Npa - 2021-15 New Air Mobility

European Union Aviation Safety Agency
Notice of Proposed Amendment 2021-15

in accordance with
Articles 6(3), 7 and 8 (‘Standard procedure’: public consultation) of MB Decision
No 18-2015
New air mobility

Continuing airworthiness (CAW) rules for electric and hybrid propulsion aircraft and other non-
conventional aircraft
RMT.0731 (SUBTASK 1)
EXECUTIVE SUMMARY
The objective of this Notice of Proposed Amendment (NPA) is to close the gaps that currently exist in Regulation
(EU) No 1321/2014, which pose compliance difficulties in relation to the management of manned aircraft that
are not conventional or have a powerplant other than a piston engine or a turbine.
This NPA proposes to amend the different Annexes to Regulation (EU) No 1321/2014 in order to address the
regulatory gaps that the Agency has identified regarding non-conventional aircraft (i.e. aircraft other than
aeroplanes, rotorcraft, sailplanes, balloons or airships) or aeroplanes or rotorcraft with a powerplant other than
a piston engine or turbine. Several of the regulatory gaps need to be addressed only due to the fact that some
requirements of the rule are unnecessarily explicit in regard to the list of aircraft categories or powerplants
considered, leading to blocking points that would be eliminated by considering a new aircraft category ‘any
other aircraft/powerplant’. Besides that, in the Part-66 licensing system, new training and experience
requirements are proposed that would entitle maintenance certification rights for these aircraft. Finally, some
alleviations that the rule permits, which were intended to apply for simple aircraft, are established in the rule
using a piston engine as a discriminant of a simple aircraft, but this is no longer the case and therefore has also
led to certain proposed regulatory changes in this NPA.
The proposed amendments are expected to maintain the same safety levels as regards the continuing
airworthiness of non-conventional aircraft and will eliminate the need for the Member States (MSs) grant
approvals for these aircraft by exemption.
Domain: New technologies and concepts
Related rules: Regulation (EU) No 1321/2014 (the CAW Regulation) and the related AMC & GM
Affected stakeholders: national competent authorities (NCAs), organisations approved under Part-145, Part-147, Part-
CAMO and Part-CAO, holders of licences issued under Part-66, type certificate holders (TCHs),
and applicants for any of these approvals/licences/certificates
Driver: Safety Rulemaking group: No
Impact assessment: Yes Rulemaking Procedure: Standard
EASA rulemaking procedure milestones
Start Public consultation Proposal to the Adoption by the Decision

Terms of Reference (NPA) Commission Commission Certification Specifications,
Acceptable Means of
EASA Opinion Implementing Rules
Compliance, Guidance
Material
SubT 1: 9.9.2020 21.12.2021 2023 2024 2024
TE.RPRO.00034-011 © European Union Aviation Safety Agency. All rights reserved. ISO 9001 certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 1 of 74
An agency of the European Union
European Union Aviation Safety Agency NPA 2021-15
Table of contents
Table of contents
1. About this NPA...................................................................................................................... 4
1.1. How this NPA was developed ................................................................................................... 4
1.2. How to comment on this NPA .................................................................................................. 4
1.3. The next steps .......................................................................................................................... 4
2. In summary — why and what ................................................................................................ 6
2.1. Why we need to amend the rules — issue/rationale .............................................................. 6
2.2. What we want to achieve — objectives ................................................................................... 7
2.3. How we want to achieve it — overview of the proposed amendments.................................. 7
2.4. What are the expected benefits and drawbacks of the proposed amendments .................... 8
3. Proposed amendments and rationale .................................................................................. 10
3.1. Draft regulation (draft EASA opinion) and draft acceptable means of compliance and
guidance material (draft EASA decision) ........................................................................................... 10
COVER REGULATION ......................................................................................................................... 10
Article 2 Definitions ........................................................................................................................... 10
Article 3 Continuing airworthiness requirements ............................................................................. 11
GM Articles 3 and 4, M.A.201 and ML.A.201 Continuing airworthiness requirements and approvals
for organisations involved in the continuing airworthiness.............................................................. 12
ANNEX I (PART-M) ............................................................................................................................. 14
M.A.201 Responsibilities ............................................................................................................... 14
Appendix VII — Complex Maintenance Tasks ............................................................................... 17
ANNEX II (PART-145) ......................................................................................................................... 18
Appendix II — Class and rating system for the terms of approval of Part-145 maintenance
organisations ................................................................................................................................. 19
ANNEX III (PART-66) .......................................................................................................................... 22
66.1 Competent authority ............................................................................................................. 22
66.A.3 Licence categories and subcategories ................................................................................ 22
66.A.5 Aircraft groups .................................................................................................................... 23
66.A.20 Privileges .......................................................................................................................... 25
66.A.25 Basic knowledge requirements ........................................................................................ 27
66.A.30 Basic experience requirements ........................................................................................ 27
66.A.45 Endorsement with aircraft ratings ................................................................................... 27
66.B.110 Procedure for the change of an aircraft maintenance licence to include an additional
basic category or subcategory ....................................................................................................... 32
APPENDICES TO ANNEX III (Part-66) ................................................................................................. 33
Appendix I — Basic Knowledge Requirements (except for category L licence) ............................ 33
Appendix II — Basic examination standard (except for category L licence).................................. 36
Appendix III — Aircraft type training and examination standard — On the job training.............. 37
Appendix IV — Experience requirements for extending a Part-66 aircraft maintenance licence 44
Appendix V — Application Form — EASA Form 19 ....................................................................... 45
Appendix VI — Aircraft Maintenance Licence referred to in Annex III (Part-66) — EASA Form 26
46
Appendix II — Aircraft Type Practical Experience and On-the-Job Training - List of Tasks............... 48
ANNEX IV (PART-147) ........................................................................................................................ 48
Appendix I — Basic training course duration ................................................................................ 50
Appendix II — Maintenance Training Organisation Approval — EASA Form 11 ........................... 50
Appendix III — Certificates of Recognition referred to in Annex IV (Part-147) — EASA Forms 148
and 149 51
Table of contents
ANNEX Vb (PART-ML) ........................................................................................................................ 52

ML.1 52
ML.A.302 Aircraft maintenance programme................................................................................. 52
Appendix III — Complex maintenance tasks not to be released by the Pilot-owner .................... 55
ANNEX Vc (PART-CAMO) ................................................................................................................... 55
CAMO.A.315 Continuing airworthiness management .................................................................. 56
ANNEX Vd (PART-CAO) ...................................................................................................................... 56
CAO.A.020 Terms of approval ....................................................................................................... 56
CAO.A.105 Changes to the organisation ....................................................................................... 58
Appendix I — Combined airworthiness organisation (CAO) certificate - EASA Form 3-CAO ........ 58
4. Impact assessment (IA)........................................................................................................ 63
4.1. What is the issue .................................................................................................................... 63
4.2. What we want to achieve — objectives ................................................................................. 64
4.3. How we want to achieve it — options ................................................................................... 64
For non-conventional aircraft, in order for the TC holder to define the specific type training
syllabus referred to in Option 2 and other related information (see Chapter 3 for full details), CS-
MCSD need to be amended so that the operational suitability data for these aircraft contains such
data. The proposed amendment to CS-MCSD will be published in due time separately from this
NPA, as an addendum. ...................................................................................................................... 65
4.4. What are the impacts ............................................................................................................. 65
5. Proposed actions to support implementation ...................................................................... 71
6. References .......................................................................................................................... 72
6.1. Related EU regulations ........................................................................................................... 72
6.2. Related EASA decisions .......................................................................................................... 72
6.3. Other references .................................................................................................................... 72
7. Appendix ............................................................................................................................ 73
8. Quality of the NPA .............................................................................................................. 74
8.1. The regulatory proposal is of technically good/high quality .................................................. 74
8.2. The text is clear, readable and understandable ..................................................................... 74
8.3. The regulatory proposal is well substantiated ....................................................................... 74
8.4. The regulatory proposal is fit for purpose (capable of achieving the objectives set) ............ 74
8.5. The impact assessment (IA), as well as its qualitative and quantitative data, is of high quality
74
8.6. The regulatory proposal applies the ‘better regulation’ principles ....................................... 74
8.7. Any other comments on the quality of this NPA (please specify) .......................................... 74
Error! Reference source not found.. About this NPA
1. About this NPA

1.1. How this NPA was developed
The European Union Aviation Safety Agency (EASA) developed this NPA in line with Regulation
(EU) 2018/11391 (the ‘Basic Regulation’) and the Rulemaking Procedure2. This Rulemaking Task
(RMT).0731 is included in the European Plan for Aviation Safety (EPAS) for 2021-20253. The scope and
timescales of the task were defined in the related Terms of Reference (ToR)4.
EASA developed this NPA and discussed the main concepts contained in this proposal with stakeholder
experts and its advisory bodies (ABs). It is hereby submitted to all interested parties for consultation
in accordance with Articles 6(3), 7 and 8 of the Rulemaking Procedure5.
The major milestones of this RMT are presented on the cover page.
1.2. How to comment on this NPA

Please submit your comments using the automated Comment-Response Tool (CRT) available at
http://hub.easa.europa.eu/crt/6.
The deadline for the submission of comments is 21.3.2022.
1.3. The next steps

Following the public consultation, EASA will review all the comments received. Based on them, EASA
will revise, if necessary, the proposed amendments to the CAW Regulation7 and issue an opinion. A
summary of the comments received will be provided in the Explanatory Note to the opinion.
The opinion will be submitted to the European Commission, which will decide whether to amend the
CAW Regulation based on the opinion.
If the European Commission decides to amend the Regulation, EASA will issue a decision to amend the
related acceptable means of compliance (AMC) & guidance material (GM) to support the
implementation of the amendments to the Regulation.
1 Regulation (EU) 2018/1139 of the European Parliament and of the Council of 4 July 2018 on common rules in the field of
civil aviation and establishing a European Union Aviation Safety Agency, and amending Regulations (EC) No 2111/2005,
(EC) No 1008/2008, (EU) No 996/2010, (EU) No 376/2014 and Directives 2014/30/EU and 2014/53/EU of the European
Parliament and of the Council, and repealing Regulations (EC) No 552/2004 and (EC) No 216/2008 of the European
Parliament and of the Council and Council Regulation (EEC) No 3922/91 (OJ L 212, 22.8.2018, p. 1) (https://eur-
lex.europa.eu/legal-content/EN/TXT/?qid=1535612134845&uri=CELEX:32018R1139).
2 EASA is bound to follow a structured rulemaking process as required by Article 115(1) of Regulation (EU) 2018/1139.
Such a process has been adopted by the EASA Management Board (MB) and is referred to as the ‘Rulemaking Procedure’.
See MB Decision No 18-2015 of 15 December 2015 replacing Decision 01/2012 concerning the procedure to be applied
by EASA for the issuing of opinions, certification specifications and guidance material (http://www.easa.europa.eu/the-
agency/management-board/decisions/easa-mb-decision-18-2015-rulemaking-procedure).
3 https://www.easa.europa.eu/downloads/123563/en
4 https://www.easa.europa.eu/document-library/terms-of-reference-and-group-compositions/tor-rmt0731
5 http://www.easa.europa.eu/the-agency/management-board/decisions/easa-mb-decision-18-2015-rulemaking-procedure
6 In case of technical problems, please send an email to [email protected] with a short description.
7 Commission Regulation (EU) No 1321/2014 of 26 November 2014 on the continuing airworthiness
of aircraft and aeronautical products, parts and appliances, and on the approval of organisations and
personnel involved in these tasks (OJ L 362, 17.12.2014, p. 1) (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32014R1321&qid=1637597331895).
Error! Reference source not found.. About this NPA
The individual comments received on this NPA and the EASA responses to them will be reflected in a
comment-response document (CRD), which will be published on the EASA website8.
8 https://www.easa.europa.eu/document-library/comment-response-documents
2. In summary — why and what

2.1. Why we need to amend the rules — issue/rationale
The objective of this NPA is to propose a regulatory amendment to close the gaps that currently exist
in the CAW Regulation, which pose compliance difficulties in relation to the management of manned
aircraft which are not conventional or have a powerplant other than a piston engine or a turbine.
Some of the recent industry projects for new aircraft fall into the non-conventional category (aircraft
and/or powerplant).
The difficulties for compliance are derived from the fact that the requirements are sometimes
prescriptive when establishing requirements in respect of certain aircraft (called ‘conventional
aircraft’ in this document, i.e. aeroplane, helicopter, sailplane, balloon and airship), while making no
reference whatsoever to the rest of aircraft. As a consequence, the rules are not fit for non-
conventional aircraft. The situation is similar as regards the aircraft powerplant as in most cases, the
rule considers only piston engine and turbine.
Also, the definition of complex motor-powered aircraft (CMPA), which is used as a discriminant to
identify aircraft subject to Part-M, includes ‘tilt rotor aircraft’. A definition of tilt rotor aircraft is given
in the proposed Article 3. Being a CMPA implies that all tilt rotor aircraft are subject to Part-M.
A different situation arises in certain scenarios for which the rule contains alleviations intended to be
applicable for small aircraft. Often, these alleviations are introduced by referring to ‘… in the case of
piston-engine aircraft …’ or similarly. This scenario does not cater for other simple aircraft that may
not have a piston-engine powerplant and that could be also entitled to the same alleviation, resulting
in an unfair situation to them. A similar case to this one is, for instance, the definition of the aircraft
subject to Part-ML.
Lastly, the licensing system of Part-66 caters again, for certain privileges, only for conventional aircraft
or aircraft with piston engine/turbine as powerplant (conventional powerplant). Different licence
categories are established for each of those aircraft. For non-conventional aircraft, there are no
defined aircraft maintenance licence (AML) subcategories and therefore, the current subcategories
do not permit the release to service of certain maintenance on aircraft that are not addressed in any
of the existing subcategories/privileges — for more information on this, please refer to Chapter 4.
The first aircraft for which it was identified that the rules were not totally suitable (existing regulatory
gap) was the electric variant of Pipistrel Virus SW121, a small aeroplane with an electric battery and
engine as powerplant, that obtained an EASA Type Certificate for the electric variant (Virus SW 128)
in June 2020. For this aircraft, some Members States granted an exemption in accordance with Article
71 ‘Flexibility provisions’ of the Basic Regulation, allowing the users to derogate from compliance with
certain rule requirements while imposing on them some mitigating measures tailored for an electric
aeroplane.
Stakeholders are invited to provide their views on whether small tilt rotor aircraft conducting non-
commercial operations should be subject to Part-ML.
2.2. What we want to achieve — objectives

The overall objectives of the EASA system are defined in Article 1 of the Basic Regulation. The
proposals contained in this NPA would contribute to achieving the overall objectives by addressing
the issues described in Section 2.1.
The specific objectives of this RMT are to establish the necessary legal framework:
— to ensure the continuing airworthiness of electric and hybrid propulsion aircraft;
— to embrace non-conventional aircraft and aircraft with non-conventional powerplants, where
some regulatory gaps have been identified;
— more generally, to support the development of new technologies;
— to ensure smooth and flexible transitioning of AML holders in the current subcategories to
obtain certification privileges for the maintenance of non-conventional aircraft; and
— to support the competitiveness of the EU industry.
The above-mentioned legal framework is expected to provide a level playing field while maintaining a
high uniform level of civil aviation safety in the Union.
2.3. How we want to achieve it — overview of the proposed amendments

Where the rule is explicit on certain aircraft or powerplant, but it does not take into consideration
non-conventional aircraft or aircraft with non-conventional powerplants — for instance, when
defining permitted ratings for organisation approvals — the proposal is to amend the rule to also refer
to these aircraft/powerplants. This proposal would not have any impact since the applicable
requirements would not be specific for them.
Secondly, EASA has assessed the existing alleviations in the requirements applicable for piston-engine
aircraft and considered whether such alleviations should be expanded to other small/simple aircraft
with other powerplants due to their lower risk. Certain rule changes are proposed accordingly.
Also, the proposal aims to consistently use the terms ‘helicopter’ and ‘rotorcraft’ across the regulation,
by mainly using this second term except in some areas (e.g. dedicated AMC) which are only adequate
for helicopters. Part-66 licences in the category B1 are also affected by this terminology misalignment
and the NPA proposes that the related licence (sub)categories are applicable to ‘rotorcraft’, assuming
that the related licences already issued can be extended to rotorcraft at time of their next renewal
without further action (the regulatory transitioning process is not defined in the NPA), and slightly
amending the path for obtaining new rotorcraft licences.
Lastly, in regard to the maintenance licensing system (Part-66), this NPA proposes amendments to
Part-66 that would permit licence holders to obtain certification privileges for the release of
maintenance of conventional aircraft with an electrical powerplant and of any non-conventional
aircraft. Two different strategies are proposed: one for aeroplanes and rotorcraft with an electrical
powerplant and another one for non-conventional aircraft. See Section 4.3. for more details on this.
Aiming to attain the above, there is also the intention to not impact the applicable provisions for the
aircraft already considered by the rules.
Note: Considering that, as per Article 4(4) of the CAW Regulation, organisations approved in
accordance with Subpart F or Subpart G of Annex I (Part-M) of this Regulation will cease to exist after
24 March 2022, this NPA does not propose changes to these Subparts or any other point that only
affects these Subparts.
Note: NPA 2020-12 proposed amendments to Part-66, including provisions for an AML suitable for
electrical aircraft. NPA 2020-12 was published for comments by stakeholders, which are currently
being reviewed by the Agency. With the present NPA, EASA is consulting again on such AML for
aeroplanes and rotorcraft with an electrical powerplant, considering the reactions to this topic
received during the consultation of NPA 2020-12 and later inputs from the ABs.
2.4. What are the expected benefits and drawbacks of the proposed amendments
The expected benefits and drawbacks of the proposed amendments can be grouped into three main
topics and are summarised below.
Point being amended Benefits Drawbacks
Requirements for which aircraft categories Legal certainty None

are explicitly mentioned but contain no
different technical requirements among the
different aircraft categories considered
Expanding alleviations to simple aircraft Alleviations do not None
with a powerplant other than piston engine apply based on a
particular powerplant;
instead, they apply
based on more fair
criteria
Process to acquire maintenance certification See full description in Chapter 4 ‘Impact
privileges/Part-66 assessment’.
In order to adapt the Part-66 requirements to address the issue in consideration of the objectives, the
following options have been considered in the impact assessment:
— Option 0 (No policy change)
— Option 1 (new basic knowledge): Amend Part-66 by establishing new AML privileges for the
certification of maintenance of non-conventional aircraft or aircraft with non-conventional
powerplants. The new privileges would be granted to personnel having followed training on
new basic modules defined by TC applicants of non-conventional aircraft to address their
specificities.
— Option 2 (type rating endorsement): Amend Part-66 by allowing the endorsement of an AML
corresponding to one of the existing subcategories (i.e. for a conventional aircraft) with a non-
conventional aircraft type rating (syllabus defined by the TC applicant), without the aircraft
belonging to the scope of the licence. The same approach would be taken for aircraft with non-
conventional powerplants.
After assessing the impact of these options, Option 2 is preferred since it has a higher positive social
impact and provides higher economic advantages while maintaining the current safety level.
For more information, please refer to Chapter 4.
3. Proposed amendments and rationale

The amendment is arranged to show deleted, new or amended, and unchanged text as follows:
— deleted text is struck through;
— new or amended text is highlighted in blue;
— an ellipsis ‘[…]’ indicates that the rest of the text is unchanged.
Where necessary, the rationale is provided in blue italics.
Note: The proposed text shows amendments to the officially adopted text. In this respect, the
amendments to Part-66, as proposed through NPA 2020-12, have not been taken into consideration.
3.1. Draft regulation (draft EASA opinion) and draft acceptable means of compliance and
guidance material (draft EASA decision)
Commission Regulation (EU) No 1321/2014 and the Agency Executive Director Decisions 2015/029/R9,
2019/009/R10 and 2020/002/R11 are amended as follows:
[…]
COVER REGULATION
[…]
Article 2 Definitions
[…]
(s) ‘flying display’ means ‘flying display’ as defined in Article 2(11) of Regulation (EU) No 965/2012;.
(t) ‘aeroplane’ means an engine-driven fixed-wing aircraft heavier than air that is supported in
flight by the dynamic reaction of the air against its wings during all phases of flight;
(u) ‘rotorcraft’ means a heavier-than-air aircraft that depends principally for its support in all
phases of flight on the lift generated by one or more rotors with substantially vertical axes.
(v) ‘tilt rotor aircraft’ means an aircraft with one or more rotors that can tilt during flight and which
provides substantial lift or thrust depending on the phase of flight.
Rationale: The proposal regarding the suitable Part-66 licence subcategories for certifying staff
requires certainty as regards the aircraft for which a licence subcategory is adequate. The
establishment of certain definitions is therefore required. The proposed definitions take consideration
of the syllabus covered with the basic knowledge in Part-66. Also certainty is required to establish
which aircraft are subject to Part-M or Part-ML, and therefore the definitions of the categories of
aircraft being complex motor-powered aircraft are proposed for the purpose of the CAW Regulation.
9 https://www.easa.europa.eu/document-library/agency-decisions/ed-decision-2015029r
Article 3 Continuing airworthiness requirements

[…]
2. The requirements of Annex Vb (Part-ML) shall apply to the following other than complex motor-
powered aircraft:
(a) aeroplanes of 2 730 kg maximum take-off mass or less;
(b) rotorcraft of 1 200 kg maximum take-off mass or less, certified for a maximum of up to
four 4 occupants;
(c) other ELA2 aircraft;.
(d) aircraft other than aeroplanes, rotorcraft, sailplanes, balloons and airships with a MTOM
of:
(i) 1 200 kg or less if they can maintain zero horizontal speed, or
(ii) 2 730 kg or less for other than those in (i).
Where an aircraft referred to points (a), (b), (c) and (c)(d) of the first subparagraph is listed in
the air operator certificate of an air carrier licensed in accordance with Regulation (EC)
No 1008/2008, the requirements of Annex I (Part-M) shall apply.
3. In order to be listed in the air operator certificate of an air carrier licensed in accordance with
Regulation (EC) No 1008/2008, an aircraft referred to in points (a), (b), (c) and (c)(d) of the first
subparagraph of paragraph 2 shall comply with all of the following requirements:
(a) its aircraft maintenance programme has been approved by the competent authority in
accordance with point M.A.302 of Annex I (Part-M);
(b) due maintenance required by the maintenance programme referred to in point (a) has
been performed and certified in accordance with point 145.A.48 and 145.A.50 of Annex
II (Part-145);
(c) an airworthiness review has been performed and a new airworthiness review certificate
has been issued in accordance with point M.A.901 of Annex I (Part-M).
4. […]
Rationale: Certain small non-conventional aircraft should also be subject to Part-ML (instead of Part-
M). Therefore, Article 3.2.(d) is proposed to include these aircraft to the ones for which the
requirements Part-ML apply, establishing for them similar discriminants as the ones already existing
for other Part-ML aircraft.
GM Articles 3 and 4, M.A.201 and ML.A.201 Continuing airworthiness requirements and approvals for
organisations involved in the continuing airworthiness
In accordance with Articles 3 and 4, as well as M.A.201 and ML.A.201, the following table provides a summary of the applicability of the Annexes to Regulation
(EU) No 1321/2014 related to continuing airworthiness requirements and organisations involved therein.
Non-licensced air carrier
Licensced air carrier12
Non-commercial Commercial13
Both conditions: Non-CMPA and Both conditions: Non-CMPA and Either
Either CMPA14 or
non-‘UHA’ Non-CMPA non-‘UHA’Non-CMPA CMPA or Non-CMPA CMPA16
17 UHA15CMPA
‘Light’ Non-‘Light’ ‘Light’ Non-‘Light’ UHA
Part-M (Annex I) N/A Part-M mandatory N/A Part-M mandatory
Part-ML (Annex Vb) Part-ML mandatory N/A Part-ML mandatory N/A
Part-CAMO (Annex Vc) Individual CAM18 Part-CAMO mandatory Part-CAMO mandatory

CAO-CAM19
for CA management or CAO-CAM
N/A or CAMO N/A
Part-CAO (CAO-CAM) or CAMO
(Annex Vd) for maintenance Individual maintenance20 CAO-M
N/A N/A
(CAO-M) or CAO-M21 or Part-145
12
Air carrier licensed in accordance with Regulation (EC) No 1008/2008.
13 Commercial = balloon operated under Subpart-ADD of Part-BOP or sailplane operated under Subpart-DEC of Part-SAO or other aircraft, not operated under Part-NCO; includes commercial ATO and commercial
DTO.
14
CMPA = complex motor-powered aircraft, ref. Article 3(j) of Regulation (EC) 216/2008.
15 UHA (unconventional heavy aircraft; not formal denomination) = aircraft with MTOM of 3 175 kg or more or certified for more than 10 occupants, other than aeroplanes, helicopters, airships and balloons.
16 CMPA = Complex motor-powered aircraft, ref. Article 3(j) of Regulation (EC) No 216/2008.
17
‘Light’ a/c (not formal denomination) = non-CMPA which are: aAeroplanes up to 2 730 kg MTOM, rotorcraft up to 1 200 kg MTOM / max four 4 occupants, and other ELA2 aircraft, or aircraft other than aeroplanes,
rotorcraft, sailplanes, balloons and airships with a certified MTOM of 1 200 kg or less if they can maintain zero horizontal speed, or 2 730 kg or less for other.
18 Individual CAM (not formal denomination) = continuing airworthiness of the a/c managed by the owner under its own responsibility.
19
CAO-CAM (not formal denomination) = Part-CAO organisation with continuing airworthiness management privilege.
20
Individual maintenance (not formal denomination) = maintenance released by pilot-owner or independent certifying staff.
21 CAO-M (not formal denomination) = Part-CAO organisation with maintenance privilege.
Part-145 (Annex II) or Part-145 Part-145 mandatory Part-145 mandatory
Rationale: Table updated to be aligned with the proposed amendment to Article 3, M.A.201 and ML.A.201.
ANNEX I (PART-M)
[…]
M.A.201 Responsibilities
[…]
(f) For complex motor-powered aircraft and aircraft with MTOM of 3 175 kg or more or certified
for more than 10 occupants, other than aeroplanes, helicopters, airships and balloons, and
which are used for commercial specialised operations, for CAT operations other than those
performed by air carriers licensed in accordance with Regulation (EC) No 1008/2008 or by
commercial Aapproved Ttraining Oorganisations (‘ATOs’) and Ddeclared Ttraining
Oorganisations (‘DTOs’) referred to in Article 10a of Regulation (EU) No 1178/201122, the
operator shall ensure that:
(1) no flight takes place unless the conditions set out in point (a) are met;
(2) the tasks associated with continuing airworthiness are performed by a CAMO approved
in accordance with Annex Vc (Part-CAMO) or Subpart G of this Annex (Part-M); when the
operator is not a CAMO approved in accordance with Annex Vc (Part-CAMO) or Subpart G
of this Annex (Part-M), it shall conclude a written contract as regards the performance of
those tasks in accordance with Appendix I to this Annex with an organisation approved in
accordance with Annex Vc (Part-CAMO) or Subpart G of this Annex (Part-M);
(3) the CAMO referred to in point (2) is approved in accordance with Annex II (Part-145) as
an organisation to qualify for the issue of an approval for the maintenance of aircraft and
of components for installation thereon, or that CAMO has concluded a written contract
in accordance with point CAMO.A.315(c) of Annex Vc (Part-CAMO) or point M.A.708(c)
of this Annex (Part-M) with organisations approved in accordance with Annex II (Part-
145).
(g) For complex motor-powered aircraft and aircraft with MTOM of 3 175 kg or more or certified
for more than 10 occupants, other than aeroplanes, helicopters, airships and balloons, and
which are not included in points (e) and (f), the owner shall ensure that:
in accordance with Annex Vc (Part-CAMO) or Subpart G of this Annex (Part-M); when the
owner is not a CAMO approved in accordance with Annex Vc (Part-CAMO) or Subpart G
of this Annex (Part-M), it shall conclude a written contract as regards the performance of
those tasks in accordance with Appendix I to this Annex with an organisation approved in
accordance with Annex Vc (Part-CAMO) or Subpart G of this Annex (Part-M);
(3) the CAMO referred to in point (2) is approved in accordance with Annex II (Part-145) as
an organisation to qualify for the issue of an approval for the maintenance of aircraft and
of components for installation thereon, or that CAMO has concluded a written contract
in accordance with point CAMO.A.315(c) of Annex Vc (Part-CAMO) or point M.A.708(c)
of this Annex (Part-M) with organisations approved in accordance with Annex II (Part-
145).
22
Commission Regulation (EU) No 1178/2011 of 3 November 2011 laying down technical requirements and administrative procedures
related to civil aviation aircrew pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council (OJ L 311,
25.11.2011, p. 1).
(h) For aircraft other than those referred to in point (f) (regardless of their use), which are complex
motor-powered aircraft used for commercial specialised operations or for CAT operations other
than those performed by air carriers licensed in accordance with Regulation (EC) No 1008/2008,
or by commercial ATOs and commercial DTOs referred to in Article 10a of Regulation (EU) No
1178/2011, the operator shall ensure that:
in accordance with Annex Vc (Part-CAMO) or Subpart G of this Annex (Part-M), or a
combined airworthiness organisation (‘CAO’) approved in accordance with Annex Vd
(Part-CAO); when the operator is not a CAMO approved in accordance with Annex Vc
(Part-CAMO) or Subpart G of this Annex (Part-M), or a CAO approved in accordance with
Annex Vd (Part-CAO), it shall conclude a written contract in accordance with Appendix I
to this Annex with a CAMO approved in accordance with Annex Vc (Part-CAMO) or
Subpart G of this Annex (Part-M), or a CAO approved in accordance with Annex Vd (Part-
CAO);
(3) the CAMO or CAO referred to in point (2) is approved in accordance with Annex II (Part-
145) or in accordance with Subpart F of this Annex (Part-M) or as a CAO with maintenance
privileges, or that CAMO or CAO has concluded a written contract with organisations
approved in accordance with Annex II (Part-145) or in accordance with Subpart F of this
Annex (Part-M) or Annex Vd (Part-CAO) with maintenance privileges.
(i) For aircraft other those referred to in (f) (regardless of their use), which are complex motor-
powered aircraft not included in points (e) and (h), or used for limited operations, the owner
shall ensure that flight takes place only if the conditions set out in point (a) are met. To that
end, the owner shall:
(1) attribute the continuing airworthiness tasks referred to in point M.A.301 to a CAMO or
CAO through a written contract concluded in accordance with Appendix I; or
(2) carry out those tasks himselfthemselves; or
(3) carry out those tasks himselfthemselves except the tasks of the development of and the
processing of the approval of the AMP, only if those tasks are performed by a CAMO or
CAO through a limited contract concluded in accordance with point M.A.302.
[…]
Rationale: The requirements on operators/owners of complex motor-powered aircraft in points

M.A.201 (f) and (g) are extended to operators/owners of non-conventional aircraft which had not been
considered before, establishing discriminants comparable to the existing ones for complex motor-
powered aircraft. A similar approach has been taken for M.A.201 (h) and (i).
GM M.A.201 Responsibilities
Quick summary table
Complex
motor-powered aircraft, OR
Other-than-complex motor-powered
Select your type of operation aircraft with MTOM of 3 175 kg or aircraft (aircraft subject to Part-ML
and your category of aircraft more or certified for more than 10
are excluded here)
occupants, other than aeroplanes,
helicopters, airships and balloons
Is a CAMO or Is maintenance Is a CAMO or Is maintenance by

CAO required by a CAO required for a maintenance
for the maintenance the management organisation
management of organisation of continuing required?
continuing required? airworthiness?
airworthiness?
Air carriers Yes, a CAMO is Yes, Yes, a CAMO is Yes, maintenance
licensed in required, and it maintenance by required, and it by a Part-145
accordance with shall be part of a Part-145 shall be part of organisation is
Regulation (EC) the AOC organisation is the AOC required
No 1008/2008 (M.A.201(e)) required (M.A.201(e)) (M.A.201(e))
(M.A.201(e))
CAT
CAT other than Yes, a CAMO is Yes, Yes, a CAMO or Yes, maintenance
air carriers required maintenance by CAO is required by a Subpart F, by
licensed in (M.A.201(f)) a Part-145 (M.A.201(h)) a Part-CAO or by a
accordance with organisation is Part-145
Commercial operations
Regulation (EC) required organisation is

No 1008/2008 (M.A.201(f)) required
(M.A.201(h))
Commercial Yes, a CAMO is Yes, Yes, a CAMO or Yes, maintenance
Commercial operations other than CAT
specialised required maintenance by CAO is required by a Subpart F, by

operations (M.A.201(f)) a Part-145 (M.A.201(h)) a Part-CAO or by a
organisation is Part-145
required organisation is
(M.A.201(f)) required
(M.A.201(h))
Commercial Yes, a CAMO is Yes, Yes, a CAMO or Yes, maintenance
training required maintenance by CAO is required by a Subpart F, by
organisations (M.A.201(f)) a Part-145 (M.A.201(h)) a Part-CAO or by a
(ATOs) organisation is Part-145
required organisation is
(M.A.201(f)) required
(M.A.201(h))
Other than commercial Yes, a CAMO is Yes, No, a CAMO or No, maintenance
operations including limited required maintenance by CAO is not by a Subpart F, by
operations as defined in (M.A.201(g)) a Part-145 required a Part-CAO or
Article 2(p) organisation is (M.A.201(i)) Part-145
required organisation is not
(M.A.201(g)) always required
(M.A.201(i))
[…]
Rationale: Table updated to be aligned with the proposed amendment to M.A.201.
AMC M.B.301(b) Maintenance programme

1. […]
6. In the case of aircraft used by air carriers licensed in accordance with Regulation (EC) No
1008/2008 or complex motor-powered aircraft or aircraft with MTOM of 3 175 kg or more or
certified for more than 10 occupants, other than aeroplanes, helicopters, airships and balloons,
the development of the aircraft maintenance programme is dependent upon sufficient
satisfactory in-service experience which has been properly processed. In general, the task being
considered for escalation beyond the MRB limits should have been satisfactorily repeated at
the existing frequency several times before being proposed for escalation. Appendix I to AMC
M.A.302 and M.B.301(b) gives further information.
7. […]
Rationale: M.B.301(b)(6) updated to be aligned with the proposed amendment to M.A.201 in order
to impose the maintenance programme requirements of non-conventional aircraft similarly to those
for CMPA.
Appendix VII — Complex Maintenance Tasks
[…]
(d) the disturbing of individual parts of units which are supplied as bench tested units, except
for the replacement or adjustment of items normally replaceable or adjustable in service.
3b. the performance of maintenance on the powerplant that would require disassembly of
engine(s), main batteries or fuel cell(s), other than removing them from the aircraft and
reinstalling them back.
3c the performance of maintenance on high-pressure reservoirs and components belonging to
high-pressure lines/systems related to the powerplant.
4. The balancing of a propeller, except:
[…]
Rationale: Complex maintenance tasks are amended taking into account the new aircraft being
considered.
AMC to Appendix VIII — Limited Pilot Owner Maintenance

1. […]
3. Therefore, the following lists are considered to be the representative scope of limited Pilot-
owner maintenance referred to in M.A.803 and Appendix VIII:
− Part A applies to piston-engine aeroplanes;
− Part B applies to piston-engine rotorcraft;
− Part C applies to sailplanes and powered (piston engine) sailplanes;
− Part D applies to balloons and airships.
4. […]
Rationale: Text adapted since the cases covered are only for piston-engine aircraft and to be explicit
that Parts A to C of this AMC refer to piston-engine aircraft.
ANNEX II (PART-145)
[…]
GM 145.A.10 Scope
This Guidance Material (GM) provides guidance on how the smallest organisations satisfy the intent
of Part-145:
1. […]
3. Where only one person is employed (in fact having the certifying function and others), these
organisations approved under Part-145 may use the alternatives provided in point 3.1 limited
to the scope mentioned in point (m) of Appendix IIfollowing:
Class A2 Base and Line maintenance of aeroplanes of 5 700 kg and below (piston engines only).
Class A3 Base and Line maintenance of single-engined helicopters of less than 3 175 kg.
Class A4 Aircraft other than A1, A2 and A3
Class B2 Piston engines with maximum output of less than 450 HP.
Class C Components.
Class D1 Non-destructive Testing.
3.1. […]
Rationale: Text adapted to refer to Appendix II, point (m) (also proposed for amendment, see below)
that contains the scope for one-man organisations.
AMC 145.A.20 Terms of approval

The following table identifies the ATA Specification 2200 chapter for the category C component rating.
If the maintenance manual (or equivalent document) does not follow the ATA Chapters, the
corresponding subjects still apply to the applicable C rating.
CLASS RATING ATA CHAPTERS
COMPONENTS OTHER C1 Air Cond & Press 21
THAN COMPLETE C2 Auto Flight 22
ENGINES OR APUs C3 Comms and Nav 23 - 34
C4 Doors - Hatches 52
C5 Electrical Power & Lights 24 – 33 - 85
C6 Equipment 25 - 38 - 44 – 45 - 50
C7 Engine – APU 49 - 71 - 72 - 73 - 74 - 75 - 76 - 77 - 78 -
79 - 80 - 81 - 82 - 83
C8 Flight Controls 27 - 55 - 57.40 - 57.50 -57.60 - 57.70
C9 Fuel 28 - 47
C10 RotorcraftHelicopters - Rotors 62 - 64 - 66 - 67
C11 RotorcraftHelicopter - Trans 63 - 65
C12 Hydraulic Power 29
C13 Indicating/Recording Systems 31 – 42 - 46
C14 Landing Gear 32

C15 Oxygen 35
C16 Propellers 61
C17 Pneumatic & Vacuum 36 - 37
C18 Protection ice/rain/fire 26 - 30
C19 Windows 56
C20 Structural 53 - 54 - 57.10 - 57.20 - 57.30
C21 Water Ballast 41
C22 Propulsion Augmentation 84
C23 Other
Rationale: References to ‘helicopter’ are changed to ‘rotorcraft’. Addition of new row, with C23 Other,
to align with Appendix II.
AMC3 145.A.30(e) Personnel requirements

When relevant for the organisation scope, additionalAdditional training in on fuel tank safety as well
as on the associated inspection standards and maintenance procedures should be required for
maintenance organisations’ technical personnel, especially technical personnel involved in the
compliance of CDCCL tasks.
EASA guidance is provided for training to maintenance organisation personnel in Appendix IV to AMC
145.A.30(e) and 145.B.10(3).
Rationale: As fuel tank safety training would not be required for all aircraft considered (e.g. aircraft
without fuel tanks), the necessary text change is proposed.
Appendix II — Class and rating system for the terms of approval of

Part-145 maintenance organisations
(a) […]
(l) Table
CLASS RATING LIMITATION BASE LINE
AIRCRAFT A1 […] […] […]
Aeroplanes above 5 700
kg maximum take-off
mass (MTOM)
A2 […] […] […]
Aeroplanes of 5 700 kg
MTOM and below
A3 [Shall state the […] […]
RotorcraftHelicopters rotorcrafthelicopter
manufacturer or the
group or series or
type and/or the
maintenance task(s)]
Example: Robinson
R44

State whether the
issuing of
airworthiness review
certificates is
authorised (only
possible for aircraft
covered by Annex Vb
(Part-ML))
A4 [Shall state aircraft […] […]
Aircraft other than A1, A2 category (sailplane,
and A3 balloon, airship, etc.)
when possible, the
manufacturer or group
or series or type and/or
the maintenance
task(s)]
State whether the

issue of
airworthiness review
certificates is
authorised (only
possible for aircraft
covered by Annex Vb
(Part-ML))
ENGINES B1 […]
Turbine
B2 […]
Piston
B3 […]
APU
B4 [Shall state the engine manufacturer or group or series
Engines other than B1, B2 or type and/or the maintenance task(s)]
and B3
COMPONENTS C1 Air Cond & Press […]
OTHER THAN C2 Auto Flight
COMPLETE C3 Comms and Nav
ENGINES OR
C4 Doors — Hatches
APUs
C5 Electrical Power &
Lights
C6 Equipment
C7 Engine — APU
C8 Flight Controls
C9 Fuel
C10 RotorcraftHelicopters
— Rotors
C11 RotorcraftHelicopters
— Trans
C12 Hydraulic Power
C13 Indicating —
recording system
C14 Landing Gear

C15 Oxygen
C16 Propellers
C17 Pneumatic & Vacuum
C18 Protection
ice/rain/fire
C19 Windows
C20 Structural
C21 Water ballast
C22 Propulsion
Augmentation
C23 Other
SPECIALISED D1 Non-Destructive […]
SERVICES Testing
(*) Delete as appropriate
(m) A maintenance organisation which employs only one person to both plan and carry out all its
maintenance activities can only hold limited terms of approval. The maximum permissible limits
are as follows:
CLASS RATING LIMITATION
AIRCRAFT A2 PISTON ENGINE AEROPLANE
OF 5700 KG MTOM OR LESS
AEROPLANES of 5700 KG
MTOM OR LESS WITH PISTON
ENGINE or ELECTRICAL
POWERPLANT WITH NO FUEL
CELL
AIRCRAFT A3 SINGLE PISTON ENGINE
HELICOPTER OF 3175 KG
MTOM OR LESS
ROTORCRAFT of 3 175 KG
MTOM OR LESS WITH
SINGLE-PISTON ENGINE or
ELECTRICAL POWERPLANT
WITH NO FUEL CELL
AIRCRAFT A4 NO LIMITATION
AIRCRAFT of 3 175 KG MTOM
OR LESS WITH SINGLE-
PISTON ENGINE or
WITH NO FUEL CELL
ENGINES B2 LESS THAN 450 HP
ENGINES B4 ELECTRICAL ENGINE
COMPONENTS OTHER THAN C1 TO C23C22 AS PER CAPABILITY LIST
COMPLETE ENGINES OR APUs.
SPECIALISED SERVICES D1 NDT NDT METHOD(S) TO BE
SPECIFIED
It should be noted that such an organisation may be further limited by the competent authority
in the scope of approval depending on the capabilities of the particular organisation.
Rationale: Class and rating system for Part-145 organisations adapted to rotorcraft, non-conventional
aircraft, all engines, and other components. Adaptation of the scope of one-man organisations, as
these organisations should not perform maintenance of aircraft with a fuel cell due to high safety
precautions required for the maintenance of the associated system/components.
[…]
ANNEX III (PART-66)

[…]
66.1 Competent authority

[…]
(b) The Agency shall be responsible for defining:
1. the list of aircraft types; and
2. what airframe/engine combinations are included in each particular aircraft type rating.;
and
3. the appropriate licence(s’) subcategory/categories that permit(s) its (their) holder to
issue certificates of release to service after maintenance in respect of any aircraft type
that is not covered by any licence subcategory of point 1 of point 66.A.3 and point 66.A.20
privileges.
[…]
Rationale: This amendment assigns EASA the responsibility to define which is the adequate licence
(sub)category for each non-conventional aircraft.
66.A.3 Licence categories and subcategories
1. Aircraft maintenance licences include the following categories and, where applicable, subcategories
and system ratings:
(a) Category A, divided into the following subcategories:
[…]
− A3 RotorcraftHelicopters Turbine;
− A4 RotorcraftHelicopters Piston.
(b) Category B1, divided into the following subcategories:
[…]
− B1.3 RotorcraftHelicopters Turbine;
− B1.4 RotorcraftHelicopters Piston.;
− B1.E Aeroplanes/rotorcraft with an electrical powerplant.

[…]
(g) Category C
The C licence is applicable to aeroplanes and rotorcrafthelicopters.
2. The appropriate licence (sub)category(ies)for the aircraft maintenance licence for an aircraft type
and related powerplant not covered in points (a), (b), (f) and (g) of point 1., shall be the one that the
Agency consider(s) adequate among those in point 1. and which is established in the operational
suitability data established in accordance with Regulation (EU) No 748/2012, taking into consideration
a report from the applicant for or holder of the type certificate that assesses the architecture and
systems of the aircraft and the syllabus of the basic knowledge modules and knowledge levels relevant
for each subcategory referred to in point 1.
Rationale: This amendment assigns EASA the responsibility to define which is the ‘adequate’ licence
(sub)category for each non-conventional aircraft. In addition, the text referring to helicopters is
expanded to rotorcraft, and a new licence subcategory — based on B1 — is created for electric
aeroplane and rotorcraft.
66.A.5 Aircraft groups

[…]
(1) Group 1: complex motor-powered aircraft, helicopters with multiple engines, aeroplanes with
maximum certified operating altitude exceeding FL290, aircraft equipped with fly-by-wire
systems, gas airships other than ELA2 and other aircraft requiring an aircraft type rating when
defined as such by the Agency.
(1) (i) Group 1 is composed of:
(A) an aeroplane certificated for a MTOM exceeding 5 700 kg, or certificated for a maximum
passenger seating configuration of more than 19, or certificated for operation with a minimum
crew of at least two pilots, or equipped with (one) turbojet engine(s) or more than one
turboprop engine, or pressurised and with maximum certified operating altitude exceeding
FL290 or with a powerplant not being piston/turbine/electrical;
(B) a rotorcraft certificated for a MTOM exceeding 3 175 kg, or for a maximum passenger
seating configuration of more than nine, or for operation with a minimum crew of at least two
pilots, or with multiple piston/turbine engines, or with a powerplant not being
piston/turbine/electrical;
(C) gas airships other than ELA2;
(D) aircraft other than aeroplanes, rotorcraft, sailplanes, balloons and airships; and
(E) [reserved]
(F) aircraft requiring an aircraft type rating endorsement in respect of this Part, when defined
as such by the Agency
(ii) The Agency may decide to classify into Group 2, Group 3 or Group 4 or Group E, as
appropriate, an aircraft which meets the conditions set out in the first subparagraph point (i), if
it considers that the lower complexity of the particular aircraft justifies so.
(2) Group 2: aircraft other than those in Group 1 belonging to the following subgroups:
(i) subgroup 2a:
− single-turboprop engine aeroplanes,

− those turbojet and multiple-turboprop aeroplanes classified by the Agency in this
subgroup because of their lower complexity.
(ii) subgroup 2b:
− single-turbine engine rotorcrafthelicopters,
− those multiple-turbine engine rotorcrafthelicopters classified by the Agency in this
(iii) subgroup 2c:
− single-piston-engine rotorcrafthelicopters,
− those multiple-piston-engine rotorcrafthelicopters classified by the Agency in this
(3) Group 3: piston-engine aeroplanes other than those in Group 1.
(4) Group 4: sailplanes, powered sailplanes, balloons and airships, other than those in Group 1.
(5) Group E: aircraft other than those in Group 1 belonging to the following subgroups:
(i) subgroup E_A: aeroplanes with an electrical powerplant.
(ii) subgroup E_R: rotorcraft with an electrical powerplant.
Rationale: This amendment updates the definition of Group 1 to consider non-conventional

aircraft/powerplant and creates Group E for electrical aeroplanes and rotorcraft other than those in
Group 1. The intention is for non-conventional aircraft in Group 1 to require type endorsement on the
licence, and for those aeroplanes/rotorcraft in Group E to allow type endorsement, manufacturer
subgroup and full subgroup endorsement. In addition, the description for Group 1 is amended to
incorporate all complex motor-powered aircraft (CMPA) and consider that certain technological
evolutions have rendered some Group1 criteria obsolete.
GM 66.A.5 Aircraft groups
The following table summarises the applicability of categories/subcategories of Part-66 licences versus
the groups/subgroups of aircraft:
Category/subcategory L
A, B1 L1C L2C L3H L4H
B2 B2L B3
and C and and and and L5
Groups L1 L2 L3G L4G
1
— Complex motor-powered
aircraft
— Multi-engine helicopters
— Aeroplanes above FL290 X X
— Aircraft with fly-by-wire systems
— Any other aircraft when defined
by the Agency
Group 1 aircraft, except airships
1 X X
Category/subcategory L
A, B1 L1C L2C L3H L4H
B2 B2L B3
and C and and and and L5
Groups L1 L2 L3G L4G
— Gas airships other than ELA2
Group 1 airships
2
2a: Single-turboprop aeroplanes
2b: Single-turbine
X X X
rotorcrafthelicopters
2c: Single-piston
rotorcrafthelicopters
3
X X X
— Piston-engine aeroplanes
3
— Piston-engine aeroplanes (non-
X X X X
pressurised of 2 000 kg MTOM
and below)
3
X X X X X
— ELA1 piston-engine aeroplanes
4
— Sailplanes X X X X
— Powered sailplanes X X X
— Balloons X X X
— Airships not in Group 1 X X X X
Rationale: The text referring to helicopters is expanded to rotorcraft.
66.A.20 Privileges
(a) The following privileges shall apply:

[…]
8. In addition to the privileges in points 1. to 7., in respect of aircraft mentioned in point 2.
of point 66.A.3, an aircraft maintenance licence identified as adequate in the operational
suitability data established in accordance with Regulation (EU) No 748/2012, shall permit
the holder of the licence to issue certificates of release to service and, when relevant, to
act as support staff.
(b) […]
Rationale: This amendment, in respect of non-conventional aircraft, assigns privileges of the
‘adequate’ (see proposed 66.A.3) subcategories to maintenance licence holders.
GM 66.A.20(a) Privileges
1. The following definitions apply:
Electrical system means the aircraft electrical power supply source (other than the main
powerplant in aircraft with an electrical powerplant), plus the distribution system to the
different components contained in the aircraft and relevant connectors. Lighting systems are
also included in this definition. When working on cables and connectors which are part of these
electrical systems, the following typical practices are included in the privileges:
− Continuity, insulation and bonding techniques and testing;
− Crimping and testing of crimped joints;
− Connector pin removal and insertion;
− Wiring protection techniques.
Electrical powerplant means all elements of a powerplant system which are used to store,
transform/convert, control and transmit electrical energy to the aircraft elements that provide
trust and/or lift to the aircraft, such as electrical batteries, fuel cell elements (including tanks,
lines and other circuit elements for consumables), solar panels, electrical engines, cables and
connectors, mechanical attachments to the aircraft structure, related instrumentation, power
output control system, etc. Hybrid powerplant systems that transform fossil-fuel energy into
electrical energy used for trust and/or lift are not considered to be covered under electrical
powerplants.
[…]
Rationale: The definition of ‘electrical system’ is amended to clarify that this term refers to systems
other than the main powerplant. The definition of ‘electrical powerplant’ is added into this GM as it is
a term to be used in the proposed rule and to distinguish it from ‘electrical system’.
AMC 66.A.20(b)(2) Privileges
[…]
2. Nature of the experience:
[…]
For category B1, B2, B2L, B3 and L, for every aircraft included in the authorisation the experience
should be on that particular aircraft or on a similar aircraft within the same licence
(sub)category. Two aircraft can be considered to be similar when they have similar technology,
construction and comparable systems, which means equally equipped with the following (as
applicable to the licence category):
− Propulsion systems (piston, turboprop, turbofan, turboshaft, jet-engine or push
propellers, electrical powerplant); and
[…]
− Subcategory used (A1, A2, A3, A4, B1.1, B1.2, B1.3, B1.4, B1.E, B2, B2L, B3, C or L1, L1C,
L2, L2C, L3G, L3H, L4G, L4H, L5);
− Duration in days or partial-days.
Rationale: Text updated to also refer to electrical powerplant aircraft and B1.E licence.
66.A.25 Basic knowledge requirements

[…]
(b) […]
The holder of an aircraft maintenance licence in subcategory B1.2 or category B3 is deemed to meet
the basic knowledge requirements for a licence in subcategories L1C, L1, L2C and L2, except module
8L.19 at level 2 as defined in Appendix VII, when relevant.
[…]
Rationale: This amendment is required to impose basic knowledge submodule requirements to B1.2/
B3 licence holders to complete the required basic knowledge required to be eligible for L2 licence.
66.A.30 Basic experience requirements

(a) […]
2b […]
The holder of an aircraft maintenance licence in category/subcategory B1.2 or B3 is deemed to meet
the basic experience requirements for a licence in subcategories L1C, L1, L2C and L2, except practical
experience in powered sailplanes or ELA1 aeroplanes with an electrical powerplant, when relevant.
The practical experience in powered sailplanes or ELA1 aeroplanes with an electrical powerplant will
be considered as met when the holder of the licence can demonstrate 3 months of maintenance
experience covering a representative cross section of maintenance activities for aircraft with an
electrical powerplant.
[…]
Rationale: This amendment is required to establish the missing required basic experience for B1.2/B3
licence holders when seeking to complete the basic experience requirements to be eligible as applicants
for a licence in the L2 subcategory.
AMC 66.A.30(a) Basic experience requirements
[…]
6. All maintenance experience gained in aircraft referred to in point 2 of 66.A.3 should account for
a maximum of 50 % of the experience required per 66.A.30 in respect of the licence(s’)
subcategory/categories on which the aircraft type can be endorsed.
Rationale: Text adapted to count experience obtained in non-conventional aircraft.
66.A.45 Endorsement with aircraft ratings
(a) In order to be entitled to exercise certification privileges on a specific aircraft type, the holder
of an aircraft maintenance licence needs to have their licence endorsed with the relevant
aircraft ratings:
− For category B1, B2 or C, the relevant aircraft ratings are the following:
(i) for Group 1 aircraft, the appropriate aircraft type rating;
(ii) for Group 2 aircraft, the appropriate aircraft type rating, manufacturer subgroup
rating or full subgroup rating;
(iii) for Group 3 aircraft, the appropriate aircraft type rating or full group rating;
(iv) for Group 4 aircraft, for the category B2 licence, the full group rating.;
(v) for Group E aircraft, the appropriate aircraft type rating, manufacturer subgroup
rating or full subgroup rating.
− For category B2L, the relevant aircraft ratings are the following:
(i) for Group 2 and Group E aircraft, the appropriate manufacturer subgroup rating or
full subgroup rating;
(ii) for Group 3 aircraft, the full group rating;
(iii) for Group 4 aircraft, the full group rating.
− […]
(c) For other than category C licences, in addition to the requirements of point (b), the
endorsement of the first aircraft type rating within a given category/subcategory requires
satisfactory completion of the corresponding on-the-job training. This on-the-job training shall
comply with Appendix III to Annex III (Part-66), except in the case of gas airships, where it shall
be directly approved by the competent authority.
Aircraft referred to in point 2 of 66.A.3 may only be considered as the first aircraft to be
endorsed in a licence within a given category/subcategory for the purpose of the previous
paragraph, when the aircraft operational suitability data specifies that the aircraft is suitable for
on-the-job training in the given licence category/subcategory. Otherwise, and notwithstanding
the previous paragraph an adequate licence subcategory can still be endorsed with this aircraft
type after compliance with all Appendix III requirements, but on-the-job training is still required
for the first aircraft type to be endorsed which belongs to the licence subcategory in accordance
with point 1 of point 66.A.3.
(d) By derogation from points (b) and (c), for Group 2, and Group 3 and Group E aircraft, aircraft
type ratings may also be endorsed on a licence after completing the following steps:
[…]
(e) For Group 2 and Group E aircraft:
[…]
(h) […]
(ii) […]
(3) […]
The holder of an aircraft maintenance licence in subcategory B1.2 endorsed with the Group 3
rating, or in category B3 endorsed with the rating ‘piston engine non-pressurised aeroplanes of
2 000 kg MTOM and below’, is deemed to meet the requirements for the issuance of a licence in
subcategoriessubcategory L1 and, when fulfilling the missing basic knowledge and basic
experience requirements referred to in points 66.A.25(b) and 66.A.30(a), subcategory L2, with
the corresponding full ratings and with the same limitations as the B1.2/B3 licence held.
[…]
Rationale:
This amendment, in respect of non-conventional aircraft, permits:
— for licences B1, B2 and C, the endorsement of aircraft types for any Group 1 or Group E aircraft;
— for licences B1, C, B2 and B2L, the endorsement of manufacturer subgroup rating or full
subgroup rating for aircraft in Group E. Type endorsement is simplified for Group E aircraft in
the same way as it is already permitted for the endorsement of the aircraft type for aircraft in
Groups 2 and 3.
The on-the-job training of non-conventional aircraft is a special case when considered as the first
aircraft in the subcategory. A non-conventional aircraft may be endorsed in a licence as a first
endorsement, but it does not necessarily substitute the need for on-the-job training for the
endorsement of the first conventional aircraft on the licence subcategory.
In addition, it refers to the missing basic knowledge and basic experience requirements under the new
66.A.25(b) and 66.A.30(a) that B1.2/B3 licence holders need to meet in order to obtain a licence with
the L2 subcategory.
GM 66.A.45 Endorsement with aircraft ratings
The following table shows a summary of the aircraft rating requirements contained in 66.A.45, 66.A.50
and Appendix III to Part-66.
The table contains the following:
− The different aircraft groups.
− For each licence (sub)category, which ratings are possible (at the choice of the applicant):
− Individual type ratings.
− Full and/or Mmanufacturer (sub)group ratings.
− For each rating option, which are the qualification options.
− For the B1.2 licence (Group 3 aircraft), the B3 licence (piston-engine non-pressurised aeroplanes
of 2 000 kg MTOM and below) and the L licences, which are the possible limitations and ratings
to be included in the licence if not sufficient experience can be demonstrated in those areas.
Note: OJT means ‘On-the-Job Training’ (Appendix III to Part-66, Section 6) and is only required for the
first aircraft rating in the licence (sub)category. Exemptions apply for the endorsement of aircraft
referred to in point 2 of 66.A.3 and they are explained after the following table.
Aircraft rating requirements

Aircraft B1/B3/L licence B2/B2L licence C licence
Group 1 aircraft, except (For B1) (For B2)
airships
Individual TYPE RATING Individual TYPE RATING Individual TYPE RATING
- Complex motor-
powered aircraft. Type training: Type training: Type training:
- Multiple engine - Theory + examination - Theory + examination - Theory + examination
helicopters. - Practical + assessment - Practical + assessment
- Aeroplanes certified PLUS PLUS
above FL290. OJT (for first aircraft in OJT (for first aircraft in
- Aircraft equipped with licence subcategory) licence subcategory)
fly-by-wire.
- Other aircraft when
defined by the Agency.
Group 1 airships […] […] […]
Group 2 aircraft (For B1.1, B1.3, B1.4) (For B2)
Subgroups: Individual TYPE RATING Individual TYPE RATING Individual TYPE RATING
(type training + OJT) or (type training + OJT) or type training or type
2a: single-turboprop (type examination + (type examination + examination
aeroplanes (*) practical experience) practical experience)
2b: single-turbine-engine Full SUBGROUP RATING (For B2 and B2L) Full SUBGROUP RATING
rotorcrafthelicopters (*) (type training + OJT) or type training or type
(type examination + Full SUBGROUP RATING examination on at least
2c: single-piston-engine practical experience) on based on demonstration three 3 aircraft
rotorcrafthelicopters (*) at least 3 three aircraft of practical experience representative
representative of that of that subgroup
(*) Except those classified subgroup
in Group 1.
Manufacturer Manufacturer
SUBGROUP RATING SUBGROUP RATING Manufacturer
(type training + OJT) based on demonstration SUBGROUP RATING
or (type examination + of practical experience type training or type
practical experience) on examination on at least
at least 2 two aircraft 2 two aircraft
representative representative
of that manufacturer of that manufacturer
subgroup subgroup
Aircraft rating requirements

Aircraft B1/B3/L licence B2/B2L licence C licence
Group E aircraft (For B1.E) (For B2)
Subgroups: Individual TYPE RATING Individual TYPE RATING Individual TYPE RATING
(type training + OJT) or (type training + OJT) or type training or type
E_A: aeroplanes with an (type examination + (type examination + examination
electrical powerplant (*) practical experience) practical experience)
E_R: rotorcraft with an Full SUBGROUP RATING (For B2 and B2L) Full SUBGROUP RATING
electrical powerplant (type training + OJT) or type training or type
(*) (type examination + Full SUBGROUP RATING examination on at least
practical experience) on based on demonstration three aircraft
(*) Except those classified at least three aircraft of practical experience representative
in Group 1. representative of that of that subgroup
subgroup
Manufacturer Manufacturer
SUBGROUP RATING SUBGROUP RATING Manufacturer
(type training + OJT) based on demonstration SUBGROUP RATING
or (type examination + of practical experience type training or type
practical experience) on examination on at least
at least two aircraft two aircraft
representative representative
of that manufacturer of that manufacturer
subgroup subgroup
[…] […] […] […]
Type endorsement of aircraft referred to in point 2 of 66.A.3 in a given licence subcategory B1.x or B2
does not require on-the-job training if the licence subcategory has already been endorsed with an
aircraft type not being an aircraft of point 2 of 66.A.3.
If the licence subcategory has not yet been endorsed with such aircraft, the on-the-job training for the
aircraft referred to in point 2 of 66.A.3 which is being endorsed on the adequate licence subcategory,
may or may not count for the purpose mentioned in the first paragraph of point (c) of 66.A.45. This
would be specified on the operational suitability data for the aircraft. For instance, a given small and
simple aircraft referred to in point 2 of 66.A.3 might be suitable for endorsement both in the B1.1. and
B1.2. licence subcategories, but its on-the-job training may only be considered suitable for allowing
further type endorsement without conducting new on-the-job training in the B1.2 licence
subcategory.
Rationale: Table updated to consider electrical aeroplanes/rotorcraft and OJT for non-conventional
aircraft.
AMC 66.A.45(d);(e)3;(f)1;(g)1;(h) Endorsement with aircraft ratings
1. […]
2. In the case of endorsement of individual type ratings for Group 2, and Group 3 and Group E
aircraft, for the second aircraft type of each manufacturer (sub)group the practical experience
should be reduced to 30% of the tasks contained in Appendix II to AMC relevant to the licence
category and to the applicable aircraft type. For subsequent aircraft types of each manufacturer
(sub)group, this should be reduced to 20%.
3. […]
Rationale: Text updated to consider Group E aircraft.
AMC 66.A.45(e) Endorsement with aircraft ratings

1. For the granting of manufacturer subgroup ratings for Group 2 and Group E aircraft, for B1 and
C licence holders, the sentence ‘at least two aircraft types from the same manufacturer which
combined are representative of the applicable manufacturer subgroup’ means that the selected
aircraft types should cover the technologies relevant to the manufacturer subgroup in the
following areas:
[…]
2. For the granting of full subgroup ratings for Group 2 and Group E aircraft, for B1 and C licence
holders, the sentence ‘at least three aircraft types from different manufacturers which
combined are representative of the applicable subgroup’ means that the selected aircraft types
should cover all the technologies relevant to the manufacturer subgroup in the following areas:
[…]
Rationale: Text updated to consider Group E aircraft.
[…]
66.B.110 Procedure for the change of an aircraft maintenance

licence to include an additional basic category or subcategory
[…]
(d) In the case of a holder of an aircraft maintenance licence in subcategory B1.2 endorsed with the
Group 3 rating or in category B3 endorsed with the rating ‘piston-engine non-pressurised
aeroplanes of 2 000 kg MTOM and below’, the competent authority shall issue, upon
application, a fully rated licence in subcategories L1 and L2, with the same limitations as the
B1.2/B3 licence held.:
(i) upon application, a fully rated licence in subcategory L1, with the same limitations as the
B1.2/B3 licence held; and
(ii) upon application and presenting evidence of fulfilment of the missing basic knowledge
and basic experience requirements referred to in 66.A.25(b) and 66.A.30(a), a fully rated
licence in subcategory L2, with the same limitations as the B1.2/B3 licence held.
[…]
Rationale: This amendment is required to establish the path for B1.2/B3 licence holders to be entitled
to obtain an L1 licence (automatically by application) and an L2 licence (by application and completing
the missing basic knowledge and basic experience requirements).
APPENDICES TO ANNEX III (Part-66)
Appendix I — Basic Knowledge Requirements (except for category L

licence)
[…]
2. Modularisation
Qualification on basic subjects for each aircraft maintenance licence category or subcategory shall be
in accordance with the following matrix, where applicable subjects are indicated by an ‘X’:
For (sub)categories A, B1(*), B1.E and B3:
(*) – All B1 subcategories except subcategory B1.E
A or B1(*) rotorcrafthelicopter B1.E aeroplane
A or B1(*) aeroplane with: B3
with: and rotorcraft
Subject Piston-engine
module Piston non-pressurised
Turbine Turbine Piston Electrical
engine(s aeroplanes
engine(s) engine(s) engine(s) powerplant
) 2 000 kg MTOM
and below
1 X X X X X X
2 X X X X X X
3 X X X X X X
4 X X X X X X
5 X X X X X X
6 X X X X X X
7A X X X X X
7B X
8 X X X X X X
9A X X X X X
9B X
10 X X X X X X
11A X X
11B X
11C X
12 and X X X
12B
13
14
A or B1(*) rotorcrafthelicopter B1.E aeroplane

A or B1(*) aeroplane with: B3
with: and rotorcraft
Subject Piston-engine
Piston non-pressurised
module Turbine Turbine Piston Electrical
engine(s aeroplanes
engine(s) engine(s) engine(s) powerplant
) 2 000 kg MTOM
and below
15 X X
16 X X X
17A X X X X X
17B X
18 X
For categories B2 and B2L:
Subject module/submodules B2 B2L
[…]
18
[…]
MODULE 5. DIGITAL TECHNIQUES/ELECTRONIC INSTRUMENT SYSTEMS

LEVEL
MODULE 5. DIGITAL TECHNIQUES/ELECTRONIC INSTRUMENT SYSTEMS A B1.1 B1.2 B2 B3
B1.3 B1.4 B2L
B1.E
[…]
MODULE 11A. TURBINE AEROPLANE AERODYNAMICS, STRUCTURES AND SYSTEMS

LEVEL
MODULE 11A. TURBINE AEROPLANE AERODYNAMICS, STRUCTURES AND SYSTEMS
A B1.1
[…]
MODULE 12. ROTORCRAFTHELICOPTER AERODYNAMICS, STRUCTURES AND SYSTEMS

LEVEL
MODULE 12. ROTORCRAFT: HELICOPTER AERODYNAMICS, STRUCTURES AND
SYSTEMS A3 B1.3
A4 B1.4
[…]
MODULE 12B. ROTORCRAFT: GYROCOPTER SPECIFICS

LEVEL
A3 B1.3
MODULE 12B. ROTORCRAFT: GYROCOPTER SPECIFICS
A4 B1.4
B1.E
12B.1 Theory of flight — rotary wing aerodynamics 1 2
LEVEL
MODULE 12B. ROTORCRAFT: GYROCOPTER SPECIFICS A3 B1.3
A4 B1.4
B1.E
Terminology;
Blade lift and drag;
Auto-rotation;
Ground effect;
Pre-rotate, take-off, flight, and landing characteristics;
Gyroplane pitch stability, influence of centre of gravity, body aerodynamics;
Thrust line;
Horizontal tail;
Gyroplane yaw stability;
Taxi stability and roll-over risk;
Power pushover, pilot-induced oscillations, low-g manoeuvres.
12B.2 Flight control systems 1 3
Rotor control systems;
Yaw control systems;
Main rotor head: design and operation features;
Rotor blades: structure, attachments;
Trim control.
12B.3 Blade tracking and vibration analysis 1 3
Rotor alignment;
Rotor tracking;
Static and dynamic balancing;
Vibration types, vibration reduction methods;
Ground resonance.
12B.4 Transmission 1 3
Gearboxes for pre-rotator and propeller;
Pre-rotator systems;
Clutches, free wheel units and rotor brake;
Flexible couplings, drive shafts, bearings, vibration dampers and bearing
hangers.
[…]
MODULE 14. PROPULSION

LEVEL
MODULE 14. PROPULSION B2
B2L
[…] […]
14.4 Electrical powerplants 2

- Working principle of electrical engines and generators;
- Construction of rotating electric machines;
- Power electronics;
- Engine control system (control functions, speed control, torque control, position
measurement, generator mode for energy recuperation, protection functions);
- High voltage wiring, batteries, solar cells, fuel cells and auxiliary systems;
- Practical elements:
Safety procedures (high-pressure reservoirs, handling of chemicals, high voltage/currents);
Scheduled inspection/check of the engine(s)/battery(ies)/fuel cells.
[…]
MODULE 18. ELECTRICAL POWERPLANT

LEVEL
MODULE 18. ELECTRICAL POWERPLANT
B1.E
18.1 Electrical engines 3
- General understanding of electromagnetics;
- Working principle of electrical engines and generators;
- Types and classification of rotating electric machines (DC brush, DC brushless, AC
synchronous (reluctance, hysteresis, stepped, PM) and AC asynchronous (induction));
- Construction of rotating electric machines (outrunner, inrunner, rotor, stator, shaft,
bearings, magnets, windings, electrical insulation, commutators, motor cooling,
sensors, wiring);
- Power electronics (switching devices, DC-DC converters, single-phase and multiple-
phases DC-AC inverters, single-phase and multiple-phases AC-DC rectifiers);
- Engine control system (control functions, speed control, torque control, position
measurement, generator mode for energy recuperation, protection functions).
18.2 Batteries and accessories 3

- Power-storage systems (common high-density battery, chemistry batteries, load
cycles, degradation, effects of charging and overcharging, thermal runaway);
- Battery management systems (general functions, battery balancing, monitoring;
- Solar cells;
- Wiring of electric power storage, power electronics and electric motor;
- Instrumentation and cockpit indicators.
18.3 Fuel cells 3

- General understanding and chemical principles: energy density, current generation,
and generated heat;
- Typical architectures, electrolytes, catalysts and fuels and chemical products;
- Fuel cell auxiliary systems: tanks, lines, instruments;
- Degradation, maintenance and fluids replenishment.
18.4 Practical elements 3
- Safety procedures (high-pressure reservoirs, handling of chemicals, high
voltage/currents);
- Scheduled inspection/check of the engine(s)/battery(ies)/fuel cells;
- Inspection/check after unscheduled events: lightning strike, component overheating,
leakages;
- Removal/installation of different elements of the powerplant.
Rationale: Appendix I, ‘2. Modularisation’ is amended to define the required basic knowledge modules
for B1.E licence holders. Module 12 is completed with Module 12B, covering other rotorcraft. Modules
14.4 and 18 are added to expand the basic knowledge in regard to electrical powerplant aircraft for
the B2/B2L and B1.E licence holders respectively.
Appendix II — Basic examination standard (except for category L

licence)
[…]
2. Number of questions per module

[…]
2.12. MODULE 12 and 12B — HELICOPTERROTORCRAFT AERODYNAMICS, STRUCTURES AND

SYSTEMS:
[…]
2.14. MODULE 14 — PROPULSION:
Category B2 and B2L: 2430 multi-choice and 0 essay questions. Time allowed 3036 minutes.
[…]
MODULE 18 –ELECTRICAL POWERPLANT
Subcategory B1.E: 120 multi-choice and 0 essay questions. Time allowed 150 minutes.
[…]
Rationale: Appendix II is amended to provide an updated title, new values for the questions and the
duration of the examination standards for the new modules 12/12B, 14 and 18.
Appendix III — Aircraft type training and examination standard —

On the job training
[…]
3. Aircraft type training standard

[…]
3.1. Theoretical element
[…]
(c) Duration:
The theoretical training minimum tuition hours are contained in the following table:
Category Hours(**)
Aeroplanes(*) with a maximum take-off mass above 30 000 kg:
[…] […]
Aeroplanes(*) with a maximum take-off mass equal to or less than 30 000 kg and above 5 700 kg:
[…] […]
Aeroplanes(*) with a maximum take-off mass of 5 700 kg and below23
[…] […]
24
Helicoptersrotorcraft(*)
B1.3 120
B1.4 100
B2 100
C 25
Aeroplanes/rotorcraft with an electrical powerplant
23 For non-pressurised piston-engine aeroplanes below 2 000 kg MTOM, the minimum duration can be reduced by 50 %.
24
For helicoptersrotorcraft in Group 2 (as defined in point 66.A.5), the minimum duration can be reduced by 30 %.
B1.E25 150/120
C adbA
Aircraft other than aeroplanes, rotorcraft, sailplanes, balloons and airships
B1.1 adbA
B1.2 adbA
B1.3 adbA
B1.4 adbA
B1.E adbA
B2 adbA
C adbA
(*) – aircraft with piston or turbine engine
(**) – For aeroplanes and rotorcraft with propulsion system other than turbine, piston engine or
based on an electrical powerplant, the number of hours should be ‘adbA’
In the table above, adbA means ‘as determined by the Agency’ in the operational suitability data
established in accordance with Regulation (EU) No 748/2012, taking into consideration a report from the
applicant for, or holder of, the type certificate that contains an assessment of the required theoretical
knowledge of the aircraft, considering the adequate licence category on which the aircraft type would be
permitted for endorsement in accordance with 66.A.3.
[…]
(e) Content:
Level Aeroplanes Aeroplanes Helicopter Helicopter Aeroplanes Avionics
Chapters turbine piston srotorcraft srotorcraft /rotorcraft
turbine piston electric
Licence category B1 C B1 C B1 C B1 C B1.E C B2
Introduction module:
05 Time limits/maintenance 1 1 1 1 1 1 1 1 1 1 1
checks
06 Dimensions/Areas (MTOM, 1 1 1 1 1 1 1 1 1 1 1
etc.)
07 Lifting and Shoring 1 1 1 1 1 1 1 1 1 1 1
08 Levelling and weighing 1 1 1 1 1 1 1 1 1 1 1
09 Towing and taxiing 1 1 1 1 1 1 1 1 1 1 1
10 Parking/mooring, Storing 1 1 1 1 1 1 1 1 1 1 1
and Return to Service
11 Placards and Markings 1 1 1 1 1 1 1 1 1 1 1
12 Servicing 1 1 1 1 1 1 1 1 1 1 1
20 Standard practices — only 1 1 1 1 1 1 1 1 1 1 1
type particular
HelicoptersRotorcraft
18 Vibration and Noise — — — — 3 1 3 1 —/3 —/1 —

Analysis (Blade tracking)
60 Standard Practices Rotor — — — — 3 1 3 1 —/3 —/1 —
62 Rotors — — — — 3 1 3 1 —/3 —/1 1
25
For aeroplanes/rotorcraft in Group E (as defined in point 66.A.5), the minimum duration can be reduced by 30 %.

62A Rotors — Monitoring and — — — — 3 1 3 1 —/3 —/1 3
indicating
63 Rotor Drives — — — — 3 1 3 1 —/3 —/1 1
63A Rotor Drives — — — — — 3 1 3 1 —/3 —/1 3
Monitoring and indicating
64 Tail Rotor — — — — 3 1 3 1 —/3 —/1 1
64A Tail rotor — Monitoring — — — — 3 1 3 1 —/3 —/1 3
and indicating
65 Tail Rotor Drive — — — — 3 1 3 1 —/3 —/1 1
65A Tail Rotor Drive — — — — — 3 1 3 1 —/3 —/1 3
66 Folding Blades/Pylon — — — — 3 1 3 1 —/3 —/1 —
67 Rotors Flight Control — — — — 3 1 3 1 —/3 —/1 —
53 Airframe Structure — — — — 3 1 3 1 —/3 —/1 —
(HelicopterRotorcraft)
25 Emergency Flotation — — — — 3 1 3 1 —/3 —/1 1
Equipment
Specific gyrocopter systems 3 1 3 1 —/3 —/1 1
Airframe structures
51 Standard practices and 3 1 3 1 — — — — 3/— 1/— 1
structures (damage
classification, assessment and
repair)
53 Fuselage 3 1 3 1 — — — — 3/— 1/— 1
54 Nacelles/Pylons 3 1 3 1 — — — — 3/— 1/— 1
55 Stabilisers 3 1 3 1 — — — — 3/— 1/— 1
56 Windows 3 1 3 1 — — — — 3/— 1/— 1
57 Wings 3 1 3 1 — — — — 3/— 1/— 1
27A Flight Control Surfaces 3 1 3 1 — — — — 3/— 1/— 1
(All)
52 Doors 3 1 3 1 — — — — 3/— 1/— 1
Zonal and Station 1 1 1 1 1 1 1 1 1 1 1
Identification Systems.
Airframe systems:
21 Air Conditioning 3 1 3 1 3 1 3 1 3 1 3
21A Air Supply 3 1 3 1 3 1 3 1 3 1 2
21B Pressurisation 3 1 3 1 3 1 3 1 3 1 3
21C Safety and Warning 3 1 3 1 3 1 3 1 3 1 3
Devices
22 Autoflight 2 1 2 1 2 1 2 1 2 1 3
23 Communications 2 1 2 1 2 1 2 1 2 1 3
24 Electrical Power 3 1 3 1 3 1 3 1 3 1 3
25 Equipment and Furnishings 3 1 3 1 3 1 3 1 3 1 1
25A Electronic Equipment 1 1 1 1 1 1 1 1 1 1 3
including emergency
equipment

26 Fire Protection 3 1 3 1 3 1 3 1 3 1 3
27 Flight Controls 3 1 3 1 3 1 3 1 3 1 2
27A Sys. Operation: 3 1 — — 3 1 — — 3/— 1/— 3
Electrical/Fly-by-Wire
28 Fuel Systems 3 1 3 1 3 1 3 1 — — 2
28A Fuel Systems — 3 1 3 1 3 1 3 1 — — 3
29 Hydraulic Power 3 1 3 1 3 1 3 1 3 1 2
29A Hydraulic Power — 3 1 3 1 3 1 3 1 3 1 3
30 Ice and Rain Protection 3 1 3 1 3 1 3 1 3 1 3
31 Indicating/Recording 3 1 3 1 3 1 3 1 3 1 3
Systems
31A Instrument Systems 3 1 3 1 3 1 3 1 3 1 3
32 Landing Gear 3 1 3 1 3 1 3 1 3 1 2
32A Landing Gear — 3 1 3 1 3 1 3 1 3 1 3
33 Lights 3 1 3 1 3 1 3 1 3 1 3
34 Navigation 2 1 2 1 2 1 2 1 2 1 3
35 Oxygen 3 1 3 1 — — — — 3/— 1/— 2
36 Pneumatic 3 1 3 1 3 1 3 1 3 1 2
36A Pneumatic — Monitoring 3 1 3 1 3 1 3 1 3 1 3
and indicating
37 Vacuum 3 1 3 1 3 1 3 1 3 1 2
38 Water/Waste 3 1 3 1 — — — — 3/— 1/— 2
41 Water Ballast 3 1 3 1 — — — — 3/— 1/— 1
42 Integrated modular 2 1 2 1 2 1 2 1 2 1 3
avionics
44 Cabin Systems 2 1 2 1 2 1 2 1 2 1 3
45 On-Board Maintenance 3 1 3 1 3 1 — — 3 1 3
System (or covered in 31)
46 Information Systems 2 1 2 1 2 1 2 1 2 1 3
50 Cargo and Accessory 3 1 3 1 3 1 3 1 3 1 1
Compartments
Turbine Engine
70 Standard Practices — 3 1 — — 3 1 — — — — 1
Engines,
70A constructional 3 1 — — 3 1 — — — — 1
arrangement and operation
(Installation Inlet,
Compressors, Combustion
Section, Turbine Section,
Bearings and Seals,
Lubrication Systems).
70B Engine Performance 3 1 — — 3 1 — — — — 1
71 Powerplant 3 1 — — 3 1 — — — — 1

72 Engine Turbine/Turbo 3 1 — — 3 1 — — — — 1
Prop/Ducted Fan/Unducted
fan
73 Engine Fuel and Control 3 1 — — 3 1 — — — — 1
75 Air 3 1 — — 3 1 — — — — 1
76 Engine controls 3 1 — — 3 1 — — — — 1
78 Exhaust 3 1 — — 3 1 — — — — 1
79 Oil 3 1 — — 3 1 — — — — 1
80 Starting 3 1 — — 3 1 — — — — 1
82 Water Injections 3 1 — — 3 1 — — — — 1
83 Accessory Gear Boxes 3 1 — — 3 1 — — — — 1
84 Propulsion Augmentation 3 1 — — 3 1 — — — — 1
73A FADEC 3 1 — — 3 1 — — — — 3
74 Ignition 3 1 — — 3 1 — — — — 3
77 Engine Indicating Systems 3 1 — — 3 1 — — — — 3
49 Auxiliary Power Units 3 1 — — — — — — — — 2
(APUs)
Piston Engine
70 Standard Practices — — — 3 1 — — 3 1 — — 1
Engines
70A Constructional — — 3 1 — — 3 1 — — 1
arrangement and operation
(Installation, Carburettors,
Fuel injection systems,
Induction, Exhaust and
Cooling Systems,
Supercharging/Turbocharging,
Lubrication Systems).
70B Engine Performance — — 3 1 — — 3 1 — — 1
71 Powerplant — — 3 1 — — 3 1 — — 1
73 Engine Fuel and Control — — 3 1 — — 3 1 — — 1
76 Engine Control — — 3 1 — — 3 1 — — 1
79 Oil — — 3 1 — — 3 1 — — 1
80 Starting — — 3 1 — — 3 1 — — 1
81 Turbines — — 3 1 — — 3 1 — — 1
82 Water Injections — — 3 1 — — 3 1 — — 1
83 Accessory Gear Boxes — — 3 1 — — 3 1 — — 1
84 Propulsion Augmentation — — 3 1 — — 3 1 — — 1
73A FADEC — — 3 1 — — 3 1 — — 3
74 Ignition — — 3 1 — — 3 1 — — 3
77 Engine Indication Systems — — 3 1 — — 3 1 — — 3
Electrical powerplant
Electrical engines — — — — — — — — 3 1 —
Fuel cell and related systems — — — — — — — — 3 1 —
Batteries — — — — — — — — 3 1 —

Auxiliary systems to the — — — — — — — — 3 1 —
electrical powerplant
Propellers
60A Standard Practices — 3 1 3 1 3 1 3 1 3 1 1
Propeller
61 Propellers/Propulsion 3 1 3 1 3 1 3 1 3 1 1
61A Propeller Construction 3 1 3 1 3 1 3 1 3 1 1
61B Propeller Pitch Control 3 1 3 1 3 1 3 1 3 1 1
61C Propeller Synchronising 3 1 3 1 3 1 3 1 3 1 1
61D Propeller Electronic 2 1 2 1 2 1 2 1 2 1 1
control
61E Propeller Ice Protection 3 1 3 1 3 1 3 1 3 1 1
61F Propeller Maintenance 3 1 3 1 3 1 3 1 3 1 1
Special chapters for
aeroplanes/rotorcraft with a
powerplant (engine) other
than piston/turbine/electric
Identified specific chapters for adbA adbA adb adb adb adb adb adb adbA adbA adbA
the propulsion of the A A A A A A
aeroplane or rotorcraft when
the propulsion is based on a
powerplant other than
turbine, piston or electrical
engines
Special chapters due to the
aircraft not being covered by
a B1/C (or L) licence
Identified specific chapters for adbA adbA adb adb adb adb adb adb adbA adbA adbA
aircraft other than aeroplanes A A A A A A
or rotorcraft (or covered by a
category L licence)
In the table above, adbA means ‘as determined by the Agency’ in the operational suitability data established in
accordance with Regulation (EU) No 748/2012, taking into consideration a report from the applicant for, or
holder of, the type certificate that contains an assessment of the required type of theoretical knowledge of the
aircraft, considering the adequate licence category on which the aircraft type would be permitted for
endorsement in accordance with 66.A.3. For these aircraft, EASA can also consider as ‘not required’ some of the
chapters contained in the above table that would be otherwise required for a piston/turbine/electric aeroplane
or rotorcraft.
(f) Multimedia-Based Training (MBT) […]

3.2. Practical element
[…]
(b) Content:
[…]
Chapters B1/B2 B1 B2
LOC FOT SGH R/I MEL TS FOT SGH R/I MEL TS
[…]
Helicopterrotorcraft:
[…]
53 Airframe
Structure
(Helicopterrotorcraft)
Note: covered under
Airframe structures
[…]
Specific gyrocopter X/X X X X X X X X — — —
systems
[…]
Turbine/Piston
Engine/Electrical
propulsion Module:
[…]
Electrical powerplant
Electrical engines X/X X x X X X X — — X —
Fuel cell and related X/X X x X X X X — — X —

systems
X/X X x X X X X — — X —
Batteries
Auxiliary systems to X/X X x X X X X — — X —

the electrical
powerplant
[…]
61F Propeller X/X X X X X X X X X X X
Maintenance
Identified specific adbA adb adb adb adb adb adb adb adb adb adb
modules for the A A A A A A A A A A
propulsion of the
aeroplane or
rotorcraft when the
propulsion is based
on other than
turbine, piston or
electrical engines
Identified specific adbA adb adb adb adb adb adb adb adb adb adb
modules for aircraft A A A A A A A A A A
other than
aeroplanes or
rotorcraft (or covered

by a category L
licence)
In the table above, adbA means ‘as determined by the Agency’ in the operational suitability data established
in accordance with Regulation (EU) No 748/2012, taking into consideration a report from the applicant for, or
holder of, the type certificate that contains an assessment of the required practical training on the aircraft,
considering the adequate licence category on which the aircraft type would be permitted for endorsement in
accordance with 66.A.3. For these aircraft, the Agency can also exempt some of the chapters contained in the
above table that would be otherwise required for an aeroplane or a rotorcraft.
[…]
Rationale: Appendix III is amended to provide new values for duration (minimum tuition hours),
contents (chapters) and detail (levels) of the theoretical element and contents of the theoretical and
practical elements of the type training standard for the change from helicopter to rotorcraft licence
and for electrical aeroplanes/rotorcraft. The amendment also covers the type training and
examination of aircraft other than aeroplanes, rotorcraft or aircraft covered by an L licence and also
of aeroplanes and rotorcraft with propulsion systems other than turbine, engine or electrical, both in
respect of the theoretical knowledge and the practical training.
Appendix IV — Experience requirements for extending a Part-66

aircraft maintenance licence
[…]
To
A1 A2 A3 A4 B1.1 B1.2 B1.3 B1.4 B1.E B2 B2L B3
From
A1 — 6 6 6 2 years 6 2 years 1 year 2 years 2 years 1 year 6
months months months months months
A2 6 — 6 6 2 years 6 2 years 1 year 2 years 2 years 1 year 6
A3 6 6 — 6 2 years 1 year 2 years 6 2 years 2 years 1 year 1 year
months months months months
A4 6 6 6 — 2 years 1 year 2 years 6 2 years 2 years 1 year 1 year
B1.1 None 6 6 6 — 6 6 6 6 1 year 1 year 6
months months months months months months months months
B1.2 6 None 6 6 2 years — 2 years 6 6 2 years 1 year None

B1.3 6 6 None 6 6 6 — 6 6 1 year 1 year 6

months months months months months months months months
B1.4 6 6 6 None 2 years 6 2 years — 6 2 years 1 year 6

months months months months months months
B1.E 6 6 6 6 2 years 6 2 years 6 — 1 year 1 year 6

months months months months months months months
B2 6 6 6 6 1 year 1 year 1 year 1 year 1 year — — 1 year

B2L 6 6 6 6 1 year 1 year 1 year 1 year 1 year 1 year — 1 year
B3 6 None 6 6 2 years 6 2 years 1 year 2 years 2 years 1 year —
Rationale: This table is amended to provide experience requirements for extending a Part-66 aircraft
maintenance licence from one of the already existing subcategories to B1.E and vice versa.
Appendix V — Application Form — EASA Form 19

[…]
APPLICATION FOR INITIAL/AMENDMENT/RENEWAL OF PART-66 AIRCRAFT EASA FORM 19
MAINTENANCE LICENCE (AML)
APPLICANT’S DETAILS:
Name: ………………………………………………………………………………………………………………………………………………………
Address: ……………………………………………………………………………………………………………………………………………………
Tel: ……………………………………………………………………….. E-mail: …………………………………………………………………….
Nationality: …………………………………………………………... Date and Place of Birth: ………………………………………….
PART-66 AML DETAILS (if applicable):
Licence No: …………………………………………………………………. Date of Issue: …………………………………………………….
EMPLOYER’S DETAILS:
Name: ………………………………………………………………………………………………………………………………………………………
Address: ……………………………………………………………………………………………………………………………………………………
………………………………………………………………………………………………………………………………………………………………….
Maintenance Organisation Approval Reference: ………………………………………………………………………………………
Tel: …………………………………………………………………………….. Fax: ……………………………………………………………………
APPLICATION FOR: (Tick relevant boxes)
Initial AML Amendment of AML Renewal of AML
(Sub)categories A B1 B2 B2L B3 C L (see below)
Aeroplane Turbine
Aeroplane Piston
HelicopterRotorcraftTurbine
HelicopterRotorcraft Piston
Aeroplane/rotorcraft electric
Avionics See system ratings below
Piston-engine non-pressurised aeroplanes of a MTOM of 2t and
below
Complex motor-powered aircraft
Aircraft other than complex motor-powered aircraft
System ratings for B2L licence:
1. autoflight
2. instruments
3. com/nav
4. surveillance
5. airframe systems
L-licence subcategories:
L1C: Composite sailplanes
L1: Sailplanes
L2C: Composite powered sailplanes and composite ELA1 aeroplanes
L2: Powered sailplanes and ELA1 aeroplanes
L3H: Hot-air balloons
L3G: Gas balloons
L4H: Gas balloons
L4H: Hot-air airships
L4G: ELA2 gas airships
L5: Gas airship other than ELA2
Type endorsements/Rating endorsement/Limitation removal (if applicable):

…………………………………………………………………………………………………………………………………………………………………….
I wish to apply for initial/amendment of/renewal of Part-66 AML, as indicated, and confirm that the
information contained in this form was correct at the time of application.
I herewith confirm that:
1. I am do not holding any Part-66 AML issued in another Member State;
2. I have not applied for any Part-66 AML in another Member State; and
3. I never had a Part-66 AML issued in another Member State which was revoked or suspended in any
other Member State.
I also understand that any incorrect information could disqualify me from holding a Part-66 AML.
Signed: …………………………………………………………………. Name: ……………………………………………………………………….
Date: ………………………………………………………………………………………………………………………………………………………….
I wish to claim the following credits (if applicable):
…………………………………………………………………………………………………………………………………………………………………….
…………………………………………………………………………………………………………………………………………………………………….
…………………………………………………………………………………………………………………………………………………………………….
Experience credits for Part-147 training
…………………………………………………………………………………………………………………………………………………………………….
…………………………………………………………………………………………………………………………………………………………………….
…………………………………………………………………………………………………………………………………………………………………….
Examination credits for equivalent exam certificates
…………………………………………………………………………………………………………………………………………………………………….
…………………………………………………………………………………………………………………………………………………………………….
…………………………………………………………………………………………………………………………………………………………………….
Please enclose all relevant certificates
Recommendation (if applicable): It is hereby certified that the applicant has met the relevant Part-66
maintenance knowledge and experience requirements and it is recommended that the competent authority
grants or endorses the Part-66 AML.
Signed: .............................................................. Name: ..................................................................................

Position: ........................................................... Date: ....................................................................................
EASA Form 19 Issue 56
Rationale: Appendix V is amended to replace the references to helicopters with references to rotorcraft
and to consider the new subcategory B1.E.
Appendix VI — Aircraft Maintenance Licence referred to in Annex III

(Part-66) — EASA Form 26
[…]
IVa. Full name of holder:
I.
EUROPEAN UNION (*) IVb. Date and place of birth:
[STATE]
[AUTHORITY NAME & LOGO] V. Address of holder:
II. VI. Nationality of holder:

Part-66
AIRCRAFT MAINTENANCE VII. Signature of holder:
LICENCE
III.
Licence No. [MEMBER STATE
CODE].66.[XXXX]
EASA FORM 26 Issue 56 III. Licence No:
IX. Part-66 CATEGORIES

VIII. CONDITIONS:
VALIDITY A B1 B2 B2L B3 L C
Aeroplanes Turbine n/a n/a n/a n/a

This licence shall be signed by the holder and be accompanied by
an identity document containing a photograph of the licence Aeroplanes Piston n/a n/a n/a n/a
holder.
Endorsement of any categories on the page(s) entitled 'Part-66 HelicoptersRotorcraft n/a n/a n/a n/a
CATEGORIES' only, does not permit the holder to issue a Turbine
certificate of release to service for an aircraft.
HelicoptersRotorcraft Piston n/a n/a n/a n/a
This licence, when endorsed with an aircraft rating, meets the
intent of ICAO Annex 1. Aeroplanes/rotorcraft n/a n/a n/a n/a n/a
The privileges of this licence holder are prescribed by Regulation electrical powerplant
(EU) No 1321/2014 and, in particular, Annex III (Part-66) thereto. Avionics n/a n/a n/a n/a n/a
This licence remains valid until the date specified on the
limitation page unless previously suspended or revoked. Complex motor-powered n/a n/a n/a n/a n/a
aircraft
The privileges of this licence may not be exercised unless in the
preceding two2-year period, the holder had either six 6 months of Aircraft other than complex n/a n/a n/a n/a n/a
maintenance experience in accordance with the privileges motor-powered aircraft
granted by the licence, or met the provisions for the issue of the
appropriate privileges. Sailplanes, powered n/a n/a n/a n/a n/a
sailplanes, ELA1 aeroplanes,
balloons and airships
Piston-engine non n/a n/a n/a n/a n/a

pressurised aeroplanes of
2 000 kg MTOM and below
X. Signature of issuing officer & date:
XI. Seal or stamp of issuing authority:

III. Licence No: III. Licence No:
[…]
Rationale: Appendix VI is amended to replace the references to helicopters with references to
rotorcraft and to consider the new subcategory B1.E.
Appendix II — Aircraft Type Practical Experience and On-the-Job

Training - List of Tasks
The proposed amendment to this ‘Appendix II’ is not detailed in this NPA and this Appendix II to AMC
would largely follow the principles and contents proposed for amendment with NPA 2020-12. Refer to
the text proposed with such NPA, which would be adapted in consideration of:
— new modules to cover any rotorcraft, as considered in the proposed amended Appendix III to
Part-66 in this NPA;
— new modules to cover aeroplanes and rotorcraft with an electrical powerplant, as considered in
the proposed amended Appendix III to Part-66 in this NPA;
— the fact that the definition of the aircraft type training for aircraft other than aeroplanes,
rotorcraft, (powered) sailplanes, balloons and airships and for aeroplanes and rotorcraft with a
powerplant other than piston, turbine or electrical, would be established in the operational
suitability data referred to in Appendix III to Part-66 and in points 21.A.15 and 21.B.82 of
Regulation (EU) No 748/201226.
[…]
ANNEX IV (PART-147)
[…]
AMC 147.A.100(i) Facility requirements

1. […]
2. Except for the Parts and national aviation regulations, the remainder of the documentation
should represent typical examples for both large and small aircraft and cover both aeroplanes
and helicoptersrotorcraft as appropriate. Avionic documentation should cover a representative
range of available equipment. All documentation should be reviewed and updated on a regular
basis.
Rationale: Text updated to refer to rotorcraft.
GM 147.A.145(d) Privileges of the maintenance training

organisation
1. […]
3. The reason for allowing the subcontracting of training modules 1 to 6 and 8 to 10 only is that,
most of the related subjects can generally also be taught by training organisations not
specialised in aircraft maintenance and the practical training element, as specified in 147.A.200,
does not apply to them. On the contrary, the other training modules 7 and 11 to 17 are specific
26 Commission Regulation (EU) No 748/2012 of 3 August 2012 laying down implementing rules for the airworthiness
and environmental certification of aircraft and related products, parts and appliances, as well as for the
certification of design and production organisations (OJ L 224, 21.8.2012, p. 1) (https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A32012R0748&qid=1637832597996).
to aircraft maintenance and include the practical training element as specified in 147.A.200. The
intent of the ‘limited subcontracting’ option as specified in 147.A.145 is to grant Part-147
approvals only to those organisations having themselves at least the capacity to teach on
aircraft maintenance specific matters.
Rationale: Text updated to reflect the updated list of modules.
AMC 147.A.145(f) Privileges of the maintenance training

organisation
When an organisation approved to provide basic knowledge training or type training is also approved
to provide type examination in the cases where type training is not required, appropriate procedures
in the MTOE should be developed and approved, including:
− Tthe development and the conduct of the type examination;
− Tthe qualification of the examiners and their currency.
In particular, emphasis should be put on when such an examination is not regularly conducted or when
the examiners are not normally involved in aircraft or activities with technology corresponding to the
aircraft type subject to examination. An example would be the case of an organisation providing basic
knowledge training only for the B1.1 licencse. This organisation should justify how they run type
examinations for single-piston-engine rotorcrafthelicopters in the case of a B1.4 licence.
Rationale: Text updated to refer to rotorcraft.
AMC 147.A.200(g) The approved basic training course
Typical conversion durations are given below:

(a) […]
(f) The approved basic training course to qualify for conversion from holding a Part-66 aircraft
maintenance licence in subcategory A1, A3 or A4 to subcategory B1.E should not be less than
1 800 hours and for conversion from holding a Part-66 aircraft maintenance licence in
subcategory A1, A3 or A4 to subcategory B1.E combined with B2 should not be less than 2 400
hours. For conversions from A2 to B1.E or B1.E combined with B2, the minimum duration of the
basic training course should be not less than 1 950 and 2 550 hours respectively. The course
should include between 60 % and 70 % knowledge training.
(g) The approved basic training course to qualify for conversion from holding a Part-66 aircraft
maintenance licence in subcategory B1.E to B2 should not be less than 600 hours or from a
licence in category B2 to B1.E should not be less than 800 hours and should include between
80 % and 85 % knowledge training.
(h) The approved basic training course to qualify for conversion from holding a Part-66 aircraft
maintenance licence in subcategory B1.1, B1.2, B1.3 or B1.4 to subcategory B1.E should not be
less than 200, 600, 200 and 200 hours respectively, and should include between 50% and 60%
knowledge training.
Rationale: Proposed duration of basic training courses for conversions from existing subcategories to
the new B1.E and vice versa.
Appendix I — Basic training course duration
The minimum duration of a complete basic training course shall be as follows:

Basic Course Duration (in hours) Theoretical Training Ratio (in %)
[…]
B1.4 2 400 50–60
B1.E 2 600 50–60
[…]
Rationale: Proposed minimum duration for a complete basic training course for the new B1.E
subcategory.
Appendix II — Maintenance Training Organisation Approval —

EASA Form 11
[…]
Page 2 of 2
MAINTENANCE TRAINING AND EXAMINATION ORGANISATION APPROVAL SCHEDULE
Reference: [MEMBER STATE CODE (*)].147.[XXXX]
Organisation: [COMPANY NAME AND ADDRESS]
CLASS LICENCE CATEGORY LIMITATION

BASIC (**) B1 (**) TB1.1 (**) AEROPLANES TURBINE (**)
TB1.2 (**) AEROPLANES PISTON (**)
TB1.3 (**) HELICOPTERSROTORCRAFT TURBINE (**)
TB1.4 (**) HELICOPTERSROTORCRAFT PISTON (**)
TB1.E (**) AEROPLANES/ROTORCRAFT WITH AN
B2 (**)/(****) TB2 (**) AVIONICS (**)
B2L (**) TB2L (**) AVIONICS (indicate system rating) (**)
B3 (**) TB3 (**) PISTON-ENGINE NON-PRESSURISED AERO-
PLANES 2 000 KG MTOM AND BELOW (**)
A (**) TA.1 (**) AEROPLANES TURBINE (**)
TA.2 (**) AEROPLANES PISTON (**)
TA.3 (**) HELICOPTERSROTORCRAFT TURBINE (**)
TA.4 (**) HELICOPTERSROTORCRAFT PISTON (**)
L (**) (Only examination) TL (**) QUOTE THE SPECIFIC LICENCE SUB-
CATEGORY (**)
TYPE/TASK C (**) T4 (**) [QUOTE AIRCRAFT TYPE] (***)
(**) B1 (**) T1 (**) [QUOTE AIRCRAFT TYPE] (***)
B2 (**) T2 (**) [QUOTE AIRCRAFT TYPE] (***)
A (**) T3 (**) [QUOTE AIRCRAFT TYPE] (***)
This approval schedule is limited to those trainings and examinations specified in the ‘Sscope of work’
section of the approved maintenance training organisation exposition.
Maintenance training organisation exposition reference: ...............................................................................
Date of original issue: ........................................................................................................................................
Date of last revision approved: ........................ Revision No: ………………...........................................................
Signed: ...............................................................................................................................................................
For the competent authority:[COMPETENT AUTHORITY OF THE MEMBER STATE (*)]

EASA Form 11 Issue 67
__________
(*) or EASA if EASA is the competent authority.
(**) Delete as appropriate if the organisation is not approved.
(***) Complete with the appropriate rating and limitation.
(****) The approval for the Basic B2 course/examination includes approval for B2L course/examination for all system ratings.
Rationale: Appendix II is proposed for amendment to take into consideration the new scope of
approval for Part-147 organisations and to replace the references to helicopters with references to
rotorcraft.
Appendix III — Certificates of Recognition referred to in Annex IV

(Part-147) — EASA Forms 148 and 149
[…]
2. Type Training/Examination (Appendix III to Part-147)
The type training certificate template shall be used for recognition of completion of either the
theoretical elements or the practical elements, or both the theoretical and practical elements of the
type rating training course.
The certificate shall indicate the airframe/engine (or powerplant) combination for which the training
was imparted.
[…]
Rationale: Appendix III is proposed for amendment so that the Certificate of Recognition can refer to
both the airframe/engine combination and aircraft/powerplant combination.
[…]
ANNEX Vb (PART-ML)
[…]
ML.1
(a) In accordance with paragraph 2 of Article 3, this Annex (Part-ML) applies to the following other
than complex motor-powered aircraft not listed in the air operator certificate of an air carrier
licensed in accordance with Regulation (EC) No 1008/2008:
(1) aeroplanes of 2 730 kg maximum take-off mass (MTOM) or less;
(2) rotorcraft of 1 200 kg MTOM or less, certified for a maximum of up to 4 four occupants;
(3) other ELA2 aircraft;.
(4) aircraft other than aeroplanes, rotorcraft, sailplanes, balloons and airships with a MTOM
of:
(i) 1 200 kg or less if they can maintain zero horizontal speed; or
(ii) 2 730 kg or less for other than those in (i).
[…]
Rationale: Small non-conventional aircraft should also be subject to Part-ML (instead of Part-M).
Therefore, ML.1 (a)(4) is proposed to incorporate these aircraft to Part-ML, establishing for them the
same discriminants as the ones already existing for other Part-ML aircraft. This aligns with the
proposed new Article 3.2.(d).
ML.A.302 Aircraft maintenance programme
[…]
(d) An MIP:
[…]
(2) […]
(f) in the case of aeroplanes, as applicable to the aircraft powerplant:
[…]
(g) inspection of the condition and attachment of the structural items, systems and
components corresponding to the following areas:
[…]
(iv) for gas balloons:
envelope, basket, equipment and instruments.
As long as this Annex does not specify an MIP for airships and rotorcraftaeroplanes with
a powerplant other than piston/turbine and for aircraft other than aeroplanes, sailplanes
and balloons, their AMP shall be based on the ICA issued by the DAH, as referred to in
point (c)(2)(b).
(e) […]
Rationale: In the rule, the MIP is only defined for certain aircraft. Therefore, the text in ML.A.302 needs
to be amended in order to be explicit on the aircraft for which an MIP is defined. The wording proposed
excludes aeroplanes with an electrical powerplant.
GM2 ML.A.302 Aircraft maintenance programme
The following table provides a summary of the provisions contained in ML.A.302 in relation to the
content of the maintenance programme, its approval and its link with the AR:
OPTION 1 OPTION 2
Responsibility for Contracted CAMO or CAO Owner (if allowed under
developing the AMP ML.A.201(f))
Approval/declaration of Approved by the CAMO or CAO, or none Declaration by the owner or none
the maintenance required in case of compliance with required in case of compliance
programme ML.A.302(e) with ML.A.302(e)
Basis for the maintenance MIP (not applicable to aeroplanes with a powerplant other than piston/turbine
programme nor to aircraft other than aeroplanes, sailplanes and balloonsrotorcraft and
airships) or ICA issued by the DAH
Deviations from the Deviations from the DAH’s instructions are Deviations do not need to be
DAH’s ICA justified. The CAMO/CAO keeps a record of justified.
the justifications and provides a copy of
them to the owner.
AMP annual review In conjunction with the AR, by the AR staff or, if not performed in conjunction
with the AR (e.g. in case of ARC extension), by the CAMO or CAO.
Rationale: Correction required since there is no MIP for aeroplanes with an electrical powerplant and
non-conventional aircraft.
AMC1 ML.A.302(d) Aircraft maintenance programme
This AMC contains an acceptable MIP for aeroplanes of 2 730 kg maximum take-off mass (MTOM) and
below, and for ELA2 aircraft other than rotorcraft or airships, grouped in the following categories:
− Piston-engine aeroplanes of 2 730 kg MTOM and below;
− ELA2 sailplanes and ELA2 powered sailplanes; and
− ELA2 balloons.
[…]
Rationale: Correction required since the AMC is relevant only for piston-engine aeroplanes.
AMC1 to Appendix II to Part-ML — Limited pilot-owner

maintenance
[…]
(d) Therefore, the following lists are considered to meet the representative scope of limited pilot-
owner maintenance referred to in ML.A.803 and Appendix II to Part-ML:
(1) Part A applies to piston-engine aeroplanes;
(2) Part B applies to piston-engine helicoptersrotorcraft;
(3) Part C applies to sailplanes and powered sailplanes; and
(4) Part D applies to balloons and airships.
[…]
Part B — PILOT-OWNER MAINTENANCE TASKS FOR HELICOPTERSROTORCRAFT
ATA Area Task HelicopterRotorcraft
11 Placards Placards, markings — installation and renewal of Yes
placards and markings required by the AFM and the
AMM
12 […] […] […]
Rationale: Correction required so that the lists provided in this AMC1 refer to the scope of limited pilot-
owner maintenance for the intended aircraft.
Appendix III — Complex maintenance tasks not to be released by

the Pilot-owner
[…]
(4) the disturbing of individual parts of units which are supplied as bench-tested units except
for the replacement or adjustment of items normally replaceable or adjustable in service;
(c1) the performance of maintenance on the powerplant that would require disassembly of
engine(s), main batteries or fuel cell(s), other than removing them from the aircraft and
reinstalling them back
(c2) the performance of maintenance on high-pressure reservoirs and components belonging to
high-pressure lines/systems related to the powerplant.
(d) the balancing of a propeller, except:
[…]
Rationale: The tasks that are permitted to be performed by the pilot-owner are amended taking into
account the new aircraft considered.
[…]
ANNEX Vc (PART-CAMO)
[…]
AMC1 CAMO.A.310(a) Airworthiness review staff qualifications
GENERAL
[…]
(d) An appropriate licence in compliance with Annex III (Part-66) is any one of the following:
− a category B1 or L licence in the subcategory of the aircraft reviewed or such that the
licence holder the privilege to release the aircraft to service after maintenance,
− […]
Rationale: This text proposal aims to cover the scenario of airworthiness reviews of non-conventional
aircraft. For these aircraft, there is no dedicated Part-66 subcategory, so the privilege to release the
aircraft to service after maintenance is granted to licence holders by endorsing the aircraft type in an
adequate licence category (refer to the proposed amendments to Part-66 for more details). The same
criterion applies here for the airworthiness review staff.
CAMO.A.315 Continuing airworthiness management
(a) […]
(b) […]
(4) for all complex motor-powered aircraft, for aircraft other than aeroplanes, rotorcraft,
sailplanes, balloons and airships with a MTOM of 5 700 kg or of 3 175 kg if they are
capable of maintaining zero horizontal speed, or for aircraft used by air carriers licensed
in accordance with Regulation (EC) No 1008/2008, establish a procedure to assess non-
mandatory modifications and/or inspections and decide on their application, making use
of the organisation’s safety risk management process as required by point (a)(3) of point
CAMO.A.200;
(5) […]
Rationale: Point (b)(4) of CAMO.A.315 is updated to refer to non-conventional aircraft in order to
establish a level playing field as regards the need to assess non-mandatory modifications and/or
inspections, etc.
[…]
ANNEX Vd (PART-CAO)
[…]
CAO.A.020 Terms of approval
(a) The CAO shall specify the approved scope of work in its combined airworthiness exposition
(CAE), as provided for in point CAO.A.025.
(1) For aeroplanes of more than 2 730 kg maximum take-off mass (MTOM) and for
rotorcrafthelicopters of more than 1 200 kg MTOM or certified for more than 4 four
occupants and for other aircraft which also are not ELA2, the scope of work shall indicate
the particular aircraft types. Changes to this scope of work shall be approved by the
competent authority in accordance with point (a) of point CAO.A.105 and point (a) of
point CAO.B.065.
(2) For complete turbine engines other than piston or electrical, the scope of work shall
indicate the engine manufacturer or group or series or type or the maintenance task(s).
Changes to this scope of work shall be approved by the competent authority in
accordance with point (a) of point CAO.A.105 and point (a) of point CAO.B.065.
(3) A CAO which employs only one person for both planning and carrying out of all
maintenance tasks cannot hold privileges for the maintenance of:
(a) aeroplanes, rotorcraft and other aircraft which also are not ELA2, when equipped
with a powerplant being other than piston engine(s) or electrical engine(s) a
turbine engine (in the case of aircraft-rated organisations);
(b) rotorcrafthelicopters equipped with a turbine engine or with more than one piston
engine (in the case of aircraft-rated organisations);
(c) complete piston engines of 450 HP and abovecomplete engines other than piston
engines with output power below 450 HP or electrical engines (in the case of
engine-rated organisations).; and
(d) complete turbine engines (in the case of engine-rated organisations).
(4) […
(xxiii) C23: other
[…]
Rationale: The amendment in point (a)(1) mandates that the scope of work indicates the aircraft type
for some non-conventional aircraft. The amendment in point (a)(2) mandates that the terms of
approval indicate the engine manufacturer for engines other than piston or electrical, i.e. for turbines
and other engines like complete hybrid engines. The amendment in point (a)(3) proposes a limited
scope of work for one-man organisations. The amendment in point (a)(4) proposes a new ‘C23: other’
to be used for components not covered by C1 to C22.
GM1 CAO.A.020 Terms of approval
SCOPE OF WORK — AIRCRAFT CLASS

In the combined airworthiness exposition (CAE), the following guidance can be used as a the minimum
aircraft information to be indicated while specifying the scope of work of an organisation in the aircraft
class.
(a) For aeroplanes above 2 730 kg maximum take-off mass (MTOM):
The particular aircraft types included (the use of the list of type ratings contained in the AMC to
Part-66 is acceptable).
(b) For aeroplanes up to 2 730 kg MTOM:
− The type of propulsion (turbine engine, piston engine, electrical engine)
− The category (ELA1, ELA2, up to 2 730 kg)
(c) For rotorcrafthelicopters above 1 200 kg MTOM and four occupants:
The particular aircraft types included (the use of the list of type ratings contained in Appendix I
to AMC to Part-66 is acceptable).
(d) For rotorcrafthelicopters up to 1 200 kg MTOM and four occupants:
The type of propulsion (turbine engine, piston engine, electrical engine)
(e) For sailplanes:
ELA1
(f) For balloons:
− Hot-air balloons
− Gas-balloons
− Roziere balloons
(g) For airships:
− The particular airship type for those which are not classified as ELA2
− For ELA2 airships, whether it covers hot-air airships or gas-airships
(h) For any other aircraft:
− The particular aircraft types included (the use of the list of type ratings contained in the AMC to
Part-66 is acceptable).
Each category or type of aircraft specified in the scope of work is to be completed with the privileges
held (maintenance, continuing airworthiness management, airworthiness review, permit to fly) for
that aircraft category or type.
Rationale: This text proposal aims to explain how to indicate the scope of work of an organisation
approved under Part-CAO for any aircraft for which this Part is adequate.
CAO.A.105 Changes to the organisation
(a) In order to enable the competent authority to determine continued compliance with this Annex,
the CAO shall notify the competent authority of any proposal to carry out any of the following
changes, before such changes take place:
(1) changes affecting the information contained in the approval certificate laid down in
Appendix I and the terms of approval of this Annex;
(2) changes of the persons referred to in points CAO.A.035(a) and (b);
(3) changes in the aircraft types covered by the scope of work referred to in point (a)(1) of
point CAO.A.020 in the case of aeroplanes of more than 2 730 kg maximum take-off mass
(MTOM) and in the case of helicopters, rotorcraft of more than 1 200 kg MTOM or
certified for more than 4 four occupants and for any other aircraft which also is not an
ELA2;
(4) changes in the scope of work referred to in point (a)(2) of CAO.A.020 in the case of
complete turbine engines other than piston or electrical;
(5) changes in the control procedure set out in point (b) of this point.
(b) Any other changes in locations, facilities, equipment, tools, material, procedures, scope of work
and staff shall be controlled by the CAO through a control procedure provided for in the CAE.
The CAO shall submit a description of those changes and the corresponding CAE amendments
to the competent authority within 15 days from the day on which the change took place.
Rationale: This text proposal aims to update the changes to the scope of work of the organisation,
approved in accordance with Part-CAO, that need to be notified to the authority before they take place,
as regards non-conventional aircraft.
Appendix I — Combined airworthiness organisation (CAO)

certificate - EASA Form 3-CAO
(a) Within the approval class(es) and rating(s) established by the competent authority, the scope
of work specified in the CAE defines the exact limits of approval. It is therefore essential that
the approval class(es) and rating(s) and the organisations scope of work are matching.
(b) An aircraft rating, in relation to the maintenance privileges, means that the CAO may carry out
maintenance on the aircraft and any component (including engines), in accordance with aircraft
maintenance data or, if agreed by the competent authority, in accordance with component
maintenance data, only whilst such components are fitted to the aircraft. Nevertheless, such
aircraft-rated CAO may temporarily remove a component for maintenance in order to improve
access to that component except when such removal creates the need for additional
maintenance not eligible for the requirements of point (b). This will be subject to a control
procedure in the CAE to be approved by the competent authority.
(c) An engine rating (turbine, piston, or electrical or other) means that the CAO may carry out
maintenance on the uninstalled engine and engine components, in accordance with engine
maintenance data or, if agreed by the competent authority, in accordance with component
maintenance data, only whilst such components are fitted to the engine. Nevertheless, such
engine-rated CAO may temporarily remove a component for maintenance in order to improve
access to that component except when such removal creates the need for additional
maintenance not eligible for the requirements of point (c). An engine-rated CAO may also carry
out maintenance on an installed engine during base and line maintenance subject to a control
procedure in the CAE to be approved by the competent authority.
(d) A component rating (other-than-complete engines) means that the CAO may carry out
maintenance on uninstalled components (excluding complete engines) intended for fitment to
the aircraft or engine. This CAO may also carry out maintenance on an installed component
(other-than-complete engines) during base and line maintenance or at an engine maintenance
facility subject to a control procedure in the CAE to be approved by the competent authority.
(e) An non-destructive testing (NDT) rating is a self-contained rating not necessarily related to a
specific aircraft, engine or other component. The NDT rating is only necessary for a CAO that
carries out NDT as a particular task for another organisation. A CAO approved with an aircraft,
engine or component rating may carry out NDT on products they are maintaining subject to the
CAE containing NDT procedures, without the need for an NDT rating.
Page 1 of 2
[MEMBER STATE (*)]
A Member of the European Union (**)
COMBINED AIRWORTHINESS ORGANISATION CERTIFICATE

Reference: [MEMBER STATE CODE (*)].CAO.[XXXX]
Pursuant to Regulation (EU) 2018/1139 of the European Parliament and of the Council of 4 July 2018 on
common rules in the field of civil aviation and establishing a European Union Aviation Safety Agency and to
Regulation (EU) No 1321/2014 and subject to the conditions specified below, the [COMPETENT AUTHORITY
OF THE MEMBER STATE (*)] hereby certifies:
[COMPANY NAME AND ADDRESS]
as a combined airworthiness organisation in compliance with Section A of Annex Vd (Part-CAO) to

Regulation (EU) No 1321/2014.
CONDITIONS:
(a) this approval is limited to that specified in the terms of approval attached, and in the 'Scope of work'
Section of the approved combined airworthiness exposition, as referred to in Section Vd (Part-CAO) to
Regulation (EU) No 1321/2014; and
(b) this approval requires compliance with the procedures specified in the approved combined
airworthiness exposition; and
(c) this approval is valid whilst the approved combined airworthiness organisation remains in compliance
with Annex Vd (Part-CAO) to Regulation (EU) No 1321/2014; and
(d) where the approved combined airworthiness organisation contract out, under their quality system, the
service of one or several organisations, this approval remains valid subject to such organisation(s)
fulfilling applicable contractual obligations; and
(e) subject to compliance with the foregoing conditions, this approval shall remain valid for an unlimited
duration unless the approval has previously been surrendered, superseded, suspended or revoked.
Date of original issue of the approval certificate: .............................................................................................

Date of this revision of the approval certificate: ...............................................................................................
Revision No: ………………………………………………………………………………………………………………………………………………….
Signed: ...............................................................................................................................................................
For the competent authority: [COMPETENT AUTHORITY OF THE MEMBER STATE (*)]
(*) or EASA if EASA is the competent authority
(**) delete for non-EU Member States or EASA.
EASA Form 3-CAO, Issue 21
Page 2 of 2
COMBINED AIRWORTHINESS ORGANISATION TERMS OF APPROVAL
Reference: [MEMBER STATE CODE (*)].CAO.XXXX
Organisation: [COMPANY NAME AND ADDRESS]
CLASS RATING PRIVILEGES(***)

AIRCRAFT (**) Aeroplanes — other-than-complex □ Maintenance
motor-powered aircraft (**) □ Continuing-airworthiness management
□ Airworthiness review
□ Permit to fly
Aeroplanes up to 2 730 kg maximum □ Maintenance
take-off mass (MTOM) (**) □ Continuing-airworthiness management
□ Permit to fly
RotorcraftHelicopters — other-than- □ Maintenance
complex motor-powered aircraft □ Continuing-airworthiness management
(**) □ Airworthiness review
□ Permit to fly
RotorcraftHelicopters up to 1 200 kg □ Maintenance
MTOM, certified for a maximum of □ Continuing-airworthiness management
up to 4 four occupants (**) □ Airworthiness review
□ Permit to fly
Airships (**) □ Maintenance
□ Continuing-airworthiness management
□ Permit to fly
Balloons (**) □ Maintenance
□ Permit to fly
Sailplanes (**) □ Maintenance
□ Permit to fly
Other aircraft (**) □ Maintenance
□ Permit to fly
COMPONENTS (**) Complete turbine engines (**) □ Maintenance
Complete piston engines (**)
Electrical engines (**)
Other engines/powerplants (**)
Components other than complete
engines (**)
SPECIALISED Non-destructive testing (NDT) (**) □ NDT
SERVICES (**)
LIMITATIONS
(to be included only for organisations rated for certain aircraft (see CAO.A.20(a)(3)) aeroplanes,
helicopters or complete engines, if they only have one person planning and performing all maintenance
tasks)
The following maintenance is excluded from the scope of work (***):

— maintenance on aeroplanes, rotorcraft and other aircraft which also are not ELA2, when equipped with a
powerplant being other than a piston engine or electrical engine(s) a turbine engine;
— maintenance on rotorcrafthelicopters equipped with a turbine engine or with more than one piston
engine; and
— maintenance on complete piston engines of 450 HP and above, and on complete turbine engines engines
other than piston engines with output power below 450 HP or electrical engines.
List of organisation(s) working under a quality system (***)
These terms of approval are limited to the products, parts and appliances, and to the activities specified in the
‘Scope of work’ Section of the approved combined airworthiness exposition.,
Combined airworthiness exposition reference: .................................................................................................
Date of original issue of the exposition: ............................................................................................................
Date of last revision approved: ........................Revision No: ……………………………………………………………………..
Signed: ...............................................................................................................................................................
For the competent authority: [COMPETENT AUTHORITY OF THE MEMBER STATE (*)]
(*) or EASA if EASA is the competent authority
(**) delete as appropriate if the organisation is not approved.
(***) complete as appropriate
EASA Form 3-CAO, Issue 21
Rationale: This appendix is updated to align with CAO.A.20.
[…]
4. Impact assessment (IA)

The impact assessment in this chapter only covers the proposed changes in regard to the Part-66
licensing system, in order to expand it to non-conventional aircraft. The other proposed regulatory
amendments contained in this NPA are not considered to require an impact assessment since they are
not controversial (i.e. elimination of difficulties for regulatory compliance in respect of non-
conventional aircraft due to lack of consideration of them in the current rules) or the proposals have
been aligned with already existing provisions (i.e. scope of alleviations expanded to also apply to some
non-conventional aircraft).
4.1. What is the issue

In regard to the privilege to certify maintenance performed on aircraft structure, powerplant and
mechanical and electrical systems, the current Part-66 licensing system is defined only for certain
licence subcategories that cover conventional aircraft (piston and turbine aeroplanes, piston and
turbine helicopters, sailplanes, balloons and airships). There are no provisions that provide
certification privileges for the maintenance of non-conventional manned aircraft. Pending such
provisions, these types of aircraft are prevented from being maintained, hence prevented from flying.
Taking into account that the existing system in Part-66 is considered to be an important element to
attain the good safety record achieved in aircraft maintenance in Europe and the existing structure of
the licensing system established by Part-66, the proposed amendments should continue to respect
the current framework to avoid any disruption. In addition, there is a constraint on finding the
adequate balance between the high-level competence required for licence holders of ‘complex
aircraft’ and the wider flexibility needed as regards the maintenance of simpler aircraft.
Another issue is the certification of maintenance of rotorcraft: currently there are no AML
subcategories for the certification of maintenance on rotorcraft other than helicopters.
Also, in the current definition of Group 1 only aircraft of certain categories are covered; therefore, the
definition needs to be amended to also consider non-conventional aircraft. The implication of one
aircraft type being covered under the definition of Group 1 is that the endorsement of the aircraft on
the relevant AML is only possible as ‘aircraft rating’, i.e. neither ‘manufacturer rating’ nor ‘group
rating’ are possible. This implies, as a minimum, that the AML holder has followed aircraft type training
to endorse the aircraft on the AML.
Finally, there is no AML for aeroplanes and rotorcraft with electric powerplant.
4.1.1. Who is affected

Current and future AML holders, their employers (i.e. maintenance organisations), organisations
approved i.a.w. Part-147, TC applicants and licensing authorities (i.e. NCAs).
4.1.2. How could the issue evolve

Without amending the Part-66 AML system, the baseline scenario is the following:
— the certification of the maintenance of non-conventional aircraft will not be possible under the
existing provisions, which require holding a valid AML obtained in accordance with Part-66;
— maintenance staff competencies and skills will not keep pace with the technological evolutions;
and
— there will be a decrease of the competitiveness of the European aviation industry if their
technology needs are not catered for due to the lack of a suitable maintenance regulatory
framework.
4.2. What we want to achieve — objectives

The objectives of this proposal are defined in Section 2.2.
4.3. How we want to achieve it — options

In order to address some of the issues presented in Section 4.1, no assessment of different options is
required. These issues are addressed as follows:
— Certification of maintenance of rotorcraft: the privileges of AML holders of current licence
subcategories for helicopters are expanded to rotorcraft (the proposed definition of rotorcraft
is given in the amending text), without further requirements. Having assessed the basic
knowledge requirements to obtain a licence in the helicopter subcategories, it is considered
that they are sufficient as the basic knowledge requirements for a rotorcraft licence. Basic
knowledge modules to obtain a future ‘rotorcraft licence’ are amended to cover not just
helicopters, but also other rotorcraft.
— The definition of Group 1 is revised in order to include non-conventional aircraft, as per the
amended point 66.A.5.
— Creation of a new subcategory for aeroplanes and rotorcraft (see discussion above) with an
electrical powerplant: due to the comments received during the consultation of NPA 2020-12
as regards a proposal for the qualification of certifying staff of electrical aircraft, EASA decided
to follow a different strategy after consultation with the EASA ABs: the new strategy, contained
in this NPA, proposes to create a new licence subcategory in the B1 category for the certifying
staff of electrical aeroplanes and rotorcraft. The NPA contains also, similarly to NPA 2020-12,
proposed amendments to the rule that, for licence holders of (sub)categories B1.2 and B3 to
obtain an L2 licence, they need to show basic knowledge and basic experience on aircraft with
an electrical powerplant. The current scenario that gives the possibility to licence holders of
(sub)categories B1.2 and B3 to obtain an L2 licence without this relevant basic
knowledge/experience and only upon application was not intended at the time of the creation
of the licence in category L with Regulation (EU) 2018/114227.
— Creation of a new Group E, so that it is possible to endorse manufacturer subgroup and full
subgroup ratings for aeroplanes and rotorcraft with an electrical powerplant that are not in
Group 1 (refer to point 66.A.5 for the groups definition).
Different options have been considered for the following issue described in Section 4.1:
27 Commission Regulation (EU) 2018/1142 of 14 August 2018 amending Regulation (EU) No 1321/2014 as regards the
introduction of certain categories of aircraft maintenance licences, the modification of the acceptance procedure of
components from external suppliers and the modification of the maintenance training organisations' privileges (OJ L 207,
16.8.2018, p. 2) (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32018R1142&qid=1638480954378).
— Establishing the AML subcategories and rating required for the certification of maintenance of
non-conventional aircraft or aeroplanes/rotorcraft with a powerplant other than piston engine,
turbine or electrical. In addition to Option 0 ‘No policy change’, two other options have been
considered, as described in the following table:
Table 1: Selected policy options for the licences for the maintenance of non-conventional aircraft
Option Short title Description

No
0 No policy No policy change (rules remain unchanged and risks as outlined in the
change issue analysis).
1 New basic Amend Part-66 by establishing new AML privileges for the certification of
knowledge maintenance of non-conventional aircraft or aircraft with non-
conventional powerplants. The new privileges would be granted to
personnel having followed training on new basic modules defined by TC
applicants of non-conventional aircraft to address their specificities.
2 Type rating Amend Part-66 by allowing the endorsement of an AML corresponding to

endorsement one of the existing subcategories (i.e. for a conventional aircraft) with a
non-conventional aircraft type rating (syllabus defined by the TC
applicant), without the aircraft belonging to the scope of the licence. The
same approach would be taken for aircraft with non-conventional
powerplants.
Note: Refer to Chapter 3 for the proposed text following the selection of
Option 2.
For non-conventional aircraft, in order for the TC holder to define the specific type training syllabus
referred to in Option 2 and other related information (see Chapter 3 for full details), CS-MCSD need
to be amended so that the operational suitability data for these aircraft contains such data. The
proposed amendment to CS-MCSD will be published in due time separately from this NPA, as an
addendum.
4.4. What are the impacts
4.4.1. Methodology
The methodology applied for this impact assessment is the multi-criteria analysis (MCA), which allows
comparing all options by scoring them against a set of criteria.
The MCA covers a wide range of techniques that aim at combining a variety of positive and negative
impacts into a single framework to allow an easier comparison of scenarios.
The MCA key steps in this RIA include:
— establishing the criteria to be used for comparing the options (these criteria must be
measurable, at least in qualitative terms);
— scoring how well each option meets the criteria (the scoring needs to be relative to the baseline
scenario); and
— ranking the options by combining their scores.
The criteria used to compare the options were derived from the Basic Regulation and the guidelines
for the impact assessment were developed by the European Commission. The principal objective of
the Basic Regulation, in accordance with Article 1(1), is to ‘establish and maintain a high uniform level
of civil aviation safety in the Union’. As additional objectives, the Basic Regulation identifies
environmental, economic, proportionality, and harmonisation aspects, which are reflected below.
For the scoring of the impacts, a scale of -10 to +10 is used to indicate the negative and positive
impacts of each option (i.e. from ‘very high’ to ‘very low’ negative/positive impacts). The intermediate
levels of benefits are termed ‘high’, ‘medium’ and ‘low’, with also a ‘no impact’ score possible.
4.4.2. Safety impact

Option 0 ‘No policy change’ has neutral impact because the aircraft in the scope of this NPA will not
be allowed to fly due to the lack of maintenance requirements (see Section 4.1).
Both Options 1 and 2, as regards non-conventional aircraft, rely on the fact that the applicant for the
aircraft type certificate will identify what is the required training syllabus and depth of knowledge, as
basic knowledge (Option 1) or as detailed knowledge on the aircraft type (option 2), to cover what is
particular in its aircraft. In this sense, both options are considered to keep a safe system equivalent to
the existing one. The knowledge obtained under Option 2 is more focused on the aircraft subject to
the maintenance event, and therefore probably safer than Option 1.
4.4.3. Environmental impact

None identified for any of the options.
4.4.4. Social impact

Option 0 ‘No policy change’ has a negative impact because the AML holders (or students pursuing to
obtain one) will not have the means to expand their competencies and skills for aircraft in the scope
of this NPA. As a result, in the medium/long term:
— the attractiveness of jobs in the maintenance field may decrease over time;
— the AML holders in the EU may face job reductions if the maintenance regulatory framework is
not adapted to keep pace with new technologies and the type of aircraft in the scope of this
NPA.
Neither Option 1 nor Option 2 changes existing privileges for the current holders of AML (or students
pursuing to obtain one), valid for conventional aircraft with conventional powerplants.
Further to both Option 1 and Option 2, an AML holder is required to attend new training (less
demanding for Option 2) if they want to expand their privileges and certify maintenance on non-
conventional aircraft, which is not permitted with their current licence subcategory. This provides a
social positive impact for AML holders since they will acquire new competencies and have new
business opportunities.
4.4.5. Economic impact

Option 0 ‘No policy change’ has a negative impact because the maintenance regulatory framework
will remain not adapted to keep pace with new technologies and the type of aircraft in the scope of
this NPA, hence decreasing the competitiveness of the EU aviation industry in the medium/long term.
— Economic impact on licence holders/their employers paying for the licence: Whichever option
is retained, Option 1 or Option 2, obtaining an AML that entitles the holder to certify
maintenance of a non-conventional aircraft will require attending additional training and/or
examination. In the current system, for AML holders to expand their certification privileges with
an aircraft of Group1, it is required that they follow type training on the aircraft type. In this
sense, Option 2 as regards expanding the certification privileges to certify maintenance on
large/complex non-conventional aircraft classified in the new Group 1 would have no relative
impact, when compared to endorsing one existing licence with a Group 1 conventional aircraft,
since this also demands type endorsement.
The biggest economic impact of Option 2 is related to small/simple non-conventional aircraft
(which are also included in new Group1). For a small/simple conventional aircraft, the current
system allows to exercise certification privileges when the AML is endorsed with the ‘aircraft
manufacturer’ or ‘aircraft group’. This is a privilege that can be exercised for any aircraft within
the ‘aircraft manufacturer’ or ‘aircraft group’, since all the aircraft covered have similar
architecture/systems, which is/are known by the AML holder. The same approach would apply
under Option 1, once the licence holder would have acquired the relevant basic knowledge for
the same group of non-conventional aircraft. In any case, acquiring the required basic
knowledge would be more costly than following type training on a single aircraft.
Applying Option 2 to non-conventional small/simple aircraft still requires type endorsement,
since basic knowledge obtained when applying for an AML for a conventional aircraft does not
provide sufficient generic knowledge for a non-conventional aircraft.
Note that by defining a new subcategory for the AML of aeroplanes/rotorcraft with an electrical
powerplant, the endorsement of manufacturer and full subgroup ratings is allowed for aircraft
that do not belong to Group 1. This new subcategory is only possible by defining dedicated ‘basic
knowledge’ modules corresponding to this new subcategory. This strategy alleviates the
requirements applicable to the certification of maintenance of electrical aeroplanes and
rotorcraft in general aviation.
— Economic impact on training organisations: New training requirements, both for Option 1 and
Option 2, would provide a new source of revenues for this sector.
— Economic impact on TC applicants: TC applicants for non-conventional aircraft will be required
to, in the case of Option 1, define the knowledge gap compared to existing AML subcategories,
and, in the case of Option 2, propose the most adequate AML subcategory and propose the
syllabus/depth of knowledge for the type training. The impact of Option 2 is considered to be
less. Overall, new business opportunities should compensate largely this workload.
— Economic impact on NCAs: For Option 1, NCAs would need to have control of basic knowledge
modules passed by AML holders/applicants and identify their privileges based on the acquired
basic knowledge and as determined by EASA. That would demand a huge administrative effort.
For Option 2, NCAs would not be much affected since their current systems already provide for
adding type ratings to existing licence subcategories.
— Economic impact on EASA: For both options, EASA would need to devote some resources to
discuss with the TC applicant and later on identify and publish the new basic knowledge
modules syllabus (for Option 1) or identify the most adequate AML subcategory and agree on
the type training syllabus/training depth of knowledge (for Option 2).
Stakeholders are invited to provide quantified elements to justify the possible economic impacts of the
options proposed, or alternatively propose other justified solutions to the issue.
4.4.6. ICAO and third-country references relevant to this RMT

The proposal of this NPA is based on some amendments to the existing Part-66 licensing system and
does not create differences with International Civil Aviation Organization (ICAO) Standards and
Recommended Practices (SARPs).
It does also not change the continuing airworthiness principles upon which Bilateral Safety
Agreements (BASAs) are based; therefore, these BASAs and related implementation documents
should not be affected.
4.4.7. General Aviation and proportionality issues

— Option 2 does not allow endorsement of ‘aircraft group’ in the existing licence subcategories
for non-conventional aircraft. This is a disadvantage when compared to the AML subcategories
used by General Aviation (sport/recreational aircraft), since ‘group rating’ is permitted for
conventional aircraft. This is mitigated by permitting ‘type differences training’ for second types
being endorsed. It is also believed that the first non-conventional small/simple aircraft that
would be affected by the proposed regulation would not be used for sport/recreational
aviation, but rather as new business services, the economic impact of which could be passed on
to end users. In regard to sport/recreational activity, EASA believes that the most new aircraft
would be conventional aeroplanes or rotorcraft with an electrical powerplant, for which the
proposal permits the manufacturer and full subgroup endorsement on the licences.
— The impact of Option 1 would be difficult to predict: if many non-conventional small/simple
aircraft would be similar and the related basic knowledge for them could be covered by the
same new basic modules, EASA could classify them into the same new Group and allow ‘group
rating’. That would allow the AML holders to exercise AML privileges on these many different
small/simple aircraft types, if they would belong to the same group. Whether the situation just
described will materialise, we cannot say at the moment.
4.4.8. Comparison of the options

The following table contains a basic comparison of the different options:
Table 2: Comparison of the options
Impact criteria Option 0 ‘No Option 1 ‘New basic knowledge’ Option 2 ‘Type rating
policy change’ endorsement’
The scores are based on an MCA scale from -10 to +10 (see Section 4.4.1)
0 0 0
Safety impact non-conventional required basic knowledge for required type training for AML
aircraft not flying AML privileges to be identified by endorsement to be identified by
the TC applicant in order to build the TC applicant in order to build

a safe system a safe system
Environmental 0 0 0
impact
No impact No impact No impact
Social impact 0 +2 +4
No changes for existing privileges No changes for existing
(conventional aircraft) privileges (conventional aircraft)
New basic training is required for New type training is required for
the certification of maintenance the certification of maintenance
of non-conventional aircraft non-conventional aircraft, even
small/simple ones
AML holders will need to invest
time/effort to acquire the new AML holders will need to invest
privileges, but they will acquire time/effort to acquire the new
new competencies and have new privileges, but they will acquire
business opportunities. new competencies and have
new business opportunities.
With this option, endorsing an
aircraft type requires less
time/effort compared to Option
1.
Economic 0 -3 -2
impact on AML
New basic training is required for New type training is required for
holders/paying
the certification of maintenance the certification of maintenance
employers
of non-conventional aircraft of non-conventional aircraft,
even small/simple ones
Economic 0 +4 +4
impact on
Maintenance organisations may Maintenance organisations may
maintenance
decide to offer their maintenance decide to offer their
organisations
services to aircraft operators as maintenance services to aircraft
there is legal certainty stemming operators as there is legal
from the applicable requirements certainty stemming from the
applicable requirements.
Economic -2 +4 +4
impact on
Loss of business Training organisations may Training organisations may
training
opportunities decide to offer training (new basic decide to offer training (new
organisations
modules) and get new business. type training) and get new
business.
Economic -4 +4 +4
impact on TC
Loss of business TC applicants of non- TC applicants of non-
applicants
opportunities conventional aircraft would need conventional aircraft would
to devote some resources to need to devote some resources
define required basic knowledge: to identify the most adequate
minor workload AML subcategory and the
required type training syllabus
New business opportunities
and training depth of
should compensate largely this
knowledge: minor workload
workload.
New business opportunities

should compensate largely this
workload.
Economic 0 -4 -1
impact on NCAs
NCAs would need to monitor the NCA would need to add type
basic knowledge modules passed ratings to AMLs even for
by each AML applicant, to assess small/simple non-conventional
their eligibility to certify aircraft. This impact is very
maintenance on a given non- minor.
conventional aircraft.
Economic 0 -2 -1
impact on EASA
EASA would need to devote EASA would need to devote
resources to confirm the basic resources to confirm the most
knowledge modules required to adequate AML subcategory and
be entitled to certify the required type training
maintenance of non- syllabus and training depth of
conventional aircraft. knowledge.
Overall -6 +5 +12
Option 2 is the preferred option. The corresponding draft rules are in the Chapter 3.
Stakeholders are invited to provide any quantitative information they find necessary to bring to the
attention of EASA.
5. Proposed actions to support implementation
5. Proposed actions to support implementation

EASA will work with the Member State NCAs to support the implementation of the amended
regulation, including discussion on the transitional period before the proposed system becomes
applicable.
6. References
6. References
6.1. Related EU regulations
Commission Regulation (EU) No 1321/2014 of 26 November 2014 on the continuing airworthiness of
aircraft and aeronautical products, parts and appliances, and on the approval of organisations and
personnel involved in these tasks (OJ L 362, 17.12.2014, p. 1).
6.2. Related EASA decisions

— Executive Director Decision 2015/029/R of 17 December 2015 issuing acceptable means of
compliance and guidance material to Part-M, Part-145, Part-66, and Part-147 of Regulation (EU)
No 1321/2014 and repealing Decision 2003/19/RM of the Executive Director of the Agency of
28 November 2003 ‘AMC and GM to the Annexes to Regulation (EU) No 1321/2014 — Issue 2’
— Executive Director Decision 2019/009/R of 28 March 2019 amending the Acceptable Means of
Compliance and Guidance Material to Annex I (Part-M), Annex II (Part-145), Annex III (Part-66),
Annex IV (Part-147) and Annex Va (Part-T) to Commission Regulation (EU) No 1321/2014 and
issuing the Acceptable Means of Compliance and Guidance Material to the articles of that
Regulation
— Executive Director Decision 2020/002/R of 13 March 2020 amending the Acceptable Means of
Compliance and Guidance Material to Annex I (Part-M), Annex II (Part-145), Annex III (Part-66),
Annex IV (Part-147) and Annex Va (Part-T) to as well as to the articles of Commission Regulation
(EU) No 1321/2014, and issuing Acceptable Means of Compliance and Guidance Material to
Annex Vb (Part-ML), Annex Vc (Part-CAMO) and Annex Vd (Part-CAO) to that Regulation
— Executive Director Decision 2020/019/R of 20 November 2020 issuing the Certification
Specifications and Guidance Material for Maintenance Certifying Staff Data ‘CS-MCSD – Issue 1’
6.3. Other references

— NPA 2020-12 ‘Review of Part-66’
— ToR for RMT.0230 ‘Introduction of a regulatory framework for the operation of unmanned
aircraft systems and for urban air mobility in the European Union aviation system’
7. Appendix
7. Appendix
N/A
8. Quality of the NPA
8. Quality of the NPA

To continuously improve the quality of its documents, EASA welcomes your feedback on the quality
of this NPA with regard to the following aspects:
8.1. The regulatory proposal is of technically good/high quality

Please choose one of the options below and place it as a comment in CRT; if you disagree or strongly disagree,
please provide a brief justification.
Fully agree / Agree / Neutral / Disagree / Strongly disagree
8.2. The text is clear, readable and understandable

8.3. The regulatory proposal is well substantiated

8.4. The regulatory proposal is fit for purpose (capable of achieving the objectives set)
8.5. The impact assessment (IA), as well as its qualitative and quantitative data, is of high
quality
8.6. The regulatory proposal applies the ‘better regulation’ principles[1]

8.7. Any other comments on the quality of this NPA (please specify)
Note: Your comments on Chapter 8 will be considered for internal quality assurance and management
purposes only and will not be published in the related CRD.
[1] For information and guidance, see:

− https://ec.europa.eu/info/law/law-making-process/planning-and-proposing-law/better-regulation-why-and-
how_en
how/better-regulation-guidelines-and-toolbox_en
how/better-regulation-guidelines-and-toolbox/better-regulation-toolbox_en

Npa - 2021-15 New Air Mobility

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European Union Aviation Safety Agency

Notice of Proposed Amendment 2021-15

New air mobility

EASA rulemaking procedure milestones

Start Public consultation Proposal to the Adoption by the Decision

SubT 1: 9.9.2020 21.12.2021 2023 2024 2024

ANNEX Vb (PART-ML) ........................................................................................................................ 52

1. About this NPA

1.2. How to comment on this NPA

1.3. The next steps

2. In summary — why and what

2.2. What we want to achieve — objectives

2.3. How we want to achieve it — overview of the proposed amendments

Point being amended Benefits Drawbacks

Requirements for which aircraft categories Legal certainty None

3. Proposed amendments and rationale

Article 3 Continuing airworthiness requirements

Part-ML (Annex Vb) Part-ML mandatory N/A Part-ML mandatory N/A

Part-CAMO (Annex Vc) Individual CAM18 Part-CAMO mandatory Part-CAMO mandatory

Part-145 (Annex II) or Part-145 Part-145 mandatory Part-145 mandatory

Rationale: The requirements on operators/owners of complex motor-powered aircraft in points

Quick summary table

Is a CAMO or Is maintenance Is a CAMO or Is maintenance by

Regulation (EC) required organisation is

specialised required maintenance by CAO is required by a Subpart F, by

AMC M.B.301(b) Maintenance programme

Appendix VII — Complex Maintenance Tasks

4. The balancing of a propeller, except:

AMC to Appendix VIII — Limited Pilot Owner Maintenance

AMC 145.A.20 Terms of approval

C14 Landing Gear 32

AMC3 145.A.30(e) Personnel requirements

Appendix II — Class and rating system for the terms of approval of

CLASS RATING LIMITATION BASE LINE

State whether the

CLASS RATING LIMITATION BASE LINE

ANNEX III (PART-66)

66.1 Competent authority

66.A.3 Licence categories and subcategories

− B1.E Aeroplanes/rotorcraft with an electrical powerplant.

66.A.5 Aircraft groups

− single-turboprop engine aeroplanes,

Rationale: This amendment updates the definition of Group 1 to consider non-conventional

GM 66.A.5 Aircraft groups

Rationale: The text referring to helicopters is expanded to rotorcraft.

(a) The following privileges shall apply:

AMC 66.A.20(b)(2) Privileges

66.A.25 Basic knowledge requirements

66.A.30 Basic experience requirements

AMC 66.A.30(a) Basic experience requirements

Rationale: Text adapted to count experience obtained in non-conventional aircraft.

66.A.45 Endorsement with aircraft ratings

GM 66.A.45 Endorsement with aircraft ratings

Aircraft rating requirements

Group 2 aircraft (For B1.1, B1.3, B1.4) (For B2)

Aircraft rating requirements

AMC 66.A.45(d);(e)3;(f)1;(g)1;(h) Endorsement with aircraft ratings

Rationale: Text updated to consider Group E aircraft.

AMC 66.A.45(e) Endorsement with aircraft ratings