Maintenance Check Flights

[soloviev]

Hi. EASA has issued regulation 2019/1384 introducing rules for maintenance check flights.
A lot of doubts are there from people how to deal with the subject.
First of all many are convinced that the procedure for the MCF applies both to AOC and to NCC.
To me it's only applicable to AOC holders, but I admit that the way the regulation is written does not help understanding.
Talked to the authority: lost in space.
Does anyone have any experience?
Thanks

[YOUNGBUCK]

I would interpret the MCF requirements defined for the ‘Operator’ being applicable to both AOC and NCC.

Whilst I cannot qualify the origin of the regulation, I would use the thinking that the regulation was wrote with the complexity and size of the aircraft in mind.
An identical aircraft could be owned / operated by both NCC & AOC but would be subject to required maintenance standards.

I have been involved in AOC MCF directly but not NCC, although I know of privately operated jets undergoing MCF I am unsure if regulated or by owner request.

[soloviev]

Hi Youngbuck, thanks for your involvement.
I do agree with you by principle, but strictly talking about requirements, I shall apply what is required by the regulation.
If my complex aircraft is not under AOC, my understanding is that SPO.SPEC.MCF is not required.
Different story is: should I have a procedure because MCF are sensitive?
So far, I shall not be required to comply with SPO.SPEC.MCF is not under AOC.

[YOUNGBUCK]

Originally Posted by soloviev

Hi Youngbuck, thanks for your involvement.
I do agree with you by principle, but strictly talking about requirements, I shall apply what is required by the regulation.
If my complex aircraft is not under AOC, my understanding is that SPO.SPEC.MCF is not required.
Different story is: should I have a procedure because MCF are sensitive?
So far, I shall not be required to comply with SPO.SPEC.MCF is not under AOC.

Hi, As your original post, I agree in your justification but not as clear as it should be!
NCC is designed so the rules of AOC are applied proportionately, but a lot of what is required to be complied with above the basic is on a case by case dependant on the operation, guided from the NAA.
Does the NAA have a take on this that you know of?
Has the NCC operator's OPS manual included anything for MCF?

[Rigga]

Surprised by the CAA response - they produced this a few years ago - but their response indicates it may now be out of kilter with EASA!

CAP1038: CAA Check Flight Handbook

[soloviev]

Thanks Youngbuck.
Authorities (2-3 of them I'm dealing with) simply lost in space.
I've received no clear answer based on a specific point of the regulation, only something like "it's better..." or "why not...".

[YOUNGBUCK]

From this, I think by asking the question you will struggle to get an answer from the NAA to confirm that a MCF is not required if there is option for it to be carried out. This effectively rules their 'get out of jail' card if you had in writing an interpretation of the regulation which deemed it not to be necessary (the MCF) and then it was later found to be non compliant.
This highlights a greater problem across all areas of EASA regulation when it comes to the poor quality of service from NAA's. From experience dealing with the UK CAA and lack of experienced subject matter experts their seems to be hesitation in actually confirming / backing up the rules in which they are enforcing.
Inconsistency across member states also adds to the problem.

Ultimately, if you are acting diligently with regards to compliance and are able to justify procedures which have been submitted/approved IAW the regulation, you can go back to the NAA whom approved the particular manual (CAMME etc.) - just my take on it.
Maybe then they will advise otherwise.

[Rigga]

Originally Posted by YOUNGBUCK

.... if you are acting diligently with regards to compliance and are able to justify procedures which have been submitted/approved IAW the regulation, you can go back to the NAA whom approved the particular manual (CAMME etc.) - just my take on it.
Maybe then they will advise otherwise.

The above mentioned method works. State clearly to the NAA your PROPOSAL to change the MOE/CAME and itemise the process you want to place in your exposition...and sit back. If it is reasonable and within the Regs they will accept it - if its not acceptable your surveyor WILL contact you...