ED Decision 2023/013/R
For aircraft not used by air carriers licensed in accordance with Regulation (EC) No 1008/2008 other than complex motor-powered aircraft, an example of limitations could be where a person holds a pre-Part-66 qualification which covered privileges to release work performed on aircraft structures, powerplant, mechanical and electrical systems but excluded privileges on aircraft equipped with turbine engine, aircraft above 2 000 kg MTOM, pressurised aircraft and aircraft equipped with retractable landing gear. This person would be issued with a Part-66 aircraft maintenance licence in the B1.2 or B3 (sub)category with the following limitations (exclusions):
- aircraft used by air carriers licensed in accordance with Regulation (EC) No 1008/2008 (this limitation always exists);
- aircraft above 2 000 kg MTOM;
- pressurised aircraft;
- aircraft equipped with retractable landing gear.
Another example of limitations could be where a pilot-owner holds a pre-Part-66 qualification which covered privileges to release work performed on aircraft structures, powerplant, mechanical and electrical systems but limited to their own aircraft and limited to a particular aircraft type (for example, a Cessna 172). This pilot-owner would receive a Part-66 aircraft maintenance licence in the B1.2 or B3 (sub)category with the following limitations (exclusions):
- aircraft used by air carriers licensed in accordance with Regulation (EC) No 1008/2008 (this limitation always exists);
- aircraft other than a Cessna 172;
- aircraft not owned by the licence holder.
One more example would be the case where a person holds a pre-Part-66 qualification that covers privileges to release work on composite and metal sailplanes and powered sailplanes, covering aircraft structures, powerplant, mechanical and electrical systems. This person would be issued a Part-66 aircraft maintenance licence in the L2 subcategory, with the following limitations (exclusions):
- ELA1 aeroplanes;
- wooden-structure aircraft covered with fabric;
- aeroplanes with metal-tubing structure covered with fabric.
And one more example would be the case where a person holds a pre-Part-66 qualification that covers privileges to release work on composite sailplanes up to the annual inspection but not including complex maintenance tasks, repairs and changes. This person would be issued a Part-66 aircraft maintenance licence in the L1C subcategory, with the following limitations:
- complex maintenance tasks described in Appendix VII to Annex I (Part-M), standard changes described in point 21.A.90B of Part 21 or points 21L.A.62 or 21L.A.102 of Part 21 Light, and standard repairs described in point 21.A.431B of Part 21 or points 21L.A.202 or 21L.A.222 of Part 21 Light.
The essential aspect is that the limitations are established in order to maintain the privileges of the pre-Part-66 qualification without comparing the previous qualification with the standard of Part-66 Appendix I and II.
For removal of limitations, refer to 66.A.50(c).
EASA GM 66.A.70(d) explains conversion limitations for pre-Part-66 qualifications, with examples for B1.2, B3, L2, and L1C licences, and notes that removal of limitations is covered by 66.A.50(c).
* Summary by Aviation.Bot - Always consult the original document for the most accurate information.
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