NPA 2024-06

European Union Aviation Safety Agency

Notice of Proposed Amendment 2024-06(B)

in accordance with Article 6 of MB Decision 01-2022

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Proposed AMC and GM

to the initial airworthiness requirements

for UAS subject to certification

European Union Aviation Safety Agency NPA 2024-06(B)

Proposed AMC and GM to the initial airworthiness requirements

for UAS subject to certification

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Table of contents

Proposed amendments ........................................................................................................................... 3

GM 21.A.35(b2) Flight Tests.................................................................................................................... 3

GM1 21.A.35 (f)(21)(i) Flight Tests .......................................................................................................... 3

GM2 21.A.35(f)(1)(i) Flight Tests ............................................................................................................. 4

GM 21.A.35(f)(1)(ii) Flight Tests .............................................................................................................. 8

GM 21.A.35(f)(2) Flight Tests .................................................................................................................. 8

AMC1 21.A.308(a);(b) Eligibility of a component for installation in a CMU ......................................... 11

GM1 21.A.308(b) CMU component that is part of a higher-level assembly......................................... 12

European Union Aviation Safety Agency NPA 2024-06(B)

Proposed AMC and GM to the initial airworthiness requirements

for UAS subject to certification

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Proposed amendments

The amendments are arranged to show deleted, new and unchanged text as follows:

— deleted text is struck through;

— new text is highlighted in blue;

— an ellipsis ‘[…]’ indicates that the rest of the text is unchanged.

Where necessary, the rationale is provided in italics.

GM 21.A.35(b)(2) Flight Tests

OBJECTIVE AND CONTENT OF THE FUNCTION AND RELIABILITY (F&R) FLIGHT TESTING

1. OBJECTIVE

The objective of this the F&R flight testing is to expose the aircraft to athe variety of uses, including

training and operational suitability flights, if applicable, which are representative of the operations,

that are likely to be conducted occur when the aircraft, the UAS or the CMU is in routine service. This

testing should provide an the assurance that the aircraft, the UAS or the CMU it performs its intended

functions to the standard required for certification, and should continue to do so in service.

[…]

GM1 21.A.35(f)(21)(i) Flight Tests

FLYING TIME FOR THE FUNCTION AND RELIABILITY (F&R) FLIGHT TESTING

For aeroplanes and helicopters, Aall flying carried out on an aircraft that is not significantly different

from the final type design may count towards the 150-hours airframe flight time required by point

21.A.35(f)(21)(i).

For aircraft with novel design features not widely used in industry at the time of application for the

issue of a type certificate, additional flight hours and/or specific tests with integration benches may

be required to confirm the adequate function and reliability of the aircraft. Such features may include

among others, for example, novel propulsion systems, and fly-by-wire control incorporating new

technologies or combined lift-thrust-control functions. The overall duration of the F&R flight testing

required should, however, not exceed 300 hours.

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GM2 21.A.35(f)(1)(i) Flight Tests

DETERMINATION OF THE REQUIRED AMOUNT OF FUNCTION AND RELIABILITY (F&R) FLIGHT TESTING HOURS AND OPERATION HOURS FOR VTOL-CAPABLE AIRCRAFT

(a) VTOL-CAPABLE AIRCRAFT CERTIFIED IN THE CATEGORY ‘ENHANCED’

(1) Duration

The overall duration of the F&R flight testing should not be less than 150 flight hours.

The following conditions apply:

(i) If the VTOL-capable aircraft incorporates any of the following, it should be subject

to a further 150 hours of operation in addition to the minimum 150 flight hours of

F&R flight testing:

(A) new technologies with safety-critical functions; and/or

(B) new engines of a type not previously used in type-certified aircraft.

(ii) Integration benches may be used to accrue these additional 150 hours of operation

of point 1 following agreement with EASA. If integration benches are used, the

same benches and test specimens should be used throughout the tests.

(iii) The duration of single flights should be representative of the intended operations

of the aircraft, aligned with the aircraft’s concept of operations and the applicable

certification limitations and conditions.

(iv) The minimum number of energy refilling/consumption cycles of the energy storage

system (ESS) to be accumulated during F&R flight testing should be agreed with

EASA, if applicable.

(2) Aircraft configuration and use

The use of aircraft and their configuration for F&R flight testing should meet all the

following conditions:

(i) At least 50 % of the required flight hours should be performed with the same

aircraft (referred to as ‘main aircraft’ in the following text), and its configuration

should be close to the final type design. Acceptable deviations from the final type

design configuration should be described, justified, and agreed with EASA.

(ii) Other aircraft may be used for the remaining portion of the F&R testing if their

configuration is close to the final type design. Acceptable deviations from the final

type design configuration should be described, justified, and agreed with EASA.

(iii) If ESSs are swapped during normal operation, the number of different sets of ESSs

for a particular testing and the initial state of health (SoH) or degradation

condition, as and if applicable, for each ESS set should be agreed with EASA. The

main aircraft should be operated with ESSs that are replaced only as per the

proposed ICAs. If the ESSs are replaced before reaching their end of life, the

replacement ESS should present similar ageing or degradation.

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(iv) Not more than 30 % of the required flight hours may correspond to flights for

development or flights used to demonstrate compliance with the applicable

requirements of the certification basis and engine reliability and durability

requirements. These flights should be agreed with EASA on a case-by-case basis.

Note: Engine endurance testing is typically carried out on a specific engine test

bed, thus not fully representative of the aircraft integration and operation

use. Therefore, it is usually considered inadequate with respect to point (iv)

above.

(3) F&R flight test programme

The F&R flight test programme should include:

(i) a continuous operation schedule for the main aircraft described in point (a)(2)(i),

as though it were in service, which is aligned with the aircraft’s concept of

operations and the applicable certification limitations and conditions;

(ii) both routine operations and simulation of selected abnormal operating conditions;

(iii) a range of representative ambient operating conditions and vertiports;

(iv) the proposed ICAs’ line maintenance activities, and any maintenance tasks

delegated to the pilot;

(v) information about the flight crew composition, which should include, where

possible, the participation of an operator’s own flying and maintenance crews.

(b) VTOL-CAPABLE AIRCRFAT CERTIFIED IN THE CATEGORY ‘BASIC’

(1) Duration

The overall duration of the F&R flight testing should not be shorter than 150 flight hours,

with the following conditions:

(i) Reserved.

(ii) Reserved.

(iii) The duration of the single flights should be representative of the intended

operations of the aircraft, aligned with the aircraft’s concept of operations and the

applicable certification limitations and conditions.

(iv) The minimum number of energy refilling/consumption cycles of the energy storage

system (ESS) to be accumulated during the F&R flight testing should be agreed with

EASA, if applicable.

(2) Aircraft configuration and use

The use of aircraft and their configuration for F&R flight testing should meet the following

conditions:

(i) At least 50 % of the required flight hours should be performed with the same

aircraft (referred to as ‘main aircraft’ in the following text) and its configuration

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should be close to the final type design. Acceptable deviations from the final type

design configuration should be described, justified, and agreed with EASA.

(ii) Other aircraft may be used for the remaining portion of the F&R flight testing if

their configuration is close to the final type design. Acceptable deviations from the

final type design configuration should be described, justified, and agreed with

EASA.

(iii) Not more than 50 % of the required flight hours may correspond to flights for

development or used to demonstrate compliance with applicable SC-VTOL

requirements and engine reliability and durability requirements.

Note: Engine endurance testing is typically carried out on specific engine test bed,

thus not fully representative of the aircraft integration and operation usage.

Therefore, it is usually considered inadequate with respect to point (iii)

above.

(3) F&R flight test programme

The F&R flight test programme should include:

(i) a continuous operation schedule for the main aircraft as described in point (b)(2)(i),

as though it were in service, which is aligned with the aircraft’s concept of

operations and the applicable certification limitations and conditions;

(ii) both routine operations and simulation of selected abnormal conditions, according

to their probability estimated in certification;

(iii) a range of representative ambient operating conditions and vertiports;

(iv) the proposed ICAs’ first line maintenance activities, and any maintenance tasks

delegated to the pilot;

(v) information about the flight crew composition, which should include, where

possible, operator’s own flying and maintenance crews.

(c) F&R Test Report

The F&R test report should provide, as a minimum, an accurate and comprehensive record of:

(1) the actual duration of the F&R test campaign, following point (a)(1) or (b)(1) as per the

applicable aircraft category;

(2) the actual aircraft used and their configuration, following point (a)(2) or (b)(2) as per the

applicable aircraft category, including:

(i) the justification for any differences in configuration from the type-certification

standard;

(ii) if different sets of ESSs were used: their number, their initial and final SoH or

degradation condition, as and if applicable;

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(iii) the line maintenance activities performed on each aircraft during the test

campaign, including the date and the associated flight, as well as any additional

maintenance activity;

(3) the corresponding flight test programme, by reference, prepared following point (a)(3)

or (b)(3) as per the applicable aircraft category;

(4) a log of the individual flights performed, identifying:

(i) the date and time;

(ii) the aircraft used;

(iii) the ESS present when different sets are used in the F&R testing, including the initial

and final state of charge (SoC) or energy content and SoH;

(iv) the flight crew;

(v) the flight time;

(vi) the purpose of the flight (e.g. compliance with certification requirement

VTOL.XXXX);

(vii) any relevant maintenance activities performed before or after the flight, as per the

prepared ICAs, as well as any additional maintenance;

(viii) any other actions performed on the aircraft;

(ix) any malfunction, anomaly, or any other discrepancy from the expected behaviour

of the aircraft and its systems and components;

(x) other data which could be of technical interest (e.g. mass and CG);

(5) if integration benches are used in accordance with point (a)(1)(ii):

(i) the detailed description of the bench configuration;

(ii) the individual bench operation(s), including the dates and times of start and stop;

(iii) the maintenance activities performed as per the prepared ICAs as well as any

additional maintenance carried out during the test campaign;

(iv) any other actions performed on the bench;

(v) any malfunction, anomaly, or any other discrepancy from the expected behaviour

during the bench operation.

Finally, the F&R test report should analyse the above records and assess the need to

introduce modifications to the design or procedures (AFM, ICAs).

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GM 21.A.35(f)(1)(ii) Flight Tests

FLYING TIME FOR THE FUNCTION AND RELIABILITY (F&R) TESTING All flying carried out with engines and associated systems not significantly different from the final type-certificate standard may count towards the 300-hours airframe flight time required by point 21.A.35(f)(1)(ii). […]

GM1 21.A.35(f)(2) Flight Tests

DETERMINATION OF REQUIRED AMOUNT OF FUNCTION AND RELIABILITY (F&R) FLIGHT TESTING HOURS FOR UAS AND CMUs

(a) GENERAL

The following guidance may evolve with further experience gathered in type certification of UAS

and CMUs.

EASA will specify the necessary amount of flight hours, integration bench tests or other relevant

methods to determine the appropriate function and reliability of the type design, including its

CMU as applicable, considering the respective concept of operations.

Specific consideration should be given to the UAS configuration and any existing data providing

substantiation of its function and reliability. If the design includes systems already in use in

other type-certified aircraft of a similar concept of operations and certification standard, the

respective reduction of the flight hours identified hereafter could be considered.

The use of integration test benches that appropriately reflect the intention of an operationally representative exposure of a UA and CMU may be agreed with EASA to complement the flight hours by hours of operation, in particular when the flight endurance is either very limited (e.g. shorter than 1 hour) or extremely long (e.g. several days).

(b) TYPE CERTIFICATION OF A CMU

It is possible to type-certify a CMU separately from a UA. The appropriate function and reliability

need to be demonstrated also for the CMU. Aspects like the qualification with a particular UA,

the operation of one UA per CMU or several UA per one CMU, handover of a UA between

different CMU, etc., should be considered when determining the required flight hours to

confirm the CMU’s function and reliability.

A CMU might require portions of the F&R flight testing to employ specific technologies or a

combination of technologies to appropriately simulate and record the operational environment

while demonstrating its function and reliability. This might, for example, encompass simulation

of the UA, simulation of the C2 link, simulation of air traffic, etc., if adequate. However, the

amount of the actual F&R flight test hours with a UA would need to be specified by EASA.

If a single CMU is utilised to control several UA, the minimum amount of actual flight hours with

relevant UA dedicated to demonstrating this capability should be agreed with EASA.

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Portions of the F&R demonstration may be conducted on integration benches or by simulation, as agreed with EASA.

(c) UAS OPERATED IN THE ‘CERTIFIED’ CATEGORY

For UAS that require a type certificate for the ‘certified’ category of operations, the following

approach, derived from aircraft certified with pilot on board, should be applied:

(1) Duration

The overall duration of the F&R flight testing should not be shorter than 150 flight hours.

The following conditions apply:

(i) If the UAS incorporates any of the following, it should be subject to a further

150 hours of operation in addition to the minimum 150 flight hours of F&R flight

testing:

(A) new technologies with safety-critical functions; and/or

(B) new engines of a type not previously used in a type-certified aircraft.

(ii) Integration benches may be used to accrue these additional 150 hours of operation

in agreement with EASA. If integration benches are used, the same benches and

test specimens should be used throughout the tests.

(iii) The duration and distance of the single flights should be representative of the

intended operations of the UAS, aligned with the UAS concept of operations and

the applicable certification limitations and conditions.

(iv) The minimum number of energy refilling/consumption cycles of the energy storage

system (ESS) to be accumulated during the F&R flight testing should be agreed with

EASA, if applicable.

(2) UAS configuration and use

The use of UAS and their configuration for the F&R flight testing should meet the

following conditions:

(i) At least 50 % of the overall flight time should be performed with the same UAS

(referred to as ‘main UAS’ in the following text), and its configuration should be

close to the final type design. Acceptable deviations from the final type design

configuration should be described, justified, and agreed with EASA.

(ii) Other UAS may be used for the remaining portion of the F&R testing if their

configuration is close to the final type design. Acceptable deviations from the final

type design configuration should be described, justified, and agreed with EASA.

(iii) If ESSs are swapped during normal operation, the number of different sets of ESSs

for this testing and the initial state of health (SoH) or degradation condition, as and

if applicable, for each set should be agreed with EASA. The main UAS should be

operated with ESSs that are replaced only as per the proposed ICAs. If the ESSs are

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replaced before reaching their end of life, the replacement ESS should present a

similar ageing or degradation.

(iv) Not more than 30 % of the overall flight time may correspond to flights for

development or used to demonstrate compliance with applicable requirements of

the certification basis and engine reliability and durability requirements. These

flights should be agreed with EASA on a case-by-case basis.

Note: Engine endurance testing is considered inadequate with respect to point (iv)

above, since it requires a specific flight test set-up (always at the engine

limits) that might not be achievable during F&R flight testing.

(3) F&R flight test programme

The F&R flight test programme should include:

(i) a continuous operation schedule for the main UAS described in point (c)(2)(i), as

though it were in service, which is aligned with the UAS concept of operations and

the applicable certification limitations and conditions;

(ii) both routine operations and simulation of selected abnormal operating conditions;

(iii) a range of representative ambient operating conditions and airports, heliports,

vertiports, airfields or operating sites, as applicable;

(iv) the proposed ICAs’ line maintenance activities, and any maintenance tasks

delegated to the UAS crew;

(v) information about the UAS crew composition, which should include, where

possible, operator’s own flying and maintenance crews.

(d) UAS OPERATED IN THE ‘SPECIFIC’ CATEGORY REQUIRING A TYPE CERTIFICATE (AS PER ARTICLE 40 OF REGULATION (EU) No 945/2019)

For UAS operated in the ‘specific’ category requiring a type certificate, the guidance provided

in Section ERROR! REFERENCE SOURCE NOT FOUND.’ should be used as far as applicable.

A shorter duration of the F&R flight testing may be agreed with EASA considering the complexity

of the design of the UAS and the risk of the operation.

Note: A minimum amount of 50 hours for specific assurance and integrity level (SAIL)1 V,

100 hours for SAIL VI.

AMC1 21.A.308(a);(b) Eligibility of a component for installation in a CMU

IDENTIFICATION OF CMU COMPONENTS THAT ARE CRITICAL, AND MEANING OF ‘CRITICAL’

1 As defined in the AMC to Article 11 of Commission Implementing Regulation (EU) 2019/947.

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CMU components that are identified as critical in accordance with point 21.A.308(a) should be listed

in the ICAs.

For the purpose of point 21.A.308(a) and (b), when it is mentioned that a CMU component ‘is critical

for the intended UAS operation’, it means that:

(a) any failure, malfunction or defect of that CMU component may result in a hazardous or

catastrophic failure condition; or

(b) the compromised protection from intentional unauthorised electronic interaction (IUEI) due to

a non-conformity of that CMU component may result in a threat condition that has a potentially

hazardous or catastrophic safety effect on the intended UAS operation.

When assessing the safety effect or threat condition of a CMU component identified in point

21.A.308(a) and (b), the design approval holder (DAH) may assume that the installer will conduct any

specific verification activities on the component or release documentation, as identified in the ICAs,

before installing it in the CMU.

GM1 21.A.308(a);(b) Eligibility of a component for installation in a CMU

Examples:

(a) A CMU uses a screen to display alerts to the flight crew. The malfunction of not alerting the

crew with the correct colour scheme may result in a hazardous or catastrophic failure condition.

To mitigate this risk, the design data may include detailed configuration settings and the ICAs

may contain instructions and specific verification activities with regard to the component. When

assessing the safety effect of the screen in accordance with point 21.A.308(a) and (b), the DAH

may assume that the installer will conduct those specific verification activities on the screen, as

identified in the ICAs, before installing it in the CMU and may determine that the component is

not critical.

(b) A CMU design includes a COTS component that connects two or more networks (e.g. a network

router connecting the CMU with different C2 links) that may result in a threat condition with a

hazardous safety effect. To mitigate this threat condition, the CMU design data may include the

deactivation or specific configuration of certain connectivity functions of that COTS component

to ensure protection against IUEI. When the installer of that component is able to verify that

the COTS device complies with the design data (e.g. deactivation or specific configuration) in

accordance with the DAH’s ICAs and does not compromise protection against IUEI, the DAH may

determine that the component is not critical.

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GM2 21.A.308(b) CMU component that is part of a higher-level assembly

An EASA Form 1 is not required for a CMU component when that component is an element of a higher-

level assembly for which an EASA Form 1 is not required.

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Notice of Proposed Amendment 2024-06(C)

in accordance with Article 6 of MB Decision 01-2022

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Proposed AMC and GM to the UAS Regulations

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Proposed AMC and GM to the UAS Regulations

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Table of contents

Proposed amendments ................................................................................................................ 3

GM1 ARTICLE 2(1) DEFINITIONS .................................................................................................... 3

UNMANNED AIRCRAFT SYSTEMS ............................................................................................................ 3

AMC1 ARTICLE 5 ‘SPECIFIC’ CATEGORY OF UAS OPERATIONS ........................................................ 3

TRANSPORT OF DANGEROUS GOODS IN THE ‘SPECIFIC’ CATEGORY...................................................... 3

GM1 ARTICLE 40(1)(A) REQUIREMENTS FOR UAS OPERATED IN THE ‘CERTIFIED’ AND ‘SPECIFIC’ CATEGORIES EXCEPT WHEN CONDUCTED UNDER A DECLARATION ...................................... 4

UA LIGHTER THAN AIR ............................................................................................................................ 4

GM1 ARTICLE 40(1A) REQUIREMENTS FOR UAS OPERATED IN THE ‘CERTIFIED’ AND ‘SPECIFIC’ CATEGORIES EXCEPT WHEN CONDUCTED UNDER A DECLARATION ...................................... 4

UAS SPECIFICALLY DESIGNED OR MODIFIED FOR RESEARCH, EXPERIMENTAL OR SCIENTIFIC PURPOSES, AND WHICH ARE LIKELY TO BE PRODUCED IN VERY LIMITED NUMBERS ................. 4

GM1 ARTICLE 40(2A) REQUIREMENTS FOR UAS OPERATED IN THE ‘CERTIFIED’ AND ‘SPECIFIC’ CATEGORIES EXCEPT WHEN CONDUCTED UNDER A DECLARATION ...................................... 5

COMPLIANCE WITH COMMISSION DELEGATED REGULATION (EU) 2024/1107 ..................................... 5

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Proposed amendments

The amendments are arranged as follows to show deleted, new, and unchanged:

— deleted text is struck through;

— new text is highlighted in blue;

— an ellipsis ‘[…]’ indicates that the rest of the text is unchanged.

Where necessary, the rationale is provided in italics.

GM1 Article 2(1) Definitions

UNMANNED AIRCRAFT SYSTEMS

Small balloons, often used during celebrations, and small free flight aircraft, often made of cardboard

or very light material, that do not pose any risk to people or manned aircraft are not required to

comply with Commission Implementing Regulation (EU) 2019/947.

AMC1 Article 5 ‘Specific’ category of UAS operations

TRANSPORT OF DANGEROUS GOODS IN THE ‘SPECIFIC’ CATEGORY

[…]

(b) The assessment of the operational risk of transporting dangerous goods should take into account the following:

(1) the risk that such goods pose to persons that are directly involved in their handling, to the environment, and to third parties and their properties;

(2) the hazard posed by the quantity and class of the dangerous goods;

(3) the characteristics of the container for the dangerous goods;

(4) the level of competence of those handling the dangerous goods; and

(5) the geographical area in which the flight will be operated.

Consumer commodities that pose a lower risk may be transported in the ‘specific’ category if they comply with the applicable dangerous goods regulations.

[…]

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GM1 Article 40(1)(a) Requirements for UAS operated in the ‘certified’ and ‘specific’ categories except when conducted under a declaration

UA LIGHTER THAN AIR

According to AMC1 to Article 11 (Rules for conducting an operational risk assessment) of Commission

Implementing Regulation (EU) 2019/947, UAS that have a maximum dimension greater than 3 metres,

when operated over assemblies of people, pose a high risk to third parties. In this case, the safety

objectives identified by the SORA are not enough to mitigate the risk, hence, the operation is classified

in the ‘certified’ category and requires the use of a UAS with a type certificate or a restricted type

certificate. However, the ground risk model used by the SORA was developed for UAS configurations

other than lighter than air and, for such configurations, the resulting ground risk class may be over-

conservative.

Therefore, operations conducted with UAS lighter than air, with a maximum dimension greater than

3 metres, are not necessarily classified in the ‘certified’ category. In this case, the applicant may

propose a dedicated risk assessment and identify the appropriate risk class. If the resulting SAIL of the

operation does not exceed VI, then the operation may be classified in the ‘specific’ category.

GM1 Article 40(1a) Requirements for UAS operated in the ‘certified’ and ‘specific’ categories except when conducted under a declaration

UAS SPECIFICALLY DESIGNED OR MODIFIED FOR RESEARCH, EXPERIMENTAL OR SCIENTIFIC PURPOSES, AND WHICH ARE LIKELY TO BE PRODUCED IN VERY LIMITED NUMBERS

Annex I to Regulation (EU) 2018/1139 (the Basic Regulation) lists the categories of manned aircraft

that are excluded from the applicability of that Regulation. The list includes in point (b) ‘(manned)

aircraft specifically designed or modified for research, experimental or scientific purposes, and likely

to be produced in very limited numbers’. The Basic Regulation recognises that the level of risk of

operations conducted with this type of aircraft is different compared to aircraft designed to conduct

commercial or non-commercial operations. The condition defined in the Basic Regulation refers

mostly to the fact that, being such manned aircraft designed only for research, experimental or

scientific purposes, they will be produced in very limited numbers. In this case, a Member State may

define the requirements appropriate to the UAS level of risk according to its national regulations.

Annex I to the Basic Regulation is not applicable to UAS since the UAS regulations are developed

following a risk-based approach. They allow competent authorities to identify the requirements

appropriate to the level of risk of UAS also when they are designed only for research, experimental or

scientific purposes.

In this case, Commission Implementing Regulation (EU) 2019/947 allows the identification of adequate

design requirements whose compliance, depending on the risk of the intended operation, may be

assessed without the need for a type certificate issued in accordance with Annex I (Part 21) to

Commission Regulation (EU) No 748/2012.

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Proposed AMC and GM to the UAS Regulations

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GM1 Article 40(2a) Requirements for UAS operated in the ‘certified’ and ‘specific’ categories except when conducted under a declaration

COMPLIANCE WITH COMMISSION DELEGATED REGULATION (EU) 2024/1107

When a UAS is intended to be used in an operation that may be classified in SAIL V or VI, then a type

certificate or a restricted type certificate issued in accordance with Commission Regulation (EU)

No 748/2012 is required, as well as compliance with Commission Regulation (EU) 2015/640 and

Commission Delegated Regulation (EU) 2024/1107. A UAS design organisation may, for business

reasons, decide to apply for a type certificate or a restricted type certificate issued in accordance with

Commission Regulation (EU) No 748/2012 even if the UAS is intended to be operated in operations

classified in SAIL IV. In this case, compliance with Commission Delegated Regulation (EU) 2024/1107

is not required unless the UA is subject to a (restricted) certificate of airworthiness ((R)CofA).

European Union Aviation Safety Agency

Notice of Proposed Amendment 2024-06(D)

in accordance with Article 6 of MB Decision 01-2022

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Proposed AMC and GM

to the continuing airworthiness requirements

for organisations

European Union Aviation Safety Agency NPA 2024-06(D)

Proposed AMC and GM to the continuing airworthiness requirements

for organisations

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Table of contents

Proposed amendments ................................................................................................................ 3

GM1 Article 1 .......................................................................................................................................... 3

GM1 ML.UAS.201(a) Responsibilities ..................................................................................................... 4

AMC1 ML.UAS.201(e)(1) Responsibilities ............................................................................................... 4

GM1 ML.UAS.201(e)(1) Responsibilities ................................................................................................. 5

GM1 ML.UAS.502(b) Maintenance of UA components .......................................................................... 6

GM1 ML.UAS.520(e) Installation and maintenance of CMU components ............................................. 6

AMC1 ML.UAS.801 Certification of UA maintenance ............................................................................. 6

GM1 ML.UAS.803(a) Certification of CMU maintenance ....................................................................... 7

AMC1 ML.UAS.805 Certification of CMU installation ............................................................................. 7

GM1 ML.UAS.805 Certification of CMU installation ............................................................................... 7

AMC1 ML.UAS.903 Airworthiness review process ................................................................................. 8

GM1 ML.UAS.903(g) Airworthiness review process ............................................................................... 8

AMC1 CAO.UAS.020 Scope of work and terms of approval ................................................................... 9

AMC1 CAO.UAS.025 Organisation manual ............................................................................................. 9

AMC1 CAO.UAS.025(b)(6) Organisation manual .................................................................................. 12

AMC1 CAO.UAS.035(e) Personnel requirements ................................................................................. 13

AMC2 CAO.UAS.035(e) Personnel requirements ................................................................................. 15

AMC1 CAO.UAS.040(b) Certifying staff ................................................................................................. 15

AMC2 CAO.UAS.040(b) Certifying staff ................................................................................................. 16

GM1 CAO.UAS.040(b) Certifying staff ................................................................................................... 17

AMC1 CAO.UAS.102(a) Protection of information and communication systems and data ................. 18

GM1 CAO.UAS.102 Protection of information and communication systems and data ....................... 19

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Proposed amendments

The amendments are arranged as follows to show deleted, new and unchanged text:

— deleted text is struck through;

— new text is highlighted in blue;

— an ellipsis ‘[…]’ indicates that the rest of the text is unchanged.

Where necessary, the rationale is provided in italics.

GM1 Article 1

APPLICABILITY OF THE CONTINUING AIRWORTHINESS REQUIREMENTS

As established in point (i) of Article 7(2a) of Commission Implementing Regulation (EU) 2019/947, a

UA must have an airworthiness certificate issued in accordance with Annex I (Part 21) to Commission

Regulation (EU) No 748/2012 when it is intended to be operated in the ‘specific’ category and the

related risk assessment demonstrates that the risk of the operation cannot be adequately mitigated

without the certification of the UAS, as defined in point 1(d) of Article 40 of Commission Delegated

Regulation (EU) 2019/945. Such operation is commonly referred to as ‘high risk’ (i.e. SAIL V to VI)

operation in the ‘specific’ category and must be conducted with a certified UAS.

The issuance of such airworthiness certificate in this case creates the need for the UAS to comply with

Commission Delegated Regulation (EU) 2024/1107 for its continuing airworthiness to be ensured

(i.e. Part-ML.UAS to be complied with, and the Part-CAO.UAS organisation to ensure carrying out the

associated tasks). Compliance with that Regulation is required as long as the airworthiness certificate

is not surrendered or revoked, regardless of the type of operation effectively conducted.

This means that even though the certified UAS conducts a lower-risk operation in the ‘specific’

category, if an airworthiness certificate has been obtained from the competent authority of the

Member State of registry, compliance with that Regulation is required.

On a voluntary basis, the owner/operator may decide to comply with that Regulation for UAS operated

in low-/medium-risk operations (i.e. SAIL I to IV) in the ‘specific’ category. The reason behind such a

decision could be to ensure a smooth transition when the operation shifts to ‘high-risk’, or simply

because the owner/operator wishes to adhere to higher continuing airworthiness standards. This may

be achieved by requesting, and obtaining, an airworthiness certificate issued in accordance with

Annex I (Part 21) to Commission Regulation (EU) No 748/2012, even though it is not required as per

point (i) of Article 7(2a) of Commission Implementing Regulation (EU) 2019/947. By doing so,

Commission Delegated Regulation (EU) 2024/1107 applies, and the relevant applicable requirements

must be complied with.

If the airworthiness certificate has been issued but the UAS is not (or no longer) used in ‘high-risk’

operations in the ‘specific’ category, the owner/operator may decide to surrender the airworthiness

certificate to avoid being required to fulfil the applicable requirements established by Commission

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Delegated Regulation (EU) 2024/1107. However, it should be noted that if a new airworthiness

certificate is requested after the previous one has been surrendered, an airworthiness review in

accordance with point ML.UAS.903 must be carried out.

GM1 ML.UAS.201(a) Responsibilities

ACCOUNTABILITY FOR THE CONTINUING AIRWORTHINESS OF THE UAS

To ensure the continuing airworthiness of the UAS, it is fundamental to determine the related

accountabilities. Point ML.UAS.201(a) indicates that the owner of the UA is accountable for the

continuing airworthiness of both the UA and the CMU(s) that is (are) used to operate that UA.

If a CMU is used to operate different UA of different owners, the UA owners are accountable for the

continuing airworthiness of the CMU to the extent the CMU applies to the owned UA.

The main obligation of the owner, as provided for in point ML.UAS.201(e), is to ensure that the tasks

related to the continuing airworthiness management of the UA, and of the CMU(s) used to operate

that UA, are carried out by an organisation approved in accordance with Annex II (Part-CAO.UAS) to

Commission Delegated Regulation (EU) 2024/1107.

AMC1 ML.UAS.201(e)(1) Responsibilities

CONTINUING AIRWORTHINESS OF SHARED CMUs

When a CMU is used to operate different UA of different owners, various Part-CAO.UAS organisations

may be involved in the continuing airworthiness of the CMU, and in respect of such CMU, they would

be responsible for the continuing airworthiness tasks to the extent that the CMU applies to the

managed UA. In this case, it is expected that Part-CAO.UAS organisations will establish an arrangement

for the continuing airworthiness of the CMU. When a Part-CAO.UAS organisation is contracted by the

owner, such arrangement should be documented in the written contract established in accordance

with Appendix 1 ‘Continuing airworthiness management contract’ to Annex I (Part-ML.UAS) to

Commission Delegated Regulation (EU) 2024/1107.

The arrangement is intended to ensure that all relevant information and records regarding the CMU

are continuously shared between the two organisations concerned for the entire duration of the

sharing. Such information and records include but are not limited to:

— all maintenance performed on the CMU during the sharing period, including modifications and

repairs;

— CMU’s defects not corrected or which have been deferred;

— CMU’s recurrent defects;

— records identified in point ML.UAS.305 that apply to the CMU;

— any safety-related event or condition of the CMU that endangers or, if not corrected or

addressed, could endanger the UAS or any person involved in its operation;

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— any information requested by the organisation that manages the continuing airworthiness of

the UAS in order to fulfil its responsibilities.

GM1 ML.UAS.201(e)(1) Responsibilities

ACCOUNTABILITY FOR THE CONTINUING AIRWORTHINESS OF THE UAS

(a) When a contract is concluded in accordance with Appendix 1 ‘Continuing airworthiness

management contract’ to Annex I (Part-ML.UAS) to Commission Delegated Regulation (EU)

2024/1107 between an owner/operator and an organisation approved in accordance with

Annex II (Part-CAO.UAS) to that Regulation, a set of obligations is established that both parties

need to fulfil. Therefore, the Part-CAO.UAS organisation becomes responsible for the proper

performance of the continuing airworthiness tasks in relation to the UAS, as referred to in point

ML.UAS.301, for which it has been contracted.

If the owner of the UA is also appropriately approved in accordance with Annex II (Part-

CAO.UAS), a contract is not needed; however, the same obligations as specified in Appendix 1

‘Continuing airworthiness management contract’ to Annex I (Part-ML.UAS) are expected to be

fulfilled.

(b) As specified in point ML.UAS.201(e)(1), the tasks associated with the continuing airworthiness

management of a UAS must be carried out by an organisation approved in accordance with

Annex II (Part-CAO.UAS) to Commission Delegated Regulation (EU) 2024/1107. This requires

that the UA and all the CMUs used to operate it are within the scope of work of the Part-

CAO.UAS organisation and specified in the organisation manual. This is due to the fact that the

continuing airworthiness of the UA is connected to, and dependent on, the CMU’s configuration

and status, and vice versa. This interdependence implies that certain continuing airworthiness

tasks encompass both systems, examples of which include the following:

— The aircraft maintenance programme (AMP) is developed including the scheduled

maintenance tasks for both the UA and the CMU(s).

— The configuration of both the UA and the CMU(s) is known and controlled.

— Organise that all UAS maintenance be performed by an approved maintenance

organisation.

— The defects detected in either the UA or the CMU(s) are rectified by an appropriately

approved maintenance organisation or deferred in a controlled manner.

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GM1 ML.UAS.502(b) Maintenance of UA components

DECLARATION OF MAINTENANCE ACCOMPLISHED

A ‘declaration of maintenance accomplished’ is a certificate prepared in any format/form by the

person or organisation that has performed any type of maintenance of the component covered by the

certificate and subject to the conditions established in point ML.UAS.502(b).

That person or organisation does not need an approval to perform maintenance in accordance with

Commission Delegated Regulation (EU) 2024/1107; however, this does not exclude a maintenance

organisation approved under Part-CAO.UAS from issuing a ‘declaration of maintenance

accomplished’. For the component to be eligible for installation with a ‘declaration of maintenance

accomplished’, the declaration, together with other records, should allow determining that the

component was first installed as ‘new’, as a component referred to in point ML.UAS.502(b). Such a

component should not be installed in a UA if there is information contained in the certificate that is

not readable or not understandable or states that the component is not in a satisfactory condition for

operation.

GM1 ML.UAS.520(e) Installation and maintenance of CMU components

DECLARATION OF MAINTENANCE ACCOMPLISHED

A ‘declaration of maintenance accomplished’ is a certificate prepared in any format/form by the

person or organisation that has performed any type of maintenance of the component covered by the

certificate and subject to the conditions established in point ML.UAS.520(e).

That person or organisation does not need an approval to perform maintenance in accordance with

Commission Delegated Regulation (EU) 2024/1107; however, this does not exclude a maintenance

organisation approved under Part-CAO.UAS from issuing such a ‘declaration of maintenance

accomplished’. For the component to be eligible for installation with a ‘declaration of maintenance

accomplished’, the declaration, together with other records, should allow determining that the

component was first installed as ‘new’, as a component referred to in point ML.UAS.520(e). Such a

component should not be installed in a CMU if there is information contained in the certificate that is

not readable or not understandable or states that the component is not in a satisfactory condition for

operation.

AMC1 ML.UAS.801 Certification of UA maintenance

In addition to the information required by points (b) and (c) of point ML.UAS.801, the certificate of

release to service following UA maintenance should contain the following statement:

‘Certifies that the work specified, except as otherwise specified, was carried out in accordance with

Part-CAO.UAS and in respect to that work, the UA is considered ready for release to service’.

AMC1 ML.UAS.803 Certification of CMU maintenance

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The maintenance performed on the CMU should be certified on an EASA Form 1 as set out in

Appendix II ‘Authorised Release Certificate’ to Annex I (Part-M) to Commission Regulation (EU) No

1321/2014, following the instructions provided in Appendix 3 ‘EASA Form 1 fill-in instructions’ to

Commission Delegated Regulation (EU) 2024/1107.

Alternatively, the certificate of release to service may be established in a different form than with an

EASA Form 1. In this case, in addition to the information required by point ML.UAS.803(b), the

certificate of release to service for the CMU maintenance should contain the following statement:

‘Certifies that the work specified, except as otherwise specified, was carried out in accordance with

Part-CAO.UAS and in respect to that work the CMU is considered ready for release to service.’

GM1 ML.UAS.803(a) Certification of CMU maintenance

Point ML.UAS.803 addresses the certification of CMU maintenance when such maintenance involves

any component that is considered critical for the UAS operation, as referred to in point 21.A.308(a) of

Annex I (Part 21) to Commission Regulation (EU) No 748/2012.

When CMU maintenance does not involve any component that is considered critical for the UAS

operation, such maintenance may be certified in accordance with point ML.UAS.803, but it may also

be declared by a person, other than a certifying staff, authorised for such maintenance by the

Part-CAO.UAS organisation managing the continuing airworthiness of the CMU. In this case, the

declaration should be similar to what is established in GM1 ML.UAS.502(b) and GM1 ML.UAS.520(e).

Such maintenance requires adherence to point ML.UAS.401 maintenance data and to the

maintenance standards of the Part-CAO.UAS organisation.

It is important to include such declaration in the UAS continuing airworthiness records system, as

required by point ML.UAS.305(b)(2).

AMC1 ML.UAS.805 Certification of CMU installation

In addition to the information required by point ML.UAS.805(b), the certificate of release to service

for the installation of the CMU should contain the following statement:

‘Certifies that the installation of the CMU, except as otherwise specified, was carried out in accordance

with Part-CAO.UAS and in respect to that work the CMU is considered ready for release to service.’

GM1 ML.UAS.805 Certification of CMU installation

For the purpose of this Regulation, as regards the installation of the CMU, it is expected that similar

standards will be followed as for maintenance, such as incoming inspection, clean work area, and

segregation of components.

Depending on the CMU design, and without prejudice to the limitations and instructions provided in

the installation instructions, the installer should also consider factors such as CMU size, protection

against adverse weather, wildlife, and dust, as well as the availability of secure network and electrical

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connections, as applicable, in order to determine whether a given physical environment is appropriate

for installing the CMU. A physical environment could be, for example, a room, a van, a tent, or a field.

AMC1 ML.UAS.903 Airworthiness review process

AIRWORTHINESS REVIEW STANDARDS

(a) Airworthiness review staff (ARS) are responsible for the accomplishment of both the

documented review and the physical survey of the UA and the respective CMU(s). If more than

one CMU is used to operate a specific UA, all CMUs should be part of the airworthiness review,

except those CMUs that have been included in the airworthiness review of an UA of the same

type in the last 6 months, as specified in point ML.UAS.903(b).

(b) ARS should follow the Part-CAO.UAS procedures that establish the depth of the documented review and the physical survey, but ARS should go beyond such depth if they consider it necessary.

(c) An airworthiness review report should be produced by the ARS, detailing all items checked and the outcome of the review. The airworthiness review report should identify the CMU (or CMUs) that was (were) part of the review, including the CMU(s) with non-compliances not properly addressed as per AMC1 ML.UAS.903(g). In such cases, a statement should be included indicating that the particular CMU(s) should not be used to operate the UA until the non-compliances are corrected, or properly deferred, in accordance with point ML.UAS.403. Additionally, the airworthiness review report should include the justification for any CMU(s) used to operate the UA that was (were) not reviewed, for example, due to the reasons specified in point ML.UAS.903(b). In this case, the justification should include the reference to the airworthiness review report issued upon the completion of the airworthiness review covering the particular CMU(s).

(d) The issuance of the airworthiness review certificate (ARC) by the ARS only certifies that the UAS is considered airworthy in relation to the scope of the airworthiness review performed and the fact that the ARS are not aware of instances of non-compliance which could endanger flight safety. Furthermore, the ARC only certifies that the UAS is considered airworthy at the time of the review.

(e) The airworthiness review report should be sent to the organisation that manages the UAS’s continuing airworthiness, if different from the organisation that issues the ARC, as specified in point CAO.UAS.090(a)(4).

GM1 ML.UAS.903(g) Airworthiness review process

NON-COMPLIANCE DETECTED IN THE CMU(s)

Non-compliance detected in the CMU(s) are to be corrected, or properly deferred, in accordance with

point ML.UAS.403 before the airworthiness review certificate (ARC) is issued. However, in cases where

there are still non-compliances in one or more CMUs for a particular UA, the ARC may be issued

provided that at least one CMU does not have non-compliances, or such non-compliances in that CMU

have been properly deferred. The remaining CMU(s) with the non-compliances cannot be used to

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operate that UA, or any other UA to which the non-compliance relates, until they have been corrected

or properly deferred.

AMC1 CAO.UAS.020 Scope of work and terms of approval

INCLUSION OF UA AND CMU(s) IN THE SCOPE OF WORK

When the continuing airworthiness of a CMU is managed by different Part-CAO.UAS organisations

(ref. GM1 ML.UAS.201(a)), those Part-CAO.UAS organisations should provide this information in the

scope of work. The relevant organisation manuals should provide the details of the arrangement with

the other Part-CAO.UAS organisation(s) and a procedure should be established detailing how the risks

associated with this set-up will be mitigated, including which records and information are expected to

be shared between these organisations, as specified in GM1 ML.UAS.201(a).

To include a UA or a CMU, or both, in the identification of the UA and the CMU(s) managed (point

CAO.UAS.020(d)(2)) within the scope of work of a Part-CAO.UAS organisation (i.e. UAS phase-in), that

organisation should ensure that the records and information received are accurate and complete. This

process may require verifying that the information received corresponds to the status of the UA or

the CMU(s), as well as verifying:

— whether the UA and the CMU have been previously subject to the continuing airworthiness

requirements established by Commission Delegated Regulation (EU) 2024/1107;

— whether the CMU has been included in the airworthiness review of an UA of the same type in

the last 6 months.

AMC1 CAO.UAS.025 Organisation manual

This AMC provides an outline of the layout of an acceptable organisation manual.

Chapter Description Regulation reference

PART A — GENERAL DESCRIPTION

A.1 Statement by the accountable manager CAO.UAS.025(b)(1); CAO.UAS.035(a)

A.2 General presentation of the organisation CAO.UAS.035(a); CAO.UAS.100(e)

A.3 Description and location of the facilities CAO.UAS.025(b)(4); CAO.UAS.030

A.4 Scope of work CAO.UAS.020; CAO.UAS.025(b)(2); CAO.UAS.025(b)(6); CAO.UAS.025(b)(11) CAO.UAS.095; point (a) of the Appendix ‘Part-CAO.UAS certificate — EASA Form 3-CAO.UAS’ to the Annex (Part-AR.UAS) to Commission Implementing Regulation (EU) 2024/1109

A.5 Exposition amendments and changes to the organisation including ‘phase-in’

CAO.UAS.025(b)(5)/(d); CAO.UAS.105; CAO.UAS.020

A.6 Procedure for alternative means of compliance

CAO.UAS.017

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Chapter Description Regulation reference

A.7 Management personnel CAO.UAS.025(b)(3); CAO.UAS.035(b); CAO.UAS.035(c)

A.8 Organisation chart CAO.UAS.025(b)(3)

A.9 Manpower CAO.UAS.035(f)

A.10 List of certifying staff CAO.UAS.025(b)(7)

A.11 List of staff responsible for the development and approval of the aircraft maintenance programme (AMP)

CAO.UAS.025(b)(8)

A.12 List of airworthiness review staff CAO.UAS.025(b)(9)

A.13 List of staff responsible for the issuance of permits to fly (PtFs)

CAO.UAS.025(b)(10)

PART B — GENERAL PROCEDURES

B.1 Quality (or organisational review) system CAO.UAS.100

B.2 Audit plan (or frequency and content of organisational review)

CAO.UAS.100(b);(c);(e)

B.3 Monitoring of maintenance contracts CAO.UAS.100(c)

B.4 Qualification, assessment and training of staff

CAO.UAS.035(e);(f);(g);(h); CAO.UAS.040; CAO.UAS.045(a);(b)

B.5 Subcontracting CAO.UAS.095(a)(2);(c)(3); CAO.UAS.100(e)

B.6 Maintenance data and continuing airworthiness management data

CAO.UAS.055(a); CAO.UAS.080

B.7 Records management and retention CAO.UAS.050(b); CAO.UAS.075(a);(b)(9); CAO.UAS.090; CAO.UAS.085

B.8 Carrying out the airworthiness review CAO.UAS.085; CAO.UAS.095(d)

B.9 Conformity with approved flight conditions CAO.UAS.095(e); CAO.UAS.086

B.10 Issue of a permit to fly CAO.UAS.095(e); CAO.UAS.086; CAO.UAS.048

B.11 Information security CAO.UAS.102

PART C — MAINTENANCE PROCEDURES

C.1 Maintenance — general CAO.UAS.025(a)

C.2 Work order acceptance CAO.UAS.055(b)

C.3 Components, equipment, tools and materials (supply, acceptance, segregation, storage, calibration, etc.)

CAO.UAS.050; CAO.UAS.060(b)(3); CAO.UAS.030(b)(2)

C.4 Maintenance facility (selection, organisation, cleanliness and environmental limitations)

CAO.UAS.060(b)(1);(b)(4);(b)(5)

C.5 Maintenance accomplishment and maintenance standards

CAO.UAS.095(a)(1); CAO.UAS.060(b)(2); points (b), (c) and (d) of the Appendix ‘Part-CAO.UAS certificate — EASA Form 3- CAO.UAS’ to the Annex (Part-AR.UAS) to Commission Implementing Regulation (EU) 2024/1109

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Chapter Description Regulation reference

C.6 Prevention of maintenance error CAO.UAS.060(b)(6);(b)(8)

C.7 Critical maintenance tasks and error- capturing methods

CAO.UAS.060(7)

C.8 Fabrication CAO.UAS.095(a)(5)

C.9 Certifying staff responsibilities, maintenance and installation release

CAO.UAS.040(a); CAO.UAS.065; CAO.UAS.070; CAO.UAS.071; CAO.UAS.072; CAO.UAS.095(a)(4); CAO.UAS.095(b)

C.10 Defects arising during maintenance CAO.UAS.060(a); CAO.UAS.075(b)(6)

C.11 Maintenance outside approved locations CAO.UAS.095(a)(3); CAO.UAS.025(b)(6);

C.12 Procedure for component maintenance under UAS or engine rating

Points (b) and (c) of the Appendix ‘Part- CAO.UAS certificate — EASA Form 3- CAO.UAS’ to the Annex (Part-AR.UAS) to Commission Implementing Regulation (EU) 2024/1109

C.13 Procedure for maintenance of installed engine (or component) under engine (or component) rating

Points (c) and (d) of the Appendix ‘Part- CAO.UAS certificate — EASA Form 3- CAO.UAS’ to the Annex (Part-AR.UAS) to Commission Implementing Regulation (EU) 2024/1109

C.14 Special procedures (specialised tasks, non- destructive testing (NDT), engine running, etc.)

CAO.UAS.030(a); point (e) of the Appendix ‘Part-CAO.UAS certificate — EASA Form 3-CAO.UAS’ to the Annex (Part-AR.UAS) to Commission Implementing Regulation (EU) 2024/1109

C.15 Issue of airworthiness review certificate (ARC) under maintenance privilege

CAO.UAS.095(c)

C.16 Procedure for the maintenance of UA performed and certified remotely from the CMU

CAO.UAS.025(b)(11)

PART D — CONTINUING AIRWORTHINESS MANAGEMENT PROCEDURES

D.1 Continuing airworthiness management — general

CAO.UAS.025(a); CAO.UAS.095(c)(1); CAO.A.075(a);(b)(7);(b)(9)

D.2 Application of minimum equipment list (MEL) (and configuration deviation list (CDL))

CAO.UAS.075(a)

D.3 Aircraft maintenance programme (AMP) development, control and periodic review

CAO.UAS.075(a);(b)(1);(b)(2); CAO.UAS.095(c)(2)

D.4 Airworthiness directives and other mandatory airworthiness requirements

CAO.UAS.075(a);(b)(5);(b)(8)

D.5 Modifications and repairs CAO.UAS.075(b)(3)

D.6 Pre-flight inspection CAO.UAS.075(a)

D.7 Management of defects CAO.UAS.075(b)(6); CAO.UAS.060(a)

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Chapter Description Regulation reference

D.8 Establishment of contracts and work orders for the maintenance

CAO.UAS.075(a);(b)(4);(b)(7)

D.9 Coordination of maintenance activities CAO.UAS.075(b)(8)

D.10 Mass and balance statement CAO.UAS.075(a);(b)(10)

D.11 Issue of ARC or ARC recommendation CAO.UAS.095(d)

D.12 ARC extension CAO.UAS.095(c)(4)

D.13 Maintenance check flights CAO.UAS.075(a)

D.14 Continuing airworthiness management of shared CMU(s)

CAO.UAS.020

PART E — SUPPORTING DOCUMENTS

E.1 Sample documents

E.2 List of subcontracted organisations

E.3 List of organisations contracted by the CAO

E.4 List of currently approved alternative means of compliance

E.5 Copy of contracts for subcontracted continuing airworthiness tasks

AMC1 CAO.UAS.025(b)(6) Organisation manual

MAINTENANCE OUTSIDE APPROVED LOCATIONS

(a) When carrying out maintenance outside the locations listed in the organisation manual, certain

safeguards offered by these locations are not present. Therefore, a procedure needs to be

established to define the prerequisites and conditions that must be fulfilled before and during

such maintenance so as to ensure that appropriate maintenance standards are met, as specified

in point CAO.UAS.060.

The procedure should ensure that all the aspects relevant to the work to be performed are

addressed, such as:

— Manpower:

— Manpower availability should account for additional time required to reach the

location where the maintenance will be performed, including but not limited to

fatigue and travel time.

— If applicable, availability of staff to ensure the implementation of error-capturing

methods (e.g. independent inspection) after the performance of critical

maintenance tasks.

— Work environment:

— Ensure that the area where maintenance is performed is well organised and clean.

— When necessary, the appropriate conditions must be ensured to protect the UAS,

components, and staff from adverse weather such as rain, hail, ice, snow, and

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wind, as well as from wildlife (including birds and rodents) and dust. This can be

achieved by performing the maintenance in appropriate facilities or by using other

means such as an inflatable shelter, maintenance tent, or inside a van.

— Maintenance resources and supplies:

— Ensure the availability and proper condition of components, standard parts,

materials, tools, and equipment required for maintenance. The corresponding

documentation, such as EASA Form 1 and certificate of conformity (CofC), should

be readily available upon request.

— When necessary, ensure the appropriate conditions to transport, store, and

segregate components, standard parts, materials, tools, and equipment.

— Maintenance data, records, and occurrence reporting:

— Ensure that current maintenance data is readily available.

— The records system allows for proper records of all stages of maintenance, and

ensures they are properly stored and protected.

— Ensure the necessary conditions for both mandatory and voluntary reporting.

— If applicable, ensure there are alternatives in case of no internet connection.

— Information security:

— Access to computers and networks is secured and restricted to authorised

personnel.

(b) The scope of maintenance allowed to be carried out outside approved locations should be

defined in point A.4 of the organisation manual. It should be considered that having the

capability to perform specific maintenance at a location listed in the organisation manual does

not necessarily mean the organisation has the same capability at another location. For example,

the lack of a proper facility to carry out maintenance may limit the scope of tasks that are

allowed to be performed elsewhere.

AMC1 CAO.UAS.035(e) Personnel requirements

BASIC KNOWLEDGE FOR CERTIFYING STAFF

(a) The Part-CAO.UAS organisation should ensure that all certifying staff receive basic training that

encompasses:

— maintenance standards and good practices;

— general knowledge of Commission Delegated Regulation (EU) 2024/1107 and of UAS

operations;

— general technical knowledge.

The basic training should consist of both theoretical and practical components. By the end of

the training, certifying staff should be able to:

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(1) provide a simple description of the UAS matters using common words and examples and

typical terms, and identify general safety precautions related to UAS;

(2) use and understand general maintenance data (e.g. maintenance manual,

troubleshooting manual, structural repair manual, component maintenance data,

airworthiness directive);

(3) use standard tools and equipment;

(4) report any event which could negatively impact on safety;

(5) demonstrate knowledge of Commission Delegated Regulation (EU) 2024/1107,

particularly of the limitations and privileges related to maintenance;

(6) demonstrate basic knowledge of the applicable regulations that cover UAS operations;

(7) demonstrate knowledge of maintenance standards as specified in point CAO.UAS.060

and good practices (e.g. applying and recording the proper torque settings), ensuring

accurate and thorough record-keeping of all maintenance activities (e.g. identifying the

P/N of the components installed), and maintaining a clean and organised work

environment;

(8) properly handle and store a UAS and its components.

The practical elements of the basic training may be replaced by aircraft maintenance experience

in:

— servicing,

— inspection,

— operational testing,

— simple functional testing,

— simple defect rectification,

— replacing components.

The basic training may have different formats, such as a single full course, several training

sessions over time, or combined with training in a particular aircraft in accordance with point

CAO.A.040. The basic training may be provided, whole or parts of it, by the Part-CAO.UAS

organisation or any other organisation that is acceptable to the Part-CAO.UAS organisation.

The basic training should be delivered at least once to certifying staff.

(b) The Part-CAO.UAS organisation should ensure that the certifying staff for components receive:

— theoretical and practical component training; for simple components, this may be

replaced by experience and/or previous training in a component from the same family

and technology;

— training in bench tests, when applicable;

— training for the use of specific tools, when applicable.

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AMC2 CAO.UAS.035(e) Personnel requirements

EXPERIENCE RECENCY FOR CERTIFYING STAFF

The Part-CAO.UAS organisation should ensure that in any consecutive 2-year period all certifying staff

are involved in the maintenance of that particular or similar aircraft, CMUs or components for a period

of at least of 6 months. For the purposes of this AMC, ‘involved in the maintenance’ means that the

staff has either exercised the privileges of the certification authorisation and/or has carried out

maintenance.

For the meaning of ‘similar aircraft or CMUs’, please refer to GM1 CAO.UAS.040(b).

AMC1 CAO.UAS.040(b) Certifying staff

INITIAL TRAINING RELEVANT TO A PARTICULAR UA AND CMU

The initial training for UA or CMU certifying staff should consist of theoretical and practical training.

The theoretical training should provide detailed knowledge of the UA and CMU applicable systems,

structure, operations, maintenance, repair and troubleshooting according to maintenance data.

The objectives of the theoretical training should be such that the trainee will be able, as applicable to

the scope of the certification authorisation, to:

— define the general layout of the UA’s and CMU’s major systems and characteristics of the

engine(s) and identify the locations of the principal components;

— identify special tooling and test equipment used with the UA and the CMU;

— apply knowledge in a practical manner using detailed procedures;

— recall the safety precautions to be observed when working on or near the UA, engine and

systems;

— describe systems and UA handling particularly access, power availability and sources;

— explain the normal functioning of each major system, including terminology and nomenclature;

— perform servicing associated with the UA;

— demonstrate proficiency in the use of pilot reports and on-board reporting systems (minor

troubleshooting) and determine aircraft airworthiness per MEL/CDL when they exist;

— demonstrate the use, interpretation and application of appropriate documentation including

instructions for continued airworthiness, maintenance manual, illustrated parts catalogue,

structural repair manual, troubleshooting manual, etc.;

— demonstrate theoretical knowledge of UAS systems and structures (see AMC2 CAO.UAS.040(b))

and interrelationships with other systems, provide a detailed description of the subject using

theoretical fundamentals and specific examples, and interpret results from various sources and

measurements, and apply corrective action where appropriate;

— perform system, engine, component and functional checks as specified in the maintenance

manual;

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— correlate information for the purpose of making decisions in respect of fault diagnosis and

rectification to maintenance manual level;

— describe procedures for the replacement of components unique to the UA and CMU type;

— demonstrate maintenance knowledge of the parts related to the transportation of goods, such

as payloads, hooks, and winches;

— demonstrate knowledge of the most common defects with associated consequences.

The objective of the practical training is to gain the required competence in performing maintenance,

inspections and routine work safely according to the maintenance manual and other relevant

instructions and tasks as appropriate for the type of UA and CMU, for example, troubleshooting,

repairs, adjustments, replacements, rigging and functional checks. It includes awareness of the use of

all technical literature and documentation for the UA and CMU, the use of specialist/special tooling

and test equipment for performing removal and replacement of components and modules unique to

the UA and CMU type.

When the practical training is delivered by a Part-CAO.UAS organisation, the source of the training

material should be described. For example, training directly in operator’s maintenance

documentation, or in training material issued by the operator, or in training material provided by the

UAS manufacturer, or another third party.

AMC2 CAO.UAS.040(b) Certifying staff

KNOWLEDGE OF UAS SYSTEMS AND STRUCTURES

The following topics should be part of the knowledge of the UA and CMU systems and structures, as

applicable to the UAS configuration and CONOPs:

— Storage, transportation, and preparation for flight.

— Rotors and rotor-drive system: drive, transmission, control, indications.

— Structure: fuselage, nacelles, arms, stabilisers, wings, control surfaces, fairings.

— Lifting fluid in airships.

— Autopilot/control system: flight controller, accelerometers, servos and command system.

— Communications: command and monitoring data link, payload data link, antennas.

— Navigation: GNSS, IMU, airspeed, compass, altimeters.

— Electrical energy: generation, storage, distribution, and control. Protections, wiring, and

connections.

— Placards and markings.

— Accessories and payloads: systems, installations, lights, stabilisation, cameras, others.

— CMU: flight controls, instruments, indication.

— Fuel system: storage, distribution, filtering, control, and indications.

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— Batteries: maintenance, storage, and indication.

— Engines: structural layout, indication and operation:

— electrical;

— turbine (installation intake, compressors, combustion section, turbine section, bearings

and seals, lubrication systems);

— piston (installation, carburettors, fuel injection systems, induction, exhaust and cooling

systems, supercharging/turbocharging, lubrication systems);

— others.

— Landing gear: fixed or retractable.

— Propellers: structure, pitch control, synchronisation, electronic control.

— Software functionalities, updates, and maintenance.

— Other systems: Detect and Avoid / Sense and Avoid, Flight Termination System, Parachutes,

Flight Vision System / First-Person View (FPV), Geocaging, Geofencing, etc.

GM1 CAO.UAS.040(b) Certifying staff

Two aircraft, regardless of being manned or unmanned, or two CMUs are considered similar when

they have similar technology, construction, and comparable systems, which means:

(a) aircraft equipped with equivalent:

— propulsion systems (e.g. piston, turboprop, turbofan, turboshaft, jet engine, push

propellers, electrical engine); and

— power/energy systems (e.g. similar power supply requirements, whether battery

operated, solar powered, or fuel based); and

— flight control systems (only mechanical controls, hydromechanically powered controls or

electromechanically powered controls); and

— avionics systems (analogue or digital systems); and

— structure (manufactured of metal, composite, or wood);

(b) a CMU that is used to operate the same or similar UA and is equipped with equivalent:

— human–machine interface (e.g. touchscreen, physical controls, or remote interface); and

— control systems (e.g. manual control, semi-automatic control, or fully autonomous

control systems); and

— monitoring systems (e.g. sensor types and capabilities, such as GPS, gyroscopes,

accelerometers, cameras, and environmental sensors); and

— communication systems (e.g. similar communication protocols and technologies, such as

Wi-Fi, Bluetooth, radio frequency, or satellite); and

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— physical attributes (e.g. fixed or mobile).

AMC1 CAO.UAS.102(a) Protection of information and communication systems and data

PROTECTION OF SOFTWARE, DATA AND HARDWARE

The Part-CAO.UAS organisation should establish procedures to:

(a) procure software from trusted suppliers;

(b) verify the authenticity and integrity of software;

(c) update software and hardware timely;

(d) secure and restrict access to computers and networks to authorised personnel.

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GM1 CAO.UAS.102 Protection of information and communication systems and data

GENERAL

Practical recommendations to secure small organisations may be found in the publications of the

European Union Agency for Cybersecurity (ENISA).

Network protection can be implemented by:

(a) securing internal networks with user access control;

(b) protecting end point devices used to access the network with anti-malware software that is

kept up to date;

(c) enabling and properly configuring state-of-the-art secure protocols on Wi-Fi networks;

(d) establishing virtual private networks with multi-factor authentication for all remote

connections.

European Union Aviation Safety Agency

Notice of Proposed Amendment 2024-06(E)

in accordance with Article 6 of MB Decision 01-2022

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Proposed AMC and GM

to the continuing airworthiness requirements

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European Union Aviation Safety Agency NPA 2024-06(E)

Proposed AMC and GM

to the continuing airworthiness requirements for authorities

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Table of contents

Proposed amendments ................................................................................................................ 3

AMC1 AR.UAS.GEN.010 Competent authority ....................................................................................... 3

European Union Aviation Safety Agency NPA 2024-06(E)

Proposed AMC and GM

to the continuing airworthiness requirements for authorities

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Proposed amendments

The amendments are arranged as follows to show deleted, new and unchanged text:

— deleted text is struck through;

— new text is highlighted in blue;

— an ellipsis ‘[…]’ indicates that the rest of the text is unchanged.

Where necessary, the rationale is provided in italics.

AMC1 AR.UAS.GEN.010 Competent authority

OVERSIGHT COOPERATION BETWEEN COMPETENT AUTHORITIES

When the same CMU is used to operate different UA registered in different Member States, the

competent authorities of both UA should establish an arrangement for the oversight of the continuing

airworthiness of the CMU. The arrangement should ensure the exchange of information relevant for

the performance of the competent authorities’ tasks, such as sharing the results of oversight activities

performed (e.g. monitoring of the UAS’s continuing airworthiness). The arrangement may include the

performance of oversight tasks by one competent authority on behalf of another.

Competent authorities should inform UA owners of such arrangements.