Part T has been proposed by EASA and is currently classified as NPA 2010-10. Once adopted Part T will be known as Annex V to Reg EC 2042/2003 and will be completely standalone. It is driven by the requirement to ensure certain aircraft which currently are not covered directly by Part M requirements are brought into the EASA regulatory environment.
NPA 2010-10 also introduces the term CMPA into Part M terminology previously the term large aircraft was used. (A/C over 5700 KG) now it has been reclassified and the term means Complex Motor Powered Aircraft. Some classifications of twin engine helicopter will fall outside of the scope of aircraft which must be maintained by EASA Part 145 Maintenance Organisation.
Within Part T will be a number of Subparts
Subpart A General
Subpart B Requirements
Subpart C Maintenance Procedures
Subpart E Qualified Maintenance Organizations
Subpart F Management Systems
Subpart G CAMO-T
Part T concerns aircraft which are described in EASA Basic Regulation EC 216/2008 ref article 4 (1) (C) as –
Aircraft which are registered in a third country and
1/ Used by a Community Operator if oversight is provided by a member state.
2/ Used into within or out of the community by an operator established or residing in the community.
Through NPA 2010-10 Part T will establish requirements for the above aircraft which may operate in a number of defined situations for example
Dry lease in of an aircraft from outside the Community, Wet lease in of an aircraft from outside the community. Code Share Operations and Private Operations.
In Accordance with NPA 2010-10 Essentially Part T establishes the requirements for the above mention aircraft to comply with Basic Regulation Annex IV Sect 6 which covers the requirements for
Operation of Aircraft, Pre Flight Inspection, Maintenance Program, Preservation of Records, Release to Service, Modifications and Repairs.
In respect of wet lease-in code-share agreements by an operator for which any Member State ensures oversight of operations?
Compliance will probably be achieved through audit and conformity with ICAO Annex 6 (possible issues with IOSA not satisfying the intent).
In addition NPA 2010-10 requires Part T to comply with Basic Regulation Annex IV 8.g Operation of CMPA (Complex Motor Powered Aircraft) or Operations for Commercial Purposes.
A CAMO-T (Continuous Airworthiness Management Organisation (T) is an organisation approved in accordance with Part-M Subpart G which in addition complies with the requirements of Part-T subpart-G
CAME-T shall contain procedures specifying how the CAMO-T ensures compliance with Part-T Subpart G.
According to NPA 2010-10, WHO will require a CAMO-T? – Operators of third country registered:
Private CMPA, CMPA operated by ATO to provide flight training, (ATO Approved Flight Training Organisation) Aircraft operated by ATO to provide flight training for commercial purposes,
Note – (Dry lease-in of a third country registered aircraft is incompatible with:
Current EU-OPS 1.180(a)(1); and, Future Part-OR Subpart-OPS, because they require that all aircraft operated have a certificate of airworthiness in accordance with Part 21
CAMO-T is not required in case of: Wet lease-in, code share, .Private operations with other than CMPA and “Other than CMPA” operated by ATO to provide training for non-commercial purpose.
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