**Executive Summary**
This document proposes amendments to CAR M, Issue 2, dated November 2016, specifically CAR M R1. The amendments aim to incorporate CAR 66 requirements and align with the latest EASA amendments to Part M. The document outlines specific changes to paragraphs within CAR M related to Continuing Airworthiness Requirements.
**Key Points / Main Content**
* **CAR M R1 Amendment Purpose:**
* Include CAR 66 requirements.
* Harmonize with latest EASA amendments to Part M.
* **M.A.201 Responsibilities Amendment:**
* Note 2 clarifies that M.A.201(b) includes foreign-registered aircraft operated by Indian Scheduled Commuter Operators.
* Clarifies responsibilities of operators certified under Schedule XI of Aircraft Rule 1937 for aircraft airworthiness.
* Scheduled Commuter Operators with non-complex aircraft/helicopters may contract Continuing Airworthiness Management Function to an approved organisation, while retaining responsibility.
* **GM M.A.201(b) Note 2 Amendment:**
* Indian Operators must demonstrate compliance with Aircraft Rules, 1937, and CAR through an approved CAMO, subject to DGCA inspection.
* **AMC M.A.201(e)(2) Responsibilities Amendment:**
* Air operators certified under Schedule XI of Aircraft Rules, 1937, only need a CAMO approval as part of AOC for continuing airworthiness management, except when contracting the function. If combined with complex aircraft or helicopter, operator needs CAMO approval. Airworthiness review approval is optional.
* **M.A.303 Airworthiness Directives Amendment:**
* If DGCA reissues an "Airworthiness Directive" mandated by the state of design as a "Mandatory Modification", a compliance matrix can replace separate detailed compliance records.
* **M.A.501 Installation Amendment:**
* Documents equivalent to CA Form 1 for CAR-M purposes include: Release document from organization under DGCA bilateral agreement; EASA Form ONE; FAA Form 8130-3; Airworthiness release documents from aircraft manufacturer for new components, acceptable for aircraft with DGCA-accepted Type Certificate; any other form acceptable to DGCA.
**Impact Analysis**
**Stakeholder: Aircraft Owners/Operators**
* **Impact:** Changes to responsibilities related to aircraft leasing and continuing airworthiness management, particularly for foreign-registered aircraft and those under Schedule XI.
* **Action Required:** Review and comply with revised responsibilities, including demonstrating compliance to DGCA, ensuring CAMO approval, and adhering to updated procedures for airworthiness directives and component installations.
**Stakeholder: Scheduled Commuter Operators**
* **Impact:** Clarification on options for contracting Continuing Airworthiness Management Function and associated responsibilities.
* **Action Required:** Evaluate options for managing airworthiness, either through an internal CAMO or by contracting an approved organisation.
**Stakeholder: DGCA (Directorate General of Civil Aviation)**
* **Impact:** Increased oversight and inspection responsibilities to ensure compliance with amended CAR M provisions.
* **Action Required:** Implement procedures for inspecting operator compliance with the updated regulations.
**Stakeholder: Approved CAMOs (Continuing Airworthiness Management Organisations)**
* **Impact:** Potential for increased responsibilities related to providing airworthiness management services for scheduled commuter operators.
* **Action Required:** Ensure their operations meet the requirements of the amended CAR M and are prepared to support scheduled commuter operators as needed.
Key Entities Referenced
DGCA: Directorate General of Civil Aviation, India's regulatory body for civil aviation.
EASA Part M: European Aviation Safety Agency's regulations related to continuing airworthiness.
CAR 66: Civil Aviation Requirements, Section 66, concerning aircraft maintenance licensing requirements.
CAR M: Civil Aviation Requirements, Section M, concerning Continuing Airworthiness Requirements.
Aircraft Rules, 1937, Schedule XI: Indian Aircraft Rules concerning the standards and procedures for civil aviation in India.
CAR M
CAR – M
CONTINUING AIRWORTHINESS REQUIREMENTS
CAR M R1 is proposed to be amended to include
CAR 66 requirements and to harmonise with latest
EASA amendments to Part M.
The proposed amendments were placed on public
website for comments. Subsequently, following
paragraphs of CAR M are proposed to be
amended.
The text of the amendment is arranged to show
new or amended text as shown below:
The new or amended text is highlighted in grey;
1
Issue 2, dated …….November 2016CAR M
Subpart B ACCOUNTABILITY
M.A.201 Responsibilities
GM M.A.201(b) Note-2 Responsibilities
Subpart C CONTINUING AIRWORTHINESS
M.A.303 Airworthiness Directives
AMC 303 (2) Airworthiness Directives
SUBPART B
ACCOUNTABILITY
M.A.201 Responsibilities
(b) When the aircraft is leased, the responsibilities of the owner are transferred to
the lessee if:
1. the lessee is stipulated on the registration document, or;
2. detailed in the leasing contract.
Note1 :-When reference is made in this CAR to the ‘owner’, the term
owners/operators covers the owner or the lessee, as applicable.
Note 2:- M.A.201 (b) would include foreign registered aircraft operated by
Indian Scheduled Commuter Operators.
--------- ----
(e) In the case of aircraft used by air operator certified in accordance with
Schedule XI of Aircraft rule 1937, the operator is responsible for the
continuing airworthiness of the aircraft it operates and shall:
(1) ensure that no flight takes place unless the conditions defined in point (a)
are met;
(2) be approved, as part of its air operator certificate, as a continuing
airworthiness management organisation pursuant to M.A. Subpart G
(CAMO) for the aircraft it operates;
By derogation to the above Scheduled Commuter Operators of non-
complex aircraft and helicopter may contract the Continuing Airworthiness
Management Function to an appropriately approved Organisation while
retaining the responsibility with itself.
(3) be approved in accordance with CAR-145 or establish a contract in
accordance with M.A.708(c) with such organisation.
2CAR M
GM M.A.201(b) Note 2
In addition to complying with the the requirements of Aviation Authority of the
State of Registry, the Indian Operator shall demonstrate to the DGCA and provide
for inspection of the activities, wherever they may be performed through an
appropriately approved CAMO that the provisions of applicable Aircraft Rules,
1937 and this CAR is being complied either directly or through an approved
alternate means for which DGCA is not the ‘Authority’ in respect of the aircraft
AMC M.A.201(e)(2) Responsibilities
1. An air operator certified in accordance with Schedule XI of Aircraft Rules,
1937, only needs to hold a CAMO approval as part of its air operator
certificate (AOC) for the management of the continuing airworthiness of the
aircraft listed on its AOC with the exception of contracting the function to an
appropriately approved CAMO by operators of non-complex aircraft for
scheduled commuter operations. However, if the scheduled commuter
operation is conducted combined with complex motor aircraft or helicopter,
the operator is required to have his own CAMO approval to manage the
Continuing Airworthiness of the Aircraft. The approval to carry out
airworthiness review is optional.
SUBPART C
CONTINUING AIRWORTHINESS
AMC M.A.303 (2) Airworthiness Directives
Where DGCA had reissued the ‘Airworthiness Directive’ mandated by a state of
design as ‘Mandatory Modification’ a compliance matrix may be provided in
place of duplicating the detailed compliance record separately for Airworthiness
Directives and DGCA Mandatory modifications
3CAR M
SUBPART E
COMPONENTS
M.A.501 Installation
AMC M.A.501 (a) Installation
5. For the purpose of CAR - M, a document equivalent to a CA Form 1 may
be:
- a release document issued by an organisation under the terms of a
bilateral agreement signed by DGCA
- EASA Form ONE
- FAA Form 8130-3
- Airworthiness release documents issued by the manufacturer of aircraft for
new components shall be acceptable for the installation on type of aircraft
for which Type Cerficate is accepted by DGCA.
- Any other form acceptable to DGCA.
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