Part ML
Regulation 1321/2014
Annex Vb
Part CAO
Regulation 1321/2014
Annex Vd
Acceptable Means of Compliance and Guidance Material to Part ML
(FR: Les privilèges du propriétaire en EASA)
Since March 2020, EASA Part-ML is in effect. The rules governing the maintenance of light airplanes are set into law and apply to all applicable airplanes bearing an EASA registration, no matter the national country.
This new regulation is a real earthquake for people dealing with light aircrafts maintenance in Europe.
At last, the days of inquiring “can I extend engine TBO in France” or “can I postpone my oil change by 2 months in Germany” are gone. The rules are harmonized throughout EASA member states, and they are seemingly more adequate for the operations they intend to regulate. By many aspects, the Part ML system was drawn near the American (FAA, N-reg) system, making the old comparison more or less obsolete.
The main idea is that the administration will not approve the maintenance programme anymore in most cases. The maintenance programme will be declared, and the owner can elect either to pay for an organization to write it and bear full responsibility for airworthiness, or do it by himself. Fortunately, he will be helped in that commitment by the very detailed guide offered by the EASA, in the form of Acceptable Means of Compliance (AMC) and Guidance Material (GM) annex, summarizing the dense Part ML legislative text. He will also rely on aircraft factory documentation (called the aircraft maintenance manual or AMM) to elaborate the so-called Aircraft Maintenance Programme (AMP). More on that later.
“If an owner (see definition in point ML.1(c)(3)) decides not to make a contract with a CAMO or CAO, the owner is fully responsible for the proper accomplishment of the corresponding continuing airworthiness management tasks. As a consequence, it is expected that the owner properly and realistically self-assesses his or her own competence to accomplish those tasks or otherwise seek the necessary expertise.“
Endorsing aircraft airworthiness responsability is a significant saving, but also the best thing you can do to better understand how your aircraft is maintained, and the kind of expense which will come ahead. It is an excellent manner to forecast and spend money in an educated way. Knowing the defects or schedule operations to come, you will have the opportunity to buy aircraft parts or choose the workshop offering the best conditions. Pricing for same performance can vary hugely.
Part ML is applicable to privately owned and operated (according to EASA Part NCO) airplanes with a maximum weight not exceeding 2730kg. Part NCO means “Non Commercial Operations”, this is grossly to be opposed with Part CAT (“Commercial Air Transport”), Part SPO (“Specialized Operations” or air work) and Part DTO (“Declared Traning Organization”)
There is an important nuance to understand.
If, as an owner, you rent (commercially) your aircraft to a private pilot, for private flights, you are still within Part NCO scope. What matters, is the nature of the flight, not the nature of the agreement for the rent. So, a typical private owner, renting his aircraft to private pilots, can endorse legally airworthiness responsability.
At 1406kg MTOW, the Cessna 182 is considered as an ELA2 aircraft, and fullfill the condition for Part ML rules application.
Why Part ML is a whole new approach and why most private owners can benefit from it.
Aeropages 