Hello everyone,
I recently had a discussion with our CAMO regarding original documents to be carried on board of the aircraft. The issue is with CofA or airworthiness certificate we do have the original on board but we have only copy of the ARC in CAT.GEN.MPA.180 ARC is not mentioned at all but i.a.w. 1321/2004 CofA is not valid without ARC. Could you please give me some hints where to look for conformation....
Regards Costa

Mohamed Salih
Mohamed Salih

Hello Costa,
As you have mentioned, IAW CAT.GEN.MPA.180, and additionally IAW NCO.GEN.135 and IAW NCC.GEN.140. ARC is not even required to be onboard the aircraft (neither a copy nor an original). Unless otherwise specified in the operator's procedures.

Regards.

Kyra Ferrari
Kyra Ferrari

EASA issues CoA without an expiration date since these are supplemented by the ARC, if you refer to EASA Form 25 i.e. the certificate of airworthiness, the final line states "A current Airworthiness Review Certificate shall be attached to this certificate". Therefore a certificate of airworthiness is valid only if a valid airworthiness review certificate is attached to it (21.B.325) and therefore the statement that it is not required onboard as stated above is incorrect.

Although it is not specifically allowed to carry other than the original of the document, it is accepted to carry a certified true copy provided that it is certified by the issuing authority. Electronic copies could also be accepted as long as their reliability is assured e.g. by a letter from the authority allowing the electronic carriage of document copies.

Benjamin  Hari
Benjamin Hari

The issue you raised about carrying original documents on board, specifically the Certificate of Airworthiness (CofA) and the Airworthiness Review Certificate (ARC), is indeed addressed by EASA regulations.

According to CAT.GEN.MPA.180, operators are required to carry a set of documents on each flight. This includes the original Certificate of Airworthiness (CofA). While the ARC is not explicitly listed under CAT.GEN.MPA.180, it is an essential part of maintaining the validity of the CofA as per Regulation (EU) No 1321/2014. This regulation stipulates that the CofA is only valid if the ARC is valid. Therefore, while the ARC itself might not be explicitly mentioned in CAT.GEN.MPA.180, it is implicitly required to ensure the CofA is valid.

To summarise, here are some key points:

1. Certificate of Airworthiness (CofA): Must be carried on board as an original document.
2. Airworthiness Review Certificate (ARC): While not explicitly required to be carried as an original under CAT.GEN.MPA.180, it must be valid to ensure the CofA is valid.

In practical terms, carrying a copy of the ARC may suffice for operational needs, but it is critical to ensure that the original or a certified true copy is readily available, possibly retained at the base, to demonstrate compliance during inspections or audits.

For detailed regulatory references, you can consult the Easy Access Rules for Air Operations and the specific provisions in Regulation (EU) No 1321/2014 concerning airworthiness review certificates.

Konstantin Stoyanov
Konstantin Stoyanov

Hello Dear All,

Thank you for sharing your opinion, seems there is no 100% clear answer if the original has to be on board or copy is sufficient.
Dear Kyra, I personally share your opinion for the current situation. Also I do not understand why EASA does not make a clear statement on this in the regulations or guidance materials. Maybe not bad idea to be added during next revision...
I understand that carrying the original is quite hard to comply, especially when extension is needed and the aircraft is in daily use also this document has unique tracking number (similar to the EASA Form Ones) so I would support not carrying the original document on board if legal to do so.
Actually I have another similar question but for light piston aircraft. I work with a CAMO located in a different country than the country we operate the aircraft, each time new ARC extension is done they produce new original ARC with the extension on it. Do you consider it legal?

Regards


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