Airworthiness Notice - B033, Edition 1 - 30 April 1996

Maintenance Requirements for the Issuance of Extended Charter and Points Abroad Operational Authority

Introduction

The purpose of this notice is to provide air carriers, which are engaged or may engage in foreign or extended charter operations, with the maintenance related requirements for these operations.

Background

Extended charter operations involve the charter of a Canadian commercial aircraft to a Canadian or foreign air carrier for a specified period.  This is done to supplement the fleet of the air carrier that is chartering the aircraft.  Under this arrangement, the aircraft operates on behalf of another Canadian or foreign air carrier under a charter or extended charter agreement.  Extended charters are not recognized as leases in Canada.  Transfer of custody and control of an aircraft operating an extended charter is not permitted.  During the extended charter, the operation and maintenance of the aircraft must comply with all aspects of the Canadian air carrier's operating certificate (OC) and maintenance control manual (MCM).

At present there are two types of extended charter operations:  21 days or less, and greater than 21 days.  Operational approval to permit extended charters of 21 days or less is issued in the form of a "Points Abroad" designation in Part IV of the operating certificate.  For periods greater than 21 days, an "Extended Charter Operations Specification" must be issued.  In either case, the aircraft used in this operation must be maintained in accordance with the conditions specified in the air carrier's approved MCM and maintenance specifications.

The use of Canadian commercial aircraft on extended charter operations has not significantly increased over the years; however, "first time" operators in this area may not be fully aware of their maintenance responsibilities.

Maintenance Requirements

To permit air carriers which are seeking "Points Abroad" authority the maintenance flexibility to respond to short notice requests for the use of their aircraft, the MCM must be amended prior to the issuance of the operating certificate to include sufficient policy and procedures to cover aircraft maintenance for any three week or less charter period.  Similarly, prior to the issuance of an extended charter operations specification, the MCM must be amended to address maintenance requirements over the longer term.  As a minimum, the MCM must include information on the following:

  1. Location of maintenance facilities, personnel, spare parts and publications;
  2. Minimum equipment list (MEL) compliance handling procedures, including submission of a copy or reference to the MEL that will be utilized and any required changes with respect to the intended operation;
  3. Flight permit authorizations, e.g. validation procedures must be addressed for use of the aircraft in foreign airspace;
  4. Changes and/or use of contract maintenance facilities;
  5. Additional air carrier maintenance coordinator responsibilities; and
  6. Communications needed to transmit maintenance information for record keeping or monitoring purposes.

Note:   The above items apply to both points abroad and extended charter operations.  The MCM must include policy and procedures with sufficient detail to account for either type of operation.  This list of items should not be considered all inclusive and may include other items as appropriate.

In addition:

  1. The Canadian air carrier must identify the approved maintenance schedule along with any proposed amendments as a result of the intended operation; and
  2. The agreement must clearly specify that the Canadian air carrier retains airworthiness control and responsibility for the aircraft.

The foregoing must be evaluated to determine if any changes are required to the aircraft maintenance schedule, location of maintenance facilities, personnel, etc. prior to commencement of the operation.

Air carriers whose maintenance is performed under contract, or subcontract, must ensure that the contract maintenance organization(s) is capable of supporting and has accepted these added maintenance responsibilities.  Appropriate amendments to the maintenance contract and contractor's MCM will be needed as outlined above.

The need for early notification between the air carrier and the responsible Transport Canada airworthiness office cannot be over-emphasized.  The extent of the changes needed in the MCM to address this type of operation will be assessed on an individual basis and each air carrier is encouraged to consult with Transport Canada Airworthiness Branch on specific issues.

Surveillance and Cost Recovery

Once the points abroad procedure has been approved in the MCM, the air carrier shall advise the responsible Transport Canada airworthiness office within 48 hours of each use.

Prior to the issuance of an extended charter operations specification and in addition to the foregoing, a base inspection of the foreign facilities will be conducted by Transport Canada airworthiness inspectors.  The inspection may also include discussions with the foreign airworthiness authority regarding compliance with any special airworthiness or maintenance conditions required by either Transport Canada or the foreign authority prior to approving the arrangement.

The Canadian air carrier must agree to reimburse the department for travel, accommodation and other expenses incurred by the Minister for the approval and continuing surveillance of short or long term extended charter operations.  The air carrier must also obtain written authorization from the civil aviation authority of the chartering air carrier for the operation and confirmation that Transport Canada airworthiness inspectors will be permitted access to perform periodic inspections of maintenance facilities, personnel and/or documents, as deemed necessary, in the operating country.