ARC expiry during an overrunning heavy check with an unembodied AD
Skyline is a Part-CAMO organisation holding the airworthiness review privilege for the six aircraft it manages. One of them, an Airbus A320, has an airworthiness review certificate expiring on 12 November. A 2C check began at a Part-145 base on 28 October. On 4 November the base finds widespread corrosion in the centre wing box, obtains a repair scheme from the type certificate holder and warns that the check will overrun to about 30 November. The continuing airworthiness manager notes that the maintenance programme revision incorporating a newly issued EASA AD has been drafted but not yet approved, and that the AD's compliance date fell on 1 November. The lessee wants the aircraft back in commercial service on 15 November and suggests that Skyline 'extend the ARC by 30 days and complete the airworthiness review retrospectively once the aircraft is flying again'.
1. Is Skyline entitled to extend the ARC? Set out the conditions and who may grant the extension.
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An extension exists in principle, but on these facts it is not available.
The rule (M.A.901 and the corresponding Part-CAMO provisions) allows a single extension of the ARC, not exceeding 30 days, where the airworthiness review cannot be completed before expiry because the aircraft is in a maintenance check. It must be granted in accordance with the organisation's procedures by a person authorised for that purpose within the CAMO holding the privilege, must be recorded in the aircraft records, and the review must actually be completed within the extended period. Skyline's 30 November completion is 18 days past 12 November, so it would fit inside the 30-day window.
However, the extension is not a device for keeping an aircraft with outstanding mandatory items in service. It presupposes that continuing airworthiness has been properly managed up to expiry, including the maintenance programme in force and AD compliance. Here the AD became due on 1 November and the amendment embodying it has neither been approved nor embodied, so at the moment of expiry the aircraft is not in compliance. That is a compliance gap, not an administrative delay.
Conclusion: the extension must not be granted, and the review cannot be signed off retrospectively. An extension is granted before expiry, never after the aircraft is flying again.
2. The lessee insists the aircraft must fly on 15 November. What are the regulatory options and their limits?
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Without a valid ARC and without a validly granted extension, the aircraft cannot be flown for commercial air transport. Commercial pressure does not create a privilege: the CAMO cannot backdate an ARC, and the Part-145 cannot release the aircraft into service on the strength of an extension that was never validly granted. Signing or issuing an ARC in those circumstances would be a serious finding for both organisations.
Realistic options:
- Complete the work and issue the ARC late. Finish the check, embody the AD, fit the approved repair, then complete the airworthiness review and issue the ARC - realistically after 30 November.
- Permit to fly for a ferry flight. Under Part-21 a permit to fly may be requested for a non-commercial flight (for example a ferry to another maintenance base), subject to the competent authority's approval and to the aircraft being safe for that flight. It is not an ARC, cannot be issued by the CAMO as a substitute, and cannot be used to carry passengers for reward.
- Renegotiate the delivery date with the lessee and document the decision.
The CAMO should record the assessment, the reason the extension was refused and the alternative chosen, so that the judgement is auditable later.
3. What must be resolved about the corrosion repair and the maintenance programme before an ARC can be issued?
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Three things must close before the review can succeed.
Approval of the repair data. Check that the TC holder's scheme is approved data for the damage actually found and for this aircraft's configuration. If the repair is major and is not covered by the TC holder's approved data, it needs approval under Part-21 from EASA or a design organisation. A repair designed and fitted without that approval cannot support an ARC.
Recording. The Part-145 must record the repair in the aircraft logbook and in the continuing airworthiness records, referencing the approved data and any Form 1 for parts used, so the review can trace it.
Continuing airworthiness consequences. The repair may introduce repetitive inspections, change the corrosion programme or add structural repair manual references; these must be reflected in the maintenance programme. The programme revision itself must be approved through the CAMO's approved route (directly by the competent authority, or under an indirect approval where one has been granted) before the aircraft is maintained to it. Separately, the AD must be embodied - compliance with an applicable airworthiness directive is not optional and does not wait for programme approval.
The airworthiness review then checks AD status, repair records, mass and balance, modifications and the approved programme against the actual aircraft.