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All aircraft operators
The purpose of this Continuing Airworthiness Notice (CAN) is to remind operators of their responsibility for continuing airworthiness and to publish the application and approval process (see section below), and the conditions under which an operator (not deemed an essential business*) may operate or maintain their aircraft during the period of COVID-19 restrictions (Alert Level 4 and those operators unable to operate under Alert Level 3 restrictions).
Revision 1 of this CAN is raised to address the different COVID-19 restrictions in Alert Level 4 and Level 3.
Note: This CAN does not address aircraft operations beyond those specifically required to ensure continuing airworthiness, nor does it address operation or maintenance for those deemed essential service providers (who do not require authorisation).
*Essential business is explained on the Government COVID-19 website(external link)
This CAN is prompted by the introduction of the government’s COVID-19 Level 4 Lockdown restrictions, which have resulted in the cessation of aircraft operations deemed non-essential services. For those operators affected, aircraft may be in storage for several weeks with restrictions in place preventing both operation and maintenance. Under these circumstances, operators will face costly and time-consuming maintenance activities following the easing of COVID-19 restrictions, which will prolong the NZ aviation systems return to operation.
On Saturday 18 April 2020 the Director General of Health agreed to allow aircraft that are at risk to be maintained in accordance with the manufacturer’ instructions during all Alert Levels (Alert Level 4 and those operators unable to operate under Alert Level 3 restrictions).
This revised CAN is prompted by the introduction of the government’s COVID-19 Level 3 Lockdown restrictions, which continue to restrict aircraft operations deemed recreational activity. Under COVID-19 Level 3, maintenance of all aircraft in accordance with manufacturer’s instructions is permitted, however, operation of recreational aircraft (i.e. private, non-commercial operators) remains prohibited unless authorised by CAA.
Recommendation:
If a breach of Alert Level 4 or Level 3 restrictions is required, CAA approval must be requested prior to maintenance activity, flight, or operation of, an aircraft.
Participants undertaking any aviation activities during COVID-19 restrictions must ensure that they
Under Alert Level 4 –
CAA will approve urgent maintenance of aircraft, provided there is a demonstrable need for essential maintenance
Operators who wish to fly their aircraft to a maintenance location to enable preservation action to be completed should follow the application process below.
Under Alert Level 3 -
CAA approval must be requested prior to flight, or operation, of recreational aircraft for the purposes of either-
Operators who wish to fly their aircraft as detailed above, should follow the application process below.
Operators who wish to fly an aircraft which has not been maintained in accordance with its maintenance schedule must also apply to CAA for a special flight permit, detailing the items of non-compliance. CAA will not charge for the issuance of a Special Flight Permit under these circumstances.
Note: A certificate of fitness for flight (which is normally required for the issue of a special flight permit) will not be required if the reason for the aircraft not being airworthy is limited to maintenance schedule over-run.
Application and Approval process:
Operators must complete CAA 24091C19 (available on CAA website at FORMS and return to airworthiness@caa.govt.nz.
Where possible, groups who are subject to the same operating provisions (aero clubs for example) are encouraged to make a combined application.
Approval will be granted by letter detailing those individuals approved to conduct activities during the COVID 19 restriction period.
Restricted aircraft operation to ensure continuing airworthiness.
Where aircraft ICA’s identify a minimum utilisation (e.g. 1 hour flight every 30 days, etc.) to ensure continuing airworthiness and no other practicable preservation procedure is available, operators must ensure compliance with the following:
‘Flight of xxx duration completed to ensure continuing airworthiness of the aircraft during COVID-19 restrictions in accordance with (insert specific ICA reference)’.
Relocation of aircraft to a maintenance provider.
Under Alert Level 4 –
Where an aircraft needs to be relocated to another aerodrome so that essential maintenance activity can take place, a one-off ferry flight for the purposes of maintenance may be authorised provided there is a clear need for the flight and this flight, including crew details, location of departure, location of arrival and expected date, must be included in the request for authorisation
Under Alert Level 3 –
Where a recreational aircraft needs to be relocated to another aerodrome for the purpose of undergoing maintenance in accordance with manufacturer’s instructions, a return ferry flight for the purposes of maintenance may be authorised.
Details of the need for the flight, crew details, location of departure, location of arrival and expected date, must be included in the request for authorisation.
Activity that is not permitted
For non-essential service providers –
Any flying activity not directly related to ensuring continuing airworthiness, or transiting to and from maintenance provider (i.e. no BFR, no competency checks or training).
An activity that is not related to maintenance to prevent degradation of airworthiness.
For recreational aircraft –
Any flying activity not directly related to ensuring continuing airworthiness, or transiting to and from maintenance provider (i.e. no BFR, no competency checks or training).
Maintenance on recreational aircraft not required for continuing airworthiness in accordance with the manufacturer’s instructions is not permitted under Alert Level 3 (i.e. no third-party modifications).
Process for Authorisation:
Note: postal and hand submissions will not be accepted.
Note: that any missing details means you will not receive an authorisation, and due to the expected volume of requests you will only receive a “declined” message and not receive a request for further information.
(The more complete, concise and clearer the application, the quicker the application can be processed) :
Maintenance actions to ensure continuing airworthiness
(for aircraft maintenance activity for non-essential operators under Level 4 restrictions & only required if maintenance activity requires a breach under Level 3 restrictions)
Relocation of aircraft to a maintenance provider
(for restricted aircraft operation for non-essential operators under Level 4; & recreational (e.g. private/non-commercial) operators under Level 3 restrictions)
Restricted aircraft operation to ensure continuing airworthiness
(for restricted aircraft operation for non-essential operators under Level 4; & recreational (e.g. private/non-commercial) operators under Level 3 restrictions)
Maintenance and Operation Practices
The following practice criteria provide guidance for those involved in the maintenance and operation of affected aircraft:
Minimise the number of maintenance staff working during Alert Level 3 or 4.
Operate split shifts, or introduce staggered start times and meal breaks.
Adhere to the physical distancing requirements to ensure at least a 2m physical separation between staff. For further information refer: https://covid19.govt.nz/covid-19/how-were-uniting/physical-distancing/(external link)
Enforcement
New Zealanders are relying on each other to keep everyone safe and stop the spread of COVID-19. If operators are too generous in their interpretation of what is essential or flout these requirements, then the Government will take further action and breaches will be reported to the New Zealand Police.
For Lycoming engine preservation for stored engines refer to Lycoming Service Letter No. L180B, dated 13 November 2001, or later revision.
For Continental engine preservation for stored engines refer to Continental Aerospace Technologies Service Bulletin SB20-03, dated 13 April 2020, or later revision.