I have the following question about an ambiguity between the Cover Regulation Article 2 §7/SPO.GEN.005 and SPO.SPEC.MCF:

- Article 2 §7 considers Maintenance Check Flights as a specialised activity
"‘specialised operation’ means any operation, other than commercial air transport operation, where the aircraft is used for specialised activities such as agriculture, construction, photography, surveying, observation and patrol, aerial advertisement, maintenance check flights"
=> My French SPO operator declares MCF as an activity and starts writing an SOP about it.

- Although SPO.GEN.005 (a) says that maintenance check flights are a specialised activity, the list under GM1 SPO.GEN.005 does not mention maintenance check flights as an specialised activity.
Under SPO.SPEC.MCF an SOP is not required.

=> The question is if MCF are a specialised activity an SOP is required by SPO.OP.230.
But under SPO.SPEC.MCF, an SOP is not required.

Can somebody resolve this ambiguity?
Would it be a correct conclusion if you give priority to SPO.SPEC which requires no SOP for MCF?

Thank you, Guy Wouters

Ian Scott

No SOP, but it does require a manual:

SPO.SPEC.MCF.110 Maintenance check flight manual for a 'Level A' maintenance check flight

Regulation (EU) 2019/1384

The operator conducting a “Level A” maintenance check flight shall:

(a) describe those operations and associated procedures in the operations manual referred to in point ORO.MLR.100 of Annex III or in a dedicated maintenance check flight manual;

(b) update the manual when necessary;

(c) inform all affected personnel of the manual and of its changes that are relevant to their duties;

(d) provide the competent authority with the manual and its updates.

Ana Fonseca

From what I've seen, usually, checklist for maintenance check flights can be found in maintenance manuals and/or FCOM.
Maintenance check flights are also mentioned in Operator and Airworthiness organizations manuals but never read a SOP about it.


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