During the transfer of an aircraft due to the sale or end of lease, the lease return conditions suddenly become very important and we pay attention (maybe for the first time!) the wish of course is to return the aircraft as it is!
Obviously the primary concern of the lessee is to minimise any unnecessary expenditure, whereas the lessor is of course focused positioning the aircraft in the best way possible to provide the maximum appeal to the next customer means to receive the aircraft in an as new condition.
Key areas of interest become Engines / APU and Component status. The AMP may be different to that which is currently in use by the operator and may require a bridging check to be performed.
Note that it is necessary to have availability of all work packs etc. in order to update the various status reports for the aircraft.
As a result of the EASA regulatory environment we are all now very familiar with the process of Airworthiness Review Certificate ARC and understand that the obligation of the Regulator of the state of the operator is to accept a valid ARC without a further showing.
However there is nothing to stop the new leaseholder from performing a “Dummy ARC” Indeed from the point of view of Due Diligence it may be considered an essential activity.
For used aircraft being imported into the EU for the first time there is a range of obligations which need to be considered, including back to birth status of AD’s Mods, STC’s and repairs as well as the initial ARC which is signed and accepted by the regulator as part of the importation process.
Amongst the End of Lease issues which frequently occur is the fact that due to the physical lease document being located in the “legal department” the CAMO technical group is not familiar with the return conditions. Components may need to be changed for various reasons.
When receiving an aircraft from outside EASA jurisdiction repair data (physical workscope & Certification also known as the Dirty Finger Print – (DFP) may not be available together with the applicable approvals RAS for Airbus and 8100-9 for Boeing for example. This could result in the need for rework.
Seat Covers, Carpets and Curtains all need to be accounted for with appropriate release and burn certification available. For any MODS’s or STC’s which have been incorporated the associated Aircraft Flight Manual AFM may require supplements.
Test Flight and Engine Run requirements need to be considered and understood. There continues to be differences (all be it small) between the various European Member States, so it is important to liaise with the regulatory authority for a full understanding.
Does the aircraft comply with the Flight Deck door surveillance system requirements (EU‐OPS 1.1255(c).2). Several Member States have mandated a camera installation – some accept a deviation involving an approved procedure to be adopted.
Chemical oxygen generators (ref FAA AD 2011‐04‐09) – superseded by (AD) 2012-11-09 see also 14 CFR 121.1500 – SFAR No. 111
February 2011, FAA issue AD 2011‐04‐09 mandating discharge or removal of chemical oxygen generators from aircraft lavatories. Following EASA review of FAA AD 2011-04-09, EASA has determined that the measure implemented by the subject FAA AD is not within the scope of Regulation (EC) No 216/2008.
Consequently this AD does not fall within the scope of ED Decision 02/2003 and cannot be considered for adoption.As a result, no corresponding EASA AD can be issued either on the same subject for aeroplanes registered or operating in Europe within the scope of Regulation (EC) No 216/2008.
April 2011, DGAC‐OSAC issue Operational Directive F‐2011‐01 – mandating compliance with the FAA AD.
Tags:
Aircraft Transfers, Airworthiness, CAMO, EASA Part M, Lease Considerations
