• Owners of ELA 1 aircraft operated privately currently using LAMP need to transfer to a Self-Declared Maintenance Programme (SDMP) at the next Airworthiness Review but no later than  31 May 2018.

    An amendment to the EASA Part M Regulation introduced the Self-Declared Maintenance Programme (SDMP) and applies to ELA1 aircraft not involved in Commercial Operations.

    The transition to the EASA Regulations means that the generic UK Light Aircraft Maintenance Programme (LAMP) will no longer be available from September 2016. 

    • an aeroplane with an maximum take-off mass (MTOM) of 1,200 kg or less that is not classified as complex motor-powered aircraft;
    • a sailplane or powered sailplane of 1,200 kg MTOM or less;
    • a balloon with a maximum design lifting gas or hot air volume of not more than 3,400 m3 for hot air balloons, 1,050 m3 for gas balloons, 300 m3 for tethered gas balloons;
    • an airship designed for not more than four occupants and a maximum design lifting gas or hot air volume of not more than 3,400 m3 for hot air airships and 1,000 m3 for gas airships
  • To standardise maintenance programmes for EASA regulated aircraft the Self-Declared Maintenance Programme (SDMP) has been introduced. This is an amendment to the Part M regulation and will initially apply to ELA1 aircraft – those with a Maximum Take-off Mass (MTOM) of 1,200 kg or less, non complex and not involved in commercial operations.

    Owners can now choose from a number of different aircraft maintenance programmes. The new regulation introduces two new options to the existing Part M requirements, one of which is the Minimum Inspection Programme (MIP), the other is a programme based on manufacturer’s recommendations. All programmes shall not be less restrictive than the MIP, must be specific to the aircraft and must include a declaration signed by the owner that they accept full responsibility for the programme’s content.

    Who does this affect?

    For ELA1 aircraft moving to a SDMP following the phasing-out of the Light Aircraft Maintenance Programme (LAMP)

    Owners of ELA1 aircraft, Part 145 maintenance organisations, Part M Subpart G Continuing Airworthiness Maintenance Organisations (CAMO) and Part M Subpart F maintenance organisations and licensed engineers.

    For aircraft with a MTOM of 2,730 kg or less and not classified as complex motor-powered aircraft

    Part 145 organisations, Part M Subpart G CAMOs and Part M Subpart F maintenance organisations and licensed engineers.

    Registered training facilities

    Private Pilot Licence training in the UK is delivered by registered training facilities (RTF), Approved Training organisations (ATO) or Declared Training organisations (DTO), which are classed with respect to Part M as commercial operations and currently cannot use 302(h) (MIP).

    RTFs, ATOs and DTOs operating ELA1 aircraft may remain on LAMP or move to an approved programme. It was envisaged that, Part M Light may expand the applicability of the self-declared maintenance route to incorporate flying training operations.

    More information on flying training schools and airworthiness regulations.

    What are the main changes?

    • Owners can self-declare their aircraft maintenance programme which can either be the MIP template or manufacturer’s recommendations.
    • Annual inspection and issue of the Airworthiness Review Certificate (ARC) can be done at the same time by the Part M subpart F or Part 145 approved maintenance organisation, as long as the same authorised engineer certifying the inspection also carries out the airworthiness review.
    • An annual review of the maintenance programme will be carried out and recorded by the Part M Subpart F, G or Part 145 organisation or authorised engineer (if part of a Part M Subpart F, G or Part 145 organisation) at the same time as the airworthiness review is carried out.
    • Part M Subpart F and Part 145 organisations can apply for additional new privileges to carry out airworthiness reviews and issue Airworthiness Review Certificates (new EASA Form 15c) for aircraft within the scope of their approval, for which they have carried out the annual inspection.
    • Part M Subpart F and Part 145 organisations that apply for additional privileges will have to amend their expositions to include procedures for performing the airworthiness review, annual review and airworthiness review staff qualification.
    • For Part M subpart G organisations will need an additional process for performing the airworthiness review.

    Timelines

    ELA 1 aircraft (privately operated)

    The transition to MIP or manufacturer’s recommendations was originally advised to owners through the issue of CAP 1454 in October 2016.  Eligible ELA1 aircraft below 1200Kg were to have transferred to a Part M compliant programme by 30 September 2017. 

    A recent CAA telephone poll of CAMO organisations indicated that transfer to an M.A.302 compliant programme was approximately 70-75%. Owners, CAMOs, maintenance companies and authorised certifying staff must make every effort to ensure that all remaining eligible aircraft have transferred but in any case no later than 31 May 2018.

    Aircraft that are eligible and have not transferred after this date will have invalidated their Certificate or Airworthiness and shall not fly.  

    Failure to transition may result in an aircraft being grounded and could lead to suspension of the Certificate of Airworthiness.

    Remaining aircraft

    The transition for all remaining aircraft from CAA LAMP and LAMP(H) to a Part M, M.A.302 compliant programme was originally aligned to the adoption of Part M Light. As the date for introduction of this new regulation is currently unknown, the timescale for transfer to a Part M compliant maintenance programme is the 31 December 2019 or to a Part -ML compliant maintenance programme one year after the introduction of Part-ML but in any case, CAA LAMP, must not be used after 31 December 2019.

    This new deadline for Part M applies to ELA1 aircraft operated commercially (flying training), aircraft with MTOM of above 1200Kg but less than 2730Kg and all helicopters below 1200Kg currently on CAA LAMP(H).
    Owners, CAMOs, maintenance companies and engineers should plan accordingly.

    The introduction of Part-M Light (Part-ML) would mean owners/operators will have the option to use an SDMP/MIP based programme, as detailed by Part-M L.

    Helicopters single piston above 1200Kg below 2730Kg, will not be affected by the changes proposed by Part M L.

    Helicopters above 1,200 kg currently on LAMP

    These aircraft are not included in the recent changes to the Part M regulation and Part M Light will not be applicable, therefore the new approach to maintenance programmes cannot be used. Helicopters currently on LAMP are to move to an approved maintenance programme in accordance with Part M, M.A.302 at the next ARC renewal.

    Guidance

    CAP1454 Guidance for implementing SDMP for use with ELA1 aircraft

    Acceptable Means of Compliance/guidance material

    Aircraft Maintenance Programme Template

    A template for the SDMP can be found here: Aircraft Maintenance Programme Template