Looming large on the horizon, from August 25, 2016 operators in Europe who do not comply with EASA’s Part-NCC requirement will be grounded. Enrollment in a CAMO program could be a straight-forward solution for those still needing to comply. Lufthansa Bombardier Aviation Services’ Jörg Rumstedt and Matthias Büttner explain why…
In spite of the imminent threat of grounding, there are still many aircraft that have yet to comply with EASA’s Part-NCC (Non-Commercial operations with Complex motor-powered aircraft) mandate. Part-NCC will impact all jet and turboprop aircraft, including some that are not even registered within the EU...
According to the UK’s CAA, Part-NCC requires all operators to adhere to the same essential requirements as commercial air transport operators. But instead of holding an Air Operator’s Certificate (AOC), private operators will need to submit a declaration to their local aviation authority concerning their operation, helping establish and maintain the required oversight program for the aircraft. That program should be tailored to the nature and complexity of each individual operation; by submitting the declaration, the operator ultimately accepts responsibility, accountability and liability for itself under the new regulation.
Also required, operators must have an Operations Manual (containing procedures, instructions and guidance for use by operational personnel in the execution of their duties), and operators must also be able to demonstrate they have an active management system in place.
Beware: Part-NCC will impact more than just aircraft registered to an EASA state.
The requirements extend to those not registered within the EU but where the operator is established or residing in an EASA state. Currently, there are around 1,200 N-Registered aircraft that are active within Europe (for example), and these should ensure they will not fall foul of the new rules when they come into effect.
When EASA made it mandatory for all EU-registered aircraft to join a Continuing Airworthiness Management Organization (CAMO) program, we saw some operators move their aircraft onto non-EU registers while continuing to operate within EASA states. This included some jets joining the Isle of Man register.
Part-NCC will squeeze such operators to enroll in a CAMO program (or at least parts of it) irrespective of where their aircraft is registered if their primary operations fall within EASA airspace. In effect, the net is closing…
How Could CAMO Help?
As a requirement for aircraft used for private or public transport within the EASA region, Continuing Airworthiness Management is designed to help operators achieve better dispatch reliability, improve their safety levels and reduce the overall cost of operation.
Within the increasingly complex regulatory environment of EASA airspace, however, CAMO can help those seeking to become compliant with Part-NCC. As an example, one of the key aspects of an operator’s aircraft on-board documentation is the Minimum Equipment List (MEL). Part-NCC requires private operators (including those not registered within the EU but primarily operating there) to tailor the MEL to their aircraft.
With an aircraft-specific MEL required, an operator must think beyond the generic MMEL supplied by the OEM that may not take into account any individual aircraft configurations or subsequent modifications.
Some owners would certainly benefit from having the dedicated eyes of a CAMO-provider developing and maintaining their tailored MEL.
Furthermore, a CAMO solution could help satisfy Part-NCC’s requirement for regular audits and inspections of an aircraft by an approved organization, assuring continuous airworthiness management with a tailored management system for an individual aircraft that tracks and predicts maintenance tasks, life limited components, airworthiness directives and service bulletins, while forecasting and monitoring maintenance, tracking operating hours, and collecting and reporting on engine data.
Taking care of technical records management (including airframe, engine, log books and more) while addressing EASA’s goal to press for increased safety standards within its airspace by ensuring a more proactive approach from its operators, CAMO helps operators coordinate all maintenance requirements (including scheduling, creating work packages and providing job cards to the chosen maintenance facility), providing repair/modification approval and status management, supervising the event and ensuring continued airworthiness for the operator.
It may also be worth understanding that in relation to operators obtaining certification of airworthiness, some CAMO providers are additionally approved to carry out an airworthiness review of a client’s aircraft in the name of the applicable aviation authority. Check with a prospective provider if this is something required by your operation.
Tailored to Need: MMS
While all EU operators of Complex Motor-Powered Aircraft are required to subscribe to a whole CAMO program and non-EU registered aircraft whose primary business is within EASA states also need to nominate a person or organization responsible for continuing airworthiness per Part-NCC requirements, operators of aircraft registered and/or operated elsewhere may find it worthwhile contacting a CAMO provider to discuss their specific needs in relation to Maintenance Management Services (MMS).
For example, the MMS offered by Lufthansa Bombardier Aviation Services is a program tailored to a specific operator’s requirements by modular selection of its CAMO product – thus the operator can select only the aspects of a CAMO program that enables them to comply with Part-NCC, irrespective of where the aircraft is based within the world.
Effectively CAMO (or MMS in the case of non-EASA registered aircraft) helps bring the various threads relating to ongoing airworthiness (Part-NCC included) into one point of contact, freeing the aircraft owner to concentrate on maximizing the productivity of their Business Aviation operations – the quick and convenient transportation of key personnel aboard the company aircraft!