM), and its usage is mandatory in those contexts.
• Part-CAMO (Annex Vc) is mandatory for organizations managing the continuing airworthiness of licensed air carriers operating CMPA or non-CMPA, whether they are involved in commercial or non-commercial operations. It may also apply optionally to individual continuing airworthiness management.
• Part-CAO (Annex Vd) applies in a dual role: for continuing airworthiness management (CAO-CAM) and maintenance privileges (CAO-M), depending on the aircraft and operational type. It provides flexibility for certain types of aircraft that are maintained under the supervision of organizations or individual operators.
• Part-145 (Annex II) is mandatory for all commercial operators and complex motor-powered aircraft maintenance, ensuring that high standards of maintenance are applied consistently across operators that fall under these categories.

This table essentially categorizes the rules for managing continuing airworthiness and outlines which regulatory parts apply depending on whether the aircraft is used commercially, non-commercially, or operated under specific maintenance organizations.

For starters, the table is confusing; however, in reality, the table serves to simplify the tasks of explaining the terms.

Here’s a simple and detailed explanation of the parts or annexes (M, ML, CAMO, CAO, 145) referred to in the context of EASA's continuing airworthiness regulations:

1. Part-M (Annex I)

• Purpose: Part-M is focused on the continuing airworthiness of aircraft. It sets out requirements for owners, operators, and organizations involved in maintaining the airworthiness of both commercial and non-commercial aircraft.
• Who it applies to: Licensed air carriers and larger aircraft operations, including complex motor-powered aircraft (CMPA), and in some cases, non-licensed air carriers.
• Key Requirements: Owners and operators must maintain aircraft in a condition that meets airworthiness standards, conduct regular inspections, maintain records, and comply with airworthiness directives.

2. Part-ML (Annex Vb)

• Purpose: Part-ML is specifically tailored for light aircraft. It simplifies the airworthiness requirements for smaller, less complex aircraft, reducing the administrative burden on aircraft owners while ensuring safety.
• Who it applies to: Non-commercial operations of light aircraft, such as planes with a maximum take-off mass (MTOM) of up to 2,730 kg or small rotorcraft.
• Key Requirements: Owners are responsible for keeping their light aircraft in airworthy condition, following simplified maintenance rules suited to the smaller aircraft's less complex systems.

3. Part-CAMO (Annex Vc)

• Purpose: Part-CAMO (Continuing Airworthiness Management Organisation) defines the requirements for organizations that manage the continuing airworthiness of aircraft. It ensures that aircraft remain safe and compliant with airworthiness regulations throughout their lifecycle.
• Who it applies to: CAMO applies to licensed air carriers, both for complex motor-powered aircraft and non-complex motor-powered aircraft, whether for commercial or non-commercial operations.
• Key Requirements: These organizations must oversee the planning and execution of all maintenance and airworthiness checks, ensuring that the aircraft remains safe to operate.

4. Part-CAO (Annex Vd)

• Purpose: Part-CAO (Combined Airworthiness Organisation) allows organizations to provide both continuing airworthiness management and maintenance services under a single approval. This offers flexibility for smaller organizations that might not need the full capabilities of larger CAMOs or maintenance organizations.
• Who it applies to: Typically smaller organizations involved in general aviation that want to combine both airworthiness management and maintenance under one roof.
• Key Requirements: Organizations operating under Part-CAO can manage airworthiness and conduct maintenance on specific aircraft, ensuring compliance with the necessary regulations for both roles.

5. Part-145 (Annex II)

• Purpose: Part-145 covers the approval and regulation of maintenance organizations, ensuring that they meet stringent standards for maintaining aircraft and their components. It includes rules for carrying out maintenance activities to ensure the airworthiness of commercial aircraft and complex motor-powered aircraft.
• Who it applies to: Organizations performing maintenance on larger or more complex aircraft, especially those used in commercial operations.
• Key Requirements: These organizations must follow strict procedures for aircraft repair, servicing, and inspection, ensuring high standards of safety and compliance with aviation regulations.

Summary:

• Part-M (Annex I): General airworthiness rules for all aircraft, focusing on ensuring continuous airworthiness.
• Part-ML (Annex Vb): Simplified airworthiness management for light aircraft in non-commercial operations.
• Part-CAMO (Annex Vc): Organizations managing the airworthiness of aircraft, ensuring they meet ongoing safety standards.
• Part-CAO (Annex Vd): Combined organizations that handle both airworthiness management and maintenance for smaller aircraft operators.
• Part-145 (Annex II): Maintenance organizations that work on commercial or complex aircraft, ensuring high safety and quality standards.

These parts define the framework under which different organizations and aircraft owners maintain the airworthiness of aircraft in Europe, ensuring safety across various types of operations.

The "N/A" (Not Applicable) entries in the column for "Non-licensed air carrier, non-commercial" in the table on page 34 indicate that the specific Part or Annex is not required for that category of operation. Here's a breakdown of why each of these parts or annexes is marked as N/A for non-licensed, non-commercial operations:

1.    Part-M (Annex I):

o   Reason for N/A: This Part is focused on the continuing airworthiness of larger and more complex aircraft, typically for licensed air carriers or those involved in commercial operations. Non-licensed, non-commercial aircraft, such as those used privately, are not bound by the full scope of Part-M. These aircraft usually fall under simplified rules like Part-ML, which is tailored for light aircraft and non-commercial operations.

2.    Part-ML (Annex Vb):

o   Reason for N/A: Part-ML is meant to simplify airworthiness regulations for light aircraft in non-commercial operations. However, when it says N/A here, it is because the table entry implies that Part-ML is not universally mandatory for all non-licensed, non-commercial operations, especially if the aircraft do not fall under the "light" category defined by this annex.

3.    Part-CAMO (Annex Vc):

o   Reason for N/A: Part-CAMO is intended for organizations managing continuing airworthiness of complex aircraft or commercial operations. For non-licensed, non-commercial operations, the owner usually manages the airworthiness themselves (without a CAMO organization), so Part-CAMO is not applicable.

4.    Part-CAO (Annex Vd):

o   Reason for N/A: Part-CAO allows for combined airworthiness management and maintenance organizations. For individual non-commercial operators, especially non-licensed air carriers, such combined organizations are not mandatory, as their needs can be simpler, typically involving individual maintenance or owner-pilot management.

5.    Part-145 (Annex II):

o   Reason for N/A: Part-145 regulates maintenance organizations handling more complex and commercially operated aircraft. For non-licensed, non-commercial aircraft, owners often perform maintenance themselves or use smaller, less regulated maintenance options, which do not require full Part-145 compliance.

The "N/A" indicates that the regulations under these parts or annexes are not required for non-licensed, non-commercial operations because such operations generally involve simpler, less regulated airworthiness management and maintenance practices, often performed by the aircraft owner or pilot, and do not require the formal structures set out in the respective Parts (M, ML, CAMO, CAO, 145). The requirements in these parts are more suited to complex, commercial, or licensed operations.

For the "Non-commercial, CMPA (Complex Motor-Powered Aircraft)" category, the table indicates that CAO-CAM and CAO-M are Not Applicable (N/A). The reason behind this is related to the specific roles and requirements of these categories:

1.    CAO-CAM (Continuing Airworthiness Management under Part-CAO):

o   Reason for N/A: The CAO (Combined Airworthiness Organisation) concept is designed for smaller, less complex operations, often involving non-complex aircraft in general aviation. Complex Motor-Powered Aircraft (CMPA) are sophisticated and require more stringent airworthiness oversight due to their complexity, often involving commercial-like standards even in non-commercial operations. Therefore, the applicable framework for managing the airworthiness of CMPA falls under Part-CAMO, which is more rigorous and specifically designed for such complex aircraft. Part-CAO is not considered robust enough to handle the airworthiness management of CMPA, so it is marked as N/A in this category.

2.    CAO-M (Maintenance under Part-CAO):

o   Reason for N/A: Similar to CAO-CAM, CAO-M (maintenance under Part-CAO) is intended for smaller, less complex aircraft and simpler operations. CMPA, on the other hand, requires higher standards of maintenance due to their complexity, which involves more regulated and specialized maintenance procedures typically handled by organizations approved under Part-145. Since Part-145 offers a more rigorous and appropriate framework for maintaining CMPA, CAO-M is not suitable or applicable for these aircraft. As such, CAO-M is marked as N/A because it would not meet the required standards for complex aircraft maintenance.

In short, CAO-CAM and CAO-M are marked as N/A for non-commercial CMPA because these aircraft are subject to more stringent regulations due to their complexity. Part-CAMO and Part-145 provide the necessary level of oversight and maintenance rigor for CMPA, while the CAO framework is intended for simpler, less complex operations and aircraft.

Let's break down the N/A (Not Applicable) entries under the columns "Non-licensed air carrier, commercial" and "Licensed air carrier" in relation to the different parts (M, ML, CAMO, CAO, 145) from the table:

1. Non-licensed Air Carrier, Commercial

For non-licensed air carriers operating commercially, certain Parts are marked as N/A because they do not apply to such operations. Here’s why:

• Part-ML (Annex Vb):
• Reason for N/A: Part-ML is intended for light, non-commercial aircraft operations. Commercial operations, even for non-licensed air carriers, are expected to follow stricter airworthiness and maintenance regulations. Since Part-ML is designed for non-commercial, light aircraft operations, it is not applicable to any commercial use, even by non-licensed carriers. Hence, Part-ML is marked as N/A for non-licensed air carrier, commercial operations.
• CAO-CAM and CAO-M (Annex Vd):
• Reason for N/A: CAO regulations (combined airworthiness and maintenance organizations) are typically intended for smaller or non-commercial operators who manage their own continuing airworthiness and maintenance. Commercial operators, even if non-licensed, are subject to higher regulatory standards to ensure safety due to the nature of their operations. They are expected to follow more comprehensive frameworks like Part-CAMO for airworthiness management and Part-145 for maintenance, both of which are more stringent and appropriate for commercial activities. As a result, CAO-CAM and CAO-M are marked N/A for commercial non-licensed air carriers.

2. Licensed Air Carrier

For licensed air carriers (e.g., airlines), certain parts are also marked N/A because they are not relevant to the scale and nature of these operations. Here's why:

• Part-ML (Annex Vb):
• Reason for N/A: Part-ML is aimed at light, non-commercial aircraft. Licensed air carriers operate larger, more complex aircraft, and are required to follow more comprehensive regulations (like Part-M) that cover continuing airworthiness for commercial operations. Since Part-ML is meant for simpler aircraft and non-commercial use, it is not applicable to licensed air carriers operating commercial flights. Thus, Part-ML is marked as N/A for licensed air carriers.
• CAO-CAM and CAO-M (Annex Vd):
• Reason for N/A: Licensed air carriers typically operate complex fleets of aircraft that require the highest level of oversight and regulation. This means their continuing airworthiness and maintenance must be handled by organizations complying with Part-CAMO and Part-145, respectively, which are more suitable for managing large, complex, and commercial aircraft. CAO provisions are intended for smaller, less complex operations that do not meet the rigorous demands of large licensed air carriers. Therefore, CAO-CAM and CAO-M are marked as N/A for licensed air carriers because these carriers must adhere to more stringent standards.

• Non-licensed air carrier, commercial: Parts like Part-ML, CAO-CAM, and CAO-M are not applicable because non-licensed commercial operators must follow stricter, more comprehensive regulations designed for commercial activities, such as Part-M, Part-CAMO, and Part-145.
• Licensed air carrier: For licensed air carriers, Part-ML, CAO-CAM, and CAO-M are not applicable because these carriers operate larger, more complex aircraft, which require adherence to more rigorous frameworks like Part-M, Part-CAMO, and Part-145 that ensure higher safety standards in commercial aviation.

Here’s a memory guide to help clarify and remember which parts or annexes apply to different categories of aircraft and carriers. This guide simplifies the logic of applicability based on the categories of aircraft and operations.

Memory Guide for Parts Applicability

Key Points to Remember

1.    Part-M: Comprehensive for larger, complex, or commercial aircraft.

2.    Part-ML: Simplified for light, non-commercial aircraft.

3.    Part-CAMO: Mandatory for managing complex aircraft and commercial airworthiness.

4.    Part-CAO: Combined for smaller, simpler non-commercial aircraft.

5.    Part-145: Strict maintenance regulations for complex and commercial aircraft.

Categories and Applicability Overview

1. Licensed Air Carrier, Commercial (e.g., Airlines)

• Part-M: Mandatory
• Part-ML: Not Applicable (Because commercial airlines operate larger, more complex aircraft)
• Part-CAMO: Mandatory
• Part-CAO: Not Applicable (Used for smaller organizations, not large commercial airlines)
• Part-145: Mandatory (Aircraft maintenance)

Memory Tip: Big and Complex = Part-M, Part-CAMO, and Part-145 are always mandatory.

2. Non-licensed Air Carrier, Commercial

• Part-M: Mandatory (Required for airworthiness of commercial non-licensed operations)
• Part-ML: Not Applicable (Because it’s for non-commercial light aircraft)
• Part-CAMO: Mandatory
• Part-CAO: Not Applicable (Like licensed commercial carriers, they need higher regulation)
• Part-145: Mandatory (Maintenance must follow strict standards)

Memory Tip: Non-Licensed but Commercial = Still requires Part-M, Part-CAMO, and Part-145.

3. Licensed Air Carrier, Non-commercial

• Part-M: Mandatory
• Part-ML: Not Applicable
• Part-CAMO: Mandatory
• Part-CAO: Not Applicable
• Part-145: Mandatory

Memory Tip: Licensed Air Carriers (even non-commercial) = Part-M, Part-CAMO, and Part-145 are still mandatory because of the complexity of the aircraft.

4. Non-licensed Air Carrier, Non-commercial

• Part-M: Not Applicable
• Part-ML: Mandatory (if light aircraft)
• Part-CAMO: Not Applicable (not needed unless aircraft is complex)
• Part-CAO: Optional (can use for combined airworthiness management and maintenance if needed)
• Part-145: Not Applicable (not needed for simple or light aircraft)

Memory Tip: Non-Licensed and Non-commercial = Part-ML for light aircraft and CAO for combined operations.

5. Complex Motor-Powered Aircraft (CMPA), Non-commercial

• Part-M: Mandatory
• Part-ML: Not Applicable
• Part-CAMO: Mandatory (CMPA requires strict management, even non-commercial)
• Part-CAO: Not Applicable
• Part-145: Mandatory (Strict maintenance rules for CMPA)

Memory Tip: CMPA always requires = Part-M, Part-CAMO, and Part-145, no matter if commercial or non-commercial.

Quick Mnemonics:

• Commercial & Complex = Part-M, Part-CAMO, Part-145 Mandatory.
• Light Non-commercial = Part-ML or CAO (simpler management).
• If it’s big or commercial, forget Part-ML, it’s N/A.
• CAO is for smaller organizations; licensed and complex operations need stricter rules.

By associating each type of carrier and operation with key parts (M, ML, CAMO, CAO, and 145), you can recall their mandatory or non-applicable statuses more easily. Just remember, larger and commercial operations require stricter standards, while non-commercial light aircraft get simpler rules.

-ooo-