Sofema Aviation Services considers the responsibilities related to the management of Continuing Airworthiness.
An Approved Training Organisation (ATO) is required to comply with Part ORA of Regulation (EU) No 1178/2011 and either Part-NCC or Part-NCO of Regulation (EU) No 965/2012, depending on the aircraft being operated. Part-ORO is not applicable to ATOs.
Declared Training Organisation (DTO)- describes a new type of pilot training organisation for providing training to leisure pilots for aeroplanes, helicopters, sailplanes and balloons. In the context of EASA’s General Aviation (GA) Road Map and its objective to develop simpler, lighter and better rules for general aviation, the requirements of the new Part-DTO (Annex VIII to Regulation (EU) No 1178/2011) have been designed as a simple and concise regulatory framework, proportionate to the general aviation (GA) training domain.
Commission Regulation 2018/1119 for Declared Training Organisations (DTO) entered into force on 2 September 2018.
GM1 ML.A.201(e)
Identifies the Following Aircraft as NOT being operated by a commercial ATO or a commercial DTO:
(a) Aircraft operated by an organisation holding an ATO certificate or a DTO declaration, created with the aim of promoting aerial sport or leisure aviation, on the conditions that:
(1) the aircraft is operated by the organisation on the basis of ownership or dry lease;
(2) the ATO/DTO is a non-profit organisation; and
(3) whenever non-members of the organisation are involved, such flights represent only a marginal activity of the organisation.
(b) Aircraft operated under Part-NCO by its owner together with an ATO or a DTO flight instructor for the purpose of training, when the contract between the owner and the training organisation and the procedures of the training organisation allows it.
The continuing airworthiness of such aircraft remains under the responsibility of the owner, or of the CAMO or CAO contracted by the owner, if the owner has elected to contract a CAMO or CAO in accordance with ML.A.201(f).
(c) Aircraft used for very limited training flights due to the specific configuration of the aircraft and limited need for such flights.
GM1 ML.A.201(f) Responsibilities
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.
Note – Concerning Use of Aircraft Included in an AOC for Non-Commercial Operations or Specialised. The management of continuing airworthiness of the aircraft by the CAMO or CAO of the AOC holder means that the other operator has established a written contract as per Appendix I to Part-ML with this CAMO or CAO.
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CAMO, EASA Continuing Airworthiness, Approved Training Organisation (ATO), ATO, CAO, Part-ML, DTO, Declared Training Organisation, SAS blogs, Regulation (EU) No 1178/2011, Commission Regulation (EU) No 965/2012, Part NCO, CAMO Software, Non-Commercial Operations
