rulemaking-docs-crd-CRD CA Part 66

Part-66 Comment Response Document
Paragraph Organisation RD Proposed text / Comment Reason Response

Ref.
66.A.1 Avionics Mobile 109 It has been suggested that as there is little difference 1- Some aircraft below 5700
Services limited between the basic requirements between a B1.2 and a B2 kg have complex avionics
license holder that it is impossible to break down a B2 systems.
license into an easier qualification (for low end GA). I 2- The B2 basic knowledge
disagree with this. A person working on below 5,700kg requirement permits group
piston aircraft should not have to be examined on rating for aircraft below
CVR,FDR,GPWS,EGPWS, complex autopilots, complex 5700kg, which once the
electrical systems, complex entertainment systems, satcom, licence is obtained, reduces
complex FMS systems, auto land, auto throttle etc. These the burden on the licence
subjects could be an additional examination should this light holder.
aircraft person wish to progress at a later date. In its current
proposed form a person signing out a single engine piston Text not changed.
aircraft VOR/ILS would need to hold a full B2 license. This is
something GA can do without. We need two electronic
licenses, a full B2, and a B2.1. A B2.1 licence holder would
not need to be examined on those subjects listed but would
only be allowed to certify work on piston engine fixed wing
and rotary aircraft on those systems listed on his
authorisation document. This approach should enable the
training time requirements for the B2.1 license course to be
considerably reduced.
The requirement for a B2 license holder for low end GA
aircraft as it stands is a burden that this part of the industry
cannot possibly live with.
66.A.1 GAMTA 151 The B2 licence should be complimented by a B2.1 licence. 1- Some aircraft below 5700
The B2.1 licence would allow the holder to work on Piston kg have complex avionics
Engined fixed and rotary wing aircraft with simple systems systems.
that will be classified on the authorisation. 2- The B2 basic knowledge
requirement permits group
rating for aircraft below
5700kg, which once the
licence is obtained, reduces
the burden on the licence
holder.
Text not changed.

66.A.1 Aircraft Electronics 142 Category B2 license does not conform to the existing skill 1- Some aircraft below 5700
Association and knowledge basis of general aviation avionics kg have complex avionics
technicians. There is no safety basis or explanation for the systems.
enhanced skill and knowledge basis proposed by this 2- The B2 basic knowledge
regulation. requirement permits group
Category B2 should be subcategorized into turbine-powered rating for aircraft below
aeroplanes and helicopters, and pistonpowered 5700kg, which once the
aeroplanes and helicopters. The careers in aviation and licence is obtained, reduces
avionics maintenance are progressive careers where a the burden on the licence
technician will progress from basic knowledge in entry level holder.
general aviation employment to advanced knowledge in
corporate or commercial aircraft/avionics maintenance. The Text not changed.
provisions of the aircraft maintenance licenses needs to
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Ref.
acknowledge this career progression in the complexity of
individual licenses.
A person working on below 5,700kg piston aircraft should not
have to be examined on CVR,FDR,GPWS,EGPWS, complex
autopilots, complex electrical systems, complex
entertainment systems, satcom, complex FMS systems, auto
land, auto throttle etc. These subjects could be an additional
examination should the light aircraft maintenance technician
wish to progress towards
heavy turbine-powered aircraft at a later date.
Part 66 should recognize two electronic licenses, a full B2,
and a B2.1. The B2.1 license holder would not need to be
examined on systems typical to heavy turbine-powered
aircraft and would only be allowed to certify work on piston
engine fixed and rotary wing aircraft on those systems listed
on his/her authorisation document.
This approach should enable the training time requirements
for the B2.1 license course to be considerably reduced and
would more closely parallel the typical avionics technician
career path.
Recommended Change: Add paragraph (c) which reads:
“Category B2 is subcategorized into a full B2 license will full
authority and B2.1 limited to piston-powered
aeroplane/helicopter aircraft only.”
66.A.1 CFDT, France 144 For the purpose of this Part, the competent authority shall be It is clearer to write that the competent The competent authority is not
the civil service in charge of civil aviation of the Member authority is a part of the state administration. necessarily part of the state
State to whom a person applies for the issuance of an If the intention of the proposed text were administration.
aircraft maintenance licence. something different, its place were not in an Text not changed.
IR but in the regulation because of the
Parliament and Council competences.
66.A.10 LBA 055 There should be a more detailed description which non This was not in the original
technical requirements shall be fulfilled by JAR 66 and Part-66 is a
the applicant (e.g. certificate of good conduct). technical requirement.
A legal basis is necessary, to require such certificates. Text not changed.
66.A.10 ENAC, Italy 102 The Paragraph doesn’t take into consideration the renewal of This is addressed by 66.A.40
the license. It is proposed to integrate the paragraph with the and 66.B.120
renewal case, with the inclusion of the presentation of the Text not changed.
EASA Form 19
66.A.10 CAA, UK 118 No period of validity is specified for compliance with This was not in the original
knowledge and practical experience requirements for licence JAR 66 requirement. There
issue. Without such specification, an applicant may claim are some valid points in the
A.25 compliance from examination credits from previous comment but an additional
academic training, but not meet the practical experience requirement to Part-66 cannot
requirements until more recently. This allows the applicant be introduced at this stage
to extend the licensing compliance in an unlimited manner without proper consultation.
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Ref.
and denies the coherence of the process. Text not changed but the
issue should be reviewed at a
Note: The seven year period include in the suggested text later stage.
was discussed at the JAA JAR-66 Top Ten working group.
Suggested text:
An applicant who meets the knowledge and practical
experience requirements of this part within 7 years
immediately before the date of application for a basic licence
or the extension of a basic licence is entitled to a licence
issued by the competent authority.
66.A.10 GAMTA 151 The initial applications for an aircraft maintenance license This comment is not relevant
and an amendment to the license are made in different as amendment must be made
manner. While it is clear that the initial application for an by the original authority (the
aircraft maintenance license is made to the local competent competent authority). This is
authority, it is not clear which competent authority should be clearly stated in 66.1.
contacted to amend an existing license. If the amendment is Text not changed.
made through the local authority, how does the issuing
authority receive notification of the amendments? Section
66.A.10 should separately describe the procedures for initial
application for a license and the process of applying to
amend an existing license.
Recommended Change: Amend paragraph (a) to read: “An
application for an initial aircraft maintenance license shall be
made on EASA Form 19 and in a manner established by the
competent authority and submitted thereto. An application to
amend an existing aircraft maintenance license shall be
local competent authority and submitted thereto. In addition,
when the issuing authority is different than the local
authority, a copy of the amended license will be sent to the
issuing authority.”
66.A.10 Aircraft Electronics 142 The initial applications for an aircraft maintenance license This comment is not relevant
Association and an amendment to the license are made in different as amendment must be made
manner. While it is clear that the initial application for an by the original authority (the
aircraft maintenance license is made to the local competent competent authority). This is
authority, it is not clear which competent authority should be clearly stated in 66.1.
contacted to amend an existing license. Text not changed.
If the amendment is made through the local authority, how
does the original issuing authority receive notification of the
amendments? Section 66.A.10 should separately describe
the procedures for initial application for a license and the
process of applying to amend an existing license.
Recommended Change: Amend paragraph (a) to read: “An
application for an initial aircraft maintenance license shall be
competent authority and submitted thereto. An application to
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Ref.
amend an existing aircraft maintenance license shall be
local competent authority and submitted thereto. In addition,
when the issuing authority is different than the local
authority, a copy of the amended license will be sent to the
issuing authority.”
66.A.15 FOCA Switzerland 029 The minimum age to apply for a Part 66 licence is set to 18 18 years old is the ICAO
years in order to align with ICAO Annex 1 (Ref. §66.A.15). minimum requirement.
Part 145 requires that certifying staff Category B1 and B2 be It is correct that Part-145 has
at least 21 years old (Ref. §145.A.35(m)). Part M on the more stringent requirements
other hand allows for the certification privilege by the licence than Part-M on most issues.
holder on its own for the case of small non-complex aircraft Text not changed.
(Ref. M.A.801(b)3). Realistic handling of these different
certification privileges (Part 145 versus Part M with respect
to minimum age) is not seen.
66.A.15 CAA, UK 118 The age limit of 18 for licence issue cannot be met in any of The age limit of 18 can be met
the cases detailed in 66.A.30, unless experience was by persons having undergone
accepted and deemed worthy by applicants under 16 years Part-147 approved training.
of age. 18 years old is the ICAO
minimum requirement.
Part 145.A.35 (M) sets a minimum age of 21 for all certifying It is correct that Part-145 has
staff. Part 66 should align with this established and more stringent requirements
accepted age limit. To maintain a differential would suggest than Part-M on most issues.
certification outside of Part 145 approval was to a lower Text not changed.
standard.
Suggested text:
Delete 18 and add 21.
66.A.15 LBA 055 The minimum age of an applicant of 18 years does not 18 years old is the ICAO
correlate with Part 145. A person may hold a minimum requirement.
Part 66 licence, but will not be allowed to work as certifying The minimum age is not the
staff in a Part 145 organisation until same in Part-66 and Part-145
she/he is 21 years old. because of the introduction of
There should be the same minimum age in both parts. Part-M, which permits the use
of certifying staff below 21
years of age.
Text not changed.
66.A.15 Martinair Maintenance 061 Minimum age to apply for AML 18 years, but they become 66.A.20 specifies that
145 certifying staff at 21 years. category A licence holders
It is not clear if this also applies for ECAR 66 Cat A Certifying may only exercise their
Staff. privileges within a Part-145
We propose to make it possible to become Cat A certifying approved maintenance
staff before 21 years. organisation. In turn Part-145
makes it clear that category A
certifying staff (like other
categories) must have at least
21 years of age. This
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Ref.
corresponds to the original
JAA requirements
Text not changed.
66.A.15 British Airways 097 Reduction of the age limit of individuals to 18 to apply for a 18 years old is the ICAO
Maintenance 66 licence brings concerns over the experience of those minimum requirement. Similar
individuals. age requirements have been
in place in numerous states
without raising concerns.
Text not changed.
66.A.20 CAA, UK 118 (a) 1. A category “A” licence does not permit the There is no need to change
holder to issue Certificates of Release to Service. This the text as 66.A.20(b) requires
privilege is given by a Part 145 organisation. compliance with Part-145 or
(a) 2. Improve text. Part-M as applicable. Part-145
requires to hold a certification
(a) 4. Should include aeroplanes at 5700kg and authorisation.
above, and helicopters at or above 3175kg. Text not changed.
Suggested text:
1. A Category A aircraft maintenance licence permits
the holder to be authorised by a Part 145 organisation to
issue Certificate of Release to Service following minor
scheduled licence maintenance and simple defect
rectification, within the limits of tasks specifically endorsed
on the authorisation.
2. Change last sentence to: Category B1 includes the

appropriate Subcategory A privileges.
3. A Category C aircraft maintenance licence permits

the holder to be authorised by a Part 145 organisation to
issue Certificates of Release to Service following base
maintenance…….... aeroplanes with a maximum take off
mass of 5700kg and above, or helicopters of a maximum
take off mass of 3175kg or above.
Note: The remainder of the text is duplication from 145.A.30

(J).
66.A.20 LFV, Sweden 105 It should be more expressed in (a) 1, 2, 3 and 4 that: There is no need to change
The holder of an aircraft maintenance licence must have a the text as 66.A.20(b) requires
authorisation as certifying staff from a Part 145 organisation compliance with Part-145 or
before he/she can issue certificates of release to service Part-M as applicable. Part-145
(CRS). requires to hold a certification
(a) authorisation.
1. A category A aircraft maintenance licence qualify the Text not changed.
holder for an authorisation to issue certificates of release to
service following minor scheduled line maintenance and
simple defect rectification within the limits of tasks
specifically endorsed on the authorisation. The
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Ref.
certification….
2. A category B1 aircraft maintenance licence shall qualify

the holder for an authorisation to issue certificates of release
to service following maintenance, including aircraft structure,
powerplant and mechanical and electric systems.
Replacement……..
3. A category B2 aircraft maintenance licence shall qualify

the holder for an authorisation to issue certificates of release
to service following maintenance on avionic and electrical
systems.
4. A category C aircraft maintenance licence shall qualify the
holder for an authorisation to issue certificates of release to
service following base maintenance on aeroplanes with a
maximum….
66.A.20 ENAC, Italy 102 The proposed text is considered ambiguous and should be This paragraph should be read
modified to include the full privileges of B1 certifying staff. in conjunction with
145.A.35(b) and M.A. Subpart
The text of the article should specify that B1 staff privileges H, which together describe the
include line maintenance for aircraft with a MTOM more than full privileges of certifying staff
5700 kg amd Base Maintenace for aircraft with a MTOM at in each category.
or below 5700 kg. Text not changed.
66.A.20 CAA, Denmark 121 From 66.A.20(b) 1 . A holder of an AML may not exercise the The use of the licence outside
certification privileges unless in compliance with the the EU jurisdiction is not
applicable requirements of Part M and/or Part 145. relevant.
As the licence is a personnel licence and from para 2 the Text not changed.
requirement given in ICAO annex 1 is back in Part 66
regulation from JAA 145, it should be possible to use this
licence outside EU and JAA countries, on conditions for
keeping it valid.
This is also relevant for AML holders exercising the
privileges inside EU/JAA countries not employed in an
organisation under Part M or Part 145 or only employed for a
short period so short that they do not receive continuation
training.
It is the problem for people having a contract as substitute
technician.
The organisations responsible for substitutes have no
system for continuation training.
Clarification.
Part66.A.20 should have a para (c) saying:
Notwithstanding para (b) The holder of an EU AML may not
exercise certification privileges as substitute technician or
outside EU unless:
a) in compliance with Part 66.A.20 (b) 2 and 3
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Ref.
b) Have continuation training equivalent to requirements in
Part 145 relative to privileges exercised.
c) In compliance with EU regulation relative to licence and
privileges except for part 66.A.20(b) 1.
d) In compliance with ICAO Annex 1.
66.A.20 CAA, Ireland 154 Part 66.A.20 defines the privileges of the various licence 66.A.20 text is based upon
categories. existing JAR 66.20 text. It is
The present JAR 66.20 privileges are causing considerable not clear from the comment
confusion, particularly in respect of the electrical system and where the confusion resides
instruments. In fact the only way to make any determination and no change proposal is
is to use the appendix 1 syllabus as a guide. This is not the offered. Furthermore it is true
best way to do that. that Appendix 1 to Part-66 (the
It is proposed that part 66.A.20 should be revised to clearly basic knowledge syllabus)
define the categories so that there is no confusion. provides detailed information
on the scope of each licence
category.
Text not changed.
66.A.20 LFV, Sweden 105 The weight factor in regard of aircraft and helicopters is not Text changed to ensure
used in a consistent way. It sometimes reads: “a maximum consistency throughout
take-off mass of 5 700 kg or above” and sometimes: “a maintenance regulations.
maximum take-off mass below 5 700 kg”.
The ICAO definition should be applied.
66.A.20(a) LBA 055 Category B1 and B 2 aircraft maintenance licence should be Category C was originally
limited to line maintenance. designed for large aircraft and
“4. A category C aircraft maintenance licence shall permit the is not adapted to light aircraft
holder to issue certificates of release to environment.
service following base maintenance on aircraft without any Category C is rather
weight limit.” management oriented and is
needed for complex
maintenance packages using
complex documentary
systems. For light aircraft base
maintenance, category B1 and
B2 qualifications are found
appropriate.
Text not changed.
66.A.20(a)(1) DGAC, France 162 “(a) Subject to compliance with paragraph (b), the following The category A has certifying privileges only The proposal is redundant
privileges shall apply: in a Part 145 organisation. with 66.A.20(b)1.
1. A category A aircraft maintenance licence permits Text not changed.
the holder, when authorised by a Part 145 Maintenance
organisation, to issue certificates of release to service
following minor scheduled line maintenance and simple
defect rectification he has personally performed, within the
limits of tasks specifically endorsed on the authorisation..”
66.A.20(a)(2) and British Airways 064 Paragraphs 2 and 3 identify privileges of category B1 and B2 The wording of the paragraphs should 66.A.20 text is based upon
7

Ref.
(3) aircraft maintenance licence respectively, and include differentiate distinctly between the areas of existing JAR 66.20 text. The
electrical systems as privileges for both categories. responsibility for each category so that the respective areas of
areas of responsibility are clear in each case. responsibility are clarified by
Part-66 Appendix 1 (basic
knowledge requirement).
Text not changed.
66.A.20(a)(4) ENAC, Italy 102 A category C aircraft maintenance licence shall permit the Category C was originally
holder to issue certificates of release to service following designed for large aircraft and
base maintenance on aeroplanes with a maximum take off is not adapted to light aircraft
mass above 5700kg or helicopters of a maximum take off environment. The text is not
mass above 3175 kg. The privileges apply to the aircraft in seen as a burden for those
its entirety. organisations maintaining both
The limitation to large aircraft seems to have no large and small aircraft but on
justification, and may lead to problem in the procedures the contrary will permit the use
of those maintenance organisation approved for both simplified released to service
classes of aircraft. procedures for light aircraft.
Text not changed.
66.A.20(a)(4) RAES, UK 107 We note that Article 2 (e) of the Commission Regulation Text changed to ensure
includes the term “ a multi-engined helicopter” in the consistency with Article 2(e),
definition of a “large aircraft”, while in paragraph 66.A.20 Part-M and Part-145.
(a)(4) reference to “helicopters of a take off mass of above
3175kg”. We believe the paragraph should be redrafted to
make reference to, “multi-engined helicopters or those with a
take off mass of above 3175kg”.
66.A.20(a)1 Assn. of Licensed 010 Add to the last sentence, the following sentence:- "It shall not Already covered by Part-145
Aircraft Engineers include fault finding or the use of test equipment to prove a AMC.
system is serviceable for return to service". Text not changed.
66.A.20(b) 2 CAA, Finland 157 In case of simple light aeroplane (single piston engine, The requirement is 6 months
MTOM below 2000kg) in non commercial (private) use, the experience every two years.
competent authority should be allowed in certain cases, after This should be achievable
evaluating the licence holder’s competence, to reduce the even with short flying seasons.
requirement of 6 months of maintenance experience in Text not changed.
preceding two years.
In some EU countries, due to short flying season caused by
geographical location and small number of aeroplanes, the
fulfilling the minimum 6 months requirement is not possible in
practice.
66.A.20(b)3 CFDT, France 144 he/she is able to read, write and communicate to an It is difficult to ask the same level of Part-66 text is based upon
understandable level in the language(s) in which the understanding and communication of a existing JAR 66 text. The
technical documentation and procedures necessary to foreign language to different types of people complexity of the language
support the issue of the certificate of release to service are who have not the same needs. used in technical
written taking in account his/her level of certification. documentation and
procedures is not necessarily
linked with the scope of and
individual’s certification
8

Ref.
privileges.
No text change.
66.A.25 CAA, UK 118 (a) Appendix 1 only refers to Category A, B1 and B2. (a) Appendix 1 on the contrary
A Category C applicant has no basic knowledge specifies that a category C
specification. This means applicants holding an academic must by either the B1 or B2
degree in a technical discipline may not have been basic knowledge levels.
examined on any relevant aeronautical maintenance (b) 66.A.25(b) text is based
syllabus. upon existing JAR 66 text. It
(b) The text suggests an applicant will be given a allows among other things to
credit for technical qualifications held. This is not the case, accept an academic degree
as technical qualifications that may be credited must first be based on its equivalence to
evaluated for compliance with Appendix 1. This task cannot the B1 or B2 basic knowledge
be accomplished at the point of application for a licence, or requirements. Proposed new
be assessed from a certificate alone. The criteria to paragraph (c) is more
determine acceptance will require detailed review of the stringent than existing JAA
administration of the qualification, the syllabus, and the text and would somehow
examination process. Furthermore, this process can only be contradict paragraph (b).
carried out at the National Level. It would not be reasonable No text change.
to accept technical qualifications from other EU states
without the cooperation of the State in which the application
is made.
Suggested text:
Full or partial credit against the basic knowledge
requirements and associated examination may be given for
any technical qualification assessed by the competent
authority to be equivalent to the knowledge standard of this
part. Such credits shall be established in accordance with
Section B, Subpart E of this Part.
(c) “Applicants for Category C must demonstrate that

an academic degree for qualification under paragraph
66.A.30 3 (iii) meets the syllabus requirements for Category
B1 and or B2”.
66.A.25 CAA, Finland 157 Postpone implementation until EASA PART 66 Appendix 1 Final Article 7 of the
knowledge requirements question data bank is available. Commission Regulation
Competent authority is unable to carry out examinations in includes a two year transition
those countries that has no PART 147 approvals. period for Part-66
requirements, which should be
sufficient for the preparation of
the number of examination
questions required by
Appendix 2 to Part-66. It
should also be noted that
there is no requirement for a
database of examination
questions.
Considering the change in
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Ref.
Article 7, there is no need to
change 66.A.25.
66.A.25(a) ENAC, Italy 102 An applicant for ... shall demonstrate, by examination Part-147 specifies that
conducted by the competent authority or by an organisation approved basic training
approved according to Annex Part 147, to have a level of organisations have the
knowledge.... privilege to conduct
examinations that are
According to the present text the examination may be recognised for the purpose of
conducted by the Authority only, which is not acceptable. Part-66; there is no need to
repeat this in Part-66. The
same approach was taken in
JAR 66
Text not changed.
66.A.30 Assn. of Licensed 010 For subcategories B1. and B1.3 or B2:, Suggestion. 66.A.30 text is based upon
Aircraft Engineers Experience requirements for the Avionic Engineer should be existing JAR 66 text.
the same as the requirements for categories B1.2 and B1.4 Proposed B2 experience
and B1 and A. If you are avionically minded 3 years requirements are not
experience is quite adequate. substantiated and would not
be consistent with the B1.1
experience requirement.
No text change.
66.A.30 LFV, Sweden 105 Rename subcategories to categories in (a) 1. and 2 Text changed.
(a)
1. for category A, and categories B1.2 and B1.4:
2. for categories B1.1 and B1.3 or B2:
Wrong nomenclature, as B1.1, B1.2, B1.3 and B1.4 are
categories.
66.A.30 GAMTA 151 Paragraph (a)(3). Paragraph (a)(3) allows for five years of The intent of 66.A.30 is
experience as a B1.2 or B1.4 technicians as identified in misunderstood, therefore the
paragraph (a)(3)(ii) or academic qualifications as identified in proposed change is not
paragraph (a)(3)(iii), however, Section 66.A.45(b) requires relevant.
that category C technicians must be appropriately type rated. Text not changed.
In order to be appropriately type rated a category C
technician would need to possess an A or B1.1 or B1.3
license. The criteria in Paragraph (a)(3)(ii) and (iii) are
redundant, confusing and should be deleted.
Recommended Change: Delete paragraphs (a)(3)(ii) and
paragraph (a)(3)(iii)
66.A.30 GAMTA 151 Proposed change to the

Paragraph (c). Paragraph (c) requires category B2 experience requirements
technicians to be involved with a representative cross exclude electrical systems and
section of maintenance tasks on aircraft. For B2 avionics therefore is not consistent with
technicians this is an unacceptable burden. Since B2 has the scope of the category B2
combined both avionic and electrical systems, the B2 licence as defined by 66.A.20
mechanics would have to regularly work on every aircraft Text not changed.
system connected to the electrical system. The typical
avionics technician regularly works on communication,
10

Ref.
navigation and radar systems. Their experience should be a
cross section of these systems as applicable to their specific
work environment.
Recommended Change: Amend paragraph (c) to read: “For
category A and B1 the experience must be practical which
means being involved with a representative cross section of
maintenance tasks on aircraft. For category B2 the
applicable experience must be practical which means being
involved with a representative cross section of
communication, navigation, or radar systems either on the
aircraft or bench.”
66.A.30 (a) (3) Aircraft Electronics 142 Paragraph (a)(3) defines the experience criteria for licensing The intent of 66.A.30 is
Association as a category C technician. Paragraph (a)(3)(ii)allows for five misunderstood, therefore the
years of experience as a B1.2 or B1.4 technicians; or proposed change is not
academic qualifications as identified in paragraph (a)(3)(iii), relevant.
however, Section 66.A.45(b) requires that category C Text not changed.
technicians must be appropriately type rated. In order to be
appropriately type rated a category C technician would need
to possess an A or B1.1 or B1.3 license.
The criteria in Paragraph (a)(3)(ii) and (iii) are redundant,
confusing and should be deleted.
Paragraph (a)(3)(ii) and (iii) can be interpreted to mean that
a B1.2 or B1.4 technician can become a category C
technician without having experience on large turbine-
powered aircraft.
Recommended Change: Delete paragraphs (a)(3)(ii) and
paragraph (a)(3)(iii).
66.A.30(a) RAES, UK 107 We note that paragraph 66.A.30 (a) clarifies the role of the Comment noted; no action
Category B1 and B2 licence holders in relation to base required.
maintenance, and their relationship with Category C licence
holders.
66.A.30(a)(2) (ii) CAA, Ireland 154 Part 66.A.30 (a) (2) (ii) refers to non-aviation technical trade. Agreed.
& 66.A.30 (a) (1) This does not provide for acceptance of an aviation Text changed.
(ii) apprenticeship whereas Part 66.A.3. (a) (1) (ii) does not use
the term “non-aviation”.
It is proposed to amend Part 66.A.30 (a) (2) (ii) by removing
the term “non-aviation”.
66.A.30(a)(3) ENAC, Italy 102 It should be avoided that the experience in maintenance of Agreed.
small aircraft be used to obtain a "C" AML valid on large Text changed.
aircraft also.
66.A.30(a)(3) (i), IVW, The Netherlands 099 Twelve month experience as Base Maintenance Support Covered by the AMC.
(ii) Staff should be a minimum requirement to be incorporated in Text not changed.
the total number of years for an applicant for a category C.
This was already recommended by JAA-TGL 39, not
applicable for Cat C applicant holding a relevant academic
degree.
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Ref.
66.A.30(a)(3) (iii) CAA, UK 118 (a) The text mixes two issues, knowledge and 66.A.30 (a) (3) (iii) is based
experience. As this paragraph only refers to experience the upon existing JAR 66 text and
text should be simplified. specifies on which basis
general maintenance
Suggested text: experience an be accepted.
Text not changed.
(a) 3.(iii) For an applicant holding an acceptable academic
degree, three years of experience working in a civil aircraft
maintenance environment directly associated with aircraft
maintenance, including six months observation of base
maintenance tasks.
66.A.30(a)(3) (iii) CAA, UK 118

(e) Inconsistent reference to who accepts maintenance Proposed text is covered by
experience. - No period specified for gaining civil the AMC.
experience. Text not changed.
Suggested text:
(e) Insert - .... shall be accepted by competent authority......

Amend last paragraph. One year’s additional experience of
civil aircraft maintenance shall, however, be required to
ensure understanding of the civil aircraft maintenance
environment.
66.A.30(a)(3). (ii) LBA 055 change "base maintenance support staff" to "B1 and B2 Agreed.
support staff" Text changed.
Use the same wording as in 145.A.35.
66.A.30(a)1 (ii) & CAA, UK 118 Specify different criteria for intermediate experience Agreed.
2 (ii) requirements for a skilled worker. 1 (ii) refers to ‘a technical Text changed.
trade’ while 2 (ii) refers to ‘a non-aviation technical trade’.
Requirement for it to be non-aviation discriminates against

those trained within the aviation industry (including aircraft
maintenance training/apprenticeship if it was outside Part-
147!).
Suggested text:
Delete ‘non-aviation’ from 2 (ii).
66.A.30(a)1. LBA 055 delete "B1.2 and B1.4" Not agreed. The turbine
The requirements for practical maintenance experience for engine aeroplane category
aeroplanes turbine and aeroplanes piston includes aircraft the
should be equivalent. technology of which is far
more complex than the
technology found on piston
12

Ref.
engine aircraft. Experience
requirements cannot be
equivalent.
Text not changed.
66.A.30(a)1. (ii) LBA 055 copy (iii) from 66.A.30(a) 2. to 66.A.30(a) 1. and reduce the Agreed.
time limit to one year. Text changed.
An equivalent wording in 66.A.30(a) 1. and 66.A.30(a) 2.
shall be used.
66.A.30(a)1. (ii) LBA 055 change "technical trade" to "non-aviation technical trade" Text harmonised but not as
It is important to make it impossible to fulfil (i) and (ii) suggested.
together in a three years time.
66.A.30(a)2. LBA 055 change "B1.1 and B1.3" to "B1" Not agreed. The turbine
The requirements for practical maintenance experience for engine aeroplane category
aeroplanes turbine and aeroplanes piston includes aircraft the
should be equivalent. technology of which is far
more complex than the
technology found on piston
engine aircraft. Experience
requirements cannot be
equivalent. Text not changed.
66.A.30(c) Aircraft Electronics 142 Paragraph (c) requires category B2 technicians to be Proposed change to the
Association involved with a representative cross section of maintenance experience requirements
tasks on aircraft. For B2 avionics technicians this is an exclude electrical systems and
unacceptable burden. Since B2 has combined both avionic therefore is not consistent with
and electrical systems, the B2 mechanics would have to the scope of the category B2
regularly work on every aircraft system connected to the licence as defined by
electrical system. The typical avionics technician regularly 66.A.20.Text not changed.
works on communication, navigation and radar systems.
Their experience should be a cross section of these systems
as applicable to their specific work environment.
Recommended Change: Amend paragraph (c) to read: “For
category A and B1 the experience must be practical which
means being involved with a representative cross section of
maintenance tasks on aircraft. For category B2 the
applicable experience must be practical which means being
involved with a representative cross section of
communication, navigation, radar or electrical systems.”
66.A.30(d) CAA, UK 118 Experience required for additional categories/subcategories Appendix 4 changed to ensure
nd
(2 sentence) is subjective and conflicts with that quoted in consistency.
paragraph 66.A.30 3 (b) and Appendix 4.
Suggested text:
nd rd
Delete 2 and 3 sentence of this paragraph.
13

Ref.
66.A.30(d) CAA, UK 118 Clarify recency. The experience should it be in the immediate Recency is clarified in the
12 months before application. AMC.
No text change.
Suggested text:
First sentence: For all applicants, at least one year of the
required experience must be in the preceding twelve months
on aircraft of the category/subcategory for which the initial
aircraft maintenance licence is sought.
66.A.30(d) British Airways 097 The existing text refers to ‘additional experience’ for person ‘Additional experience’ is an un-quantified Clarification is given by the
Maintenance from a non civil aviation background. phrase. Inclusion of a clarification potential AMC.
matrix based on existing knowledge and No text change.
experience should be included as a
reference guide.
66.A.30(d) DGAC, France 162 “(d) For all applicants, at least 12 month of the required Implementation problem: Recent experience The intent of the proposal is
experience shall be maintenance experience on aircraft of should be defined, in addition, the covered by the AMC.
the category/subcategory for which the initial aircraft experience usually required is not a block of Text not changed.
maintenance licence is sought gained in the last 7 years, of one year, but rather a total of 12 month.
which 6 month shall be gained in the last 12 month. For
subsequent category/subcategory additions to an existing
aircraft maintenance licence, the additional maintenance
experience required may be less than 12 month, but must be
at least three months in the last 12 month. The required
experience must be dependent upon the difference between
the licence category /subcategory held and applied for. Such
additional experience must be typical of the new licence
category/subcategory sought.
(e) Notwithstanding paragraph (a), aircraft maintenance
experience gained outside a civil aircraft maintenance
environment shall be accepted when such maintenance is
equivalent to that required by this Part. Additional experience
of civil aircraft maintenance shall, however, be required to
ensure understanding of the civil aircraft maintenance
environment. For category A, the additional experience of
civil aircraft maintenance should be a minimum of 6 months.
For category B1 or B2, the additional experience of civil
aircraft maintenance should be a minimum of 12 months”
66.A.30(e) CAA, UK 118 The additional civil experience requirements for experience Covered by the AMC.
gained outside civil a/c maintenance environment should be Text not changed.
stated.
Suggested text:
Amend last sentence: Additional civil aircraft maintenance
experience shall, however be required as described in (d) to
ensure an understanding of the civil aircraft maintenance
environment.
14

Ref.
66.A.30(e) ENAC, Italy 102 The present text of the involved paragraph does not give The intent of the text is exactly
any indication about the experience credit for maintenance the same as JAR 66.30(e).
activities outside civil aircraft (i.e. military or State aircraft). Text not amended
The present JAR 66.30(e) text should be used.
66.A.40 LFV, Sweden 105 Missprint in last part of (a). Agreed.

Change 66.A.120 to 66.B.120 Text changed.
66.A.40 Lufthansa Technik 021 ....pursuant to 66.A.120. Must read: 66.B.120 (Typing error) Text changed.
66.A.40 LBA 055 The validation period of five years for a Part 66 licence is not The ICAO Annex 1
in accordance with ICAO Annex 1, requirement referred to is in
which requires a validation period of two years. fact adequately covered by
The validation period shall be reduced to two years to be in 66.A.20(b)2. ICAO Annex 1
conformity with ICAO Annex 1. does not require a revalidation
of the experience by the
competent authority. Under
ICAO Annex 1, this is the
responsibility of the licence
holder.
Text not changed.
66.A.40 CAA, UK 118 (a) This statement suggests the competent authority 66.A.40 text is based upon the
will check for inconsistencies in the licence in comparison to existing JAR 66 requirement.
the records held at each 5 year period or at a time where an Suggested text would
amendment is required. This process as described does not introduce a new requirement
deal with licence validity, instead implies that the competent that cannot be incorporated
authority will check that the licence has not been amended without proper consultation
illegally. This is not sustainable and is inappropriate. and therefore cannot be
accepted at this stage.
However, a renewal process is valued and affords the Text not changed.
issuing authority a check to ensure the applicant can
demonstrate compliance with 66.A.20 (b) 2 at the 5 year
interval.
Suggested text:
66.A.40 The renewal of the aircraft maintenance licence
(a) “The aircraft maintenance licence becomes invalid

five years after its last issue or amendment,
unless the holder submits his/her aircraft
maintenance licence to the competent authority
that issued it, in order to verify compliance with
66.A.20 (b) 2”,
(b) New item (d): Inform the competent authority that
issued the licence of any change to the personal
details.
15

Ref.
66.A.40 Aircraft Electronics 142 Section 66.A.40 does not contain provisions for continued The authority must check the
Association validity while the aircraft maintenance license is in transit to original licence. Similar
the competent authority which issued the initial license for procedure applies for
the 5 year validation. additional type rating
Many regulations require the technician to be in possession endorsements. 66.A.40
of their license in order to exercise the privileges of their provisions does not prevent
license. The provisions of Section 66.A.40 cause a the licence holder from
subsequent violation of regulations and/or company policies exercising his certification
by requiring the holder of the license to submit the license to privileges. Finally 66.A.40 is
the original issuing authority for validation. Under the based upon existing JAR 66
standardized approach of EASA Part 66, the initial issuing requirement.
authority may not be the authority of residence and the Text not changed.
validation process may take weeks to complete. Some
provision for the license to remain valid during the 5 years
validation process is necessary.
Recommended Change: Add paragraph (d) to Section
66.A.40 which reads: “The aircraft maintenance technicians
may demonstrate the validity of their license during the 5
year validation process with a photocopy of their aircraft
maintenance license plus all ratings.”
66.A.40(a) CAA, Finland 157 (a) The aircraft maintenance licence becomes invalid five Agreed.
years after its last issue or amendment, unless the holder Text changed
submits his/her aircraft maintenance licence to the
competent authority that issued it, in order to verify that the
information contained in the licence is the same as that
contained in the competent authority records, pursuant to
66.B.120.
Wrong reference to non existing 66.A.120 (correct reference
should be 66.B.120)
66.A.45 LFV, Sweden 105 (a) Missprint. Second sentence duplicated. Agreed.
Text changed.
66.A.45 LFV, Sweden 105 (g) Category C. Not in compliance with 66.A.20 (a) 4. Agreed.
Text changed.
66.A.45 LFV, Sweden 105 (g) This is a new requirement that

1. Manufacture group ratings requires at least 3 years cannot be added at this stage
maintenance experience as certifying staff, should be without proper consultation.
mentioned in the text Text not changed.
2. Full group ratings requires at least 5 years maintenance
experience as certifying staff, should be mentioned in the
text
66.A.45 LFV, Sweden 105 (g) The intent is that the Agency
3. A definition of simple and complex aircraft types should be will publish a list of complex
16

Ref.
added. aircraft in the AMC.
Text not changed
66.A.45 Lufthansa Technik 021 same sentence twice, once: “shall”, once: “must” Agreed.
(typing error) Text changed.
66.A.45 Lufthansa Technik 021 In addition to the existing paragraph for Cat B1 and B2 add Argument: Parallel to complete type-rating- Agreed. Will be addressed in
the following note: courses it must also be allowed to conduct the AMC.
NOTE: In case of difference training, the difference type difference/delta type-rating-courses in order
training shall cover theoretical training elements and to save time and effort.
practical training elements, if applicable. The content of the Examples:
difference training shall be approved by the competent · A B1 holding a B747-400 with GE CF6
authority. adds a B747-400 with PW4000 on his
license. So the training he receives is the
PW4000 engine training and the interfaces.
The practical part needed afterwards is on
the engine and the interface only
· A B2 holding an A340 with CFM56 adds an
A330 with RR Trent on his license. Since
there is no difference in avionic between an
A340 and an A330, the training needed will
focus on the engine (FADEC and indication)
only. Practical hands-on training is
unnecessary.
· Both B1 or B2 taking difference courses for
example A318 to A319/320/321; B737-
600/700/800 to B737 300/400/500 or A340-
200/300 to A340-500/600. For all these
courses there is no need for 2 weeks
practical training.
66.A.45 Airbus MTO 015 “The training shall include practical hands on training and Agreed.
theoretical training as appropriate for each task authorised. Text changed.
Satisfactory completion of training shall be demonstrated by
an examination and/or by workplace assessment carried out
by an appropriately approved Part145 or Part-147
organisation.
“The training shall include practical hands on training and

theoretical training as appropriate for each task authorised.
Satisfactory completion of training muste be demonstrated
by an examination and/or by workplace assessment carried
out by an appropriately approved Part145 or Part-147
organisation".
To delete one of those paragraphs.
66.A.45 ERA 079 The last sub-paragraph that commences with the phrase Agreed.
“The training shall include practical hands on…” is repeated Text changed.
twice and differ slightly from each other. One should be
17

Ref.
deleted.
66.A.45 DGAC, France 162 In sub-paragraph (a) what is the meaning of appropriately Implementation problem: A part 145 Agreed. Will be addressed in
approved ? organisation is not approved for training. the AMC.
66.A.45 DGAC, France 162 Modify sub-paragraph (d) as follows: Editorial: Coherence of the training course Agreed.
“(d) Category B1 and B2 approved type training shall include with certifying privileges of 66.A.20 Text amended although not
theoretical and practical elements and consist of a aircraft exactly as suggested.
structure, powerplant, mechanical and electrical system
course for category B1 and an avionics and electrical system
course for category B2. Theoretical and practical training
shall comply with Appendix 3 to this Part.”
66.A.45 Assn. of Licensed 010 The majority of the proposals are acceptable. The proposals Comment noted.
Aircraft Engineers on Light and General Aircraft would appear to alleviate JAR No action required.
147 training in as much as it is levelled at the basic
knowledge of simple types of aircraft and
components. The grouping of types is also acceptable under
manufacturers as the ethos should be acceptable to
competent authorities. I am not too happy with grouping of a
range of manufacturers after 3 type ratings. I believe for
safety's sake this should be looked at again. Ethos between
manufacturers may not be the same.
66.A.45(a) CAA, UK 118 Amend (a) to reflect comment in 66.A.20 (a) 1 and simplify Text simplified but reference
text. to the authorisation not added
as it would repeat 66.A.20(b).
Suggested text:
(a) “The holder of a Category A aircraft

maintenance licence may only exercise
privileges of his authorisation on a specific
aircraft type following satisfactory completion
of practical hands on training and theoretical
training as appropriate for each task
authorised. Satisfactory completion of training
shall be demonstrated by an examination
and/or by work place assessment carried out
by an appropriately approved part 145 or part
147 organisations.
66.A.45(a) CAA, UK 118 (a) Duplication of para 2. Text changed.

Suggested text:
rd
(a) Delete 3 paragraph.
66.A.45(a) IVW, The Netherlands 099 CAA-NL sees no reason not to restrict the privilege of Part-M organisations are not
practical training Part a45 approved AMO’s only, Part M allowed to use category A
subpart F AMO’s should also be included. CAA-NL certifying staff therefore there
18

Ref.
suggests to ad Part M subpart F approved organisation to is no need for them to conduct
the last sentence of this paragraph. ( ps. The last two category A task training.
sentences are printed twice.) Text not changed.
66.A.45(a) Tyrolean Airways 100 The second subpara commencing with „the training shall Agreed.
include......“ is repeated/redundant. Text changed.
66.A.45(a) Wideroe, Norway 028 The section starting with: “The training shall include practical Agreed.
hands on……………” is written twice. Text changed.
(typing error?)
66.A.45(a) CAA, Finland 157 The text of the second paragraph duplicated in error in the Agreed.
third paragraph (only one word difference). Text changed.
66.A.45(a) LBA 055 To approve the Part 145 organisation for task training an Agreed. Will be clarified in the
AMC in Part 145 is needed (see comment AMC.
to 145.A.75(a)). Text not changed.
The AMC shall require that the Part 145 organisation should
fulfil the requirements of Part 147 for
the task training of category A maintenance personnel.
66.A.45(a) LBA 055 To approve the Part 145 organisation for task training an Agreed. Will be clarified in the
AMC in Part 145 is needed (see comment AMC.
to 145.A.75(a)).
The AMC shall require that the Part 145 organisation should
fulfil the requirements of Part 147 for
the task training of category A maintenance personnel.
66.A.45(a) CAA, Denmark 121 Double text, use the text with… must be demonstrated by an Agreed.
examination and/or workplace assessment…. Text changed.
66.A.45(c) CAA, UK 118 There is no limit on the time that a type course is valid for. 66.A.45 is based upon existing
Since the value of the training diminishes over time if it is not JAR 66 requirement.
put into practice, there should be a time limit between Suggested text includes a new
completion of training and issue of the type rating. requirement that cannot be
included without proper
Suggested text: consultation.
Add new paragraph (i): Any type course taken to qualify for Text not changed.
the issue of a type rating must have been completed within
three years immediately before application for that type
rating.
66.A.45(d) British Airways 097 This paragraph refers to a mechanical course for B1 and an ATA 104 is the industry standard of training Reference to ATA 104 is
Maintenance avionic course for B2. to which no reference has been made. made in the Guidance
Instead the new amendment refers to Material.
specific written text requirements. Text not changed.
66.A.45(d) Airbus MTO 015 In addition to the existing paragraph for Cat B1 and B2 , add To take into account the “difference training” Agreed. Will be addressed by
19

Ref.
the following note: the AMC.
NOTE: In case of difference training, the difference type

training shall cover theoretical training elements and
practical training elements, if applicable. The competent
authority shall approve the content of the difference training.
66.A.45(e) Airbus MTO 015 In addition to the existing paragraph for Cat C the following To take into account the “difference training” Agreed. Will be addressed by
note: the AMC.
NOTE: In case of difference training, the difference type

training shall cover theoretical training elements approved by
the competent authority.
66.A.45(e) Eurocopter France, 004 (e) Category C approved type training shall comply with The current text did not specify anything The knowledge required for
Jean-Francis Suquet Appendix 3 to this Part. In the case of a category C person about the knowledge required other than first subsequent type training is
qualified by holding an academic degree as specified in type training. addressed by the first
66.A.30 (a), (3), (iii), the first relevant aircraft type theoretical sentence of the paragraph
training shall be at the category B1 or B2 level. The other (general case).
aircraft theoretical knowledge shall be evaluated Text not changed.
according to the level 1 "General Familiarisation" of
Appendix 3.
66.A.45(f) CAA, UK 118 Assumes that practical aspects of type training will be - The practical element must
carried out by Part 147 organisations as an integrated also be assessed (see
course. Appendix 3 to Part-66).
- The term satisfactory is
Suggested text: redundant with “demonstrated
Add ‘theoretical’ between ‘type’ and ‘training’. by an examination”.
Consistency issue. Use “ Satisfactory completion”. Text not changed.
Suggested text:
Satisfactory completion of approved type training,
as.........
66.A.45(g) CAA, UK 118 (g) “Notwithstanding paragraph (b), the holder of a The first part of the proposal
Category B1 or B2 aircraft maintenance licence may would result in requiring 6
also …………………………………”. aircraft type qualification for a
group rating, instead of 3. No
(g) 2. This should reflect three aircraft manufacturers not proper justification is given for
three aircraft types. This would require less manufacturers such a drastic change.
experience that someone qualified for a manufacturers group Text not changed.
in (g) 1. It should state that the 2 types of the manufacturer
or the 3 types needed for the full group have to be endorsed
on the licence first before the group is given. There is no
value endorsing the last type required if the group is to be The intent of second part of
given. the proposal (substituting
“endorse” by “qualified for”) is
Suggested text: accepted.
20

Ref.
66.A.45 (g) 1 Text changed, although not
Delete ‘endorsement of’ and substitute ‘qualifying for’. exactly as proposed.
66.A.45 (g) 2
“Full group ratings may be granted after qualifying for three
manufacturers groups representation of the full group”.
Example 1: C152 and C210 = limitation Cessna aircraft
rating.
Example 2: Piper aircraft and Cessna aircraft and Mooney

aircraft = aeroplane Single Piston engine – metal structure
(No limitations).
66.A.45(g) CAA, Finland 157 Group ratings should be used only for single engine Proper justification for the
aeroplanes MTOM below 2000kg. All helicopters regardless change missing. Group ratings
of their MTOM should need a separate type rating. for helicopters are envisaged
This is due to safety reasons: The fact is that the errors in in conjunction with the basic
maintaining helicopters can have more severe results than knowledge level requirements
errors in aeroplane maintenance. of Appendix 1 to Part-66.
Text not changed.
66.A.45(g)(1) Rolls Royce Germany 087 Change: “Manufacturer Group” into “Type approval The term “manufacturer
group”, because there are several cases where the same Group” is kept but the issue
type design is used by different manufacturers (license will be clarified in the AMC.
production) and the rating should be related to the type
design and not dependent on the manufacturing
organisation.
66.A.45(g)(2) ENAC, Italy 102 ” However , no full group rating may be granted to B1 The fact that twin engine
multiple turbine engine aeroplanes and helicopters,…..”. helicopters are generally
complex helicopters and
The modification should avoid that a full group rating is therefore should not be
instituted for multiengine helicopters. Multiengine helicopters subject to group ratings, is
are high complexity aircraft and the maintenance procedures accepted.
may greatly vary with type and manufacturer. Text changed.
66.A.45(g)(2) Assn. of Licensed 010 (g) 2. Should be deleted in its entirety. (See preamble to No justification provided.
Aircraft Engineers submissions). The sentence dealing with Multiple Turbine Text not changed.
Engined Aeroplanes should be added to (g) 1.
66.A.45(g)(2) CAA, Denmark 121 For Manufactory and Full group rating a clear acceptance The issue is covered by
system for exercising the privileges of new types under a 66.A.20(b)2 for continuing
group rating must be defined as well as the responsibility of experience and 66.A.45(g) for
the AML holder for exercising these privileges. determination of complexity of
Clarification needed for this area. the new type.
Text not changed.
66.A.45(g)(3) LBA 055 No group ratings should be allowed for aircraft with turbine Some simple turbine aircraft
21

Ref.
engines. may be adequately covered by
These aircraft are too complex for a group rating. group ratings. Furthermore
subparagraph (g) specifies
that complex small aircraft are
subjected to type ratings only.
Text not changed.
66.A.45(h) CAA, UK 118 (H) This paragraph should include a provision to The intent was indeed that
accept type training in lieu of type examination. While type paragraph (h) would not
training is not essential, organisations have set up Part 147 exclude paragraph (c) type
type training for this weight of aircraft at industry’s request. training option.
This should be an acceptable process for type rating Text changed, although not
purposes, and recognised as a preferred option to type exactly as proposed.
examination.
The list of aircraft types will be
Reference to paragraph 3 unnecessary. included in the AMC.
A new appendix is necessary to specify which aircraft are
considered complex and require a type training course.
Without this specific reference an applicant may presume his
group ratings already cover the type in question.
Suggested text:
(H) “Notwithstanding paragraph (C), ratings on

aeroplanes with a maximum take off mass of
5700 kg or less and helicopters with a maximum
take of mass of 3175 kg or less shall be granted,
subject to satisfactory completion of the relevant
Category B1 or B2 aircraft type examination or
approved type training course, and demonstration
of practical experience on the aircraft type, unless
the Agency has determined the aircraft is
complex as listed in appendix **, where approved
type training is essential.”
66.A.45(h) CAA, Finland 157 Notwithstanding paragraph (c), ratings on aeroplanes with a Recent experience is covered
maximum take off mass of 5700 kg or less and helicopters by 66.A.20(b)2.
with a maximum take off mass of 3175 kg or less shall be Text not changed.
granted, subject to satisfactory completion of the relevant
category B1 or B2 aircraft type |examination and
demonstration of recent practical experience after
completing the training |course on the aircraft type, unless
the Agency has determined that the aircraft is complex,
where paragraph 3 approved type training is required.
Reason for this change: If the practical knowledge has been
gained too long ago, most or part of it may have been
forgotten and knowledge may not be up to date.
66.A.45(h) CAA, Finland 157 Notwithstanding paragraph (c), ratings on aeroplanes with a If the practical knowledge has been gained Recent experience is covered
maximum take off mass of 5700 kg or less and helicopters too long ago, most or part of it may have by 66.A.20(b)2.
22

Ref.
with a maximum take off mass of 3175 kg or less shall be been forgotten and knowledge may not be Text not changed.
granted, subject to satisfactory completion of the relevant up to date.
category B1 or B2 aircraft type |examination and
demonstration of recent practical experience after
completing the training |course on the aircraft type, unless
the Agency has determined that the aircraft is complex,
where paragraph 3 approved type training is required.
66.A.45(h) CAA, Ireland 154 Part 66.A.45 (h) introduces the requirement for type The possible development of a
examinations for aircraft under 5700 kgs and for helicopters central examination database
under 3175 kgs. by the Agency is not relevant
The use of multi-choice questions is recognized by JAR 66 to the consultation.
as the only way of ensuring that the same standards are
applied in all EU member States.
It is proposed that EASA should provide a central question
bank for each aircraft type in the relevant weight categories.
66.A.45(h)(3) Assn. of Licensed 010 (h) 3. "Aircraft type practical experience shall include a This is covered by the AMC.
Aircraft Engineers representative cross section of maintenance activities Text not changed.
relevant to the category."
Add following few words, "as proven by the applicants
personal engineering log book".
66.A.45(h)(3) CAA, Finland 157 Aircraft type recent practical experience shall include a If the practical knowledge has been gained Recent experience is covered
representative cross section of | too long ago, most or part of it may have by 66.A.20(b)2.
maintenance activities relevant to the category. been forgotten and knowledge may not be Text not changed.
up to date.
66.A.50 ENAC, Italy 102 The JAR 66.50 should be used instead of the proposed text, 66.A.50 clearly puts the
because it is not sufficiently clear the responsibility to avoid responsibility on the licence
that a Certifying Staff not medically fitted issues Certificate holder and removed the
of Release to Service. ambiguity caused by the terms
“know or suspect”. It is
therefore considered better
than the original JAR 66 text.
Text not changed.
66.A.50 Assn. of Licensed 010 This is not good enough. Self monitoring does not work. It At the moment there is no
Aircraft Engineers has to be the management who will decide fitness for work. such monitoring programme,
The Americans carry out this requirement correctly. If you therefore self monitoring is the
really want this paragraph added you only possibility.
must put some fire into its wording, or forget about it . As it Text not changed.
is written there is absolutely nothing to back it up. No one
will quit work because they think they are not fit, the fear of
dismissal is always there. What support will E.A.S.A. give to
the engineer who suspends himself from duty?
66.A.50 British Airways 097 The statement suggests ‘A licence holder should not Previously the word ‘suspects’ has been
Maintenance exercise the privileges of his/her licence if their physical or included in such a statement. If a persons The term “suspects” made the
mental condition makes them unfit’ ‘mental’ condition renders them unfit, it is, by requirement weaker.
then, too late to make a considered Text not changed.
judgement. Addition of ‘suspects’ pre-empts
23

Ref.
this to some degree.
66.A.50 GAMTA 151 The proposed EASA language of section 66.A.50 reduces With the original JAR 66.50
the level of safety established by JAR 66.50. There is a provision, a technician could
subtle difference between having a condition which renders argue he did not suspect his
the technicians unfit verses having the technicians take physical condition was not
preventive measures if they suspect that a condition may appropriate. New text is more
compromise there ability to safely exercise the privileges of stringent.
their certificate. Text not changed.
Recommended change: Replace the proposed language of
66.A.50 with the original JAR 66.50 language so that section
66.A.50 reads: “Aircraft maintenance license holders shall
not exercise their privileges if they know or suspect that their
physical or mental condition renders them unfit to exercise
such privileges”.
66.A.50 DGAC, France 162 Propose to delete paragraph Impracticable: This paragraph should be 66.A.50 is based upon existing
reserved for the time being. We consider that JAR 66 text. It deals with the
this text is not mature enough to become a individual’s responsibility and
community Regulation as it interferes with does not require the
general provisions of the social legislation involvement of the employer
concerning workers capacity. as no medical testing is
required. Finally EU law
prevails over National law.
Text not changed.
66.A.50 Aircraft Electronics 142 The proposed EASA language of section 66.A.50 reduces With the original JAR 66.50
Association the level of safety established by JAR 66.50. There is a provision, a technician could
subtle difference between having a condition which renders argue he did not suspect his
the technicians unfit verses having the technicians take physical condition was not
preventive measures if they suspect that a condition may appropriate. New text is more
compromise there ability to safely exercise the privileges of stringent.
their certificate. Text not changed.
Recommended change: Amend the proposed language of
66.A.50 with the original JAR 66.50 language so that section
66.A.50 reads: “Aircraft maintenance license holders shall
not exercise their privileges if they know or suspect that their
physical or mental condition renders them unfit to exercise
such privileges”.
66.A.50 CFDT, France 144 Too difficult to implement taking into account the medical Medical secrecy is not the
secrecy issue. This paragraph is about
individual responsibility, not
medical testing.
Text not changed.
66.A.50 & AMC CAA, Denmark 121 We have until now had the attitude that medical approval or This is a new requirement that
66.A.50 control for mechanics/technicians are not needed. cannot be included at this
But seen in the light of Estacy and other artificial produced stage without proper
24

Ref.
drugs and the know problems with alcohol, we feel it is time consultation.
for a new attitude or approach. Text not changed.
As a start we could extend AMC 66.50 with para 5 saying.
5. Holders of an Aircraft Mechanical Licence exercising the
privileges of that licence shall on request from the
Competent Authority or the Agency undergo any medical test
or examination the Competent Authority or the Agency finds
necessary for being able to decide if a situation exist in
conflict with the above item 1, 2, 3, 4 to this paragraph and to
decide if a situation exist to render the licence invalid.
66.A.70 IVW, The Netherlands 099 Conversion provisions. Extend protected right according to
TGL 32, there is personnel who hold the qualification and The term “qualification valid in
experience required to exercise certification privileges but, a Member State” intends to
due to another job assignment, are not currently exercising cover this case.
or have not yet exercised these certification privileges. The conversion provision has
These rights should also be protected rights. CAA-NL no time limit.
suggests to include the relevant wording of TGL 32 into this
paragraph, to make it legal. Text not changed.
66.A.70 ENAC, Italy 102 The transition phase does not give any grandfather right to
those certifying staff presently under training. According to Agreed. Original provisions for
the proposed text, those people should ask again for AML JAR 66.1(e) were missed.
Part 66, and no training credit has been defined. Italian New subparagraph (b) in
industry would greatly hurt by the proposed text. introduced along the lines of
JAR 66.1 text should be adopted instead of the proposed JAR 66.1(e).
text.
66.A.70 Austro Control 081 66.A.70 should read ”The holder of a certifying staff
qualification and/or an national aircraft maintenance licence Paragraph should clearly state that also The term “qualification valid in
valid in a member state, prior...” national maintenance licences are subject to a Member State” intends to
be converted; some European countries cover this case.
have a national licensing system.
The conversion provision has
no time limit.
Text not changed.
66.A.70 LBA 055 A procedure for transfer of national licences or national
privileges not issued in accordance with JAA The term “qualification valid in
procedures to Part 66 category A, B1, B2, and C is needed. a Member State” intends to
A regulation for grandfather rights holders according JAR-66 cover JAR 66 licences and pre
is missing. JAR 66 qualifications.
As transfer period of JAR-66 was until 2011. The conversion provision has
no time limit.
Text not changed.
66.A.70 Atitech S.p.A. - Alitalia 111 Add new paragraph following 66.A.70 to recognize According to JAR66.1 and 66.3 personnel
Group “personnel undergoing a course of approved basic or type “under training” at the date of JAR 66 has Agreed. Original provisions for
training at the date of effectivity of JAR66 (par. 66.1.e and been declared to Authority and accepted. JAR 66.1(e) were missed.
25

Ref.
66.3)”. It is not acceptable and uneconomical for the
industry to cancel this transitional measure. New subparagraph (b) in
introduced along the lines of
JAR 66.1(e).
66.A.70 Alitalia 067 Add new paragraph following 66.A.70 to recognize According to JAR66.1 and 66.3 personnel
“personnel undergoing a course of approved basic or type “under training” at the date of JAR 66 has Agreed. Original provisions for
training at the date of effectivity of JAR66 (par. 66.1.e and been declared to Authority and accepted. It JAR 66.1(e) were missed.
66.3) is not acceptable and uneconomical for the New subparagraph (b) in
industry to cancel this transitional measure. introduced along the lines of
JAR 66.1(e).
66.A.70 DGAC, France 162 A personnel authorised under article 5 of the regulation to Impracticable: It is necessary to take into
exercise certification privileges in accordance with national account persons who will be in the course of Agreed. Original provisions for
regulations valid in a Member State, prior to the date of entry a qualification at the time of entry into force JAR 66.1(e) were missed.
into force of this Part, is entitled to an aircraft maintenance of Part 66. See also comment to article 5 of New subparagraph (b) in
licence issued by the competent authority without further the regulation. introduced along the lines of
examination subject to the conditions specified in 66.B.130. A drafting similar to 66A.10(b) seems more JAR 66.1(e).
Where necessary, the aircraft maintenance licence shall appropriate.
contain technical limitations in relation to the scope of the
pre–existing qualification.
66.A.75 ERA 079 Replace the word “that” with “than” on the first line. “that” not found in the text.
Comment not relevant.
No text change.
66.A.75 LBA 055 It does not correlate with EU regulation 1592/2002, Part M Comment noted. No action
and Part 145, if maintenance personnel is required at this stage of the
holding licences in accordance with national regulation. consultation.
Therefore a common regulation for technical maintenance
personnel for these types of aircraft (gliders, balloons, etc.)
shall be published as soon as possible, because a European
standard is needed in this field.
66.A.75 DGAC, France 162 Propose to delete paragraph Regulation 1592/2002 only requires Text is found compatible with
66.A.80 implementing rules for certifying staff if Regulation 1592/2002.
required to hold a certificate. For the time Text not changed.
being it has not been decided yet if
harmonisation and the requirement for a
certificate was necessary for certifying staff
of aircraft other than aeroplanes and
helicopters and of helicopters. Having
Subpart B and C included in the regulation
prejudge decision on that subject, which is
not desirable.
66.A.80 ERA 079 Add the letter s to “component” on the first line. Comment not relevant
66.A.80 ERA 079 This paragraph makes reference to component certifying. It

was my understanding from an earlier MST meeting that this 66.A.80 makes reference to
requirement had been dropped. Can the Agency please national requirement therefore
26

Ref.
explain why the topic appears within this Part 66? in practice there is no change
from existing JAR 66.
Text not changed.
66.A.80 Martinair Maintenance 061 ECAR 66 Subpart B and ECAR 66 Subpart C 66.A.80 makes reference to
national requirement therefore
In ECAR 145 the national standard for NDT (EN 4179) is in practice there is no change
removed from text as it is not in control of EASA, why from existing JAR 66Text not
mention the national standards (also not in control of EASA) changed.
on:
- Aircraft other than aeroplanes and helicopters in subpart B
and
- Components in subpart C.
We suggest to deleted the subparts.
Also, we as ECAR 145 organisation feel no need for

regulations on licensing component maintenance personnel.
Part 21, Part 66 and Part 145 and the requirement for Form
One provide adequate assurance in this matter.
66.A.80 LBA 055 It does not correlate with EU regulation 1592/2002, Part M Comment is noted, however
and Part 145, if maintenance personnel is the text is found compatible
holding licences in accordance with national regulation. with Regulation 1592/2002.
Therefore a common regulation for technical maintenance No action required at this
personnel for these components shall be stage of the consultation.
published as soon as possible, because a European
standard is needed in this field.
66.A.80 Rolls Royce Germany 087 The latest amendment to JAR66 has been ready for release Comment noted. No action
and should be implemented here. To leave this with the NAA required at this stage of the
generates an unacceptable situation due to the different consultation.
levels of qualification for component certifying staff and
causes commercial disadvantages to organizations from
several member states.
66.B.85(a) CFDT, France 144 A Member State shall designate a civil service known as It is clearer to write that the competent The competent authority is not
“competent authority” with allocated responsibilities for the authority is a part of the state administration. necessarily part of the State
issuance, continuation, amendment, suspension or If the intention of the proposed text were administration.
revocation of licences. This competent authority shall something different, its place were not in an Text not changed.
establish documented procedures and an organisational IR but in the regulation because of the
structure. Parliament and Council competences.
66.B.87 Tyrolean airways 100 Replace the words „... may use .....“ with „.... shall use ....“ in In line with Regulation
the first line of the para. to avoid different standards applied 1592/2002 Articles 13 and 14.
in different member states Text not changed.
66.B.90(b) CAA, UK 118 (b) This should include records of assessment of any Agreed. Text changed except
qualification credited towards a Part 66 licence and any for 5(b), which is included in
assessment of an academic degree accepted for Category 5(a).
C.
27

Ref.
Suggested text:
5. Change ‘authoritys’ to ‘authorities’ (typographical error).

a. Copies of examination credit reports
required by 66.B.150.
b. Copies of assessments made to
determine the acceptance of academic degree for Category
C.
and (e) to include 8 and 9.
66.B.90(b)(2) IVW, The Netherlands 099 CAA-NL does not see the necessity to hold a paper copy of The AMC will specify that copy
the licence, but finds it essential that the authority has means paper copy, computer
secured to have the information on record, possibly on a copy or a combination of both
computer database including separate and secure back-ups. methods.
CAA-NL suggests to change the wording of 66.B.90(b)(3) as Text not changed.
follows: “the detailed information of the maintenance
licence including any changes.”
66.B.90(b)(5) ERA 079 The word “authoritys” on line 1 should be replaced with Agreed.
“authorities”. Text changed.
66.B.90(c) LBA 055 The time limit of 5 years for record-keeping is different to 5 years corresponds to 1 cycle
time limit of 4 years in accordance with of licence validity renewal.
145.B.55. Text not changed.
This may cause problems in the future, when Part 66
Subpart C licences will be issued according
EASA rules.
66.B.90(f) CAA, UK 118 (f) National legislation prevents the disclosing of certain Text is in compliance with
personal information to other parties. Regulation 1592/2002 Article
11 on Information network.
Suggested text: Text not changed.
Delete ‘All records’ and substitute ‘Appropriate information’.
Note of caution: This may contradict the data protection act.
66.B.90(f) DGAC, France 162 Delete 66.B.90(f) and add a new paragraph 66.B.XX Basic principles: Text is in compliance with
Exchange of information: Coherence with Part M Regulation 1592/2002 Article
1.1 “ 66.B.XX Mutual exchange of information 11 on Information network.
No reason to give unlimited access to an Text not changed.
(a) In order to contribute to the improvement of aviation
authority’s record system outside mutual
safety, the competent authorities shall participate in a mutual
exchange of information. Unlimited
exchange of all necessary information.
access is restricted to the inspection
(b) The information exchanged shall be used solely for the
power of the Agency (as specified in
purpose of this Part and its access shall be limited to the
article 45 of regulation 1592/2002).
participating competent authorities.
(c) Without prejudice to the competencies of the Member
States, in the case of a potential safety threat involving
28

Ref.
several Member States, the concerned competent authorities
shall assist each other in carrying out the necessary
oversight action.”
66.B.95 IVW, The Netherlands 099 Repetitive and long exemptions shall be notified to the This would repeat Article 10, 3
agency and the member states. CAA-NL suggests some of the basic regulation.
standard procedures should be included here. No text change.
66.B.100 Assn. of Licensed 010 Add another short sentence:- "Such experience to be verified 66.B.100 is based upon
Aircraft Engineers by perusal of the applicants personal engineering log existing A&GM Chapter 22
book". text. The introduction of a
logbook would be a new
requirement which would
necessitate additional
consultation.
Text not changed.
66.B.100(b) CAA, UK 118 (b) As applicants may have credits for Agreed.
certain modules of the syllabus, the procedures should Text changed.
reflect their validity in lieu of examination.
Suggested text:
(b) The competent authority shall verify an
applicant’s examination status and/or confirm the validity of
any credits to ensure that all required modules of appendix 1
have been met as required by this Part.
66.B.105 CAA, UK 118 It is not clear what this procedure is designed to provide. It 66.B.105 is based upon
states that the competent authority prepares and issues the existing text from A&GM
licence. Since this is the legal obligation of the issuing Chapter 22, which has been
authority, any preparation by industry is entirely irrelevant to implemented and proved
the process. Furthermore this does not appear as a privilege satisfactory. There is no
of Part 145. The inclusion of this procedure is a legacy from objective reason to delete this
the original JAR-66 and should be omitted at this time. provision.
Text not changed.
Suggested text:
Delete 66.B.105.
66.B.105 IVW, The Netherlands 099 CAA-NL is confused on this issue. On what basis can a Part Agreed. The term “approved”
145 AMO been approved for this activity? is replaced by “authorised”.
66.B.110(c) & (d) CAA, UK 118 (c) & (d) refer to the state in which licence holder first Suggested text is not relevant
qualified. This may not be the state which issued the current because licences can only be
licence. amended by the Member
State who originally issued the
Suggested text: licence.
Text not changed.
In (c), delete all following ‘other than the Member State’ and
add ‘which issued the current licence, the application shall be
29

Ref.
sent to the issuing Member State.’
In (d), delete ‘in which he/she first qualified’ and substitute

‘which issued the current licence’ and delete ‘Member State of
first qualification’ and substitute ‘issuing Member State’.
(d) It is the applicant’s responsibility to claim credit with his

original licensing authority. This does not involve the Part 145
organisation or require their completion of the Form 19.
Suggested text:
(d) Where the applicant for amendment of the basic

categories qualifies for such variation via 66.B.150 in a
Member State other than the Member State which issued
the licence, the application shall be sent to the Member
State which issued the licence.
66.B.110(d) IVW, The Netherlands 099 Typo: the reverence should be 66.B.105. Agreed.
Text changed.
66.B.115 CAA, UK 118 Paragraph (B) repeats the content of (a). Paragraph (b) transferred to
Suggested text: the AMC and (c) renumbered.
Delete existing (b) and renumber (c) as (b).
66.B.115(b) CAA, Ireland 154 This paragraph does not cater for the non-complex aircraft Agreed.
where a type examination is required. Text changed.
It is proposed to amend this paragraph by adding “or type
examination, in the case of non-complex aircraft” after the
word: elements.
66.B.120 CFDT, France 144 (a) The holder of an aircraft maintenance licence shall (a) It is not mandatory that the Part 145 Agreed.
complete the relevant parts of EASA Form 19 and submit it organisation submits the Form 19 Text changed.
with the holder’s copy of the licence to the competent (b) Self explanatory
authority that issued the original aircraft maintenance
licence, unless the Part-145 approved maintenance
organisation has a procedure in its exposition whereby such
organisation can submit the necessary documentation on
behalf of the aircraft maintenance licence holder.
(b) The competent authority shall compare the holder’s
aircraft maintenance licence with the competent authority file
and verify for any pending 66.A.65 revocation, suspension or
variation action. If the documents are identical and no action
is pending pursuant to 66.A.65, the holder’s copy shall be
renewed for five years and the file endorsed accordingly.
(c) If the competent authority file is different from the aircraft
maintenance licence held by the licence holder:
1. the competent authority shall investigate the reasons for
such differences and may choose or not to renew the aircraft
maintenance licence.
30

Ref.
2. the competent authority shall inform both the licence
holder and the affected Part-145 or Part-M approved
maintenance organisation of such fact and shall, if
necessary, take action under paragraph 66.A.65 to revoke,
suspend or amend the licence in question.
66.B.120 Assn. of Licensed 010 Rewrite (c) as follows:- There has to be a two way dialogue between Investigation involves dialogue
Aircraft Engineers "The competent authority shall investigate the reasons for parties when such a serious breach is when necessary.
such differences and after consultation with the licence discovered. Text not changed
holder and approved maintenance organisation, may choose
not to renew the aircraft maintenance licence."
66.B.120 Tyrolean Airways 100 Reference to 66.A.65 is wrong. This para does not exist in Agreed.
this document Text changed.
66.B.120(a) LBA 055 change “shall” to “may” Agreed.

The AMO may employ personnel with a Part 66 licence but Text changed.
will not necessarily issue an
authorisation certificate to all such staff.
66.B.120(b) ENAC, Italy 102 The reference to 66.A.65 appears to be wrong. It should be Agreed.
66.B.155 Text changed.
66.B.120(b) CAA, Finland 157 The competent authority shall compare the holder’s aircraft Agreed.
maintenance licence with the competent authority file and Text changed.
verify for any pending 66.B.155 revocation, suspension or
variation action. If the documents are identical and no action
is pending pursuant to 66.B.155, the holder’s copy shall be
renewed for five years and the file endorsed accordingly.
Incorrect reference to PART 66.A.65 which does not exist.

The correct reference should be to PART 66.B.155.
66.B.120(b) and CAA, UK 118 (b) and (c) These procedures refer to an Suggested Subpart B text is
(c) administrative procedure to corroborate records with an not in line with the Subpart A
issued licence, and revocation as prescribed by 66.B.155. requirement (see
See comments on 66.A.40 corresponding comments on
66.A.40)
A renewal procedure is required to address technical Text not changed.
compliance issues. This should require the applicant to
demonstrate 6 months experience in 24 months as required
by 66.A.20. ICAO Annex 1 requires the issuing authority to
check currency of experience that can be achieved at licence
renewal. The renewal process proposed does not include
any check on current experience. This may be acceptable
when working under a Part 145 certification authorisation
and the Part 145 organisation takes responsibility for
ensuring compliance, there is no similar check when
certifying under the licence itself. For those applicants who
31

Ref.
due to their role in industry cannot meet the experience
requirement, the licence will expire but can be renewed at a
future date by meeting the experience requirements
specified.
Suggested text:
(b) The competent authority shall check that the

holder has recorded sufficient maintenance experience to
comply with 66.A.20 (b) 2 over the preceding 5 year period,
and when satisfied shall renew the licence for a further 5
years and amend the records accordingly.
New: (c) Where the applicant cannot demonstrate

compliance with 66.A.20 then a further period of experience
will be necessary before the licence can be renewed.
Delete (c) and (c) 1 and 2.
66.B.120(c)(2) IVW, The Netherlands 099 Since there is no reverence to an approved procedure with a Agreed.
Part M AMO as with an Part 145 AMO as stated in Text changed, although not
66.B120(a), CAA-NL suggests to remove the Part M AMO exactly as proposed.
here. The NAA will not standard be informed at witch Part M
AMO the licence holder is working.
66.B.125(b) CAA, UK 118 (b) Does not differentiate between an examiner who sets the Examiner is the original term
questions and an invigilator who supervises the conduct of from A&GM Chapter 23 and is
the written examination. the same term as in Part-147.
No text change.
Suggested text:
Substitute ‘invigilator(s)’ for ‘examiners’ and add ‘written’

before ‘examinations’.
66.B.125(e) DGAC, France 162 (e) New essay questions shall be raised at least every six Implementation problem: It is useless to Agreed.
months, except if no examination has been undertaken raise new essay questions if the last set of Text changed.
within the period, and the oldest questions withdrawn or essay questions has not been used yet.
rested from use. A record of the questions used shall be
retained in the records for reference.
66.B.130 CAA, Denmark 121 Part 66.B130(a) only conversion in accordance with a
(See also conversion report. 66.B.135 and .140 clarify the
Explanatory Note Review Board report prepared under JAA system seems not content of the report as being
1.3 and 66.A.70) to be accepted under part 66.B.130(a). New Report to be a generic, not an individual
prepared for each applicant. report.
Clarification: Text not changed.
Explanatory Note to Annex II (part 66) add. 1.3 transitional
measures suggest 2 years for adoption.
If all training must be reviewed on an individual basis as
given in 66.A.70 and 66.B.130 the adoption time suggested,
32

Ref.
2 years, is to short.
In general a more detailed guidance program needed for the
adoption period.
66.B.135 RAES, UK 107 In the interest of clarity we would insert the phrase “without Agreed.
limitation” immediately after, ….and the Part-66 Text changed.
module/subjects on which examination is needed to ensure
conversion to the aircraft maintenance licence….”
66.B.140 CAA, UK 118 This should also include reference to aircraft type Suggested text changes the
authorisations. The text should be simplified to improve meaning.
readability. Text not changed.
Suggested text:
The report shall describe the scope of each authorisation
and aircraft type authorisation, and reflect the relevant
Part 66 aircraft maintenance licence category, including
limitation on which examination is needed to convert the
licence. The report shall include a copy of the relevant
approval maintenance organisations procedures for the
qualification of certifying staff, on which the conversion
process is based.
66.B.150 Assn. of Licensed 010 This is a question on examination credits:- Credits are given This comment has no effect
Aircraft Engineers by some competent Authorities and not by others. What is on the regulation.
the position if a member state via it's competent authority
decides it does not like some of the credits agreed to by
another member state. Can the member state disallow such
engineers working in their state, or will it be if the agency
agrees such credits the member states will have to employ
such engineers with a basic knowledge that the employing
member state is not happy with?
66.B.155 CAA, UK 118 Add new conditions to reflect medical conditions as specified The case of a person issuing
in 66.A.50. certificates while medically
unfit is already covered by
Suggested text: paragraph 8.
9. Issuing a Certificate of Release to Service when Text not changed.
medically unfit.
66.B.155 DGAC, France 162 This paragraph is not mature Impracticable: 66.B.155 is based upon the
Usually, the licence is considered like a original text from JAR 66.
diploma and is not suspended or limited. The licence is not just a
The authority limits or suspend instead diploma as it confers
the privileges associated to the licence. privileges. Within the Part-M
Limitation, suspension or revocation of a context, suspending the
licence would necessitate the definition of licence is the only way to
conditions to get the licence back. suspend the related privileges.
Finally 66.B.155 defines the
33

Ref.
Suspension are subject to national legal criteria for suspending or
and administrative procedure, and this revoking a licence but does
regulation can not require suspension. not address the procedure for
such action, which is indeed
Such requirement can only be drafted covered by National laws,
with very serious caution as they have a therefore proposed text
major impact on the ability of mechanics creates no conflict with
to work national legal and
administrative procedures.
Text not changed.
66.B.155 CFDT, France 144 It must be written in the IR that the person can present The appeal procedure is a
his/her defence, the procedure being into the AMC National procedure.
Text not changed.
Appendix 1 CAA, UK 118 A revision of the current Appendix 1 is necessary to reflect Comment noted. No such
new practices and technologies and redraft the text to meet action can be taken at this
proper academic standards for syllabi structure. stage of the consultation..
A working group should be convened to draft a new
appendix 1 based upon academic principles.
Appendix 1 CAA, UK 118 Modularisation. Table of modules to licence categories/sub The table is a summary.
categories is incorrect in that some of the modules listed are Detailed information on
not applicable to category A. module applicability is
Does not show separation of module 11. contained in the main text.
Text not changed.
Suggested text:
Change table to show a column for each
category/subcategory.
Show module 11a & 11b.
Appendix 1 RAES, UK 107 We believe that an additional requirement should be added First paragraph of Appendix 1
to ensure that Category C Licence holders should cover (at states that Cat C must meet
least) Modules 9 and 10, as these may not have been the knowledge levels of either
covered sufficiently in the syllabus of a technical degree. B1 or B2.
Text not changed.
Appendix 1 Lufthansa Technik 021 By incorporating “light aircraft” and “helicopter” – personnel The Part-66 licence is indeed
some modules have been beefed up for the complete a basic licence intended to
community. As a result certifying staff for commercial air cover all applicable
transport now finds wooden structures, fabric covering and technologies.
wooden propeller in his syllabus. Text not changed.
Appendix 1 EAMTC working group 026 The introduction of new sub-modules in the basic exam. Article 5 of the draft
Syllabus must not lead to a conversion training for all Commission Regulation on
individuals who have already passed CAT A training or continuing airworthiness
conversion training for CAT B1 or B2. states existing JAR 66
licences remain valid. No
conversion training is
therefore needed for JAR 66
licences without a limitation.
34

Ref.
Text not changed.
Appendix 1 LBA 055 The former Module 18 for “airships with aerodynamic lift” Module 18 never existed.
shall be added. Airships are not covered by
This type of aircraft is part of Part 66 Subpart A licences. Part-66.
Text not changed.
Appendix 1 CAA, Norway 131 The item (2) Modularization is not up-dated as for M11b) etc. The table is a summary.
Detailed information on
module applicability is
contained in the main text.
Text not changed.
Appendix 1 CAA, Norway 131 Module 13 should be amended to contain the same elemts Comment too general.
as in Appendix 3 (Type training & examination standard) (2) Proposed text change is
Type training standard B2. Reason: To harmonise subject missing.
elements i.e. fuel, hydraulics, fire etc. Text not changed.
Appendix 1 DGAC, France 162 I – The proposed programme is too demanding for light I - Impracticable: The level of knowledge The Appendix 1 basic
aircraft (notably A2, B.1.2, A4 and B1.4) required is not commensurate to the knowledge requirement levels
II – Amend chapter 2 – Modularisation and Module 16- elementary nature of light aircraft (compared are intended to facilitate the
Piston Engine as follows. to what is required for much more complex possibility for an AML holder
large aircraft). There is no justification for to obtain group ratings.
such a level of knowledge. Text not changed.
A too high level of qualification for light
aircraft mechanics will create either
frustrations amongst overqualified personnel
of small general aviation maintenance
organisations or a lack of personnel as these
qualified people will go to better paying 145
organisations.
Such a decision can not be taken without a
serious regulatory impact assessment.
For information, you will find appended the
programme of our national aircraft systems
vocational training certificate which, in our
opinion, would be a better basis with
appropriate intensification where necessary.
See also comment to Part 147, Appendix 1.
II - Editorial
Module 11a and 11b are based upon former
Module 11. The matrix must follow the
syllabus.
Module 16 is Piston engine and
consequently applicable to A2 and B1.2.
Appendix 1 CAA, Ireland 154 Annex 1 shows some changes in addition to those affecting Proposed changes do not
non-complex aircraft. preclude subsequent changes.
At the top ten meeting it was agreed that the appendix 1 Text not changed.
syllabus is not detailed enough to show clearly what is
35

Ref.
required.
It is proposed that no changes be made to the present
syllabus until the complete syllabus is revised as envisaged
by the top ten meeting.
Appendix 1 Lufthansa Technik AG 148 The introduction of new sub-modules in the basic exam. Article 5 of the draft
Syllabus must not lead to a conversion training for all Commission Regulation on
individuals who have already passed CAT A training or continuing airworthiness etc.,
conversion training for CAT B1 or B2. states existing JAR 66
licences remain valid. No
conversion training is
therefore needed for JAR 66
licences without a limitation.
Text not changed.
Appendix 1 Lufthansa Technik AG 148 By incorporating “light aircraft” and “helicopter” – personnel The Part-66 licence is indeed
some modules have been beefed up for the complete a basic licence intended to
community. As a result certifying staff for commercial air cover all applicable
transport now finds wooden structures, fabric covering and technologies.
wooden propeller in his syllabus. Text not changed.
Appendix 1 ENA, Italy 102 MODULARISATION table has not been modified to accept The table is a summary.
the 11a and 11b modules introduced to account for the Detailed information on
difference with JAR 66. module applicability is
contained in the main text.
Text not changed.
Appendix 1 ALAE 036 With reference to the syllabus on basic knowledge it seems Module 1 (Mathematics) of
to be perfectly acceptable as regards basic knowledge and Appendix 1 is based upon
the required levels for the various Licences seems adequate existing JAR 66 text. No
to produce a good, finished result. However do we want the objective justification for
holders of such basic knowledge as genuine hands on changing existing text is given.
trouble shooters and all round Engineers. I personally still No change.
want a lot of convincing that a good B1 all rounder needs
algebra. I speak as an Engineer of 40 years standing,
working with a Licence. I certainly never used algebra.
However this basic knowledge document does prove that in
the majority of cases a good educational standard is
required. One can only hope that EASA will take on board
that all member states must ensure that such teaching of a
technical nature is available to young students whilst in the
national curriculum and such teaching must be agreed by the
National Competent Authority.
Appendix 1 Mr Cartry 048 We place this comment in the case of light aircraft, under 2 A lot of the knowledge is out of the subject The basic knowledge
tons. The basic knowledge requirements a person needs for for light aircrafts. To obtain this level is not requirement are set at high
the issue of a category B1.2 aircraft maintenance licence are necessary to issue a certificate of release to level to facilitate the
very high. service. If the mechanic works on light possibility for an AML holder
aircraft, he will never use a large part of the to obtain group ratings.
required knowledge. Text not changed.
A mechanic who obtains this level of
knowledge will never work in an aero-club,
but in a company.
36

Ref.
The knowledge of most part of aero-club
mechanics is very far from the proposed
requirements.
Appendix 1, ERA 079 Replace the phrase “alloys steels” with “alloy steels”. Agreed.
6.1 a) Text changed.
Appendix 1, ERA 079 The word riveting is misspelled in the second and third lines. Agreed.
7.8 Text changed.
Appendix 1, ERA 079 The phrase “tance Measuring Equipment (DME)” should be Agreed.
13.4 replaced with “Distance Measuring Equipment (DME)” Text changed.
Appendix 1, 1 ERA 079 Replace the phrase “knowledge levels indicators” with Agreed.
1 “knowledge level indicators”. Text changed.
Appendix 1, CAA, Ireland 154 The matrix shows module 4 as applicable to Category A. The table is a summary.
paragraph 2 The syllabus shows that module 4 is not applicable to Detailed information on
Category A. module applicability is
It is proposed to amend the matrix to show that module 4 is contained in the main text.
not applicable to Category A. Text not changed.
Appendix 2 CAA, UK 118 Credits given against certain modules of appendix 1 should This is a new requirement that
have the same validity as that applied to examination cannot be included without
passes. proper consultation.
Text not changed.
Suggested text:
1.11 All part 66 modules and any credits awarded in

accordance with 66.B.150, that make up a complete Part 66
aircraft maintenance licence category/subcategory must be
passed within a 5 year time period of passing the first
module, except in the case specified in paragraph 1.12.
1.12 The 5 year time period specified in paragraph 1.11

does not apply to those modules which are common to
more than one part 66 aircraft maintenance licence
category or subcategory and which were previously
passed as part of another such category or subcategory
now held on a licence.
Appendix 2 CAA, Denmark 121 JAA Question bank not mentioned. The possible development of a
Clarification needed for access to question bank. central examination databank
is not relevant to the present
consultation.
Appendix 2, 3 LBA 055 In these appendices “airships with aerodynamic lift” shall be Airships are not covered by
and 4 added (see comment to Appendix 1). Part-66.
This type of aircraft is part of Part 66 Subpart A licences. Text not changed.
37

Ref.
Appendix 3 CAA, UK 118 Amend table to reduce complexity. Show only one Category Cat C levels are not the same
C column as levels are the same in all cases. in all cases (e.g. turbine
aeroplane vs. piston
helicopter).
Text not changed.
Appendix 3 Wideroe, Norway 028 ATA 26, Fire Protection should be Level 3 for B2 as this is an (a) Fire protection is a B1 task.
(2)Type Training electronic system.
Standard ATA 28, Fuel should be Level 2 for B2 as a large portion of it (b) Fuel systems for B2
is Electrical/Electronic. changed to level 2.
In the portion of Turbine Engine the FADEC Level 3 is not
logical without a certain knowledge level of the rest of the (c) PEC added.
engine.
In the Propeller section I miss Propeller Electronic control
(PEC)
The different ATA`S and level for B2 needs a careful review.
Appendix 3 CAA, Denmark 121 ATA 104 used as a reference, own EU standard should be Comment noted. No action
developed. required.
An adoption from ATA 104 used in Appendix for type
training.
Guidance to Part 66 still refers to ATA 104 levels.
Appendix 3 CAA, Denmark 121 Practical training element must reflect the task as given in Comment noted, but no clear
Maintenance Manual and other relevant manuals. proposal made.
It should be a clear guidance for what is needed on the No text change.
practical side as this training is a training standard for the
certifying staff knowledge and a standard for type rating in
the license. Type training has become a theoretical course
with little weight on the minimum practical training needed.
This training should at least reflect the task given in the
Maintenance Manual why the word in 2.2(a) if required is to
open.
The examination standard given in (3) for type training
examination must include an acceptance of the quality of the
practical training by an assessment performed by dedicated
persons from Part 147, Part 145 or Competent authority.
Clarification needed for, that practical type training must
reflect the tasks given in the Maintenance Manual and this
covers functional test of engines and systems as well.
The practical training must be examined by an assessment,
ensure safe certification given in part 66 Appendix 3, (2.2)
not specific enough.
A certificate of recognition must reflect if full training is not
given, as an example if functional test not part of the training.
This could lead to a lower level and flight safety could be
affected. (different culture for type training to day not
exposed in certificate of recognition).
An addition to the relevant categories could solve the
problem. This addition could cover specialist training as:
Engine run, NDT based on EN standard, boroscope
38

Ref.
inspections, taxi, compass swing etc.
Appendix 3 CAA, Finland 157 There should be guidelines in the appendix III, that help to This is covered by the AMC.
define the duration of practical training (OJT), that is needed
after completion of type training course before the type rating
can be granted. Guidelines inserted only in the AMC are not
legally binding.
Appendix 3 DGAC, France 162 I – Reference to usual ATA references would be very useful I - Editorial: ATA references which are I - ATA references are not
II – Type training at T2 level for category B2 personnel commonly used will help better understand used on all aircraft types.
should be at level 1 as for training at T4 level for category C certifying staff qualifications and associated II - B2 training is for the B2
personnel privileges. needs and not for the future C
III – Paragraph (1) of chapter (3) – Type training examination II - Implementation problem: The first type needs.
standard – should be modified as follows: training for category C shall be a type III - Text is based upon
“(1) Format of the examination is of the multiple-choice type. training T1 or T2. Level of T1 / T2 type existing JAA material (TGL
Each multiple choice question must have 3 alternative training is higher than T4 type training level. 40), itself established on the
answers of which only one must be the correct answer. The As a B2 licence holder can access to a C basis of European
time for answering is based upon a nominal average of 90 licence, it’s necessary for B2 candidate to maintenance training
seconds per question.” cover all subject at least at level 1. organisations experience.
III – Implementation problem: The average of
90 seconds is more appropriate for type Text not changed.
training examination rather than 75 seconds
for level 1 and 2, and 120 seconds for level 3
because ATA 104 level defines the
objectives and not the difficulties level.
Appendix 3 (3) EAMTC working group 026 Intermission (3) statement: „...minimum of 4 question per This requirement drives the total amount of 4 questions changed to 2
Type Training syllabus subject.“ questions necessary to ridiculous levels. questions.
Examination Delete this part of the sentence. Example: For a Cat C a Level 1 course is
Standard required (average duration 5 days).
Questions 4 x 51 subjects = 204 questions
for a Level 1 course. 75 seconds per
question makes 15300 sec which are 255
minutes or 4.25 hours. Under the line it will
take a whole day of testing for a 5 or less
day course.
Appendix 3 (3) EAMTC working group 026 Training syllabus matrix Decreasing number of questions. EAMTC Number of questions reduced
Type Training A grouping of subject titles must be possible (same way as Working Group has evaluated that (see above).
Examination introduction module). approximately one question per instruction
Standard Proposal for subject groups beside the intro-module: hour reflects the present European industry
· module structure standard. There is no need for a change. In
· module airframe/avionics respect to that it must be possible to “group”
· module turbine engine certain subjects.
· module piston engine
· module propeller/rotor
· module additional engine systems
39

Ref.
Example:
Above the turbine engine subjects are 21 x 4 questions
minimum = 84 questions (2.8 hours in a level 3 course)
Turbine engine subjects grouped: Round about 25 hours

instruction = 25 questions for the whole engine ( 50 min. for
level 3 and 30 min. for level 1).
Appendix 3 (3) EAMTC working group 026 Training syllabus matrix: Certain training objectives are Rotors are included. Text not
Type Training missing. For example rotors for B1.3 and B1.4 are missing changed.
Examination
Standard
Appendix 3 (3) EAMTC working group 026 Training syllabus matrix. All subjects in the matrix are from The table includes type
Type Training basic training, but this text is dealing with type training. The training, not basic training
Examination intention to standardise independent from American subjects.
Standard specifications (here: ATA 104) is understood but highly The table would be too
counterproductive for the global acting aviation community. complex with all ATA
All documents used in manufacturing, operation, references.
maintenance and overhaul as well as Training (!) are Text not changed.
structured according to this specification. In the light of
modern – to a high degree very complex – aircraft systems,
which also refer to this specification, the selected approach
may jeopardize safety! We must stay with the ATA-chapters
for training (and other) purposes
Appendix 3 (3) EAMTC working group 026 Training syllabus matrix For future aircraft they will reflect the aircraft Text changed to open to
Type Training Appearance of new systems or ATA-chapters such as breakdown and in respect to that have to be possibility to address new
Examination · Cabin Systems ATA 44 taken into account for training needs, training technologies.
Standard · Information Systems ATA 46 manuals and tests.
· Cargo and Accessory Compartments ATA 50
These ATA-chapters must also be part of the matrix.
Appendix 3 (3) EAMTC working group 026 Training syllabus matrix. Engine condition monitoring should Certifying staff do perform
Type Training be addressed in the intro-module only. Monitoring is not engine monitoring (e.g. during
Examination performed by maintenance personnel (certifying staff) but by ground run). Engineering staff
Standard engineering staff! perform engine trend
monitoring.
Text not changed.
Appendix 3 (3) EAMTC working group 026 Training syllabus matrix. Engine run up should not form part Engine run up not in. No
Type Training of a B1 course. Run up is always specialized training (level change required.
Examination 4) followed by a special authorization
Standard
Appendix 3 (3) Lufthansa Technik 037 Training syllabus matrix: Certain training objectives are Rotors are included.
Type Training Germany missing Text not changed.
Examination For example rotors for B1.3 and B1.4 are missing
Standard
Appendix 3 (3) Airbus MTO 015 (1) Format of the examination is of the multiple-choice type. As long as there is not a common data-base Existing JAR 66 requirement.
Type training Each multiple choice question must have 3 alternative for type training examination the idea of Text not changed.
40

Ref.
examination answers of which only one must be the correct answer. The minimum should be acceptable.
standards time for answering is based upon a nominal average of 120
seconds per level 3 question and 75 seconds per level 1 or 2
question.
To Add minimum before 3 alternative answers
Appendix 3 (3) Airbus MTO 015 (3) The number of questions must be at least 1 question per Number of questions reduced
Type training hour of instruction subject to a minimum of 4 questions per to 2 per subject.
examination Syllabus subject. The competent authority of the Member
standards State will assess number and level of questions on a
sampling basis when approving the course.
To replace subject: to module (one module can be one ATA

or a group of ATA Ex: structure)
Appendix 3 §2 P. Nocaudie, Flight 005 In the Turbine Engine list, "Engine Controls" ( ATA chapter Engine controls added.
(Type training Safety 76) is not listed.
standard)
Appendix 3 para Airbus MTO 015 (1) Type training levels. Course objectives: Upon completion To take into account the “difference training” Agreed.
1 of the course, the student will be able to identify safety Text changed.
precautions related to the airframe, its systems and
powerplant
Change the format to:

Course objectives: Upon completion of the course, the
student will be able to :
1) identify safety precautions related to the airframe, its
systems and powerplant
2)……
Appendix 3, (2) Airbus MTO 015 Change the existing table to the following table (See To deal with ATA chapters and to regroup Proposed table is incomplete
Type training Attachment #1 Airbus) some subjects. and therefore cannot be used.
standard, (2-1) It does not cover all aircraft.
Theoretical Text not changed.
element
Appendix 4 CAA, UK 118 Third paragraph – editorial error “50% of the applicant has”. Agreed.
Text changed.
Suggested text:
“50% for an applicant that has completed.”.
Appendix 4 Wideroe, Norway 028 The experience requirement will be reduced by 50% if the Agreed.
Experience applicant has completed………(Typing error?) Text changed.
requirements
Appendix 4 ERA 079 The first line of this title uses the phrase “An Part 66 Aircraft Agreed.
Title on page Maintenance Licence”. This should be amended to read “A Text changed.
59/70 Part 66 Aircraft Maintenance Licence”.
Appendix 4 ERA 079 The phrase “reduced by 50% of the applicant” should be Agreed.
Third sentence on replaced with “reduced by 50% if the applicant”. Text changed.
41

Ref.
page 59/70
Appendix 4 Air France 086 As defined in the JAR 66 the additional experience requirement Note in line with JAR 66 Agreed.
for extending a B1.1 subcategory to an existing B2 category Text changed
Part 66 licence is the same as for extending a B2 category to
an existing B1.1 subcategory : in both situations the
requirement is 1 year
Appendix 4 CAA, UK 118 The experience requirements are inconsistent. For licence Agreed.
issue, 66.30 (d) requires only 1 years recent experience on Text changed.
aircraft of the category/sub-category for which the licence is
sought. However Appendix 4 in some cases requires a
greater period of experience on aircraft of the category/sub-
category to extend a licence than that required for licence
issue. Eg, B2 to B1.1 or B1.3 requires 2 years experience.
Suggested text:
Amend Appendix 4 to reflect requirements of 66.A.30.
Appendix 4 DGAC, France 162 B1.3→B2: minimum experience should be 1 year, as it is the Part of the suggestions
case for B1.1 to B2. agreed. Some of the text
B1.1→A2 : minimum experience should be 6 months, as it is changed.
the case for B1.3 to A4
B1.2→B1.1:minimum experience should be 6 months, as it is
the case from B1.1→B1.2
B1.3→B1.1 : minimum experience should be reduced to 1
year
B1.3→B1.2 :minimum experience should be 2 years, as it is
the case for B1.2 to B1.3
B1.4→B1.2: minimum experience should be 1 year
B1.1→B1.3: minimum experience should be reduced to1
year
B1.4→B1.3: minimum experience should be 6 months, as it
is the case from B1.3 to B1.4
B1.1→B1.4: minimum experience should be 2 years, as it is
the case from B1.4 to B1.1
B1.2→B1.4: minimum experience should be 1 year
B2→B1.2 : minimum experience should be 2 years as it is
the case from B2 to B1.1
B2→B1.4: minimum experience should be 2 years as it is the
case from B2 to B1.3
Appendix 5 CAA, UK 118 Example licence. Suggest new “condition” to reflect 66.A.20 Agreed.
(b) 2. Text changed.
Suggested text:
6. The privileges of this licence may not be exercised
unless in the preceding two year period the holder has
had either 6 months of maintenance experience in
accordance with the privileges granted by the licence, or
met the provision for the issue of the appropriate
42

Ref.
privileges.
Comment: Text relating to the licence format is split

between 2 pages, separated by the example application Text changed
form and some information is duplicated.
Suggested text: Put text together.
Comment: Text changed

Licence format makes fraudulent entry easy where the
ratings are pre-printed.
Suggested text: Add ‘Where a pre-printed licence format is
used, any Category, sub-category or type rating box which
does not contain a rating entry shall be marked to show that
the rating is not held.’ The licence format proved
The licence layout is designed for manual production and compatible with computer
does not lend itself to computer generation. There should be generation.
more flexibility in arranging the entries where the licence Text not changed.
pages are computer generated. The format does not allow
technical limitations against individual categories or type
ratings to be shown clearly.
suggested text:
Delete sentence starting ‘Not withstanding this..’.
Delete from 2. ‘must be printed in the standardised form

shown but’
Alternatively, delete the specimen format and text in

Appendix 5 and specify that the licence format must follow
the ICAO Annex 1 specification.
The format follows the existing
Numbering of items on the licence document does not follow JAR 66 format. ICAO Annex 1
the standard required in ICAO Annex 1 (Chapter 5 format is not a requirement.
Specification for Personnel Licences). Part-66 licence content is in
compliance with ICAO Annex
1.
Suggested text: Text not changed.
1.2 Change numbering as follows:
1.3 III Licence number

IV Name of Holder
IV a Date of Birth
43

Ref.
X Signature of Issuing Officer
XI Seal or Stamp of issuing authority
Change all other numbers to Roman numerals
Add XII before (Sub) Categories & before Type Ratings

Add IX before Conditions
Add XIII before Limitations
Appendix 5 LBA 055 1. change “variation/continuity” in the headlines on both 1. Agreed.

pages to “amendment/renewal” Text changed.
This wording is used in the Part 66 Section A and B.
2. change “Part-145 Approval” to “Part 145/Part M Approval”
Organisations which are approved in accordance with Part M 2. Agreed.
employ Part 66 personnel, too. Text changed.
3. change “Part-145 AMO” to “Part 145 AMO / Part M AMO”
Organisations which are approved in accordance with Part M
employ Part 66 personnel, too. 3. Agreed.
Text changed.
Appendix 5, ERA 079 The third block entitled “AML Details” appears to have some Agreed.
EASA Form 19 text to the left of the block that does not fit. Is this an error Format changed.
and is there any missing text that should be included?
Appendix 5, ERA 079 The bottom signature block, paragraph 3 needs the Agreed.
EASA Form 19 “ deleting from the end of the sentence. Additionally the very Text changed.
last sentence uses the phrase “an Part 66 AML”. This should
be amended to read “A Part 66 AML”.
Appendix 5, ERA 079 Paragraph 4 of the Condition block needs the word “of” Agreed.
Part-66 AML inserting between the words “requirements” and “Part M”. Text changed.
44

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Part-66 Comment Response Document

Paragraph Organisation RD Proposed text / Comment Reason Response

Text not changed.

Paragraph Organisation RD Proposed text / Comment Reason Response

Paragraph Organisation RD Proposed text / Comment Reason Response

Paragraph Organisation RD Proposed text / Comment Reason Response

Paragraph Organisation RD Proposed text / Comment Reason Response

2. Change last sentence to: Category B1 includes the

3. A Category C aircraft maintenance licence permits

Note: The remainder of the text is duplication from 145.A.30

Paragraph Organisation RD Proposed text / Comment Reason Response

2. A category B1 aircraft maintenance licence shall qualify

3. A category B2 aircraft maintenance licence shall qualify

Paragraph Organisation RD Proposed text / Comment Reason Response

Paragraph Organisation RD Proposed text / Comment Reason Response

Paragraph Organisation RD Proposed text / Comment Reason Response

(c) “Applicants for Category C must demonstrate that

Paragraph Organisation RD Proposed text / Comment Reason Response

66.A.30 GAMTA 151 Proposed change to the

Paragraph Organisation RD Proposed text / Comment Reason Response

Paragraph Organisation RD Proposed text / Comment Reason Response

66.A.30(a)(3) (iii) CAA, UK 118

(e) Insert - .... shall be accepted by competent authority......

Requirement for it to be non-aviation discriminates against

Paragraph Organisation RD Proposed text / Comment Reason Response

Paragraph Organisation RD Proposed text / Comment Reason Response

Paragraph Organisation RD Proposed text / Comment Reason Response

66.A.40 LFV, Sweden 105 Missprint in last part of (a). Agreed.

66.A.40 The renewal of the aircraft maintenance licence

(a) “The aircraft maintenance licence becomes invalid

Paragraph Organisation RD Proposed text / Comment Reason Response

66.A.45 LFV, Sweden 105 (g) This is a new requirement that

Paragraph Organisation RD Proposed text / Comment Reason Response

“The training shall include practical hands on training and

To delete one of those paragraphs.

Paragraph Organisation RD Proposed text / Comment Reason Response

(a) “The holder of a Category A aircraft

66.A.45(a) CAA, UK 118 (a) Duplication of para 2. Text changed.

Paragraph Organisation RD Proposed text / Comment Reason Response

Paragraph Organisation RD Proposed text / Comment Reason Response

NOTE: In case of difference training, the difference type

NOTE: In case of difference training, the difference type

Paragraph Organisation RD Proposed text / Comment Reason Response

Example 2: Piper aircraft and Cessna aircraft and Mooney

Paragraph Organisation RD Proposed text / Comment Reason Response

(H) “Notwithstanding paragraph (C), ratings on

Paragraph Organisation RD Proposed text / Comment Reason Response

Paragraph Organisation RD Proposed text / Comment Reason Response

Paragraph Organisation RD Proposed text / Comment Reason Response

Paragraph Organisation RD Proposed text / Comment Reason Response

66.A.80 ERA 079 This paragraph makes reference to component certifying. It

Paragraph Organisation RD Proposed text / Comment Reason Response

Also, we as ECAR 145 organisation feel no need for

Paragraph Organisation RD Proposed text / Comment Reason Response

5. Change ‘authoritys’ to ‘authorities’ (typographical error).

and (e) to include 8 and 9.

Note of caution: This may contradict the data protection act.

Paragraph Organisation RD Proposed text / Comment Reason Response