Regulatory framework: Part-66 licensing, Part-M continuing airworthiness, Part-145 organisations, Part-147 training
Module 16 items in this domain are boundary questions: they describe an act - releasing an engine, approving a maintenance programme, running a type course - and ask who may do it and under which annex of Regulation (EU) No 1321/2014. Answer with three probes: is the aircraft used in commercial air transport (CAT); is the item an aircraft or a component; and is the certificate held by a person or by an organisation.
The legal stack
- Basic Regulation (EU) 2018/1139 empowers EASA; 1321/2014 carries the detailed rules as Annex I Part-M, Annex II Part-145, Annex III Part-66 and Annex IV Part-147.
- Part-ML (Reg (EU) 2019/1383, applicable 24 March 2020) covers most aircraft at or below 2730 kg not used in CAT; Part-M Subpart F remains for the other non-CAT aircraft.
Part-66 - the person
- Categories: A (limited line), B1 (mechanical), B2 (avionics), B2L, B3 (light piston aeroplanes), C (base maintenance). The licence is valid 5 years.
- Experience: A - 2 years, or 1 with Part-147 basic training; B1.1 and B2 - 5 years, or 3 with Part-147 basic training.
- To certify, 6 months of maintenance experience on type within the preceding 2 years (145.A.35), plus a company certification authorisation.
Part-145 - the organisation
- Mandatory for aircraft used in CAT and their components: MOE, nominated persons, stores, tooling, current maintenance data, and a quality system auditing all parts within 12 months.
- Releases aircraft with a CRS and components with EASA Form 1; serious occurrences are reported within 72 hours.
Part-M and Part-147
- Part-M: continuing airworthiness - AMP, AD compliance, records, airworthiness review and the ARC (EASA Form 15a, valid 1 year). Non-CAT maintenance may be released under M.A.801 without a Part-145.
- Part-147 approves training only (75% pass mark); it grants no maintenance privileges.
Worked example
An A320 operator in CAT needs an engine change at an outstation. The mechanic holds B1.1 with the type endorsed and last certified on type 14 months ago, so recency is met. The work must still be done by a Part-145 whose capability list and MOE cover it; the aircraft is released with a CRS, the engine with an EASA Form 1, and the Part-M records are updated. The same task on a privately flown Cessna 172 could be released by a Part-M organisation or an independently authorised Part-66 holder.
Traps
- Confusing EASA Form 1 (component release) with Form 15a (ARC).
- Assuming a Part-66 licence alone permits certification on CAT aircraft - it never does without a Part-145 authorisation.
- Treating a Part-147 certificate as a licence.