66.A.70 Conversion provisions

1.As described in point 66.A.70, the conversion provisions apply to the holder of a certifying staff qualification valid in a Member State prior to the date of entry into force of Annex III (Part-66). The sentence ‘the holder of a certifying staff qualification valid in a Member State’ means any person who had a qualification valid in that Member State allowing that person the performance of activities identical to the privileges of ‘certifying staff’ contained in Regulation (EU) 1321/2014. This means that the signature of that person was sufficient to declare that the maintenance had been properly performed and the aircraft was ready for service and fit for flight in respect to such maintenance. This should not been mistaken with the responsibilities linked to the airworthiness review, which was performed at different periods (typically varying from 6 months to 3 years) in the national systems. This is an activity which is performed at very specific points of time and not after every maintenance activity. Since an airworthiness review (or equivalent term used in the national systems) is not performed after every maintenance event before the aircraft takes flight, an airworthiness review cannot be considered as a maintenance release. This means that the conversion provisions described in 66.A.70 are not applicable to persons performing airworthiness review functions unless their signature was required after every maintenance event before the aircraft can take flight.

2.The conversion applies to ‘certifying staff qualifications’ such as, for example: holding a national licence (or completed the process to obtain such a national licence); having completed a qualification process defined by the competent authority, or equivalent body under the national system, to become certifying staff; having completed the qualification requirements for certifying staff within a maintenance organisation, as defined in their procedures. This does not mean that in order to be entitled to a conversion process, the applicant has to be exercising certification privileges. A person may hold a ‘certifying staff qualification’ while not having certification privileges (or while exercising very limited certification privileges below his/her qualification) for different reasons such as, for example, the following: The person is working as ‘support staff’ in the base maintenance environment; The person has been authorised only for a very limited range of tasks (lower than what he/she would be entitled if his/her qualification is considered) since the person is working in a line station where the scope of tasks is very limited; The person holds a licence with a wider scope than the scope of the organisation where he/she is employed; The person is working outside the aviation industry or is temporarily on leave due to different reasons (medical, personal, etc). These persons are entitled to have the conversion performed in accordance with the full scope of their qualification and the full privileges that they would be entitled to hold on the basis of such qualification.

3.As described in point 66.A.70, certifying staff qualifications eligible for conversion are those valid ‘prior to the date of entry into force of Annex III (Part-66)’, which means those qualifications valid before the following dates: 28 September 2005 for aircraft above 5 700 kg MTOM; 28 September 2006 for aircraft of 5 700 kg MTOM and below. Nevertheless, since the B3, B2L and L licences did not exist at those dates, certifying staff qualifications eligible for conversion to a B3, B2L and L licence are those valid before the competent authority had the obligation to start issuing such licences, which means the following: for the B3 licence, those qualifications valid before 28 September 2012; for the B2L licence, those qualifications valid before 5 March 2019; for the L licence, those qualifications valid before 1 October 2019.

4.Although only those certifying staff qualifications gained prior to the dates indicated above are eligible for conversion, this does not mean that the application for conversion has to be submitted prior to those dates. The applicant is entitled to have the conversion performed irrespective of when he/she applies for conversion.

5.A certifying staff qualification can be subject to more than one conversion process and can also be converted to more than one licence (sub)category (with any applicable limitations). This could be the case, for example, of a person who already had the certifying staff qualification converted in the past to a B1.2 licence with limitations linked to some missing elements of the Part-66 Appendix I and II standard (following 66.A.70(c)). This person would be entitled to apply and have his/her certifying staff qualification converted to a B1.2 or a B3 or L licence on the basis of 66.A.70(d), which would mean no need to compare with the Part-66 Appendix I, II or VII standard, introducing only those limitations required in order to maintain the existing privileges.

For example, a limitation could be where a person holds a pre-existing certifying staff qualification which covered, to the standard of Part-66 Appendix I and II, all the modules/subjects corresponding to the B1 licence except for electrical power systems. This person would be issued a Part-66 aircraft maintenance licence in the B1 category with a limitation (exclusion) on electrical power systems. For removal of limitations, refer to 66.A.50(c).

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).