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Changes to regulations for the continued airworthiness of EASA aircraft

On the 28th September 2009 new airworthiness regulations come into force in Ireland. These affect owners of light aircraft that fall into the category of ‘EASA AIRCRAFT’.


An EASA aircraft is designed and manufactured in accordance with a certification specification (CS) approved by EASA. Currently there are three categories that apply to light aircraft and one currently under development.

CS-23 Normal, Utility and Aerobatic category
CS-22 Sailplanes and Powered Sailplanes
CS-VLA Very light aircraft (750kg)
CS-LSA Light sport aircraft (600kg) - UNDER DEVELOPMENT


Many light aircraft available to recreational pilots are not EASA aircraft. These aircraft are not designed or manufactured to EASA certification specifications and cannot be operated on an EASA C of A or ARC. Such aircraft are listed in Annex 2 to EC 216/2008. These are known as ‘NON EASA AIRCRAFT’ and their continuing airworthiness is regulated by the National aviation authority (NAA) of the EU state in which they are registered. This will be either by National Certificate of Airworthiness or Permit to Fly. These aircraft can only be flown within National Airspace unless specific permission has been granted by the NAA of the State you wish to visit. NON EASA AIRCRAFT are also limited to non commercial operations.

Criteria for Non EASA aircraft listed in Annex 2 to EC 216/2008

1. Historic aircraft
a) Non complex
b) Initial design before 1st Jan 1955
c) Production ceased before 1st Jan 1975
d) Clear historical significance
2. Research or prototype aircraft
3. Amateur built aircraft. Minimum 51% of construction by the owner with no commercial objective.
4. Aircraft in Military, Police or Customs service.
5. Microlight aircraft
a) Single seat up to 300kg (315kg with ballistic parachute)
b) Two seat up to 450kg (472.5kg with ballistic parachute)
c) Gyroplane up to 560kg
d) Single seat glider up to 80kg
e) Two seat glider up to 100kg
6. Replicas of historic aircraft.
7. Unmanned aerial vehicles UAVs up to 150kg.
8. Other aircraft not more than 70kg empty weight.


EC Reg No: 216/2008, 2042/2003 and 1056/2008 detail the regulations that apply to EASA AIRCRAFT.

Large aircraft (Max take off weight more than 5700kg) must be maintained by what is called a ‘Part 145’ maintenance organisation. Requirements for a Part 145 maintenance organisation are contained in Annex 2 to 2042/2003.

Light Aircraft may be maintained by a Part 145 maintenance organisation or by a smaller and simpler Part M, Subpart F maintenance organisation. In turn a Subpart F maintenance organisation can be approved as a Continuing Airworthiness Management Organisation (CAMO, Part M, Sub part G) and further, to renew Airworthiness Review Certificates or ARCs as a Part M, Subpart I approved organisation. In addition, your aircraft must have a Certificate of Airworthiness (C of A) which is permanent once issued and an Airworthiness Review Certificate (ARC) which is annual.

Aircraft Engineers are licensed in accordance with requirements given in Annex 3 to the basic regulation (2042/2003), known as Part 66.

You will have to consult with your Part M, Subpart F or Part 145 maintenance organisation before the 28th September 2009 to create and get approval from the IAA for a maintenance programme. The IAA has created a ‘generic’ maintenance programme known as the ‘Maintenance plan light aircraft’ or MPLA. This will shortly be downloadable from their web site. This maintenance programme replaces the Light aircraft maintenance schedule (LAMS) that has been in use to date.

Then you will have to decide whether to contract your Part M, Subpart F or Part 145 maintenance organisation to manage your aircraft’s continuing airworthiness or to manage it yourself. They have to be approved as a CAMO (Subpart G) to manage your aircraft.

If you opt for the CAMO, your aircraft has to be with the same maintenance organisation for 12 months to be considered to be in a ‘Controlled environment’ and able to avail of upto 2 extensions to its ARC. This is like having a three year C of A under the old system.

If you opt to manage your aircraft’s continuing airworthiness yourself, you will need to be fully familiar with all the regulations and prepared to track Airworthiness Directives (ADs) and Service bulletins (SBs) issued for your aircraft and its components. Your engineer is not obliged to do any work beyond that requested by you. You will be responsible for ensuring that your aircraft is maintained in accordance with your MPLA (maintenance plan light aircraft). Your ARC will have to be renewed each year, involving either your Part M, Subpart F or Part 145 maintenance organisation or the IAA. This is like having a C of A every year under the old system.


While it is relatively simple to give an overview of the new system, the devil is in the detail. For example the amendment to EC No: 2042/2003, EC No: 1056/2008 introduces lighter regulation for two new categories of aircraft known as ELA1 and ELA2 – European light aircraft. ELA1 covers aerplanes, sailplanes and powered sailplanes with a maximum takeoff weight (MTOW) of less than 1000kg. ELA2 less than 2000kg. These are not certification specifications such as CS-23. They are simply weight categories that qualify for simpler regulations for continuing airworthiness. The proposed new certification specification, CS-LSA (Light sport aircraft) is also subject to lighter regulation. CS-LSA is likely to be based on the American FAA LSA certification specification. This in turn uses the design standard ASTM F2245. However, lighter regulation does not mean unregulated pilot/owner maintenance! The requirements for Pilot/Owner maintenance are given in 2042 and its amendment 1056 and are essential reading for anyone intending to do any maintenance on their EASA aircraft. Talk to your engineer as soon as possible about the upcoming changes.

One outstanding issue with the regulations concerns EU factory built LSA aircraft that are not EASA aircraft (i.e. not built to an EASA certification specification). As factory built aircraft, they are not covered under Annex 2 as Non EASA aircraft that can be operated under National aviation authority regulations. They seem to be intended for the American Light sport aircraft (LSA) market although they are being marketed within the EU. As discussed above, EASA is proposing an LSA category but it is not yet in place. These aircraft do not appear to have a legal basis for operation within the EU at the present time. Frequently these aircraft are also available in kit form to meet the Annex 2 requirement for amateur built aircraft and as such can be operated within the EU under a National Permit to fly.

WARNING: The above article is my own personal interpretation of the new regulations. You should read the EASA regulations and consult your licensed engineer to determine how to ensure the continued airworthiness of your aircraft.

References and links:
CS-23, CS-22, CS-VLA Go to: Aviation Professionals & Industry then Legislation and Certification specifications
EC Regulations 216/2008, 2042/2003 and 1056/2008 Go to: Aviation Professionals & Industry then Legislation and Regulations structure.
AAM 1/09 Maintenance and management of EASA aircraft Go to: Publications then Airworthiness Advisory Memorandum.
SI 634 of 2005 Nationality and Registration – SI 324 of 1996 Airworthiness of aircraft Go to: Publications and then Statutory instruments.
CAP 747 Airworthiness requirements Go to: Short cuts then Publications then Search for a publication.

Recreational Flying Club, Bushpark, Old Ross, Newbawn, County Wexford. Tel:087 1255241 Main Header Image (c) Alan Sariel 2007 Email Webmaster

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