Joint

Aviation
Requirements

JAR–66
Certifying Staff
Maintenance

03.04.98

Printed and distributed by Westward Digital Limited, 37 Windsor Street, Cheltenham, Glos. GL52 2DG, United Kingdom
on behalf of the Joint Aviation Authorities Committee.
The members of the Joint Aviation Authorities Committee are representatives of the Civil Aviation Authorities of
the countries that have signed the ‘Arrangements Concerning the Development and the Acceptance of Joint
Aviation Requirements’. A list of these countries is kept by European Civil Aviation Conference, 3 bis Villa Emile
Bergerat, 92522 NEUILLY SUR SEINE Cedex, France.*

Applications for further copies of the Joint Aviation Requirements should be addressed to Westward Digital Ltd.,
37 Windsor Street, Cheltenham, GL52 2DG, United Kingdom (Fax No. (44) 1242 584 139).

Enquiries regarding the contents should be addressed to JAA Headquarters, Saturnusstraat 8-10, PO Box 3000,
2130 KA HOOFDDORP, Netherlands (Fax No. (31) 23 5621714).

* These countries are:-

Austria, Belgium, Cyprus, Czech Republic, Denmark, Finland, France, Germany, Greece, Hungary,
Iceland, Ireland, Italy, Luxembourg, Malta, Monaco, Netherlands, Norway, Poland, Portugal, Slovakia,
Slovenia, Spain, Sweden, Switzerland, Turkey and United Kingdom.

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 JAR–66

CONTENTS (Layout)

JAR–66

CERTIFYING STAFF – MAINTENANCE

FOREWORD

CHECK LIST OF PAGES

PREAMBLES

SECTION 1 – REQUIREMENTS

SECTION 2 – ACCEPTABLE MEANS OF COMPLIANCE AND

INTERPRETATIVE/EXPLANATORY MATERIAL (AMC AND IEM)

APPENDICES: 1, 2, AND 3.

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CONTENTS (Details)

JAR–66

CERTIFYING STAFF – MAINTENANCE

Paragraph Page

FOREWORD F-1
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PREAMBLES P-l

SECTION 1 – REQUIREMENTS
General and Presentation 1–0–1
JAR 66.1 General 1-1
JAR 66.3 Effectivity 1-1
JAR 66.5 Definitions 1-1
JAR 66.10 Applicability 1-2
JAR 66.13 Application and issue 1-2
JAR 66.15 Eligibility 1-2
JAR 66.20 Categories and certification privileges 1-2
JAR 66.25 Basic knowledge requirements 1-3
JAR 66.30 Experience requirements 1-3
JAR 66.40 Continuity of the aircraft maintenance licence 1-4
JAR 66.45 Type/Task training and ratings 1-4
JAR 66.50 Medical fitness 1-4
JAR 66.55 Evidence of qualification 1-4
JAR 66.60 Equivalent safety cases 1-5
JAR 66.65 Revocation, suspension or limitation of the JAR–66 aircraft maintenance
licence 1-5

SECTION 2 – ACCEPTABLE MEANS OF COMPLIANCE AND INTERPRETATIVE/

EXPLANATORY MATERIAL (AMC & IEM)
General and Presentation 2–0–1
AMC 66.1 General 2-1
IEM 66.15(b) Eligibility 2-2
AMC 66.20(b) Categories and Certification privileges 2-2
IEM 66.25(a) Basic knowledge requirements 2-3
AMC 66.25(c) Basic knowledge requirements 2-3
AMC 66.30(a), (b), (c) Experience requirements 2-4
AMC 66.30(d) Experience requirements 2-5
AMC 66.30(e) Experience requirements 2-5
AMC 66.40 Continuity of the aircraft maintenance licence 2-5
IEM 66.40 Continuity of the aircraft maintenance licence 2-5
AMC 66.45(a) Type/Task ratings and training 2-6
AMC 66.45(b) Type/Task ratings and training 2-6
IEM 66.45(b), (c) Type/Task ratings and training 2-7
AMC 66.45(c) Type/Task ratings and training 2-7

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CONTENTS (continued)

Paragraph Page

IEM 66.45(d) Type/Task ratings and training 2-7

AMC 66.50 Medical fitness 2-8
IEM 66.55 Evidence of qualification 2-8
AMC 66.60 Equivalent safety cases 2-8
IEM 66.65 Revocation, suspension or variation of the
JAR–66 aircraft maintenance licence 2-8

APPENDICES:
1 AMC 66.25 Basic Knowledge 2-App 1-1

2 Aircraft Maintenance Licence Application Form & Example of Licence Format 2-App 2-1

3 JAA Full Member States 2-App 3-1

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 JAR–66

FOREWORD

1 The Civil Aviation Authorities of certain countries have agreed common comprehensive and
detailed aviation requirements (referred to as the Joint Aviation Requirements (JARs )) with a
view to minimising Type Certification problems on joint ventures, to facilitate the export and
import of aviation products, and make it easier for maintenance and operations carried out in
one country to be accepted by the Civil Aviation Authority in another country. In addition there is
common agreement that flight and maintenance personnel should be trained and qualified to a
common standard to assist Industry in obtaining suitable staff and permit easy movement of
such staff across the borders of JAA Countries.

2 The JAR are recognised by the Civil Aviation Authorities of participating countries as an
acceptable basis for showing compliance with their national airworthiness codes.

3 Whilst this JAR has been numbered to align with FAR Part 66 of the United States of America
because the subject matter is the same, the detailed content is at variance with FAR Part 66.

Harmonisation with the United States remains the goal but in the meantime the Federal Aviaton
Administration has issued a Notice of Proposed Rulemaking for FAR Part 66 which will bring
FAR Part 66 closer to the JAR–66 standard.

4 JAR-66 is intended to provide a single standard for future maintenance certifying staff
throughout the JAA countries and as such has been issued with no national variants. It should
therefore be understood that when existing maintenance certifying staff are converted to
JAR–66, limitations may be applied to such staff if they do not meet the full JAR–66 standard.
Despite the limitations existing certifying staff will retain their existing authority to release to
service, subject of course, to continued satisfactory performance.

5 The Civil Aviation Authorities may also use this JAR as a basis for the qualification of certifying
staff to issue certificates of release to service in the non commercial air transport sector. These
certifying staff will have their qualifications endorsed in the JAR–66 aircraft maintenance licence
but such privileges will be limited to certifying under the control of the particular Civil Aviation
Authority in accordance with National legislation.

6 Future development of the requirements for this JAR will be in accordance with the agreed
amendment procedures. Broadly, these procedures are such that amendment of JAR–66 can be
proposed by the Civil Aviation Authority of any of the participating countries and by any
organisation represented on the Joint Steering Assembly.

7 The Civil Aviation Authorities have agreed they should not unilaterally initiate amendment of
their national codes without having made a proposal for amendment of the JAR-66 in
accordance with the agreed procedure.

8 Amendments to the text in this JAR–66 are usually issued initially as ‘Orange Paper’
Amendments. These show an effective date and have the same status and applicability as
JAR–66 from that date. Orange Paper Amendments are incorporated into the printed text by
means of a ‘ Change’.

9 New, amended and corrected text is enclosed within heavy brackets.

10 The remainder of the text in this JAR makes reference to JAA full member Authorities .This is
intended to reflect the fact that whilst all the Civil Aviation Authorities subscribe to the concept
of common JARs etc., only the JAA full member Authorities have agreed mutual recognition of
certificates, licences and approvals on the basis of standardisation audits. Nothing however
prevents a JAA candidate member Authority from issuing a certificate, licence or approval on
the basis of a JAR even though it may not be mutually recognised by the JAA full member
Authorities.

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JOINT AVIATION REQUIREMENTS

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APPROVED MAINTENANCE TRAINING

FIRST ISSUE, DATED TBD

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 JAR–66

PREAMBLES

JAR–66

The preambles are intended to be a summarized record of the main changes introduced by each
amendment of JAR–66.

Issued 03.04.98

New requirement for the maintenance certifying staff to qualify under the authority of a JAR–145
organisation to issue JAR–145.50 certificates of release to service.

It should however be noted that this first issue of JAR–66 is limited to the release to service of
aeroplanes and helicopters with a maximum take off mass of 5700 kg and above used for commercial
air transport.

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 JAR–66

SECTION 1 – REQUIREMENTS

1 GENERAL

This Section 1 contains the Requirements for Certifying Staff – Maintenance.

2 PRESENTATION

2.1 The requirements of JAR–66 are presented in two columns on loose pages, each page being
identified by the date of issue or the Change number under which it is amended or reissued.

2.2 Sub-headings are in italic typeface.

2.3 Explanatory Notes not forming part of the requirements appear in smaller typeface.

2.4 New, amended and corrected text is enclosed within heavy brackets.

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SECTION 1
JAR 66.1 General
(See AMC 66.1)
(a) JAR–145 requires appropriately
authorised certifying staff to issue a certificate
of release to service on behalf of the JAR–145
approved maintenance organisation when
satisfied that all required maintenance has been
completed.
(b) Except where stated otherwise in
paragraphs (c), (d), (e)and (f), certifying staff
responsible for issuing the certificate of release
to service must be qualified in accordance with
the appropriate requirements of this JAR–66.
(c) This JAR–66 is limited to those
certifying staff responsible for issuing the
certificate of release to service for aeroplanes
and helicopters with a maximum take off mass of
5700 kg and above.
Note: The application of JAR 66 to aeroplanes and
helicopters with a maximum take off mass below
5700 kg, airships and aircraft components will be
considered in a future issue. Aircraft components
include engines, auxiliary power units and propellers.
(d) Personnel authorised to exercise
certification privileges in accordance with
National aviation regulations valid before the
effective date of JAR–66, may continue to
exercise these privileges.
(e) Personnel undergoing a course of
approved basic or type training at the
JAR–66.3(b) compliance date in accordance
with National aviation regulations valid before
the effective date of JAR–66, may continue to be
qualified in accordance with these National
aviation regulations. The qualifications gained
following such training will be recognised for
the purposes of certification privileges in
accordance with JAR–66.1(d).
(f) Certifying staff qualified in accordance
with paragraph (d) or (e) may continue to
exercise the authorisation except in the case of
adding other basic categories / sub-categories of
qualification to that authorisation when the
appropriate additional requirements of JAR–66
will apply to such extension. Certifying staff
qualified in accordance with paragraph (d) or (e)
may extend the scope of their authorisation to
include new aircraft types subject to compliance
with National aviation regulations valid before
the effective date of JAR–66.
(g) Notwithstanding that paragraph (d), (e)
and (f) personnel may continue to exercise such
privileges, such personnel must be issued a
1–1
JAR–66
JAR 66.1(g) (continued)
JAR–66 aircraft maintenance licence based upon
the National qualification without further
examination but within the time limits of JAR
66.3 (d). The JAR–66 aircraft maintenance
licence may contain technical limitations in
relation to JAR–66 where not appropriately
qualified but does not change any existing
certification privileges. Technical limitations
will be deleted, as appropriate, when the person
satisfactorily sits the relevant conversion
examination.
JAR 66.3 Effectivity
(a) This JAR–66 was first issued on
03 April 1998 and becomes effective on 01 June
1998.
(b) After 01 June 2001 any person required
to be approved in accordance with JAR–66.1(b)
or (f) must be in compliance with this JAR–66.
(c) A JAR–66 aircraft maintenance licence
may be issued by the JAA full member Authority
during the sub-paragraph (b) transition period.
(d) Any person required by JAR–66.1 (g) to
convert a National qualification to a JAR–66
aircraft maintenance licence must do so not later
than 10 years after the end of the transition
period of sub-paragraph (b).
JAR 66.5 Definitions
For the purpose of this JAR–66, the following
definitions shall apply:
‘Aircraft maintenance licence’ means a
document issued as evidence of qualification
confirming that the person to whom it refers has
met the JAR–66 knowledge and experience
requirements for any aircraft basic category and
aircraft type rating specified in the document.
Note: The aircraft maintenance licence alone does
not permit the holder to issue certificates of release to
service in respect of aircraft used for commercial air
transport. To issue a certificate of release to service
for such aircraft, the aircraft maintenance licence
holder must in addition hold a JAR–145 certification
authorisation issued by the JAR–145 approved
maintenance organisation.
‘Certification’ means the issuance of a
certificate of release to service.
03.04.98
JAR–66
JAR 66.5 (continued)
‘JAA full member Authority’ means an
Authority who is a full member of the JAA
which means that any approval certificate or
licence issued in accordance with the JAR’s by
such an Authority will be recognised and
accepted by all other such Authorities.
Note: The JAA full member States are listed in
Section 2 Appendix 3. See also paragraph 10 of the
Foreword.
‘Organisation procedures’ means the
procedures applied by the JAR–145 approved
maintenance organisation in accordance with the
maintenance organisation exposition within the
scope of the approval.
JAR 66.10 Applicability
(a) This JAR–66 prescribes the
requirements for the qualification of those
personnel authorised by a JAR–145 approved
maintenance organisation to issue certificates of
release to service in accordance with
JAR–145.50.
Such personnel are required to hold a valid
type rated JAR–66 aircraft maintenance licence,
which attests to their knowledge and experience
and a valid JAR–145 certification authorisation
which grants certification privileges to the
individual.
(b) For the JAR–66 aircraft maintenance
licence compliance is required with JAR–66.15,
JAR–66.25 and JAR–66.30 for the appropriate
JAR–66.20 basic category or categories.
The JAR–66 aircraft maintenance licence
will be endorsed with the relevant JAR–66.20
basic category / categories and where
appropriate any aircraft type ratings granted
under JAR–66.45.
Note: The JAR–66 aircraft maintence licence can be
issued without any aircraft type ratings, but it should
be remembered that an aircraft type rating is one of
the prerequisites for a JAR–145 certification
authorisation.
(c) For the JAR–145 certification
authorisation compliance is required with
paragraph (b), JAR–66.40, JAR–66.45, JAR–
66.50 and JAR–66.55.
Note: JAR–145 contains additional requirements to
qualify for JAR–145 certification authorisation
03.04.98
SECTION 1
JAR 66.13 Application and Issue
(a) An application for a JAR 66.10 (b)
aircraft maintenance licence or amendment to
such licence must be made on a form and in a
manner prescribed by the JAA full member
Authority and submitted to such Authority.
Note: Appendix 2 of Section 2 contains an example
application form.
(b) An applicant who meets the appropriate
requirements of JAR–66.10(b) and has paid any
charges prescribed by the JAA full member
Authority is entitled to the JAR–66 aircraft
maintenance licence.
(c) The JAR–66 aircraft maintenance licence
is issued by the JAA full member Authority but
the process of preparing such licence for issue
may be delegated to appropriately approved
JAR–145 maintenance organisations.
Note: The issue of the JAR–145 certification
authorisation is carried out by the JAR–145 approved
maintenance organisation after establishing
compliance with appropriate paragraphs of JAR–66
and JAR–145.
JAR 66.15 Eligibility
(See IEM 66.15)
(a) Certifying staff must not be less than
21 years of age.
(b) Certifying staff must be able to read,
write and communicate to an understandable
level in the language(s) in which the technical
documentation and organisation procedures
necessary to support the issue of the certificate
of release to service are written.
JAR 66.20 Categories and certification
privileges
(See AMC 66.20)
(a) Certifications are made in accordance
with the procedures of the JAR–145 approved
maintenance organisation and within the scope
of the authorisation.
(b) Certifying staff qualified in accordance
with this JAR–66, and holding a valid aircraft
maintenance licence with where applicable the
appropriate type ratings, will be eligible to hold
1–2
SECTION 1
JAR 66.20(b) (continued)
a JAR–145 certification authorisation in one or
more of the following categories:
(1) A category A certifying staff
authorisation permits the holder to issue
certificates of release to service following
minor scheduled line maintenance and simple
defect rectification, as specified in JAR–145,
within the limits of tasks specifically
endorsed on the authorisation. The
certification privileges are restricted to work
that the authorisation holder has personally
performed. Category A is sub-divided into
sub-categories relative to combinations of
aeroplanes, helicopters, turbine and piston
engines.
Note: Category B1 certifying staff authorisation
automatically permits certification in the
appropriate A sub-categories. Category B2
certifying staff can qualify for any A sub-
category as can any avionic mechanic subject to
compliance with the appropriate A sub-category
requirements.
(2) A category B1 certifying staff
authorisation permits the holder to issue
certificates of release to service following
line maintenance, including aircraft structure,
powerplants and mechanical and electrical
systems. Replacement of avionic line
replaceable units, requiring simple tests to
prove their serviceability, is also included in
the privileges. Category B1 is sub-divided
into sub-categories relative to combinations
of aeroplanes, helicopters, turbine and piston
engines.
(3) A category B2 certifying staff
authorisation permits the holder to issue
certificates of release to service following
line maintenance on avionic and electrical
systems.
(4) A category C certifying staff
authorisation permits the holder to issue
certificates of release to service following
base maintenance. The authorisation is valid
for the aircraft in its entirety, including all
systems.
Note: JAR–145 specifies the personnel required to
support category C certifying staff in base
maintenance, including in particular the requirement
for qualified category B1 and B2 staff.
1–3
JAR–66
JAR 66.25 Basic knowledge requirements
(See AMC 66.25 and IEM 66.25))
(a) Certifying staff must demonstrate by
examination a level of knowledge acceptable to
the JAA full member Authority, in subject
modules appropriate to the JAR–66.20 category
for which a JAR–66 aircraft maintenance
licence is issued or extended.
(b) The levels of knowledge are directly
related to the complexity of certifications
appropriate to the particular JAR–66.20 category
which means that category A must demonstrate a
limited but adequate level of knowledge,
whereas category B1 and B2 must demonstrate a
complete level of knowledge in the appropriate
subject modules. Category C certifying staff
must meet the relevant level of knowledge for
B1 or B2.
Note: JAR–66 Section 2 Appendix 1 contains
detailed information on category A, B1 and B2 levels
of knowledge.
(c) Full or partial credit against the basic
knowledge requirements and associated
examination will be given for any other technical
qualification considered by the JAA full member
Authority to be equivalent to the JAR–66
knowledge standard.
JAR 66.30 Experience requirements
(See AMC 66.30)
(a) Certifying staff must meet a minimum
civil aircraft maintenance experience
requirement appropriate to the JAR–66 aircraft
maintenance licence sought, which will be
reduced by the JAA full member Authority when
satisfied that either JAR–147 approved training
or other appropriate technical training has been
received. For category A and B1 or B2 the
experience must be practical which means being
involved with a representative cross section of
maintenance tasks on aircraft.
(b) The minimum civil aircraft maintenance
experience before possible paragraph (a)
reductions means, for category A three years
and for category B1 or B2 five years.
(c) The minimum civil aircraft maintenance
experience for category C is three years
qualified as a B1 or B2 certifying staff in line
maintenance, or, in base maintenance supporting
the category C certifying staff, or, a combination
of both. Alternatively, the minimum civil aircraft
03.04.98
JAR–66
JAR 66.30(c) (continued)
experience for category C certifying staff
qualified by holding an academic degree in a
technical discipline from a university or other
higher educational institute accepted by the JAA
full member Authority is three years on a
representative selection of tasks directly
associated with aircraft maintenance including
six months of observation of base maintenance
tasks.
(d) For all certifying staff, at least 1 year of
the required experience must be recent
maintenance experience on aircraft typical of the
category/sub-category for which the JAR–66
aircraft maintenance licence is sought.
(e) Aircraft maintenance experience gained
outside a civil aircraft maintenance environment
will be accepted by the JAA full member
Authority when satisfied that such maintenance
is equivalent to that required by JAR–66 but
additional experience of civil aircraft
maintenance will be required to ensure
understanding of the civil aircraft maintenance
environment.
JAR 66.40 Continuity of the aircraft
maintenance licence
(See AMC and IEM 66.40)
The JAR–66 aircraft maintenance licence
holder must ensure that the information
contained in the licence is the same as recorded
in the licence copy held by the original issuing
JAA full member Authority by submitting the
said licence to that JAA full member Authority
for review no later than 5 years after the last
issue or amendment of the licence as
appropriate. Failure to carry out this action
would invalidate any JAR–145 certification
authorisation issued on the basis of such JAR–66
aircraft maintenance licence and may require
recent aircraft maintenance experience and / or
the resit of some examinations before re-issue of
the licence. The JAA full member Authority will
decide for each particular case.
JAR 66.45 Type/task training and ratings
(See AMC and IEM 66.45)
(a) Category A certifying staff are required
to hold an appropriate JAR–66 aircraft
maintenance licence prior to the grant of a JAR–
145 certification authorisation on a specific
aircraft type. JAR–145 certification
03.04.98
SECTION 1
JAR 66.45(a) (continued)
authorisations may only be granted following the
satisfactory completion of the relevant category
A aircraft task training carried out by an
appropriately approved JAR–145 or JAR–147
organisation.
(b) Category B1 and B2 certifying staff are
required to hold an appropriate aircraft type
rated JAR–66 aircraft maintenance licence prior
to the grant of a JAR–145 certification
authorisation on a specific aircraft type. Ratings
will be granted following satisfactory
completion of the relevant category B1 or B2
aircraft type training approved by the JAA full
member Authority or by an appropriately
approved JAR–147 maintenance training
organisation.
(c) Category C certifying staff are required
to hold an appropriate aircraft type rated JAR–
66 aircraft maintenance licence prior to the grant
of a JAR–145 certification authorisation on a
specific aircraft type. Ratings will be granted
following satisfactory completion of the relevant
category C aircraft type training approved by the
JAA full member Authority or by an
appropriately approved JAR–147 maintenance
training organisation except in the case of a
category C person qualified by holding an
academic degree as specified in JAR–66.30 (c),
where the first relevant aircraft type training
must be at the category B1 or B2 level.
(d) Completion of approved aircraft task or
type training, as required by sub-paragraphs (a)
to (c) above, must be satisfactorily
demonstrated by an examination.
JAR 66.50 Medical fitness
(See AMC 66.50)
Certifying staff must not exercise the
privileges of their certification authorisation if
they know or suspect that their physical or
mental condition renders them unfit to exercise
such privileges.
JAR 66.55 Evidence of qualification
(See IEM 66.55)
Certifying staff qualified in accordance with
this JAR–66 will be issued with an aircraft
maintenance licence by the JAA full member
Authority as evidence of one of the
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JAR 66.55 (continued) JAR 66.65(a)(2) (continued)

qualifications necessary for the grant of a JAR– provisionally suspend the JAR–66 aircraft
145 certification authorisation. Certifying staff maintenance licence without prior notice until
must be able to produce their licence if the sub-paragraph (a)(1) procedure is
requested by an authorised person within a complete.
reasonable time.
(b) For the JAA full member Authority to
consider a person to be not a fit and proper
person means that there is clear evidence that
the person has knowingly carried out or been
JAR 66.60 Equivalent safety cases involved in one or more of the following
(See AMC 66.60) activities;
The JAA full member Authority may exempt (1) Obtained the JAR–66 aircraft
any person, required to be qualified in maintenance licence and/or the JAR–145
accordance with JAR–66, from any requirement certification authorisation by falsification of
in JAR–66 when satisfied that a situation exists submitted evidence.
not covered by JAR–66 and subject to
(2) Failed to carry out requested
compliance with any supplementary condition(s)
maintenance combined with failure to to
the JAA full member Authority considers
report such fact to the organisation that
necessary to ensure equivalent safety. Such
requested the maintenance.
exemption and supplementary condition(s) must
be agreed by the JAA full member Authorities to (3) Failed to carry out required
ensure continued recognition of the person. maintenance resulting from own inspection
combined with failure to report such fact to
the organisation for whom the maintenance
JAR 66.65 Revocation, suspension or
was intended to be carried out.
limitation of the JAR–66 aircraft
maintenance licence (4) Negligent maintenance.
(See IEM 66.65)
(5) Falsification of the maintenance
(a) The JAA full member Authority may, on record.
reasonable grounds after due enquiry, revoke,
(6) The issue of a certificate of
suspend or limit the JAR–66 aircraft
release to service knowing that the
maintenance licence or direct the JAR–145
maintenance specified on the certificate of
approved maintenance organisation to revoke,
release to service has not been carried out or
suspend or limit the JAR–145 certification
without verifying that such maintenance has
authorisation if the JAA full member Authority
been carried out.
is not satisfied that the holder of the licence and
authorisation is a fit and proper person to hold (7) Carrying out maintenance or
such licence and authorisation subject to the issuing a certificate of release to service when
conditions of paragraph (a)(1) or (a)(2) as adversely affected by alcohol or drugs.
appropriate.
(1) Before revoking or limiting the
JAR–66 aircraft maintenance licence or
directing the JAR–145 approved maintenance
organisation the JAA full member Authority
must first give at least 28 days notice to the
affected party or parties in writing of its
intention so to do and of the reasons for its
INTENTIONALLY LEFT BLANK
proposal and must offer the affected party or
parties an opportunity to make representations
and the JAA full member Authority will
consider those representations.
(2) In the case where the JAA full
member Authority has determined that the
safe operation of the aircraft is adversely
affected the JAA full member Authority may
in addition to sub-paragraph (a)(1)

1–5 03.04.98
JAR–66 SECTION 1

INTENTIONALLY LEFT BLANK

03.04.98 1–6
SECTION 2 JAR–66

SECTION 2 – ACCEPTABLE MEANS OF COMPLIANCE AND INTERPRETATIVE /

EXPLANATORY MATERIAL (AMC & IEM)

1 GENERAL

1.1 This Section contains Acceptable Means of Compliance and Interpretative/Explanatory

Material that has been agreed for inclusion into JAR–66.

1.2 Where a particular JAR paragraph does not have an Acceptable Means of Compliance or
Interpretative/Explanatory Material, it is considered that no supplementary material is required.

2 PRESENTATION

2.1 The Acceptable Means of Compliance and Interpretative/Explanatory Material are presented
in full page width on loose pages, each page being identified by the date of issue or the Change
number under which it is amended or reissued.

2.2 A numbering system has been used in which the Acceptable Means of Compliance or
Interpretative/Explanatory Material uses the same number as the paragraph in its JAR to which it is
related. The number is introduced by the letters AMC or IEM to distinguish the material from the JAR
itself.

2.3 The acronyms AMC and IEM also indicate the nature of the material and for this purpose the
two types of material are defined as follows :

Acceptable Means of Compliance (AMC) illustrate a means, or several alternate means, but not
necessarily the only possible means by which a requirement can be met. It should however be noted
that where a new AMC is developed, any such AMC (which may be additional to an existing AMC) will
be amended into the document following consultation under the NPA procedure.

Interpretative/Explanatory Material (IEM) helps to illustrate the meaning of a requirement.

New AMC or IEM material may, in the first place, be made available rapidly by being published as a
Temporary Guidance Leaflet (TGL). Maintenance TGLs can be found in the Joint Aviation Authorities
Administrative & Guidance Material, Section Two – Maintenance, Part Three: Temporary Guidance.
The procedures associated with Temporary Guidance Leaflets are included in the Section 2 –
Maintenance, Part Two, Chapter 11.

2.4 Explanatory Notes not forming part of the AMC or IEM text appear in a smaller typeface.

2.5 New, amended or corrected text is enclosed within heavy brackets.

2–0–1 03.04.98
JAR–66 SECTION 2

INTENTIONALLY LEFT BLANK

03.04.98 2–0–2
SECTION 2 JAR–66

ACCEPTABLE MEANS OF COMPLIANCE AND INTERPRETATIVE/EXPLANATORY MATERIAL

(AMC AND IEM)

AMC 66.1
General
See JAR–66.1

1 Certification authorisations or qualifications held in accordance with JAR–66.1(d), (e) or (f)

are recognised to allow the continuation of previously held certification privileges that do not meet the
full requirements of JAR–66. Such previously held certification privileges may continue to be used
without any change in scope or limitation as permitted by the pre JAR–66 National aviation
regulations. It should be noted that holders of such JAA full member Authority issued authorisations
or qualifications may transfer such rights between JAR–145 approved maintenance organisations
within that JAA full member State but it should be noted that JAR 66.1 (g) requires such authorisation
or qualification to be replaced by a JAR–66 aircraft maintenance licence within a specified time
period.

2 In the case of certifying staff qualified in accordance with JAR–66.1(d) or (e) and who wish to
add additional aircraft types and/or tasks as permitted by JAR–66.1 (f) within existing basic
categories or sub-categories, the type and/or task qualification requirements of the pre JAR–66
National aviation regulations may continue to apply.

3 In the case of certifying staff qualified in accordance with JAR–66.1(d) or (e) and who wish to
extend their qualifications as permitted by JAR–66.1 (f) by adding other basic categories or sub-
categories, the relevant additional requirements of JAR–66 will apply. Such individuals will be
expected to pass a course of approved training under JAR–147 and/or examinations in the additional
subject modules/sub-modules.

4 Qualifications held under the provisions of paragraphs JAR–66.1(d) or (e) differ between JAA
full member Authorities reflecting the various qualification systems in use previously. The required
examinations in paragraph 3 above may therefore vary from JAA full member Authority to JAA full
member Authority.

5 Personnel holding pre JAR–66 National qualifications in accordance with paragraphs JAR–
66.1(d) or (e) will be granted a JAR–66 aircraft maintenance licence per JAR–66.1 (g) in the
appropriate category or sub-category without further examination except that such licence will contain
limitations in relation to any technical subject outside the established knowledge of the particular
person. For example, a person may hold a pre JAR–66 National licence or authorisation limited to the
release of the airframe and engine but not the electrical power system because the person has not
taken or passed the examination on electrical systems. This means that the person would be issued
with a JAR–66 aircraft maintenance licence in the B1 category with a limitation that it does not
include electrical power systems. The result is that the person retains all existing certification
privileges but has a limitation in relation to the JAR–66 subjects. This JAR–66 aircraft maintenance
licence will be recognised by all JAA full member States, but it should be realised that such a
limitation will not benefit the holder in the longer term as more ‘fully’ qualified personnel become
available.

6 Personnel holding pre JAR–66 National qualifications in accordance with JAR–66.1 (d) or (e)
who wish to transfer such qualification into a JAR–66 aircraft maintenance licence without the
limitations of paragraph (5) will need to pass an examination on any JAR–66 subject deemed by the
JAA full member Authority to be not covered by the pre JAR–66 National qualification in relation to
the appropriate category or sub-category being sought.

2–1 03.04.98
JAR–66 SECTION 2

IEM 66.15(b)
Eligibility
See JAR 66.15(b)

1 Certifying staff should have a general knowledge of the language used within the JAR–145
approved maintenance organisation including a knowledge of common aeronautical terms in the
language. The level of knowledge should be such that the applicant is able to:

- read and understand the instructions and technical manuals in use within the organisation;

- make written technical entries and any maintenance documentation entries, which can be
understood by those with whom they are normally required to communicate;

- read and understand the company procedures;

- communicate at such a level as to prevent any misunderstanding when exercising the privileges
of their authorisation.

2 In all cases, the level of understanding needs to be compatible with the level of certification
authorisation granted.

AMC 66.20(b)
Categories and certification privileges
See JAR 66.20(b)

1 Certifying staff may be granted a JAR–145 certification authorisation in relation to the JAR–
66 basic categories or sub-categories held and any type ratings listed on the JAR–66 aircraft
maintenance licence subject to the document being valid at the time of authorisation issue and the
continuing validity requirements of JAR–66.40 being met.

2 The following titles shown against each category designator below are intended to provide a
readily understandable indication of the job function:

Category A: Line maintenance certifying mechanic.

Category B1: Line maintenance certifying technician – mechanical.

Category B2: Line maintenance certifying technician – avionic.

Category C: Base maintenance certifying engineer.

The titles adopted by each JAA full member Authority may differ from those shown to reflect titles
used used in the national language for the above functions but the designators A, B1, B2 and C are
required by JAR–66.20.

3 Individual certifying staff need not be restricted to a single category. Provided that each
qualification requirement is satisfied, any combination of categories may be granted.

4 Tasks permitted by JAR–66.20 (b) (1) to be certified under the category A authorisation as
part of minor scheduled maintenance or simple defect rectification are as specified in JAR–145 and
agreed by the JAA full member Authority. JAR–145 contains a typical example list of such tasks.

5 For the purposes of category A minor scheduled line maintenance means any minor check up
to but not including the A check where functional tests can be carried out by the aircrew to ensure
system serviceability. In the case of an aircraft type not controlled by a maintenance programme
based upon the A/B/C/D check principle, minor scheduled line maintenance means any minor check
up to and including the weekly check or equivalent.

03.04.98 2–2
SECTION 2 JAR–66

AMC 66.20(b) (continued)

6 The categories B1 and B2 authorisations permit certification of unscheduled defect

rectification and scheduled maintenance checks normally completed in a line maintenance
environment. The rectification of defects arising from these scheduled maintenance checks may also
be certified.

7 The category B1 authorisation also permits the certification of work involving avionic
systems, providing the serviceability of the system can be established by a simple self-test facility,
other on-board test systems/equipment or by simple ramp test equipment. Defect rectification
involving test equipment which requires an element of decision making in its application - other than a
simple go/no-go decision - cannot be certified. The category B2 will need to be qualified as category
A in order to carry out simple mechanical tasks and be able to make certifications for such work.

8 The Category A and B1 subcategories are :

A1 and B1.1 Aeroplanes Turbine

A2 and B1.2 Aeroplanes Piston

A3 and B1.3 Helicopters Turbine

A4 and B1.4 Helicopters Piston

A5 and B1.5 Reserved

9 The category C authorisation permits certification of scheduled base maintenance by the

issue of a single certificate of release to service for the complete aircraft after the completion of all
such maintenance. The basis for this certification is that the maintenance has been carried out by
competent mechanics and both category B1 and B2 staff have signed for the maintenance under their
respective specialization. The principal function of the category C certifying staff is to ensure that all
required maintenance has been called up and signed off by the category B1 and B2 staff before issue
of the certificate of release to service. Category C personnel who also hold category B1 or B2
qualifications may perform both roles in base maintenance.

IEM 66.25(a)
Basic Knowledge requirements
See JAR 66.25(a)

The basic knowledge examinations may be conducted by an appropriately approved JAR–147

training organisation or by the JAA full member Authority except that said Authority may direct that all
such examinations be conducted by appropriately approved JAR–147 training organisations.

AMC 66.25 (c)

Basic knowledge requirements
See JAR 66.25(c)

1 For an applicant being a person qualified by holding an academic degree in a aeronautical,

mechanical or electronic discipline from a recognised university or other higher educational institute
the need for any examination will depend upon the course taken in relation to Appendix 1 of this
Section 2. Recognised university or other higher educational institute means known to a JAA full
member Authority as a university or institute with a good reputation for standards and integrity.

2–3 03.04.98
JAR–66 SECTION 2

AMC 66.25(c) (continued)

2 Knowledge gained and examinations passed during previous experiences, for example, in
military aviation and civilian apprenticeships will be credited where the JAA full member Authority is
satisfied that such knowledge and examinations are equivalent to that required by Appendix 1 of this
Section 2.

AMC 66.30 (a), (b), (c)

Experience requirements
See JAR 66.30 (a), (b), (c)

1 Regarding qualification as category A certifying staff the following experience options apply:

a. 1 year recent practical maintenance experience on operating aircraft and completion of a

JAR–147 approved basic training course; or,

b. 2 years recent practical maintenance experience on operating aircraft and completion of

training considered relevant by the JAA full member Authority as a skilled worker, in a non-aviation
technical trade; or,

c. 3 years recent practical maintenance experience on operating aircraft for an applicant having
no previous relevant technical training.

2 Regarding qualification as category B1 or B2 certifying staff the following experience options

apply:

a. 2 years recent practical maintenance experience on operating aircraft and completion of a

JAR–147 approved basic training course; or,

b. 3 years recent practical maintenance experience on operating aircraft and completion of

training considered relevant by the JAA full member Authority as a skilled worker, in a non-aviation
technical trade; or,

c. 5 years recent practical maintenance experience on operating aircraft for an applicant having
no previous relevant technical training.

3 Regarding qualification as category C certifying staff:

a. The 3 years experience qualified as a category B1 or B2 certifying staff means line

maintenance certification experience as category B1 or B2 certifying staff, or, as a qualified category
B1 or B2 supporting the category C certifying staff in base maintenance, or, a combination of both.

b. The 3 years experience for an applicant holding an academic degree in a technical discipline,
from a university or other higher educational institution accepted by the JAA full member Authority
means working in a civil aircraft maintenance environment on a representative selection of tasks
including the observation of hangar maintenance, maintenance planning, quality assurance, record
keeping, approved spare parts control and engineering development.

4 Maintenance experience on operating aircraft means the experience of being involved in

maintenance tasks on aircraft which are being operated by airlines, air taxi organisations, etc. The
point being to gain sufficient experience in the environment of commercial maintenance as opposed
to only the training school environment. Such experience may be combined with approved training so
that periods of training can be intermixed with periods of experience rather like the apprenticeship.

5 The time necessary for any additional classroom training may have to be added to the
practical experience time.

03.04.98 2–4
SECTION 2 JAR–66

AMC 66.30(a), (b), (c) (continued)

6 A skilled worker is a person who has successfully completed a course of training, acceptable
to the JAA full member Authority, involving the manufacture, repair, overhaul or inspection of
mechanical, electrical or electronic equipment. The training would include the use of tools and
measuring devices.

AMC 66.30(d)
Experience requirements
See JAR 66.30(d)

1 To be considered as recent experience, at least 50% of the required 12 month experience

should be gained within the 12 month period prior to the date of application for the JAR–66 aircraft
maintenance licence. The remainder of the experience should have been gained within the 7 year
period prior to application.

2 Different aircraft types may be considered to be typical when the construction and operation
of the airframe, powerplant, systems including avionic systems are of similar technology.

AMC 66.30(e)
Experience requirements
See JAR 66.30(e)

1 For category A certifying staff the additional experience of civil aircraft maintenance will be a
minimum of 6 months. For category B1 or B2 certifying staff the additional experience of civil aircraft
maintenance will be a minimum of 12 months.

2 Aircraft maintenance experience gained outside a civil aircraft maintenance environment can
include aircraft maintenance experience gained in armed forces, coast guards, police etc. or in
aircraft manufacturing.

AMC 66.40
Continuity of the aircraft maintenance licence
See JAR 66.40

The JAR–66 aircraft maintenance licence is only accepted if issued and/or amended by the JAA full
member Authority and the holder has signed the document in ink after having checked the
correctness of the information contained therein.

IEM 66.40
Continuity of the aircraft maintenance licence
See JAR 66.40

1 The JAA full member Authority will issue the JAR–66 aircraft maintenance licence with a
5 year review date included but the licence holder remains responsible for making application for
review to the JAA full member Authority by completing the relevant sections of JAA Form 19. The
5 year review period in the licence will be extended a further 5 years each time there is a need to
amend the document for other purposes. As the JAA full member Authority automatically carries out
such a review each time there is a need to amend the licence for such items as change of address or
changes in basic categories / sub-categories or aircraft types, there is no need to submit the licence
until 3 months before the 5 year period has expired since the last licence amendment and even then
any subsequent amendment during the period obviates the need for a separate review. Acceptance
of the JAR–66 aircraft maintenance licence is not affected by recency of maintenance experience

2–5 03.04.98
JAR–66 SECTION 2

IEM 66.40 (continued)

whereas the validity of the JAR–145 certification authorisation is affected by maintenance experience
as specified in JAR–145.

2 The JAR–145 approved maintenance organisation issues the JAR–145 certification

authorisation when satisfied that compliance has been established with the appropriate paragraphs of
JAR–145 and JAR–66. In granting the JAR–145 certification authorisation the JAR–145 approved
maintenance needs to be satisfied that the person holds a valid JAR–66 aircraft maintenance licence
and may need to confirm such fact with the JAA full member Authority that issued the licence. With
regard to continued validity of the JAR–145 certification authorisation due regard should be given to
the currency of maintenance experience and training in accordance with JAR–145.

3 Where the JAA full member Authority permits the use of the particular JAR–66 aircraft
maintenance licence as the basis for the release of aircraft not required to be maintained by a
JAR–145 approved maintenance organisation it will be necessary to demonstrate 6 months of
maintenance experience in each 2 year period to ensure continuity of such licence. In the case where
it is not possible to demonstrate such maintenance experience, the JAA full member Authority will
specify the conditions to re-establish continuity of the licence.

AMC 66.45(a)
Type/task training and ratings
See JAR 66.45(a)

For category A certifying staff specific training on each aircraft type will be required reflecting the
authorised task(s) as indicated under JAR–66.20 (b) (1). The training shall include practical hands on
training and theoretical training as appropriate for each task authorised. Satisfactory completion of
training may be demonstrated by an examination and/or by workplace assessment carried out by an
appropriately approved JAR–145 or JAR–147 organisation.

AMC 66.45(b)
Type/task training and ratings
See JAR 66.45(b)

1 Type training for categories B1 and B2 certifying staff, and equivalently qualified base
maintenance staff, will be approved if the standards specified below are met. The training will
normally be divided into a mechanical course (airframe and powerplant) for category B1 certifying
staff and an avionic course for category B2 certifying staff. Limited avionics system training will be
given to B1 certifying staff where it is intended that they be authorised to replace avionic line
replaceable units. Electrical systems will be included in both categories. The type training will include
training corresponding to at least level III in accordance with ATA specification 104, where
applicable.

2 The training should give adequate detailed theoretical knowledge of the aircraft, its main
parts, systems (all existing systems in accordance with ATA 100, where applicable), equipment,
interior and applicable components. Relevant in-service problems, service bulletins and Instructions
should also be covered, including training in the systems in use for technical manuals and
maintenance procedures.

3 Knowledge is also required of relevant inspections and limitations as applicable to the effects
of environmental factors such as cold and hot climates, wind, moisture, etc.

4 Practical training should be performed to include hands on training in maintenance of the

aircraft, rigging, adjustments, replacement of line replaceable units, trouble shooting, rectification of
minor defects and functional tests of systems. The practical training should comprise a period of
4 months for certifying staff with no recent recorded previous practical experience of aircraft of

03.04.98 2–6
SECTION 2 JAR–66

AMC 66.45(b) (continued)

comparable construction and systems, including the engines, but this can be reduced to a minimum
of two weeks for certifying staff with such previous experience. A programme of structured on-job-
training (OJT) may be prepared to satisfy this practical training requirement. Practical training may be
carried out at any JAR–145 approved maintenance organisation or at the aircraft manufacturer or a
combination of both but such training will form part of the particular aircraft type training either
approved directly by the JAA full member Authority or approved via the JAR–147 requirement.

5 Before grant of the aircraft type the applicant should be able to:

a. Demonstrate by knowledge examination a detailed understanding of applicable systems (in

accordance with ATA 100), their operation and maintenance;

b. Ensure safe certification of line maintenance, inspections and routine work according to the
maintenance manual and other relevant instructions and tasks as appropriate for the type of aircraft,
for example trouble shooting, repairs, adjustments, replacements, rigging and functional checks such
as engine run, etc, if required.

c. Correctly use all technical literature and documentation for the aircraft.

IEM 66.45(b),(c)
Type/task training and ratings
See JAR 66.45(b),(c)

Type ratings granted to certifying staff will normally reflect the listing of aircraft (including engine)
types or series as they appear on the JAR–145 approved maintenance organisation's ratings, and as
covered by the type training courses.

AMC 66.45(c)
Type/task training and ratings
See JAR 66.45(c)

Type training for category C certifying staff may be at a general level, corresponding to at least level I
of ATA specification 104, where applicable, providing the applicant has previously attended and
passed at least one full training course to ATA specification 104 level III on an aircraft type of a
similar technology. Practical training is not normally required. Category C certifying staff may not
carry out the duties of category B1 or B2, or equivalent within base maintenance, unless they hold the
relevant qualifications and have passed type training according to ATA specification 104 level III.

IEM 66.45(d)
Type/task training and ratings
See JAR 66.45(c)

The examinations in respect of category B1 or B2 or C aircraft type ratings may be conducted by

appropriately approved JAR–147 training organisations or the JAA full member Authority except that
said Authority may direct that all such examinations be conducted by appropriately approved
JAR–147 training organisations.

2–7 03.04.98
JAR–66 SECTION 2

AMC 66.50
Medical fitness
See JAR 66.50

1 Medical opinion considers that alcohol present in the blood stream in any quantity affects the
ability to make decisions. It is the responsibility of all certifying staff to ensure that they are not
adversely affected.

2 The use of any legally administered drug, or medicines, including those used for the
treatment of a disease or disorder, which has been shown to exhibit adverse side effects, which
affect the decision making ability of the user, should be administered according to medical advice. No
other drugs should be used.

3 Certifying staff are responsible for ensuring that their physical condition does not adversely
affect their ability to satisfactorily certify the work for which they are responsible. Eyesight, including,
where applicable, colour vision, is particularly important in this respect.

4 In the context of this JAR, mental condition means psychological integrity, particularly in
operational attitudes or any relevant personality factor.

IEM 66.55
Evidence of qualification
See JAR 66.55

Authorised person means any person who is required to establish that the holder has a valid JAR–66
aircraft maintenance licence including the scope of such licence. Authorised persons include the
JAR–145 approved maintenance organisation for the purpose of qualifying the holder for
issue/amendment of the JAR–145 certification authorisation and any surveyor from a JAA full
member Authority.

Reasonable time means within 5 working days.

AMC 66.60
Equivalent safety cases
See JAR 66.60

All proposed equivalent safety cases should be agreed in principal with the particular JAA full
member Authority before submission to the JAA full member authorities for consideration as an
acceptable case.

IEM 66.65
Revocation, suspension or variation of the JAR–66 aircraft maintenance licence
See JAR 66.65

The procedures for handling representation regarding revocation, suspension or variation of the JAR–
66 aircraft maintenance licence are contained in JAA Administrative & Guidance Material, Section
Two – Maintenance, Part Two – Procedures.

03.04.98 2–8
SECTION 2 JAR–66

APPENDIX 1

AMC 66.25 Basic Knowledge – Introduction

1 KNOWLEDGE LEVELS – CATEGORY A, B1, B2 AND C CERTIFYING STAFF

Basic knowledge for category A, B1 and B2 certifying staff are indicated by the allocation of
knowledge levels indicators (1, 2 or 3) against each applicable subject area in this
Appendix 1. Category C certifying staff with a mechanical background should meet the
category B1 basic knowledge levels. Category C certifying staff with a avionic background
should meet the category B2 basic knowledge levels

The knowledge level indicators are defined as follows:

LEVEL 1 A familiarisation with the principal elements of the subject.

Objectives: The student should be familiar with the basic elements of the subject.

The student should be able to give a simple description of the whole subject,
using common words and examples.

The student should be able to use typical terms.

LEVEL 2 A general knowledge of the theoretical and practical aspects of the

subject.

An ability to apply that knowledge.

Objectives: The student should be able to understand the theoretical fundamentals of the
subject.

The student should be able to give a general description of the subject using,
as appropriate, typical examples.

The student should be able to use mathematical formulae in conjunction with

physical laws describing the subject.

The student should be able to read and understand sketches, drawings and
schematics describing the subject.

The student should be able to apply his knowledge in a practical manner using
detailed procedures.

LEVEL 3 A detailed knowledge of the theoretical and practical aspects of the

subject.

A capacity to combine and apply the separate elements of knowledge in a

logical and comprehensive manner.

Objectives: The student should know the theory of the subject and interrelationships with
other subjects.

The student should be able to give a detailed description of the subject using
theoretical fundamentals and specific examples.

The student should understand and be able to use mathematical formulae

related to the subject.

The student should be able to read, understand and prepare sketches, simple
drawings and schematics describing the subject.

2–App 1–1 03.04.98

JAR–66 SECTION 2

Introduction (continued)

The student should be able to apply his knowledge in a practical manner using
manufacturer’s instructions.

The student should be able to interpret results from various sources and
measurements and apply corrective action where appropriate.
Note: The Administrative & Guidance Material, Section Two - Maintenance Part Two – Procedures, Chapter 23
contains an explanation of the basic knowledge objective relative to each subject.

2. MODULARISATION

Qualification on basic subjects for each JAR–66 aircraft maintenance licence category or
sub-category should be in accordance with the following matrix. Applicable subjects are
indicated by an ‘X’:

SUBJECT A or B1 AEROPLANE A or B1 HELICOPTER B2 RESERVED

MODULES WITH: WITH:
TURBINE PISTON TURBINE PISTON AVIONICS

ENGINE(S) ENGINE(S) ENGINE(S) ENGINE(S)

1 X X X X X
2 X X X X X
3 X X X X X
4 X X X X X TO
5 X X X X X BE
6 X X X X X DEVE-
7 X X X X X LOPED
8 X X X X X
9 X X X X X
10 X X X X X
11 X X
12 X X
13 X
14 X
15 X X
16 X X
17 X X
18 Reserved

03.04.98 2–App 1–2

SECTION 2 JAR–66

APPENDIX

AMC 66.25 Basic Knowledge Levels

SUBJECT MODULES

1. Mathematics

2. Physics

3. Electrical Fundamentals

4. Electronic Fundamentals

5. Digital Techniques / Electronic Instrument Systems

6. Materials and Hardware

7. Maintenance Practices

8. Basic Aerodynamics

9. Human Factors

10. Aviation Legislation

11. Aeroplane Aerodynamics, Structures and Systems

12. Helicopter Aerodynamics, Structures and Systems

13. Aircraft Aerodynamics, Structures and Systems

14. Propulsion

15. Gas Turbine Engine

16. Piston Engine

17. Propeller

18. Reserved

Note 1: The subject modules may be sub-divided into sub-modules for the purpose of training and/or examination.

Note 2: The levels specified in this Appendix will be subjected to regular review in the light of experience.

2–App 1–3 03.04.98

JAR–66 SECTION 2

MODULE 1. MATHEMATICS

Level
A B1 B2

1.1 Arithmetic 1 2 2
• Arithmetical terms and signs, methods of multiplication and
division, fractions and decimals, factors and multiples, weights,
measures and conversion factors, ratio and proportion, averages
and percentages, areas and volumes, squares, cubes, square and
cube roots.

1.2 Algebra
a) 1 2 2
•. Evaluating simple algebraic expressions, addition, subtraction,
multiplication and division, use of brackets, simple algebraic
fractions;
b) – 1 1
• Linear equations and their solutions;
• Indices and powers, negative and fractional indices;
• Binary and other applicable numbering systems;
• Simultaneous equations and second degree equations with one
unknown;
• logarithms;

1.3 Geometry
a) – 1 1
• Simple geometrical constructions;
b) 2 2 2
• Graphical representation; nature and uses of graphs, graphs of
equations/functions;
c)
• Simple trigonometry; trigonometrical relationships, use of tables – 2 2
and rectangular and polar co-ordinates.

03.04.98 2–App 1–4

SECTION 2 JAR–66

MODULE 2. PHYSICS

Students should become conversant with Metric, Imperial (British) and US units and measurements.

Level
A B1 B2

2.1 Matter
• Nature of matter: the chemical elements, structure of atoms, 1 1 1
molecules;
• Chemical compounds.
• States: solid, liquid and gaseous;
• Changes between states.

2.2 Mechanics

2.2.1 Statics
• Forces, moments and couples, representation as vectors; 1 2 1
• Centre of gravity.
• Elements of theory of stress, strain and elasticity: tension,
compression, shear and torsion;
• Nature and properties of solid, fluid and gas;
• Pressure and buoyancy in liquids (barometers).

2.2.2 Kinetics
• Linear movement: uniform motion in a straight line, motion under 1 2 1
constant acceleration (motion under gravity);
• Rotational movement: uniform circular motion (centrifugal/
centripetal forces);
• Periodic motion: pendular movement;
• Simple theory of vibration, harmonics and resonance;
• Velocity ratio, mechanical advantage and efficiency.

2.2.3 Dynamics
a)
• Mass; 1 2 1
• Force, inertia, work, power, energy (potential, kinetic and total
energy), heat, efficiency;
b)
• Momentum, conservation of momentum; 1 2 2
• Impulse;
• Gyroscopic principles;
• Friction: nature and effects, coefficient of friction (rolling
resistance).

2.2.4 Fluid dynamics

a)
• Specific gravity and density; 2 2 2

b) 1 2 1
• Viscosity, fluid resistance, effects of streamlining;
• effects of compressibility on fluids;
• Static, dynamic and total pressure: Bernoulli's Theorem, venturi.

2–App 1–5 03.04.98

JAR–66 SECTION 2

Module 2 (continued)

Level
A B1 B2

2.3 Thermodynamics
a) 2 2 2
• Temperature: thermometers and temperature scales: Celsius,
Fahrenheit and Kelvin;
Heat definition.
b) – 2 2
• Heat capacity, specific heat;
• Heat transfer: convection, radiation and conduction;
• Volumetric expansion;
• First and second law of thermodynamics;
• Gases: ideal gases laws; specific heat at constant volume and
constant pressure, work done by expanding gas;
• Isothermal, adiabatic expansion and compression, engine cycles,
constant volume and constant pressure, refrigerators and heat
pumps;
• Latent heats of fusion and evaporation, thermal energy, heat of
combustion.

2.4 Optics (Light) – 2 2

• Nature of light; speed of light;
• Laws of reflection and refraction: reflection at plane surfaces,
reflection by spherical mirrors, refraction, lenses;
• Fibre optics.

2.5 Wave Motion and Sound – 2 2

• Wave motion: mechanical waves, sinusoidal wave motion,
interference phenomena, standing waves;
• Sound: speed of sound, production of sound, intensity, pitch and
quality, Doppler effect.

03.04.98 2–App 1–6

SECTION 2 JAR–66

MODULE 3. ELECTRICAL FUNDAMENTALS

Level
A B1 B2

3.1 Electron Theory 1 1 1

Structure and distribution of electrical charges within: atoms,
molecules, ions, compounds;
Molecular structure of conductors, semiconductors and insulators.

3.2 Static Electricity and Conduction 1 2 2

Static electricity and distribution of electrostatic charges;
Electrostatic laws of attraction and repulsion;
Units of charge, Coulomb’s Law;
Conduction of electricity in solids, liquids, gases and a vacuum.

3.3 Electrical Terminology 1 2 2

The following terms, their units and factors affecting them:
potential difference, electromotive force, voltage, current,
resistance, conductance, charge, conventional current flow,
electron flow.

3.4 Generation of Electricity 1 1 1

Production of electricity by the following methods: light, heat,
friction, pressure, chemical action, magnetism and motion.

3.5 DC Sources of Electricity 1 2 2

Construction and basic chemical action of: primary cells,
secondary cells, lead acid cells, nickel cadmium cells, other
alkaline cells;
Cells connected in series and parallel;
Internal resistance and its effect on a battery;
• Construction, materials and operation of thermocouples;
• Operation of photo-cells.

3.6 DC Circuits – 2 2
Ohms Law, Kirchoff’s Voltage and Current Laws;
Calculations using the above laws to find resistance, voltage and
current;
Significance of the internal resistance of a supply.

3.7 Resistance / Resistor

a) – 2 2
Resistance and affecting factors;
Specific resistance;
Resistor colour code, values and tolerances, preferred values,
wattage ratings;
Resistors in series and parallel;
Calculation of total resistance using series, parallel and series
parallel combinations;
Operation and use of potentiometers and rheostats;
Operation of Wheatstone Bridge.
b) – 1 1
• Positive and negative temperature coefficient conductance;
• Fixed resistors, stability, tolerance and limitations, methods of
construction;
• Variable resistors, thermistors, voltage dependent resistors;
• Construction of potentiometers and rheostats;
• Construction of Wheatstone Bridge.

2–App 1–7 03.04.98

JAR–66 SECTION 2

Module 3 (continued)

Level
A B1 B2

3.8 Power – 2 2
Power, work and energy (kinetic and potential);
Dissipation of power by a resistor;
Power formula;
Calculations involving power, work and energy.

3.9 Capacitance / Capacitor – 2 2

Operation and function of a capacitor;
Factors affecting capacitance area of plates, distance between
plates,
number of plates, dielectric and dielectric constant, working
voltage, voltage rating;
Capacitor types, construction and function;
Capacitor colour coding;
Calculations of capacitance and voltage in series and parallel
circuits;
Exponential charge and discharge of a capacitor, time constants;
Testing of capacitors.

3.10 Magnetism
a) – 2 2
Theory of magnetism;
Properties of a magnet;
Action of a magnet suspended in the Earth’s magnetic field;
Magnetisation and demagnetisation;
Magnetic shielding;
Various types of magnetic material;
Electromagnets construction and principles of operation;
Hand clasp rules to determine: magnetic field around current
carrying conductor.
b) – 2 2
Magnetomotive force, field strength, magnetic flux density,
permeability, hysteresis loop, retentivity, coercive force
reluctance, saturation point, eddy currents;
Precautions for care and storage of magnets.

3.11 Inductance / Inductor – 2 2

Faraday’s Law;
Action of inducing a voltage in a conductor moving in a magnetic field;
Induction principles;
Effects of the following on the magnitude of an induced voltage:
magnetic field strength, rate of change of flux, number of
conductor turns;
Mutual induction;
The effect the rate of change of primary current and mutual
inductance has on induced voltage;
Factors affecting mutual inductance: number of turns in coil,
physical size of coil, permeability of coil, position of coils with
respect to each other;
Lenz’s Law and polarity determining rules;
Back emf, self induction;
Saturation point;
Principal uses of inductors;

03.04.98 2–App 1–8

SECTION 2 JAR–66

Module 3 (continued)

Level
A B1 B2

3.12 DC Motor / Generator Theory – 2 2

Basic motor and generator theory;
Construction and purpose of components in DC generator;
Operation of, and factors affecting output and direction of current
flow in DC generators;
Operation of, and factors affecting output power, torque, speed
and direction of rotation of C motors;
Series wound, shunt wound and compound motors;
Starter Generator construction.

3.13 AC Theory 1 2 2
Sinusoidal waveform: phase, period, frequency, cycle;
Instantaneous, average, root mean square, peak, peak to peak
current values and calculations of these values, in relation to
voltage, current and power;
Triangular/Square waves;
Single / 3 phase principles.

3.14 Resistive (R), Capacitive (C) and Inductive (L) Circuits – 2 2

Phase relationship of voltage and current in L, C and R circuits,
parallel, series and series parallel;
Power dissipation in L, C and R circuits;
Impedance, phase angle, power factor and current calculations;
True power, apparent power and reactive power calculations.

3.15 Transformers – 2 2
Transformer construction principles and operation;
Transformer losses and methods for overcoming them;
Transformer action under load and no-load conditions;
Power transfer, efficiency, polarity markings;
Primary and Secondary current, voltage, turns ratio, power, efficiency;
Auto transformers.

3.16 Filters – 1 1
Operation, application and uses of the following filters: low pass,
high pass, band pass, band stop.

3.17 AC Generators – 2 2
Rotation of loop in a magnetic field and waveform produced;
Operation and construction of revolving armature and revolving
field type AC generators;
Single phase, two phase and three phase alternators;
Three phase star and delta connections advantages and uses;
Calculation of line and phase voltages and currents;
Calculation of power in a three phase system;
Permanent Magnet Generators.

3.18 AC Motors – 2 2
Construction, principles of operation and characteristics of: AC
synchronous and induction motors both single and polyphase;
Methods of speed control and direction of rotation;
Methods of producing a rotating field: capacitor, inductor, shaded
or split pole.

2–App 1–9 03.04.98

JAR–66 SECTION 2

MODULE 4. ELECTRONIC FUNDAMENTALS.

Level
A B1 B2

4.1 Semiconductors

4.1.1 Diodes – 2 2
a)
Diode symbols;
Diode characteristics and properties;
Diodes in series and parallel;
Main characteristics and use of silicon controlled rectifiers
(thyristors), light emitting diode, photo conductive diode, varistor,
rectifier diodes;
Functional testing of diodes.
b) – – 2
Materials, electron configuration, electrical properties;
P and N type materials: effects of impurities on conduction,
majority and minority carriers;
PN junction in a semiconductor, development of a potential across
a PN junction in unbiased, forward biased and reverse biased
conditions;
Diode parameters: peak inverse voltage, maximum forward
current, temperature, frequency, leakage current, power
dissipation;
Operation and function of diodes in the following circuits: clippers,
clampers, full and half wave rectifiers, bridge rectifiers, voltage
doublers and triplers;
Detailed operation and characteristics of the following devices:
silicon controlled rectifier (thyristor), light emitting diode, Shottky
diode, photo conductive diode, varactor diode, varistor, rectifier
diodes, Zener diode.

4.1.2 Transistors
a) – 1 2
Transistor symbols;
Component description and orientation;
Transistor characteristics and properties.
b) – – 2
Construction and operation of PNP and NPN transistors;
Base, collector and emitter configurations;
Testing of transistors.
Basic appreciation of other transistor types and their uses.
Application of transistors : classes of amplifier (A, B, C);
Simple circuits including : bias, decoupling, feedback and
stabilisation;
Multistage circuit principles : cascades, push-pull, oscillators,
multivibrators, flip-flop circuits.

03.04.98 2–App 1–10

SECTION 2 JAR–66

Module 4 (continued)

Level
A B1 B2

4.1.3 Integrated Circuits

a) – 1 –
Description and operation of logic circuits and linear circuits /
operational amplifiers.
b) – – 2
Description and operation of logic circuits and linear circuits;
Introduction to operation and function of an operational amplifier
used as: integrator, differentiator, voltage follower, comparator;
Operation and amplifier stages connecting methods: resistive
capacitive, inductive (transformer), inductive resistive (IR), direct;
Advantages and disadvantages of positive and negative feedback.

4.2 Printed Circuit Boards – 1 2

Description and use of printed circuit boards.

4.3 Servomechanisms
a) – 1 –
Understanding of the following terms: Open and closed loop
systems, feedback, follow up, analogue transducers;
Principles of operation and use of the following synchro system
components / features: resolvers, differential, control and torque,
transformers, inductance and capacitance transmitters.
b) – – 2
Understanding of the following terms : Open and closed loop,
follow up, servomechanism, analogue, transducer, null, damping,
feedback, deadband;
Construction operation and use of the following synchro system
components : resolvers, differential, control and torque, E and I
transformers, inductance transmitters, capacitance transmitters,
synchronous transmitters;
Servomechanism defects, reversal of synchro leads, hunting.

2–App 1–11 03.04.98

JAR–66 SECTION 2

MODULE 5. DIGITAL TECHNIQUES

ELECTRONIC INSTRUMENT SYSTEMS

Level
A B1 B2

5.1 Electronic Instrument Systems 1 2 3

Typical systems arrangements and cockpit layout of electronic
instrument systems.

5.2 Numbering Systems – 1 2

Numbering systems: binary, octal and hexadecimal;
Demonstration of conversions between the decimal and binary,
octal and hexadecimal systems and vice versa.

5.3 Data Conversion – 1 2

Analogue Data, Digital Data;
Operation and application of analogue to digital, and digital to
analogue converters, inputs and outputs, limitations of various
types.

5.4 Data Buses – 2 2

Operation of data buses in aircraft systems, including knowledge
of ARINC and other specifications.

5.5 Logic Circuits – 2 2

a)
Identification of common logic gate symbols, tables and equivalent
circuits;
Applications used for aircraft systems, schematic diagrams.
b) – – 2
Interpretation of logic diagrams.

5.6 Basic Computer Structure

a) 1 2 –
Computer terminology (including bit, byte, software, hardware,
CPU, IC, and various memory devices such as RAM, ROM,
PROM);
Computer technology (as applied in aircraft systems).
b) – – 2
Computer related terminology;
Operation, layout and interface of the major components in a
micro computer including their associated bus systems;
Information contained in single and multiaddress instruction words;
Memory associated terms;
Operation of typical memory devices;
Operation, advantages and disadvantages of the various data
storage systems.

5.7 Microprocessors – – 2
Functions performed and overall operation of a microprocessor;
Basic operation of each of the following microprocessor elements:
control and processing unit, clock, register, arithmetic logic unit.

5.8 Integrated Circuits – – 2

Operation and use of encoders and decoders;
Function of encoder types;
Uses of medium, large and very large scale integration.

03.04.98 2–App 1–12

SECTION 2 JAR–66

Module 5 (continued)

Level
A B1 B2

5.9 Multiplexing – – 2
Operation, application and identification in logic diagrams
of multiplexers and demultiplexers.

5.10 Fibre Optics – 1 2

Advantages and disadvantages of fibre optic data transmission
over electrical wire propagation;
Fibre optic data bus;
Fibre optic related terms;
Terminations;
Couplers, control terminals, remote terminals;
• Application of fibre optics in aircraft systems.

5.11 Electronic Displays – 2 2

Principles of operation of common types of displays used in
modern aircraft, including Cathode Ray Tubes, Light Emitting
Diodes and Liquid Crystal Display.

5.12 Electrostatic Sensitive Devices 1 2 2

Special handling of components sensitive to electrostatic
discharges;
Awareness of risks and possible damage, component and
personnel anti-static protection devices.

5.13 Software Management Control – 2 2

Awareness of restrictions, airworthiness requirements and possible
catastrophic effects of unapproved changes to software programmes.

5.14 Electromagnetic Environment – 2 2

Influence of the following phenomena on maintenance practices
for electronic system:

EMC – Electromagnetic Compatibility

EMI – Electromagnetic Interference
HIRF – High Intensity Radiated Field
Lightning / lightning protection

5.15 Typical Electronic / Digital Aircraft Systems – 2 2

General arrangement of typical electronic/digital aircraft systems and associated BITE

(Built In Test Equipment) testing such as:

ACARS – ARINC Communication and Addressing and

Reporting System
ECAM – Electronic Centralised Aircraft Monitoring
EFIS – Electronic Flight Instrument System
EICAS – Engine Indication and Crew Alerting System
FBW – Fly by Wire
FMS – Flight Management System
GPS – Global Positioning System
IRS – Inertial Reference System
TCAS – Traffic Alert Collision Avoidance System
Note : Different manufacturers may use different terminology for similar systems.

2–App 1–13 03.04.98

JAR–66 SECTION 2

MODULE 6. MATERIALS AND HARDWARE

Level
A B1 B2

6.1 Aircraft Materials – Ferrous

a) 1 2 1
Characteristics, properties and identification of common alloy
steels used in aircraft;
Heat treatment and application of alloys steels;
b) – 1 1
Testing of ferrous materials for hardness, tensile strength, fatigue
strength and impact resistance.

6.2 Aircraft Materials – Non-Ferrous

a) 1 2 1
Characteristics, properties and identification of common non-
ferrous materials used in aircraft;
Heat treatment and application of non-ferrous materials;
b) – 1 1
Testing of non-ferrous material for hardness, tensile strength,
fatigue strength and impact resistance.

6.3 Aircraft Materials – Composite and Non-Metallic

a) 1 2 2
Characteristics, properties and identification of common
composite and non-metallic materials, other than wood, used in
aircraft;
Sealants and bonding agents.
b) 1 2 –
The detection of defects in composite material.
Repair of composite material.

6.4 Corrosion
a) 1 1 1
Chemical fundamentals;
Formation by, galvanic action process, microbiological, stress;
b) 2 3 2
Types of corrosion and their identification;
Causes of corrosion;
Material types, susceptibility to corrosion.

6.5 Fasteners

6.5.1 Screw threads 2 2 2

Screw nomenclature;
Thread forms, dimensions and tolerances for standard threads
used in aircraft;
Measuring screw threads.

6.5.2 Bolts, studs and screws 2 2 2

Bolt types: specification, identification and marking of aircraft
bolts, international standards;
Nuts: self locking, anchor, standard types;
Machine screws: aircraft specifications;
Studs: types and uses, insertion and removal;
Self tapping screws, dowels.

03.04.98 2–App 1–14

SECTION 2 JAR–66

Module 6 (continued)

Level
A B1 B2

6.5.3 Locking devices 2 2 2

Tab and spring washers, locking plates, split pins, pal-nuts, wire
locking, quick release fasteners, keys, circlips, cotter pins.

6.5.4 Aircraft rivets 1 2 1

Types of solid and blind rivets: specifications and identification,
heat treatment.

6.6 Pipes and Unions

a) 2 2 2
Identification of, and types of rigid and flexible pipes and their
connectors used in aircraft;
b) 2 2 1
Standard unions for aircraft hydraulic, fuel, oil, pneumatic and air
system pipes.

6.7 Springs – 2 1
Types of springs, materials, characteristics and applications.

6.8 Bearings 1 2 2
Purpose of bearings, loads, material, construction;
Types of bearings and their application.

6.9 Transmissions 1 2 2
Gear types and their application;
Gear ratios, reduction and multiplication gear systems, driven and
driving gears, idler gears, mesh patterns;
Belts and pulleys, chains and sprockets.

6.10 Control Cables 1 2 1

Types of cables;
End fittings, turnbuckles and compensation devices;
Pulleys and cable system components;
Bowden cables;
Aircraft flexible control systems.

6.11 Electrical Cables and Connectors 1 2 2

Cable types, construction and characteristics;
High tension and co-axial cables;
Crimping;
Connector types, pins, plugs, sockets, insulators, current and
voltage rating, coupling, identification codes.

2–App 1–15 03.04.98

JAR–66 SECTION 2

MODULE 7. MAINTENANCE PRACTICES

Level
A B1 B2

7.1 Safety Precautions – Aircraft and Workshop 3 3 3

Aspects of safe working practices including precautions to take
when working with electricity, gases especially oxygen, oils and
chemicals.
Also, instruction in the remedial action to be taken in the event of
a fire or another accident with one or more of these hazards.

7.2 Workshop Practices 3 3 3

Care of tools, control of tools, use of workshop materials;
Dimensions, allowances and tolerances, standards of
workmanship;
Calibration of tools and equipment, calibration standards.

7.3 Tools 3 3 3
Common hand tool types;
Common power tool types;
Operation and use of precision measuring tools;
Lubrication equipment and methods;
Operation, function and use of electrical general test equipment.

7.4 Avionic General Test Equipment – 2 3

Operation, function and use of avionic general test equipment.

7.5 Engineering Drawings, Diagrams and Standards 1 2 2

Drawing types and diagrams, their symbols, dimensions,
tolerances and projections;
Identifying title block information;
Microfilm, microfiche and computerised presentations;
Specification 100 of the Air Transport Association (ATA) of
America;
Aeronautical and other applicable standards including ISO, AN, MS,
NAS and MIL;
Wiring diagrams and schematic diagrams.

7.6 Fits and Clearances 1 2 1

Drill sizes for bolt holes, classes of fits;
Common system of fits and clearances;
Schedule of fits and clearances for aircraft and engines;
Limits for bow, twist and wear;
Standard methods for checking shafts, bearings and other parts.

7.7 Electrical Cables and Connectors 1 2 2

Continuity, insulation and bonding techniques and testing;
Use of crimp tools: hand and hydraulic operated;
Testing of crimp joints;
Connector pin removal and insertion;
Co-axial cables: testing and installation precautions;
Wiring protection techniques : Cable looming and loom support,
cable clamps, protective sleeving techniques including heat shrink
wrapping, shielding.

03.04.98 2–App 1–16

SECTION 2 JAR–66

Module 7 (continued)

Level
A B1 B2

7.8 Riveting 1 2 –
Riveted joints, rivet spacing and pitch;
Tools used for rivetting and dimpling;
Inspection of rivetted joints.

7.9 Pipes and Hoses 1 2 –

Bending and belling/flaring aircraft pipes;
Inspection and testing of aircraft pipes and hoses;
Installation and clamping of pipes.

7.10 Springs 1 2 –
Inspection and testing of springs.

7.11 Bearings 1 2 –
Testing, cleaning and inspection of bearings;
Lubrication requirements of bearings;
Defects in bearings and their causes.

7.12 Transmissions 1 2 –
Inspection of gears, backlash;
Inspection of belts and pulleys, chains and sprockets;
Inspection of screw jacks, lever devices, push-pull rod systems.

7.13 Control Cables 1 2 –

Swaging of end fittings;
Inspection and testing of control cables;
Bowden cables; aircraft flexible control systems.

7.14 Sheet Metal Work

– 2 –
Marking out and calculation of bend allowance;
Sheet metal working, including bending and forming;
Inspection of sheet metal work.

7.15 Welding, Brazing, Soldering and Bonding

a) – 2 2
Soldering methods; inspection of soldered joints.
b) – 2 –
Welding and brazing methods;
Inspection of welded and brazed joints;
Bonding methods and inspection of bonded joints.

7.16 Aircraft Weight and Balance

a) – 2 2
Centre of Gravity / Balance limits calculation: use of relevant
documents;
b) – 2 –
Preparation of aircraft for weighing;
Aircraft weighing.

2–App 1–17 03.04.98

JAR–66 SECTION 2

Module 7 (continued)

Level
A B1 B2

7.17 Aircraft Handling and Storage 2 2 2

Aircraft taxiing / towing and associated safety precautions;
Aircraft jacking, chocking, securing and associated safety
precautions;
Aircraft storage methods;
Refuelling / defuelling procedures;
De-icing/anti-icing procedures;
Electrical, hydraulic and pneumatic ground supplies.
Effects of environmental conditions on aircraft handling and
operation.

7.18 Disassembly, Inspection, Repair and Assembly Techniques

a) 2 3 2
Types of defects and visual inspection techniques.
Corrosion removal, assessment and reprotection.
b) – 2 –
General repair methods, Structural Repair Manual;
Ageing, fatigue and corrosion control programmes.
c) – 2 1
Non destructive inspection techniques including, penetrant,
radiographic, eddy current, ultrasonic and boroscope methods.
d) 2 2 2
Disassembly and re-assembly techniques.
e) – 2 2
Trouble shooting techniques.

7.19 Abnormal Events

a) 2 2 2
Inspections following lightning strikes and HIRF penetration.
b) 2 2 –
Inspections following abnormal events such as heavy landings
and flight through turbulence.

7.20 Maintenance Procedures 1 2 2

Maintenance planning;
Modification procedures;
Stores procedures;
Certification/release procedures;
Interface with aircraft operation;
Maintenance Inspection/Quality Control/Quality Assurance;
Additional maintenance procedures.
Control of life limited components.

03.04.98 2–App 1–18

SECTION 2 JAR–66

MODULE 8. BASIC AERODYNAMICS

Level
A B1 B2

8.1 Physics of the Atmosphere

International Standard Atmosphere (ISA), application to
aerodynamics. 1 2 2

8.2 Aerodynamics 1 2 2
Airflow around a body;
Boundary layer, laminar and turbulent flow, free stream flow,
relative airflow, upwash and downwash, vortices, stagnation;
The terms: camber, chord, mean aerodynamic chord, profile
(parasite) drag, induced drag, centre of pressure, angle of attack,
wash in and wash out, fineness ratio, wing shape and aspect
ratio;
Thrust, Weight, Aerodynamic Resultant;
Generation of Lift and Drag: Angle of Attack, Lift coefficient, Drag
coefficient, polar curve, stall;
Aerofoil contamination including ice, snow, frost.

8.3 Theory of Flight 1 2 2

Relationship between lift, weight, thrust and drag;
Glide ratio;
Steady state flights, performance;
Theory of the turn;
Influence of load factor: stall, flight envelope and structural
limitations;
Lift augmentation.

8.4 Flight Stability and Dynamics 1 2 2

Longitudinal, lateral and directional stability (active and passive).

2–App 1–19 03.04.98

JAR–66 SECTION 2

MODULE 9. HUMAN FACTORS

Level
A B1 B2

9.1 General 1 2 2
The need to take human factors into account;
Incidents attributable to human factors / human error;
‘Murphy’s’ law.

9.2 Human Performance and Limitations 1 2 2

Vision;
Hearing;
Information processing;
Attention and perception;
Memory;
Claustrophobia and physical access.

9.3 Social Psychology 1 1 1

Responsibility: individual and group;
Motivation and de-motivation;
Peer pressure;
‘Culture’ issues;
Team working;
Management, supervision and leadership.

9.4 Factors Affecting Performance 2 2 2

Fitness / health;
Stress: domestic and work related;
Time pressure and deadlines;
Workload: overload and underload;
Sleep and fatigue, shiftwork;
Alcohol, medication, drug abuse.

9.5 Physical Environment 1 1 1

Noise and fumes;
Illumination;
Climate and temperature;
Motion and vibration;
Working environment.

9.6 Tasks 1 1 1
Physical work;
Repetitive tasks;
Visual inspection;
Complex systems.

9.7 Communication 2 2 2
Within and between teams;
Work logging and recording;
Keeping up to date, currency;
Dissemination of information.

9.8 Human Error 1 2 2

Error models and theories;
Types of error in maintenance tasks;
Implications of errors (i.e accidents);
Avoiding and managing errors.

03.04.98 2–App 1–20

SECTION 2 JAR–66

Module 9 (continued)

Level
A B1 B2

9.9 Hazards in the Workplace 1 2 2

Recognising and avoiding hazards;
Dealing with emergencies.

2–App 1–21 03.04.98

JAR–66 SECTION 2

MODULE 10. AVIATION LEGISLATION

Level
A B1 B2

10.1 Regulatory Framework 1 1 1

Role of International Civil Aviation Organisation;
Role of the Joint Aviation Authorities (JAA);
Role of the JAA full member Authorities;
Role of the JAA candidate member Authorities;
Joint Airworthiness Requirements: relationship between
JAR–OPS, JAR–145, JAR–66, JAR–147 and JAR–Maintenance;
Relationship with other Aviation Authorities.

10.2 JAR–66 – Certifying Staff – Maintenance 2 2 2

Detailed understanding of JAR–66.

10.3 JAR–145 – Approved Maintenance Organisations 2 2 2

Detailed understanding of JAR–145.

10.4 JAR–OPS – Commercial Air Transportation :

a) General 1 1 1
Air Operators Certificates;
Operators Responsibilities;
Documents to be Carried;
Aircraft Placarding (Markings);
b) Subpart M 2 2 2
• Maintenance Responsibility;
• Maintenance Management;
• Aircraft Maintenance Programme;
• Aircraft Technical Log;
• Maintenance Records and Log Books;
• Accident/Occurrence Reporting.

10.5 Aircraft Certification

a) General – 1 1
Certification rules : such as JAR–23/25/27/29;
Type Certification;
Supplemental Type Certification;
JAR–21 Design/Production Organisation Approvals.
b) Documents – 2 2
Certificate of Airworthiness;
Certificate of Registration;
Noise Certificate;
Weight Schedule;
Radio Station Licence and Approval.

10.6 JAR–Maintenance 2 2 2
(when adopted)

03.04.98 2–App 1–22

SECTION 2 JAR–66

Module 10 (continued)

Level
A B1 B2

10.7 Applicable National and International Requirements for

(if not superseded by JAA requirements)
a) 1 2 2
Maintenance Programmes, Maintenance checks and inspections;
Master Minimum Equipment Lists, Minimum Equipment List,
Dispatch Deviation Lists;
Airworthiness Directives;
Service Bulletins, manufacturers service information;
Modifications and repairs;
Maintenance documentation: maintenance manuals, structural
repair manual, illustrated parts catalogue, etc.
b) – 1 1
Continuing airworthiness;
Test flights;
ETOPS, maintenance and dispatch requirements;
All Weather Operations, Category 2/3 operations and minimum
equipment requirements.

2–App 1–23 03.04.98

JAR–66 SECTION 2

MODULE 11. AEROPLANE AERODYNAMICS, STRUCTURES

AND SYSTEMS

Level
A B1 B2

11.1 Theory of Flight

11.1.1 Aeroplane Aerodynamics and Flight Controls 1 2 –

Operation and effect of:
– roll control: ailerons and spoilers;
– pitch control: elevators, stabilators, variable incidence stabilisers
and canards;
– yaw control, rudder limiters;
Control using elevons, ruddervators;
High lift devices, slots, slats, flaps, flaperons;
Drag inducing devices, spoilers, lift dumpers, speed brakes;
Effects of wing fences, saw tooth leading edges;
Boundary layer control using, vortex generators, stall wedges or leading
edge devices;
Operation and effect of trim tabs, balance and antibalance (leading)
tabs, servo tabs, spring tabs, mass balance, control surface bias,
aerodynamic balance panels;

11.1.2 High Speed Flight 1 2 –

Speed of sound, subsonic flight, transonic flight, supersonic flight,
Mach number, critical Mach number, compressibility buffet, shock
wave, aerodynamic heating, area rule;
Factors affecting airflow in engine intakes of high speed aircraft;
Effects of sweepback on critical Mach number.

11.2 Airframe Structures - General Concepts

a) 2 2 –
Airworthiness requirements for structural strength;
Structural classification, primary, secondary and tertiary;
Fail safe, safe life, damage tolerance concepts;
Zonal and station identification systems;
Stress, strain, bending, compression, shear, torsion, tension, hoop
stress, fatigue;
Drains and ventilation provisions;
System installation provisions;
Lightning strike protection provision.
b) 1 2 –
Construction methods of: stressed skin fuselage, formers,
stringers, longerons, bulkheads, frames, doublers, struts, ties,
beams, floor structures, reinforcement, methods of skinning,
anti-corrosive protection, wing, empennage and engine
attachments;
Structure assembly techniques: riveting, bolting, bonding;
Methods of surface protection, such as chromating, anodising,
painting;
Surface cleaning;
Airframe symmetry: methods of alignment and symmetry checks.

03.04.98 2–App 1–24

SECTION 2 JAR–66

Module 11 (continued)

Level
A B1 B2

11.3 Airframe Structures – Aeroplanes

11.3.1 Fuselage (ATA 52 / 53 / 56) 1 2 –

Construction and pressurisation sealing;
Wing, stabiliser, pylon and undercarriage attachments;
Seat installation and cargo loading system;
Doors: construction, mechanisms, operation and safety devices;
Windows and windscreen construction and mechanisms.

11.3.2 Wings (ATA 57) 1 2 –

Construction;
Fuel storage;
Landing gear, pylon, control surface and high lift/drag
attachments.

11.3.3 Stabilisers (ATA 55) 1 2 –

Construction;
Control surface attachment.

11.3.4 Flight Control Surfaces (ATA 55/57) 1 2 –

Construction and attachment;
Balancing – mass and aerodynamic.

11.3.5 Nacelles/Pylons (ATA 54) 1 2 –

Construction;
Firewalls;
Engine mounts.

11.4 Air Conditioning and Cabin Pressurisation (ATA 21)

11.4.1 Air supply 1 2 –

Sources of air supply including engine bleed, APU and ground
cart;

11.4.2 Air Conditioning 1 3 -

Air conditioning systems;
Air cycle and vapour cycle machines;
Distribution systems;
Flow, temperature and humidity control system.

11.4.3 Pressurisation 1 3 –
Pressurisation systems;
Control and indication including control and safety valves;
Cabin pressure controllers.

11.4.4 Safety and warning devices 1 3 –

Protection and warning devices.

2–App 1–25 03.04.98

JAR–66 SECTION 2

Module 11 (continued)

Level
A B1 B2

11.5 Instruments/Avionic Systems

11.5.1 Instrument Systems (ATA 31) 1 2 –

Pitot static: altimeter, air speed indicator, vertical speed indicator;
Gyroscopic: artificial horizon, attitude director, direction indicator,
horizontal situation indicator, turn and slip indicator, turn co-
ordinator;
Compasses: direct reading, remote reading;
Angle of attack indication, stall warning systems;
Other aircraft system indication.

11.5.2 Avionic Systems 1 1 –

Fundamentals of system lay-outs and operation of;
Auto Flight (ATA 22);
Communications (ATA 23);
Navigation Systems (ATA 34).

11.6 Electrical Power (ATA 24) 1 3 –

Batteries Installation and Operation;
DC power generation;
AC power generation;
Emergency power generation;
Voltage regulation;
Power distribution;
Inverters, transformers, rectifiers;
Circuit protection;
External/Ground power.

11.7 Equipment and Furnishings (ATA 25)

a) 2 2 –
Emergency equipment requirements;
Seats, harnesses and belts.
b) 1 1 –
Cabin lay-out;
Equipment lay-out;
Cabin Furnishing Installation;
Cabin entertainment equipment;
Galley installation;
Cargo handling and retention equipment;
Airstairs.

11.8 Fire Protection (ATA 26) 1 3 –

Fire and smoke detection and warning systems;
Fire extinguishing systems;
System tests.

11.9 Flight Controls (ATA 27) 1 3 –

Primary controls: aileron, elevator, rudder, spoiler;
Trim control;
Active load control;
High lift devices;
Lift dump, speed brakes.

03.04.98 2–App 1–26

SECTION 2 JAR–66

Module 11.9 (continued)

Level
A B1 B2

System operation: manual, hydraulic, pneumatic, electrical, fly-by-

wire;
Artificial feel, Yaw damper, Mach trim, rudder limiter, gust locks;
Balancing and rigging;
Stall protection system.

11.10 Fuel Systems (ATA 28) 1 3 –

System lay-out;
Fuel tanks;
Supply systems;
Dumping, venting and draining;
Cross-feed and transfer;
Indications and warnings;
Refuelling and defuelling;
Longitudinal balance fuel systems.

11.11 Hydraulic Power (ATA 29) 1 3 –

System lay-out;
Hydraulic fluids;
Hydraulic reservoirs and accumulators;
Pressure generation: electric, mechanical, pneumatic;
Emergency pressure generation;
Pressure Control;
Power distribution;
Indication and warning systems;
Interface with other systems.

11.12 Ice and Rain Protection (ATA 30) 1 3 –

Ice formation, classification and detection;
Anti-icing systems: electrical, hot air and chemical;
De-icing systems: electrical, pneumatic and chemical;
Rain repellant and removal;
Probe and drain heating.

11.13 Landing Gear (ATA 32) 2 3 –

Construction, shock absorbing;
Extension and retraction systems: normal and emergency;
Indications and warning;
Wheels, brakes, antiskid and autobraking;
Tyres;
Steering.

11.14 Lights (ATA 33) 2 3 –

External: navigation, landing, taxiing, ice;
Internal: cabin, cockpit, cargo;
Emergency.

11.15 Oxygen (ATA 35) 1 3 –

System lay-out: cockpit, cabin;
Sources, storage, charging and distribution;
Supply regulation;
Indications and warnings

2–App 1–27 03.04.98

JAR–66 SECTION 2

Module 11 (continued)

Level
A B1 B2

11.16 Pneumatic/Vacuum (ATA 36) 1 3 –

System lay-out;
Sources: engine / APU, compressors, reservoirs, ground supply;
Pressure control;
Distribution;
Indications and warnings;
Interfaces with other systems.

11.17 Water/Waste (ATA 38) 2 3 –

Water system lay-out, supply, distribution, servicing and draining;
Toilet system lay-out, flushing and servicing;
Corrosion aspects.

11.18 On Board Maintenance Systems (ATA 45) 1 2 –

Central maintenance computers;
Data loading system;
Electronic library system;
Printing;
Structure monitoring (damage tolerance monitoring).

03.04.98 2–App 1–28

SECTION 2 JAR–66

MODULE 12. HELICOPTER AERODYNAMICS, STRUCTURES

AND SYSTEMS

Level
A B1 B2

12.1 Theory of Flight – Rotary Wing Aerodynamics 1 2 –

Terminology;
Effects of gyroscopic precession;
Torque reaction and directional control;
Dissymmetry of lift, Blade tip stall;
Translating tendency and its correction;
Coriolis effect and compensation;
Vortex ring state, power settling, overpitching;
Auto-rotation;
Ground effect.

12.2 Flight Control Systems 2 3 –

Cyclic control;
Collective control;
Swashplate;
Yaw control: Anti-Torque Control, Tail rotor, bleed air;
Main Rotor Head: Design and Operation features;
Blade Dampers: Function and construction;
Rotor Blades: Main and tail rotor blade construction and
attachment;
Trim control, fixed and adjustable stabilisers;
System operation: manual, hydraulic, electrical and fly-by-wire;
Artificial feel;
Balancing and Rigging.

12.3 Blade Tracking and Vibration Analysis 1 3 –

Rotor alignment;
Main and tail rotor tracking;
Static and dynamic balancing;
Vibration types, vibration reduction methods;
Ground resonance.

12.4 Transmissions 1 3 –
Gear boxes, main and tail rotors;
Clutches, free wheel units and rotor brake.

12.5 Airframe Structures

a) 2 2 –
Airworthiness requirements for structural strength;
Structural classification, primary, secondary and tertiary;
Fail safe, safe life, damage tolerance concepts;
Zonal and station identification systems;
Stress, strain, bending, compression, shear, torsion, tension, hoop
stress, fatigue;
Drains and ventilation provisions;
System installation provisions;
Lightning strike protection provision.

2–App 1–29 03.04.98

JAR–66 SECTION 2

Module 12.5 (continued)

Level
A B1 B2

b) 1 2 –
• Construction methods of: stressed skin fuselage, formers,
stringers, longerons, bulkheads, frames, doublers, struts, ties,
beams, floor structures, reinforcement, methods of skinning and
anti-corrosive protection;
• Pylon, stabiliser and undercarriage attachments;
• Seat installation;
• Doors: construction, mechanisms, operation and safety devices;
Windows and windscreen construction;
Fuel storage;
Firewalls;
Engine mounts;
Structure assembly techniques: riveting, bolting, bonding;
Methods of surface protection, such as chromating, anodising,
painting;
Surface cleaning.
Airframe symmetry: methods of alignment and symmetry checks.

12.6 Air Conditioning (ATA 21)

12.6.1 Air supply 1 2 –

Sources of air supply including engine bleed and ground cart.

12.6.2 Air Conditioning 1 3 –

Air conditioning systems;
Distribution systems;
Flow and temperature control systems;
Protection and warning devices.

12.7 Instruments/Avionic Systems

12.7.1 Instrument Systems (ATA 31) 1 2 –

Pitot static: altimeter, air speed indicator, vertical speed indicator;
Gyroscopic: artificial horizon, attitude director, direction indicator,
horizontal situation indicator, turn and slip indicator, turn co-ordinator;
Compasses: direct reading, remote reading;
Vibration indicating systems – HUMS;
Other aircraft system indication.

12.7.2 Avionic Systems 1 1 –

Fundamentals of system layouts and operation of;
Auto Flight (ATA 22);
Communications (ATA 23);
Navigation Systems (ATA 34).

12.8 Electrical Power (ATA 24) 1 3 –

Batteries Installation and Operation;
DC power generation, AC power generation;
Emergency power generation;
Voltage regulation, Circuit protection;
Power distribution;
Inverters, transformers, rectifiers;
External/Ground power.

03.04.98 2–App 1–30

SECTION 2 JAR–66

Module 12 (continued)

Level
A B1 B2

12.9 Equipment and Furnishings (ATA 25)

a) 2 2 –
Emergency equipment requirements;
Seats, harnesses and belts;
Lifting systems.
b) 1 1 –
Emergency flotation systems;
Cabin lay-out, cargo retention;
Equipment lay-out;
Cabin Furnishing Installation;

12.10 Fire Protection (ATA 26) 1 3 –

Fire and smoke detection and warning systems;
Fire extinguishing systems;
System tests.

12.11 Fuel Systems (ATA 28) 1 3 -

System lay-out;
Fuel tanks;
Supply systems;
Dumping, venting and draining;
Cross-feed and transfer;
Indications and warnings;
Refuelling and defuelling.

12.12 Hydraulic Power (ATA 29) 1 3 –

System lay-out;
Hydraulic fluids;
Hydraulic reservoirs and accumulators;
Pressure generation: electric, mechanical, pneumatic;
Emergency pressure generation;
Pressure Control;
Power distribution;
Indication and warning systems;
Interface with other systems.

12.13 Ice and Rain Protection (ATA 30) 1 3 –

Ice formation, classification and detection;
Anti-icing and De-icing systems: electrical, hot air and chemical;
Rain repellant and removal;
Probe and drain heating.

12.14 Landing Gear (ATA 32) 2 3 –

Construction, shock absorbing;
Extension and retraction systems: normal and emergency;
Indications and warning;
Wheels, Tyres, brakes;
Steering;
Skids, floats.

2–App 1–31 03.04.98

JAR–66 SECTION 2

Module 12 (continued)

Level
A B1 B2

12.15 Lights (ATA 33) 2 3 –

External: navigation, landing, taxiing, ice;
Internal: cabin, cockpit, cargo;
Emergency.

12.16 Pneumatic/Vacuum (ATA 36) 1 3 –

System lay-out;
Sources: engine, compressors, reservoirs, ground supply.;
Pressure control;
Distribution;
Indications and warnings;
Interfaces with other systems.

03.04.98 2–App 1–32

SECTION 2 JAR–66

MODULE 13. AIRCRAFT AERODYNAMICS, STRUCTURES

AND SYSTEMS

Level
A B1 B2

13.1 Theory of Flight

a) Aeroplane Aerodynamics and Flight Controls – – 1
Operation and effect of:
– roll control: ailerons and spoilers;
– pitch control: elevators, stabilators, variable incidence
stabilisers and canards;
– yaw control, rudder limiters;
Control using elevons, ruddervators;
High lift devices: slots, slats, flaps;
Drag inducing devices: spoilers, lift dumpers, speed brakes;
Operation and effect of trim tabs, servo tabs, control surface bias.
b) High Speed Flight – – 1
Speed of sound, subsonic flight, transonic flight, supersonic flight,
Mach number, critical Mach number.
c) Rotary Wing Aerodynamics – – 1
Terminology;
Operation and effect of cyclic, collective and anti-torque controls.

13.2 Structures – General Concepts

a) – – 1
Fundamentals of structural systems.
b) – – 2
Zonal and station identification systems;
Electrical bonding;
Lightning strike protection provision.

13.3 Autoflight (ATA22) – – 3

Fundamentals of automatic flight control including working
principles and current terminology;
Command signal processing;
Modes of operation: roll, pitch and yaw channels;
Yaw dampers;
Stability Augmentation System in helicopters;
Automatic trim control;
Autopilot navigation aids interface;
Autothrottle systems;
Automatic Landing Systems: principles and categories, modes of
operation, approach, glideslope, land, go-around, system monitors
and failure conditions.

13.4 Communication / Navigation (ATA23/34) – – 3

Fundamentals of radio wave propagation, antennas, transmission
lines, communication, receiver and transmitter;
Working principles of following systems:
– Very High Frequency (VHF)communication;
– High Frequency (HF)communication;
– Audio;
– Emergency Locator Transmitters;
– Cockpit Voice Recorder;
– Very High Frequency omnidirectional range (VOR);
– Automatic Direction Finding (ADF);
– Instrument Landing System (ILS);
– Microwave Landing System (MLS);

2–App 1–33 03.04.98

JAR–66 SECTION 2

Module 13.4 (continued)

Level
A B1 B2

– Flight Director systems;

– Distance Measuring Equipment (DME);
– Very Low Frequency and hyperbolic navigation (VLF/Omega);
– Doppler navigation;
– Area navigation, RNAV systems;
– Flight Management Systems;
– Global Positioning System (GPS), Global Navigation Satellite
Systems (GNSS) ;
– Inertial Navigation System;
– Air Traffic Control transponder, secondary surveillance radar;
– Traffic Alert and Collision Avoidance System (TCAS);
– Weather avoidance radar;
– Radio altimeter;
– ARINC communication and reporting;

13.5 Electrical Power (ATA 24) – – 3

Batteries Installation and Operation;
DC power generation;
AC power generation;
Emergency power generation;
Voltage regulation;
Power distribution;
Inverters, transformers, rectifiers;
Circuit protection;
External/Ground power.

13.6 Equipment and Furnishings (ATA 25) – – 3

Electronic emergency equipment requirements;
Cabin entertainment equipment.

13.7 Flight Controls (ATA 27)

a) – – 1
Primary controls: aileron, elevator, rudder, spoiler;
Trim control;
Active load control;
High lift devices;
Lift dump, speed brakes;
System operation: manual, hydraulic, pneumatic;
Artificial feel, Yaw damper, Mach trim, rudder limiter, gust locks;
Stall protection systems.
b) – – 2
System operation: electrical, fly by wire.

13.8 Instrument Systems (ATA 31) – – 2

Classification;
Atmosphere;
Terminology;
Pressure measuring devices and systems;
Pitot static systems;
Altimeters;
Vertical speed indicators;
Airspeed indicators;
Machmeters;

03.04.98 2–App 1–34

SECTION 2 JAR–66

Module 13.8 (continued)

Level
A B1 B2

Altitude reporting / alerting systems;

Air data computers;
Instrument pneumatic systems;
Direct reading pressure and temperature gauges;
Temperature indicating systems;
Fuel quantity indicating systems;
Gyroscopic principles;
Artificial horizons;
Slip indicators;
Directional gyros;
Ground Proximity Warning Systems;
Compass systems;
Flight Data Recording systems;
Electronic Flight Instrument Systems;
Instrument warning systems including master warning systems
and centralised warning panels;
Stall warning systems and angle of attack indicating systems;
Vibration measurement and indication.

13.9 Lights (ATA 33) – – 3

External: navigation, landing, taxiing, ice;
Internal: cabin, cockpit, cargo;
Emergency.

13.10 On board Maintenance Systems (ATA 45) – – 2

Central maintenance computers;
Data loading system;
Electronic library system;
Printing;
Structure monitoring (damage tolerance monitoring).

2–App 1–35 03.04.98

JAR–66 SECTION 2

MODULE 14. PROPULSION

Level
A B1 B2

14.1 Turbine Engines

a) – – 1
Constructional arrangement and operation of turbojet, turbofan,
turboshaft and turbopropeller engines.
b) – – 2
Electronic Engine control and fuel metering systems
(FADEC);

14.2 Engine Indicating Systems – – 2

Exhaust gas temperature / Interstage turbine temperature systems;
Engine speed;
Engine Thrust Indication: Engine Pressure Ratio, engine turbine
discharge pressure or jet pipe pressure systems;
Oil pressure and temperature;
Fuel pressure, temperature and flow;
Manifold pressure;
Engine torque;
Propeller speed.

03.04.98 2–App 1–36

SECTION 2 JAR–66

MODULE 15. GAS TURBINE ENGINE

Level
A B1 B2

15.1 Fundamentals
Potential energy, kinetic energy, Newton’s laws of motion, Brayton
cycle; 1 2 –
The relationship between force, work, power, energy, velocity,
acceleration;
Constructional arrangement and operation of turbojet, turbofan,
turboshaft, turboprop.

15.2 Engine Performance – 2 –

Gross thrust, net thrust, choked nozzle thrust, thrust distribution,
resultant thrust, thrust horsepower, equivalent shaft horsepower,
specific fuel consumption;
Engine efficiencies;
By-pass ratio and engine pressure ratio;
Pressure, temperature and velocity of the gas flow;
Engine ratings, static thrust, influence of speed, altitude and hot
climate, flat rating, limitations.

15.3 Inlet
Compressor inlet ducts; 2 2 –
Effects of various inlet configurations;
Ice protection.

15.4 Compressors
Axial and centrifugal types; 1 2 –
Constructional features and operating principles and applications;
Fan balancing;
Operation;
Causes and effects of compressor stall and surge;
Methods of air flow control: bleed valves, variable inlet guide
vanes, variable stator vanes, rotating stator blades;
Compressor ratio.

15.5 Combustion Section 1 2 –

Constructional features and principles of operation.

15.6 Turbine Section 2 2 –

Operation and characteristics of different turbine blade types;
Blade to disk attachment;
Nozzle guide vanes;
Causes and effects of turbine blade stress and creep.

15.7 Exhaust
Constructional features and principles of operation; 1 2 –
Convergent, divergent and variable area nozzles;
Engine noise reduction;
Thrust reversers.

15.8 Bearings and Seals – 2 –

Constructional features and principles of operation.

2–App 1–37 03.04.98

JAR–66 SECTION 2

Module 15 (continued)

Level
A B1 B2

15.9 Lubricants and Fuels 1 2 –

Properties and specifications;
Fuel additives;
Safety precautions.

15.10 Lubrication Systems 1 2 –

System operation/lay-out and components.

15.11 Fuel Systems 1 2 –

Operation of engine control and fuel metering systems including
electronic engine control (FADEC);
Systems lay-out and components.

15.12 Air Systems 1 2 –

Operation of engine air distribution and anti - ice control systems,
including internal cooling, sealing and external air services.

15.13 Starting and Ignition Systems 1 2 –

Operation of engine start systems and components;
Ignition systems and components;
Maintenance safety requirements.

15.14 Engine Indication Systems 1 2 –

Exhaust Gas Temperature/Interstage Turbine Temperature;
Engine Thrust Indication: Engine Pressure Ratio, engine turbine
discharge pressure or jet pipe pressure systems;
Oil pressure and temperature;
Fuel pressure and flow;
Engine speed;
Vibration measurement and indication;
Torque;
Power.

15.15 Power Augmentation Systems – 1 –

Operation and applications;
Water injection, water methanol;
Afterburner systems.

15.16 Turbo-prop Engines

Gas coupled/free turbine and gear coupled turbines; 1 2 –
Reduction gears;
Integrated engine and propeller controls;
Overspeed safety devices.

15.17 Turbo-shaft engines 1 2 –

Arrangements, drive systems, reduction gearing, couplings,
control systems.

15.18 Auxiliary Power Units (APUs) 1 2 –

Purpose, operation, protective systems.

03.04.98 2–App 1–38

SECTION 2 JAR–66

Module 15 (continued)

Level
A B1 B2

15.19 Powerplant Installation 1 2 –

Configuration of firewalls, cowlings, acoustic panels, engine
mounts, anti-vibration mounts, hoses, pipes, feeders, connectors,
wiring looms, control cables and rods, lifting points and drains.

15.20 Fire Protection Systems 1 2 –

Operation of detection and extinguishing systems.

15.21 Engine Monitoring and Ground Operation 1 3 –

Procedures for starting and ground run-up;
Interpretation of engine power output and parameters;
Trend (including oil analysis, vibration and boroscope) monitoring;
Inspection of engine and components to criteria, tolerances and
data specified by engine manufacturer;
Compressor washing/cleaning;
Foreign Object Damage.

15.22 Engine Storage and Preservation – 2 –

Preservation and depreservation for the engine and
accessories/systems.

2–App 1–39 03.04.98

JAR–66 SECTION 2

MODULE 16. PISTON ENGINE

Level
A B1 B2

16.1 Fundamentals 1 2 –
Mechanical, thermal and volumetric efficiencies;
Operating cycles;
Piston displacement and compression ratio;
Engine configuration and firing order.

16.2 Engine Performance 1 2 –

Power calculation and measurement;
Factors affecting engine power;
Mixtures/leaning, pre-ignition.

16.3 Engine Construction

Crank case, crank shaft, cam shafts, sumps; 1 2 –
Accessory gearbox;
Cylinder and piston assemblies;
Connecting rods, inlet and exhaust manifolds;
Valve mechanisms;
Propeller reduction gearboxes.

16.4 Engine Fuel Systems

16.4.1 Carburettors 1 2 –
Types, construction and principles of operation;
Icing and heating.

16.4.2 Fuel injection systems 1 2 –

Types, construction and principles of operation.

16.5 Starting and Ignition Systems 1 2 –

Starting systems;
Magneto types, construction and principles of operation;
Ignition harnesses, spark plugs;
Low and high tension systems.

16.6 Induction, Exhaust and Cooling Systems 1 2 –

Construction and operation of: induction systems including
alternate air systems;
Exhaust systems and engine cooling systems.

16.7 Supercharging/Turbocharging 1 2 –
Principles and purpose of supercharging and its effects on engine
parameters;
Construction and operation of supercharging/turbocharging
systems;
System terminology;
Control systems;
System protection.

16.8 Lubricants and Fuels 1 2 –

Properties and specifications;
Fuel additives;
Safety precautions.

03.04.98 2–App 1–40

SECTION 2 JAR–66

Module 16 (continued)

Level
A B1 B2

16.9 Lubrication Systems 1 2 –

System operation/lay-out and components.

16.10 Engine Indication Systems 1 2 –

Engine speed;
Cylinder head temperature;
Oil pressure and temperature;
Exhaust Gas Temperature;
Fuel pressure and flow;
Manifold pressure.

16.11 Powerplant Installation 1 2 –

Configuration of firewalls, cowlings, acoustic panels, engine
mounts, anti-vibration mounts, hoses, pipes, feeders, connectors,
wiring looms, control cables and rods, lifting points and drains.

16.12 Engine Monitoring and Ground Operation 1 3 –

Procedures for starting and ground run-up;
Interpretation of engine power output and parameters;
Inspection of engine and components: criteria, tolerances, and
Data specified by engine manufacturer.

16.13 Engine Storage and Preservation – 2 –

Preservation and depreservation for the engine and
accessories/systems.

2–App 1–41 03.04.98

JAR–66 SECTION 2

MODULE 17. PROPELLER

Level
A B1 B2

17.1 Fundamentals 1 2 –
Blade element theory;
High/low blade angle, reverse angle, angle of attack, rotational
speed;
Propeller slip;
Aerodynamic, centrifugal, and thrust forces;
Torque;
Relative airflow on blade angle of attack;
Vibration and resonance.

17.2 Propeller Construction 1 2 –

Construction methods and materials used in composite and metal
propellers;
Blade station, blade face, blade shank, blade back and hub
assembly;
Fixed pitch, controllable pitch, constant speeding propeller;
Propeller/spinner installation.

17.3 Propeller Pitch Control 1 2 –

Speed control and pitch change methods;
Feathering and reverse pitch;
Overspeed protection.

17.4 Propeller Synchronising – 2 –

Synchronising and synchrophasing equipment.

17.5 Propeller Ice Protection 1 2 –

Fluid and electrical de-icing equipment.

17.6 Propeller Maintenance 1 3 –

Static and dynamic balancing;
Blade tracking;
Assessment of blade damage, erosion, corrosion, impact damage,
delamination;
Propeller treatment/repair schemes;
Propeller engine running.

03.04.98 2–App 1–42

SECTION 2 JAR–66

APPENDIX 2

Aircraft Maintenance Licence Application Form & Example of Licence Format

This appendix contains an example of the JAR–66 aircraft maintenance licence and the relevant
application form for such licence.

It should be noted that in order to qualify as JAR–145 certifying staff to issue a JAR 145.50 certificate of
release to service for an aircraft, a person requires;

a) A valid JAR–66 aircraft maintenance licence of appropriate scope,

and;

b) A valid JAR–145 certification authorisation of appropriate scope.

For information the actual JAR–66 aircraft maintenance licence issued by the JAA full member Authority
may have the pages in a different order and may not have the divider lines.

With regard to the aircraft type rating page the JAA full member Authority may choose not to issue this
page until the first aircraft type rating needs to be endorsed and will need to issue more than one
aircraft type rating page when there are a number to be listed.

Notwithstanding this, each page issued will be in this format and contain the specified information for
that page.

If there are no limitations applicable, the LIMITATIONS page will be issued stating “No limitations”.

2–App 2–1 03.04.98

JAR–66 SECTION 2

INTENTIONALLY LEFT BLANK

03.04.98 2–App 2–2

SECTION 2 JAR–66

APPLICATION FOR INITIAL / VARIATION / CONTINUITY OF JAR–66 JAA FORM 19

AIRCRAFT MAINTENANCE LICENCE (AML)
APPLICANTS DETAILS:
Name: ..........................................................................................................................................
Address: ......................................................................................................................................
.....................................................................................................................................................
Nationality: .................................................... Date and Place of Birth: ....................................
JAR–66 AML DETAILS (if applicable):
Reference No: ............................................... Date of Issue ....................................................
EMPLOYERS DETAILS:
Name: ..........................................................................................................................................
Address: ......................................................................................................................................
.....................................................................................................................................................
JAR–145 Approval Reference:
Tel: ............................................................... Fax: ..................................................................
APPLICATION FOR: (Tick (√) relevant box(es))

Initial issue AML Variation of AML Continuity of AML

Rating A B1 C B2

Aeroplanes Turbine
Aeroplanes Piston
Helicopter Turbine
Helicopter Piston
Reserved
Reserved
Avionics

Type endorsements (if applicable):

.....................................................................................................................................................
.....................................................................................................................................................
.....................................................................................................................................................
.....................................................................................................................................................
I wish to apply for initial issue / variation of/ continuity of JAR–66 AML as indicated and confirm
that the information contained in this form was correct at the time of application. I also understand
that any incorrect information could disqualify me from holding a JAR–66 AML.
Signed: ......................................................... Name: .............................................................. .
Date..............................................................................................................................................

2–App 2–3 03.04.98

JAR–66 SECTION 2

APPLICATION FOR INITIAL ISSUE/ VARIATION / CONTINUITY OF JAR–66 JAA FORM 19

AIRCRAFT MAINTENANCE LICENCE (AML)
AIRCRAFT MAINTENANCE EXPERIENCE: Conf Signature

I wish to claim the following credits (if applicable):

Experience credit due JAR–147 training
Examination credit due equivalent exam Enclose relevant certificates
JAR–145 AMO recommendation (if applicable): It is hereby certified that the applicant has met the
relevant maintenance knowledge and experience requirements of JAR–66 and it is recommended
that the Authority grants or endorses the JAR–66 AML.

Signed: ......................................................... Name: ............. ...................................................

Position: ....................................................... Date:............... ...................................................

03.04.98 2–App 2–4

SECTION 2 JAR–66

Conditions:
1. This licence must be accompanied by an identity
document containing a photograph of the licence
AUTHORITY NAME & LOGO holder.
A FULL MEMBER OF 2. Endorsement of any (sub)categories on the page(s)
THE entitled JAR–66 (SUB)CATEGORIES only does not
JOINT AVIATION AUTHORITIES permit the holder to issue a certificate of release to
service for an aircraft.
JAR–66 3. Endorsement of aircraft types on the page(s)
entitled JAR–66 AIRCRAFT TYPE RATINGS means
the holder qualified to issue certificates of release to
AIRCRAFT MAINTENANCE service for such aircraft at the date of endorsement.
4. This licence when endorsed in category B1 or B2
LICENCE or C together with a valid aircraft type JAR–145
certification authorisation meets the intent of ICAO
Annex 1.
5. It is the responsibility of the holder to ensure that
THIS LICENCE IS RECOGNISED BY ALL FULL MEMBER certificates of release to service are only issued
AUTHORITIES OF THE JOINT AVIATION AUTHORITIES within the limitations of this licence and both JAR–66
and JAR–145 except as specified in paragraph 6.
6. This licence may only be used outside the JAR–
145 organisation if a specific statement to such affect
is endorsed by the Authority that issued this licence
on the page(s) entitled LIMITATIONS.
7. This licence remains current until the review date
on the limitation page whilst in compliance with JAR–
66.40 unless previously suspended or revoked.

1. State of issue JAR–66 (SUB)CATEGORIES

2. Licence No.: A B1 B2 C

3. Full name of holder: Aeroplanes Turbine

4. Date and place of birth: Aeroplanes Piston

5. Address of holder: Helicopters Turbine

6. Nationality: Helicopters Piston

7. Signature of holder: Avionics

8. Signature of issuing officer & date: Reserved

9. Seal or stamp of issuing Authority: Reserved

Lic No:

2–App 2–5 03.04.98

JAR–66 SECTION 2

JAR–66 AIRCRAFT TYPE RATINGS JAR–66 LIMITATIONS

A/C Type Category Official

Stamp &
Date

Licence Review Date:

LIC NO: LIC NO:

03.04.98 2–App 2–6

SECTION 2 JAR–66

APPENDIX 3

The full member Authorities

Reference is made in JAR–66 to the JAA full member Authorities and the following list constitutes the
States of the JAA full member Authorities, except that it is possible for a JAA candidate member
Authority to achieve full member status and be missing from the list until the next amendment of
JAR–66. Reference should therefore be made to JAA Headquarters for the latest situation between
reissues of this Appendix.

Austria Luxembourg
Belgium Monaco
Denmark Netherlands
Finland Norway
France Portugal
Germany Spain
Greece Sweden
Iceland Switzerland
Ireland United Kingdom
Italy

2–App 3–1 03.04.98

JAR–66 SECTION 2

INTENTIONALLY LEFT BLANK

03.04.98 2–App 3–2

 NPA 66 Comment Response
5 November 1997

A total of 468 comment responses were received from 10 JAA-NAAs, 6 Euro assns, 4 Nat assns, 14
JAR 145 orgns and 4 individuals.

28 General comments were received addressing the following issues although it should be noted that
there were a number of additional specific comments which are covered by the relevant paragraphs:

(1) 2 JAA-NAAs , 1 Nat assn and 1 JAR 145 orgn supported the NPA with the assn adding that the
issues have been debated long enough.
Response: None necessary.

(2) 1 Euro assn stated that there would be a substantial and unnecessary economic burden without
giving reasons why this would be so.
1 Euro assn stated that the involvement of JAA-NAAs issuing/renewing licences means increased
costs/bureaucracy without increased safety. The qualification/authorisation process should be left
to the JAR 145 and 147 orgn with oversight audits by the JAA-NAA. The assn drew a comparison
with the USA system but stated that the JAA-NAAs oversight audits were better.
1 Euro assn and 1 Nat assn stated that the JAA-NAA should control and issue the licence under
JAA supervision in view of the increasingly competitive nature of the industry.
Response: It is difficult to see how a task carried out by the JAA-NAA puts an increased cost
burden on Industry, particularly when it is understood that 25 of the 27 JAA-NAAs either issue
or validate licences today. Having said this it is clear that the larger JAR 145 orgns have both
the will and capability to carry out the qualification process which is not necessarily the case for
all small JAR 145 orgns. Therefore JAA Administrative & Guidance Material will address the
control and issue process and current drafts already provide for JAR 145 orgns to carry out
much of the process. With regard to the actual issue of the licence the majority of JAA-NAAs
believe this should only be done by the JAA-NAAs although the draft JAA procedures permit the
document to be prepared by the JAR 145 orgn subject to a satisfactory control process. The draft
associated JAA procedures are considered flexible enough to ensure that the stated concerns will
not occur in practice and it would be wrong to adopt USA practises. Whether both JAR 145 and
147 orgns should qualify staff is debatable, but irrelevant for a combined JAR 145 147 orgn. The
JAA is however concerned about those JAR 147 orgns which are primarily educational institutes
who may not be appropriate to cover the complete spectrum of education and experience. It is
therefore not accepted that JAR 147 complete the qualification process.

(3) 1 JAA-NAA pointed out that there was no requirement about making application for the licence.
Response: A new para JAR 66.13 has been added to address this issue.

(4) 1 Nat assn requests that the term “certifying staff” be replaced by “maintenance staff” thereby
making it possible to qualify all staff and ensure flight safety.
Response: JAR 66 was only intended to cover certifying staff for the foreseeable future and
therefore such a request is not in accordance with current JAA maintenance policy. However it
should be noted that nothing prevents anyone from at least qualifying in the JAR 66 basic
categories even without the benefit of approved basic training.

(5) 1 Euro assn pointed out that JAR 66 does not cover the situation of new type aircraft being
introduced for the first time.
Response: This is accepted and an amendment has been made to the practical experience
specified in AMC 66.45 (b) 4 but there was no necessity to identify new type aircraft. Comment
(133) addressed the same issue.

(6) 1 JAR 145 orgn stated that there should be more reference to JAR 147 in JAR 66.
Response: This is agreed and both JAR 66.30 (a) and AMC 66.30 (a) amended accordingly.

1
NPA 66

(7) 1 Euro assn argued that as proposed the Category C person could release an aircraft based upon
the signatures of non-certifying staff, whereas the base maintenance inspector of today have
proven their ability. The assn therefore contends that the distinction between base and line
maintenance can be dropped. 1 Nat assn proposes that categories A, B1 and B2 should also work
in base maintenance to support the category C.
Response: The categories of certifying staff needed by a JAR 145 organisation are intended to be
spelt out in JAR 145 and there is a draft NPA 145-7 on limited informal circulation which
proposes that category B1 and B2 should sign off base maintenance, leaving aircraft release to
the category C. Nothing prevents an orgn from using category A in base maintenance but there is
no such need proposed for JAR 145.

(8) 1 Euro assn strongly opposed the category A on the basis that because of limited training it was
not possible for such a person to understand the possible impact of their maintenance actions on
other systems. Furthermore category A could not easily convert to B1 or B2 because of further
training and examination needs. The assn stated that as a compromise it would accept category A
if already qualified category B1 or B2 on a similar aircraft type. 1 JAR 145 orgn suggested that
perhaps category A should be dropped because it causes such problems.
Response: The basis of this comment is not correct because whilst the category A has only limited
training a study of the Appendix 1 knowledge requirements shows a need to have an overall
knowledge for those systems that may interact. Probably the most important element is an overall
knowledge of structural problems that the category A may find and must report to the category
B1. A number of training organisations have indicated that the structure of JAR 66 Appendix 1
makes it easy to package together training into relevant modules. Qualification in category B1
already automatically covers the category A responsibilities . The basis of the argument to delete
category A is not accepted.

(9) 1 Euro assn proposed that the opening para of the foreword should make reference to cost
efficient maintenance as the JAA is committed by objective to this issue.
Response: The aviation safety requirements have always been written to address safety and it
would be inappropriate to add statements on efficiency which is really an industry survival need.
The JAA will continue to strive to ensure that only safety related issues are addressed in the
JARs.

(10) 1 JAA-NAA and 2 Euro assns disagreed with the title JAR 66 Aircraft Maintenance Basic Licence
of which 1 reasoned that because it included aircraft types the word “basic” was inappropriate and
ICAO referred to engineers which should therefore be included. The other assn preferred the
original title “Certifying Staff Qualification Document” but could accept Aircraft Maintenance
Licence.
Response: The JAA believes that titles should be kept as short as possible and therefore accepts
the title “Aircraft Maintenance Licence”.

(11) 2 JAA-NAAs wanted JAR 66 to be applicable to helicopters above 2700kg and not 5700kg,
whereas 1 Euro assn and 1 Nat assn wanted a commitment in JAR 66 to cover aircraft below
5700kg within a specified timescale. The JAA-NAAs in support of their comment pointed out
that leaving out helicopters between 2700kg and 5700kg represented a significant gap in the
requirement.
Response: Application of JAR 66 to helicopters between 2300kg and 5700kg represents a major
change and must go to the NPA. JAR 66 is a requirement and cannot contain a commitment for
the future. However as soon as JAR 66 is adopted the JAA recognises the need to address this
issue as a high priority.

(11A) 1 individual commented that there were too many hidden requirements in the Section 2 AMC
Response: Agreed - a number of the Section 2 paras have been transferred to Section 1.

(11B) 1 individual commented that we should use the acronym NAA rather than JAA full member
Authority because it was better understood.
Response: The new term is defined and needed because there is confusion between a JAA
member who is a full member and a JAA member who is a canidate member and may issue

2
 NPA 66

licences and certificates in accordance with the JARs but may not be recognised by the other full
members of JAA.

(11C) 1 individual pointed out that the requirement was unclear in several places about who will make
the determination about company procedures ( old para 66.35(b)), examinations (old para
66.45(d)) and who will keep records (old para 66.25(c)).
Response: Company procedures have been transferred back to JAR 145, who may conduct
examinations is specified in AMC 66.45(d) and record retention transferred to JAR 147.

(11D) 1 individual proposed deletion of all notes as they have no legal power.
Response: It is agreed that notes have no legal power but they do try to help with understanding
the requirement and have therefore been retained.

10 comments on JAR 66.1 were received addressing the following issues;

(12) I JAA-NAA noted that JAR 66.1, JAR 66.3 and JAR 66. 10 mixed up issues of requirements,
procedures, etc and therefore should be reviewed by the JAA Regulation Advisory Panel (RAP)
for readability.
Response: It is agreed that these paras could be improved but in view of the 7 years of
development work trying to reconcile the different and strong views held by the various
participants, we must be cautious about the major delay such a review would cause. It should
also be noted that RAP members have been included in the consultation and some have provided
comments. Having said this, para 66.10 (b) which limits the requirement to large aircraft has
been moved to para 66.1 as this para addresses the main limitations of JAR 66.

(13) 1 JAA-NAA suggested 3 minor text changes to improve clarity. 1 of the proposed text changes
added a reference to JAR 145 certification authorisation at the end of para 66.1 (c).
Response: 2 of the changes have been adopted because there is no change of intent, but the 3rd
change proposed to 66.1 (c), now (d) was not adopted because it could be seen as a limitation.

(14) 1 JAA-NAA and 1 Euro assn proposed that the para 66.1 (c) , now (d) and (d), now (e) which
permit continued recognition of personnel qualified to existing National requirements should be
time limited, with the JAA-NAA suggesting 10 years.
Response: This issue also featured in the previous NPA 65-0 with such mixed response that it was
not possible to ensure even reasonable agreement. It was also felt that as long as there was no
automatic cross border recognition of such Nationally qualified personnel, no time limit was
necessary. However, discussions with the European Commission suggest that they cannot accept
such non cross border recognition, leaving two options. The first is to impose a time limit and the
second option is to convert existing personnel from National to JAR 66 standard without further
training/examination but with technical limitations, if necessary, in their JAR 66 licence to cover
any shortcomings. The technical limitations would be identical to that in the National
requirement and would not represent any change for the person. The JAA, after discussion with
the European Commission has agreed to convert existing Nationally qualified personnel to JAR
66 without further training or examination but with the previously mentioned technical
limitations within 10 years in view of the numbers involved. JAR 66 has been amended
accordingly. It is the opinion of JAA that all certifying staff aged 50 or less should be
encouraged to transfer to the full JAR 66 standard without technical limitation during the next 10
years because the JAR 145 orgns will increasingly wish to employ such personnel as they
become available.

(15) 1 Euro assn pointed out that as JAR 66 is limited in application to large aircraft by para 66.10 (b),
this should also be reflected in para 66.1 (b) for clarity.
Response: This is agreed but for clarity para 66.10 (b) plus its note has been transferred to
para 66.1 with editorial amendment to reflect this comment and part of the first comment to para
66.1.

Eur(16) 1o assn requested an amendment to para 66.1 (e), now (f) to ensure that personnel
qualified to existing National requirements could add new aircraft types to their National

3
NPA 66

qualification without having to meet the basic elements of JAR 66. On the other hand 1 Euro assn
and 1 Nat assn opposed such a possibility and proposed an amendment to prevent the new aircraft
types being added.
Response: It has never been the intention of JAA to stop new aircraft types being added to an
existing national qualification and therefore JAR 66 has been amended accordingly. It should be
noted that the JAR 66 aircraft type requirements will need to be met and existing personnel will
be converted with limitations in response to comment (14).

12 Comments on JAR 66.3 were received addressing the following issues;

(17) 1 Nat assn accepted the para as written.

Response: None required.

(18) 1 Euro assn proposed that an addition para be added to make it clear that the licence would be
issued by the JAA full member Authority.
Response: The para is about effectivity, which means compliance dates and has no bearing on
who will issue the licence.

(19) 1 JAA-NAA made a comment about mixing requirements, procedures, etc, against this para as per
comment (12) to para 66.1 and pointed out that the issue date was a Sunday.
Response: See response to comment (12) and the issue date changed from a Sunday.

(20) 1 Nat assn stated that the effectivity date specified in para 66.3 (a) is only acceptable if existing
national certification qualifications remain valid under JAR 66.
Response: The commentor has misunderstood the intent of AMC 66.1 because existing national
qualifications will remain valid. This will be further explained in the response to AMC 66.1. See
also comment response (22).

(21) 1 Euro assn proposes that para 66.3 be deleted in its entirety because all previous licences must
be accepted and therefore an implementation date and transition period is not necessary.
Response: This comment totally ignores the intent, which is to establish a single European
standard for the future rather than perpetuate the many existing systems. This would establish a
level playing field for industry, give it easier access to a greater number of qualified personnel
and make it easier for certifying staff to move around Europe. The key is to cater in the new
standard for personnel qualified via the old systems without causing any avoidable burden.
Without an effectivity date for new people there would be no European standard.

(22) 1 JAR 145 was concerned that the effective date should be later than that for JAR 147 otherwise
there would be a problem in obtaining JAR 66 qualified staff in time.
Response: This comment suggests a misunderstanding in that it fails to take into account para
66.1 (c), now (d) which allows personnel qualified under existing National requirements to
continue certifying within the limitations of the national qualification. Therefore from the
proposed mandatory compliance date of 01 June 2001 a JAR 145 orgn releasing aeroplanes or
helicopters 5700kg and above may use either staff fully qualified to JAR 66 or staff qualified to
national requirements via the new paras 66.1 (d) or (e) or (f) or may in fact use a mixture of such
qualified staff. However comment (14) is also relevant to this issue.

(23) 1 Euro assn proposed that the transition period be reduced to 2 years on the basis that the sooner
the better.
Response: The transition to JAR 145 which was much less controversial could not be achieved in
less than 3 years and therefore a 3 year transition for JAR 66, which it should be remembered
will run in parallel with JAR 147 implementation represents an absolute minimum time.

(24) 1 Euro assn thought it not possible to meet the 3 year transition time for all certifying staff when
aircraft components (including engines) have not yet included.
Response: This 3 year transition only applies to certifying staff who issue release to service for
the larger aeroplanes and helicopters. New compliance dates would be notified in respect of
small aircraft and aircraft components.

4
 NPA 66

(25) 1 Euro assn commented that para 66.3(b) seems to suggest that everyone who does not meet the
full JAR 66 standard within 3 years is automatically not qualified. The assn therefore proposed a
text change.
Response: This was not the intention but unfortunately the proposed text change only made the
situation worse. The text has therefore been improved and in conjunction with the changes to
para 66.1 (b) should be clearer.

(26) 1 Nat assn proposed that the para 66.3 (d) should be deleted because certifying staff authorisation
can only be given by the JAA on request from the JAR 145 orgn.
Response: The commentor seems to have misunderstood the requirement because the JAA-NAA
only issues the licence which represents a qualification. The actual certification authorisation
must be issued by the JAR 145 organisation. However it is evident that para 66.1 (d) applies to
the JAR 145 orgn and such JAR 145 orgn can issue such authorisations at any time within the
limitations of their approved procedures. The para has therefore been deleted.

(27) 1 Euro assn made reference to a general comment in relation to para 66.3 (e) which was not clear.
Response: Whilst the point of the comment was not clear a review of para 66.3 (e) shows that the
para is both unclear and incorrect in that personnel qualified to national requirements may
continue to be qualified both during and after the transition period. The para 66.3 (e) is
therefore deleted.

18 comments on JAR 66.5 were received addressing the following issues;

(28) 2 JAA-NAAs, 2 Euro assns and 1 Nat assn variously stated that the aircraft maintenance basic
licence title should be changed to aircraft maintenance licence and that the definition changed
slightly to make it clear that aircraft types cannot alone be included without the relevant basic
category. 1 Euro assn suggested this was the place to point out that the aircraft maintenance
licence alone does not permit certification.
Response: Comments accepted and text amended. See also comment (10 ) re licence title.

(29) 1 Euro assn commented that the approved course standard needs to be defined and 1 other Euro
assn requested that only the Authority should approve the courses.
Response: As JAR 147 now addresses approved courses, this definition is not required,
particularly when comment ( ) is taken into account.

(30) 1 JAA-NAA and 1 Euro assn proposed that the line and base maintenance definitions should refer
to maintenance Temporary Guidance Leaflet No 6 instead of JAR 145. 1 individual proposed
deletion because JAR 145 does not specify.
Response: It is not JAA policy to make specific reference to any TGL in a the section 1
requirements as this would make such a TGL mandatory. The Line & Base maintenance
statements have been deleted.

(31) 1 Euro assn made 3 comments in relation to certification. The first comment proposed an
amended certification text to require the licence number, etc, to be included on documentation
related to release. The second comment proposed a new “maintenance release” definition and the
third comment proposed a new “certify as airworthy” definition.
Response: JAR 66 only addresses the qualification necessary to obtain an aircraft maintenance
licence and the certification task limitations and therefore the comments are not relevant,
particularly as certification, the issue of a certificate of release to service, is a JAR 145
requirement.

(32) 1 Euro assn proposed that the “procedures” definition should use words that align with JAR 145.
Response: Agreed, text amended.

(33) 1 JAR 145 was concerned that the definition of line maintenance should not be restrictive for
smaller aircraft and proposed addition text plus a request that the JAR 145 and TGL s be revised.
Response: This is not a JAR 66 issue because it relates to JAR 145 and JAR 66 does not address
aircraft under 5700kg.

5
NPA 66

(34) 1 Euro assn pointed out that the definitions for “full member authority” and “non-full member
Authority were missing and that all general definitions should go to JAR 1.
Response: It is agreed that full member authority should be added but not the non-full member
because there is no such reference in JAR 66. Transfer to JAR 1 will occur in due course when
reviewed and accepted for JAR 1.

(35) 1 JAA-NAA commented that the JAR 1 steering group should review the definitions and pointed
out that some are not definitions and some not necessary because they are JAR 145 definitions.
Response: See comment response (34). It is also agreed that some are not definitions and maybe
in strict legal terms not necessary but the text is trying to help people understand intent and
thereby minimise misinterpretation.

16 comments on JAR 66.10 were received addressing the following issues;

(36) 1 JAA-NAA made a comment about mixing requirements, procedures, etc, against this para as per
comment (12) to para 66.1 and comment (19) to para 66.3.
Response: See response to comment (12).

(37) 1 Nat assn proposed different text for the opening sentence of para 66.10 (a) to reflect their
understanding that the authorisation is given by JAA on receipt of a request from the JAR 145
orgn.
Response: The commentor has misunderstood the requirement, in that it is the JAR 145 orgn that
issues a JAR 145 certification authorisation in accordance with procedures specified in the
approved maintenance orgn exposition. The proposal cannot therefore be agreed.

(38) 1 Euro assn proposed that that “orgn exposition” should be used in para 66.10 (a) rather than
“company exposition”.
Response: The para does not refer to expositions or procedures and therefore no change is
relevant. The assn may have been referring to para 66.15(b) which has been amended.

(39) 1 Euro assn proposed that consideration should be given to the subcontract situation where the
staff do not have 66/145 authorisation.
Response: This is an issue for JAR 145 and not JAR 66 because JAR-145 determines the
applicability of JAR 66.

(40) 1 JAA-NAA proposed a minor amendment to the 2nd sentence of para 66.10 (a) for clarification,
whereas 1 Euro assn and 1 Nat assn proposed adding the words “type rated” in front of aircraft
maintenance licence.
Response: The second proposal could not be accepted because the category A will not be issued
a type rating and it is possible to hold a JAR 66 aircraft maintenance licence with only basic
categories and no type ratings, a note has been added to reflect this possibility.

(41) 1 JAA-NAA proposed a minor amendment to the 4th sentence of para 66.10 (a) for clarification
and 1 Nat assn proposed adding endorsements “by the JAA full member Authority”.
Response: The proposed clarification amendment is accepted but the reference to JAA full
member Authority should not be in this para which covers applicability. The new para 66.13
application and issue will address the comment.

(42) 3 JAA-NAAs and 1 Euro assn proposed that the helicopter weight limit be changed to 2700kg.
Response: See comment and response (11).

(43) 2 Euro assns and 1 Nat assn proposed that the 5700kg aircraft limit also make reference to
specialized services and engines, propellers and appliances.
Response: JAR 66 is directly related to JAR 145 and JAR 145 does not use the JAR 21 terms of
engines etc. With regard to specialized services, JAA current policy is to include them in JAR 145
as there is no intention to grant licences for such activity. Note also that the relevant text has
been transferred to para 66.1.

6
 NPA 66

8 comments on JAR 66.15 have been received addressing the following issues;

(44) 2 JAA-NAAs, 1 Euro assn and 1 Nat assn strongly opposed the minimum age of 18 years for
category A staff requesting 21, whereas 1 other JAA-NAA and 1 other Euro assn also opposed
the minimum age of 18 years but requested 20 instead. It was argued that such young people
could have considerable difficulty in resisting any commercial pressures, particularly on the flight
line and it was more a question of maturity rather than technical confidence.
Response: The proposal is accepted and the age raised to 21 years.

(45) 2 Euro assns objected to the words “verbally communicate” in para 66.15 (b) on the basis that it
was impossible to establish a standard and it would discriminate again those people that have a
speech impediment. It has also been brought to the attention of JAA that there are a number of
very experienced certifying staff who cannot speak but communicate well either in writing and/or
by computer.
Response: This comment is accepted and the word “verbally” deleted.

13 comments on JAR 66.20 were received and addressed the following issues;

(46) 1 JAA-NAA proposed that para 66.20 (b) should make reference to aircraft type ratings in
relation to the licence.
Response: Proposal accepted.

(47) 2 JAA-NAAs pointed out that the A category is sub-divided into sub-categories and thus para
66.20 (b) (1) should state so. One of the JAA-NAAs also requested that a positive statement be
made that avionic mechanics could also qualify for category A.
Response: Proposals accepted but it is also necessary to mention that the B1 is automatically
qualified category A and the B2 could qualify if the category A standard is met.

(48) 1 Nat assn opposed the category A unless it was qualified to B1 or B2 level because all certifying
staff must have comprehensive knowledge and it is easier to move orgn to orgn.
Response: See comment and response (8) as a result of a similar comment from a Euro assn.

(49) 2 Euro assns proposed the deletion of “line” from line maintenance in para 66.20 (b) (2), (3) and
(4) on the basis that it implies different standards for line and base and to facilitate movement of
staff between the two areas.
Response: This proposal cannot be accepted because it would mean certification in base
maintenance was being carried out by B1, B2 and C which is not necessary and not in line with
JAA policy. The standards can not be construed as different because NPA 145-7 will call for B1
and B2 to sign for their respective specializations in base maintenance to support the C
c(ategory certificate of release to service.

(50) 2 Euro assns proposed that “certifying staff” be deleted from at least the last line of para 66.20
(b) (4) reasoning that the certifying staff who release aircraft must always rely upon
appropriately authorised staff, for example, base maintenance technicians. 1 JAA-NAA suggested
a rewording of the para because there was much misunderstanding about whether this means a
single or multiple issue of a certificate of release to service with the JAA-NAA believing both
were possible. 1 Euro assn stated that there should only be one issue of the certificate of release.
Response: These comments illustrate that the various representative organisations wish to
interpret this para in different ways which was not the intent. The most serious issue being that
the intent was to allow for the B1 or B2 category to issue one certificate of release to service for
the aircraft even if some maintenance tasks outside the scope of their technical competence had
been carried out so long as the appropriately qualified B1, B2 or A category certifying staff had
signed for such maintenance tasks. It was not intended to permit “aircraft release” based upon”
non certifying staff. As the issue is really about how the JAR 145 organisation ensures that only
“qualified staff” carry out “aircraft release”, the JAA has agreed the para serves no useful
purpose and should be deleted. This does not solve the main issue but transfers it to the more
appropriate JAR, namely JAR 145.

7
NPA 66

(51) 1 Euro assn proposed the deletion of para 66. 20 (b) (5) which means deletion of category C
unless the B1 and B2 categories were also required in base maintenance.
Response: See response to comment (49) which states that the B1 and B2 categories will be
added to JAR 145 via NPA 145-7.

(52) 1 Euro assn proposed a note at the end of para 66.20 making reference to the fact that JAR 145
will address the base maintenance requirement for non-certifying personnel and the need for
qualified B1 and B2 staff.
Response: The intent of this comment is accepted, particularly as some commentors would expect
a commitment regarding the B1/B2. It is not appropriate to include a certifying structure as this
is a requirement on JAR 145.

13 comments on JAR 66.25 were received addressing the following issues;

(53) 1 Euro assn and 1 Nat assn opposed any person who does not attend formal training (self starter) ,
reasoning that it was not possible to assure the correct knowledge level by examination alone and
therefore proposed additional text in para 66.25 (a). In addition the assn also requested mention
of JAA full member supervision and the Appendix 1 to JAR 66 Section 2.
Response: No evidence was offered to show that a formally trained person necessarily achieves
a better level of knowledge than a person who follows the longer experience route. The JAA
believes the requirement is well balanced in that it provides for a faster track to qualification if
approved training is undertaken, but does not deny the person who may not have had a training
opportunity but does have proven experience. Requirements do not include the obligations of
Authorities, such as supervision, because these are contained in various statutes covering the
powers, etc of the Authority. Preference to Appendix 1 in the Section 1 of JAR 66 raises it to the
level of primary law, which is not justified, because any minor variation in the applied standard
does not affect safety and the required “levels” are subjective. See comment response (72) which
in combination with this comment has resulted in amendment to 66.25 (a).

(54) 1 Euro assn proposed that the training and examination of category A be delegated to the JAR
145 orgn.
Response: This comment is puzzling because delegation is already proposed in respect of
category A and B1/B2 to appropriately approved JAR 147 orgns and many such orgns will be
part of a JAR 145 orgn.

(55) 1 Euro assn stated that the category A knowledge requirements were excessive relative to the
permitted simple tasks reasoning that this could result in a human factor problem if trained
beyond the job needs. It was therefore suggested that category A knowledge levels in Appendix 1
be deleted and let the JAR 145 determine the knowledge need.
Response: In terms of perceived excessive category A knowledge, this comment will be
considered with other relevant comments to Appendix 1 later. Whatever the final category A
standard, it must stay in JAR 66 to ensure long term common standards.

(56) 1 JAA-NAA proposed a minor amendment to para 66.25 (a) to make clear that it also applies to
licence extensions.
Response: This is agreed.

(57) 1 JAA-NAA and 1 Euro assn proposed that para 66.25 (b) should be amended to ensure that
“credit.......for equivalent qualifications held in other disciplines.” be clearly specified as a JAA
full member Authority decision. 1 JAR-145 stated that it was essential to provide AMC or IEM
material to explain the meaning.
Response: Reference to the “Authority” has been added and the text modified to make the intent
more specific. IEM material will also be added.

(58) 1 JAA-NAA proposed that the examination retention requirement of para 66.25 (c) should be in
the JAR and not the AMC and that the retention period the same as JAR 145 ie 2 years. 1 Euro
assn pointed out that as examinations can be carried out by appropriately approved JAR 147

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orgns, the para can be deleted as JAR 147 has specific examination requirements. 1 Euro assn
proposed amended text for the examination format.
Response: The para was written some time before JAR 147 and therefore has now been amend.
With regard to retention periods, whilst this is agreed, the periods are in fact in JAR 147 and
have now been deleted from the AMC. It is not appropriate to make requirements on the
“Authority” about retention of examination records, this being a matter to be addressed in JAA
procedures. The proposal to amend the examination format text is no longer relevant because the
format information has been deleted because it is in JAR 147 and JAA procedures.

(59) 2 Euro assns commented that clarification of grandfather rights was needed in respect to the basic
knowledge requirements of para 66.25 (a) and in particular for those persons holding an ICAO
licence.
Response: This comment should be considered with comment response (14) which has added a
new para 66.1 (g). The new para accepts any existing licence or authorisation for the particular
technical subjects without further examination.

10 comments on JAR 66.30 have been received addressing the following issues;

(60) 1 Euro assn proposed that the practical experience for university degree holding category C
personnel should be 12 months, quoting amongst other reasons that supporting expertise in base
maintenance is not required. 1 Euro assn asked if the JAA will require training information from
institutes in order that the reduction in experience due to training can recognised. 1 Euro assn and
1 Nat assn proposed adding reference to the “Authority” in para 66.30 (a).
Response: University degree holdingC category staff will be supported by B!/B2 category staff
as well as still having to meet a need for 3 years maintenance experience and therefore the
proposal is not justified. Regarding training information, the “Authority” will need such
information to justify any experience reduction. Reference to the “Authority” in para 66.30 (a) is
agreed.

(61) 1 JAA-NAA proposed that para 66.30 (a) maintenance experience should be hands-on reasoning
that this was important and logical.
Response: This is agreed for categories A and B1/B2 because they need to be able to carry out
the tasks in line maintenance which is not the case for category C in base maintenance and it
raises an important issue because JAR 66.30 does not refer to hands-on or practical experience,
whereas AMC 66.30 (a) does so for university degree holding category C personnel only. This
was not the intention and therefore the difference in the type of experience between categories A,
B1/B2 and C has been clarified in the JAR.

(62) 1 Euro assn and 1 Nat assn proposed that the para 66.30 (b) maintenance experience be
“comprehensive”.
Response: The intent is agreed but it has been covered in comment (61) response by the meaning
of “practical”

(63) 1 JAA-NAA, 1 Euro assn and 1 individual proposed that para 66.30 (c) be amended to make it
clear that the decision to recognise non-civil maintenance was a matter for each JAA-NAA.
Response: Intent agreed and text modified.

3 comments on JAR 66.35 have been received addressing the following issues;

(64) 1 JAA-NAA proposed the deletion of para 66.35 because it is a JAR 145 requirement.
Response: This is agreed, particularly as AMC 145.30 (c) contains the same need.

(65) 1 Nat assn agreed with the text of this para whereas 1 Euro assn proposed that the text of sub-
paras (a) & (b) should be combined.
Response: Comments noted but para 66.35 deleted by comment response (64).

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NPA 66

5 comments on JAR 66.40 have been received addressing the following issues;

(66) 1 Euro assn made 2 comments stating first that there should not be a validity period for the
aircraft maintenance licence because it is bureaucratic, has no safety benefit and the “Authorities”
control by approval the JAR 145 orgns. Secondly the assn stated that there should be no “basic”
licence qualification for category A and category A qualification should be left to the 147 orgns.
Response: The intent of the comment is agreed and the para has been changed from validity to
continuity. The Authority does need to ensure from time to time that the licence details are the
same in the record as on the licence. Therefore the licence needs to be inspected once in every
five year period unless inspected during the last five years. Validity will be added to the JAR 145
certification authorisation.

(67) 1 JAA-NAA proposed that para 66.40 should state “basic” licence, whereas 1 Nat assn accepted
the para as written and 1 individual proposed amended title for clarity..
Response: As “basic” has been removed from the licence title and validity replaced by
continuity,the comments have been superceded by the changes.

15 comments on JAR 66.45 have been received addressing the following issues;

(68) 1 Euro assn and 1 Nat assn proposed that the para 66.45 (a) category A task training should be
approved by the “Authority”.
Response: This is agreed but must also include Authority approval via JAR 147 and JAR 145.
Text amended.

(69) 1 Euro assn and 1 Nat assn proposed that para 66.45 (b) B1/B2 type rating and training be
endorsed/ approved by the “Authority”.
Response: The intent is agreed but reference is also needed to the aircraft maintenance licence.
Text amended.

(70) 1 Euro assn proposed the deletion of para 66.45 (c) on the basis that certification by the category
C was irrelevant due to the proposed B1/B2 category in base maintenance.
Response: This commentor misses the point that the Category C function is to ensure that all
maintenance processes have been called up and carried out, whereas the category B1/B2
function is to ensure each maintenance task called up by the process has been carried out to the
standard. This is a different function.

(71) 1 JAA-NAA proposed that para 66.45 (c) re category C be amended to be more specific on type
training and rating in a similar manner to para 66.45 (b) re category B1/B2.
Response: Agreed, the old para (c) has been combined with (b).

(72) 1 Euro assn proposed that para 66.45 (c), now (b) be amended to include reference to the need for
category C to meet B1/B2 knowledge and experience requirements because JAR 66 Section 1
does not say so and Appendix 1 does not deal with category C.
Response: This is a good comment because it illustrates the point that JAR 66 Section 1 does not
make it at all clear about how to qualify for the different categories. Therefore it is clear that
some AMC fundamentals need to be transferred into Section 1. Amendments have been made to
JAR 66.25 and JAR 66.30 to clarify the intent.

(73) 1 JAA-NAA and 1 Euro assn proposed that para 66.45 (d), now (c), should include a reference to
category A task training. 1 Euro assn and 1 Nat assn proposed a reference to examinations being
conducted by the “Authority” or the 147 org. 1 Euro assn also proposed that “competence” be
added.
Response: Apart from the “competence” proposal the comment is agreed and text amended.
Regarding the “competence” proposal, this is clearly specified in JAR 145.30 (c).

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 NPA 66

(74) 1 Euro assn pointed out that the para 66.45 (e), now (d) record retention requirement was an issue
for 145 or 147 but not JAR 66 and 1 JAR 145 orgn say no reason for keeping the record anyway.
Response: There is need to keep records for several reasons of which one is in cause of a legal
appeal against examination failure. However it is agreed this is a JAR 147 matter which does
regulate this aspect. With regard to the “Authorities”, they are covered by JAA procedures. Text
amended.

(75) 1 JAR 145 orgn believes that a type training course and examination by a 3rd party should be
acceptable.
Response: Such a possibility is available under JAR 147.

(76) 1 Euro assn proposed a new sub-para to 66.45 making it a requirement for 145 orgns to withdraw
certification authorisation when training/experience is not current.
Response: This is a JAR 145 issue and it would seem bureaucratic to require such action so long
as the 145 certification authorisation containted a statement to the affect that its validity is
dependant upon compliance with recency requirements.

2 comments on JAR 66.50 were received addressing the following issues;

(77) 1 Nat assn accepted the medical para 66.50 as written whereas 1 Euro asn could not see the point
of such para.
Response; There is an increasing public perception that in view of drug and alcohol concerns
personnel who carry out important duties affecting the public should be fit for that duty. The
para therefore remains unchanged.

5 comments on JAR 66.55 were received addressing the following issues;

(78) 1 Nat assn accepted para 66.55 as written, 1 JAA-NAA proposed that the licence format be
similar to that for the flight crew, 1 Euro assn proposed reference to engineer, the “Authority” and
linkage with the format in Appendix 2.
Response: This para is about evidence of qualification and not format, but it is appropriate to
link the licence with the “Authority”. Regarding reference to “engineer”, this has been debated
many times but it is clear that the word has different meanings in different languages which
makes translation difficult and therefore it is not used.

(79) 1 Euro assn proposed that the licence should be shown to “authorised” persons within a
“reasonable” time. 1 Euro assn wanted reference to the 145 certification authorisation instead.
Response: Comment accepted apart from the reference to the 145 certification authorisation
which is already specified in AMC 145.35 (b).

3 comments on JAR 66.60 were received addressing the following issues;

(80) 1 JAA-NAA proposed the deletion of para 66.60 re equivalent safety last sentance on the basis
that this sentance is about mutual recognition between the “Authorities” and not relevant to JAR
66.
Response: The commentor is correct, but apart from the fact that a similar sentance appears in
JAR 145 and JAR OPS Subpart M, this is a critical issue for both JAR 66 aircraft maintenance
licence holders and the European Commission and it would be wise to leave it in. However it is
appropriate to de-emphasise the reference to the agreement of “all Authorities” because some do
not comment on all equivalent safety cases.

(81) 1 Euro assn proposed that the request for equivalent safety consideration should be initiated by
the 145 or 147 orgn and 1 Nat assn accepted the text as written.
Response: The existing para does not prevent the 145 or 147 orgn from initiating such action
and there is no logical reason for limiting the possibilities of this para as there will be a need for
case consideration outside the 145/147 scene.

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NPA 66

(81A) 1 individual proposed deletion of para 66.60 because it had nothing to do with equivalent safety
and the procedure was unrealistic.
Response: This is not agreed because it is related to equivalent safety and the procedure has
worked well in JAR 145.

6 comments on JAR 66.65 were received addressing the following issues;

(82) 1 Euro assn proposed major text changes to para 66.65 on revocation which included the deletion
of some key elements and re-arranging the sequence.
Response; The original text was written by lawyers to ensure that any revocation process would
be clear and legal. The proposal cannot be accepted because it altered the original intent to an
un-acceptable extent.

(83) 1 Nat assn accepted the text as written whereas 2 Euro assns stated that the basic qualification
was not revocable.
Response; There are several reasons listed in the associatedAMC for having the possibility to
revoke, albiet these should be only on the rarest occasion. The comment cannot be agreed.

(84) 1 JAA-NAA proposed that there should be amuch stronger link between this para and the
associated AMC plus reference to evidence.
Response: This is agreed to ensure that the “Authorities” use the same basis for revocation and
certifying staff have a clear understanding of thus activities which could case a loss of licence.
The AMC text has been transferred to JAR 66 Section 1 together with one extra condition
identified by a comment to AMC 66.65(a).

(84A) 1 individual observed that national laws could also apply and was concerned that immediate
licence revocation must be possible.
Response: It is agreed that national laws could be applied but the para is intended to help those
Authorities who do not have appropriate equivalent national laws. The provisional suspension
provision of para 66.65 (a)(2) has the effect of immediate revocation.

JAR 66 Section 2 AMCs and IEMs.

2 comment on the General Intro to Section was received addressing the following issues;

(85) 1 JAA-NAA proposed that the note at the end para 2.3 be deleted bacause it pre-emps the JAA
Committee decision on “a priori” and “posteriori”. 1 individual also requested deletion of the note
because it gives AMC rule status.
Response: This is accepted although it should be noted that it is already in JAR 145.

12 comments on AMC 66.1 were received addressing the following issues;

(86) 1 Euro assn and 1 Nat assn proposed 3 amendments to AMC 66.1 to ensure that there was no loss
in existing certification limitations and pointing out that within the European Union mutual
recognition is required. 1 JAA-NAA proposed deletion of the sentance in sub-para (1) related to
non-recognition.
Response: The comment in respect of loss of certification privileges indicates a basic
misunderstanding of the requirement in that it has never been the intention to restrict or
withdraw existing certification privileges. Regarding the need for mutual recognition, this is
agreed. The text has been amended to make both these issues clear.

(87) 1 Euro assn proposed including task qualification to type qualification in AMC 66.1.2 in respect
of pre JAR 66 National requirements.
Response: Agreed.

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 NPA 66

(88) 1 Euro assn and 1 Nat assn proposed deletion of AMC 66.1.2 related to adding type ratings under
the pre-JAR 66 National requirements because it allows the old systems to continue for many
years. The same Euro assn similarly proposed the same deletion for AMC 66.1.3.
Response: The rationale about long timescale is correct, but it is not considered acceptable to
force this change as we prefer via para (5) to encourage the change over.

(89) 1 JAA-NAA proposed an amendment of AMC 66.1.3 to clarify the fact that only relevant JAR 66
requirements have to be met for conversion purposes whereas 1 Euro assn suggested that the para
does not apply to conversion from category B to C because only extra experience is required.
Response: The point about relevant requirements is accepted, but the suggestion regarding
conversion B to C is based upon a misunderstanding in that persons qualified fully to category B
can convert to C based upon experience,but the situation being covered by this para is the
conversion from a National category B which is different across the JAA States.

(90) 1 JAA-NAA proposed that AMC 66.1.5, now .6 be amended to clarify the fact that there may be a
difference between the pre JAR 66 National qualification and a JAR 66 qualification and
therefore suggested “full” be added for JAR 66.
Response: The intent is agreed and the new AMC 66.1.6 reflects this.

(91) 1 JAA-NAA proposed a new para to cover those staff who need to travel outside their own State
to certify maintenance so that the other State will know they are still authorised under grandfather
rights. This includes the need to carry evidence of authorisation.
Response: The JAR 145 orgn issues and continues to issue the certification authorisation and
thus no change is needed for this as it is the basis of that authorisation which is changed by JAR
66 which the 145 orgns will need to follow up by revised procedures. With regard to the JAR 66
aircraft maintenance licence it is believed that the revised AMC 66.1.1 & 5 covers this situation
by reference to mutual recognition.

42 comments on IEM 66.20 (b) were received addressing the following issues;

(92) 1 Euro assn and 1 Nat assn proposed that IEM 66.20 (b) 2 last sentance should limit licence
category title variations to those agreed by the “Authority”. 1 Euro assn proposed replacing
mechanic and technician with “engineer” and deleting category C. 1 JAA-NAA and 1 individual
proposed that the text be transferred to JAR 66.20 as it was a requirement. 1 JAA-NAA proposed
that category A be extended to avionics because avionic mechanics could qualify.
Response: The comment to limit title variations to the “Authorities” is accepted but the real
purpose was to cover language translation variations. The “engineer” proposal has been
debated for many years and cannot be accepted because the categories cover several levels of
expertise and causes translation problems. The proposal to transfer the text to the JAR is not
accepted because it is not intended as a reqirement but it is clear that this IEM should be an
AMC. Allowing avionic mechanics who have qualified for category A is reasonable and
permitted but the tasks are dominantly mechanical and they must qualify. A new sentance has
been added to the new AMC 66.20 (b) 4.

(93) 1 JAA-NAA proposed that IEM 66.20 (b) 4 be transferred to JAR 66.20 as it is a requirement
whereas 2 Euro assns proposed that category A should be allowed simple trouble shooting
possibilities.
Response: The text has been transferred to JAR 66.20 (b) 1 but reference to trouble shooting
deleted. Different text has been developed to ensure reasonable flexibility

(94) 2 JAA-NAAs, 3 Euro assns, 1 Nat assn and 1 145 orgn proposed changes to the introductory
paras of IEM 66.20 (b) 4 re the category A task list to either limit the list or provide more
flexibility or improve the clarity.
Response: The referenced para has been amended to ensure better control whilst retaining some
flexibility.

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NPA 66

(95) 3 Euro assns and 2 145 orgns proposed additions to the category A task list.
Response: The list of tasks have been deleted from JAR 66 and will be transferred to JAR 145 in
a new NPA145-7 because the extent of tasks permitted will be a JAR 145 issue.

(96) 1 JAA-NAA, 3 Euro assns, 1 Nat assn and 1 145 orgn proposed variously that minor scheduled
line maintenance be extended to include weekly and up to but not including check A because
category A has enough knowledge whereas 1 Euro assn proposed deletion because category A has
insufficient knowledge.
Response; The proposal to extend minor scheduled maintenance is agreed because the category
A knowledge level in Appendix 1 is more than adequate. However the extent of maintenance
permitted will be addressed by JAR 145 in due course.

(97) 1 Euro assn and 1 Nat assn proposed inclusion of “system” in IEM 66.20 (b) 8 to reflect very
modern aircrafft. 2 Euro assns proposed text for category B2 to cover mechanical systems.
Response: System added to text. With regard to mechanical tasks under category B2, an
amendment has been made to make it clear that the B2 has an option to qualify to A if necessary.

(98) 2 JAA-NAAs proposed that IEM 66.20 (b) 9 should make reference to the category A sub-
categories and 1 JAA-NAA said this was a rule. 1 Euro assn proposed deletion of piston
helicopters and airships because the standard was not defined. 1 individual proposed transfer of
sub-categories to the rule
Response: The intent of these comments is agreed apart from the reference to piston helicopters
because the standard is defined. The basic sub-categories have been added to JAR 66.20.

(99) 2 Euro assns pointed out that category C should be included.

Response: Agreed, particularly as some commentors have found it difficult to understand the
role of this category because JAR 66 was not obvious on this issue.

9 comments on AMC 66.25 were received addressing the following issues;

(100) 1 Euro assn proposed deletion of AMC 66.25 (a) as it should be in JAR 66.25 (a).
Response: This is agreed because it repeats JAR 66.25 (a).

(101) 2 145 orgns proposed that category A be delegated entirely to the the 145 orgns and the
knowledge refocused on the task list in IEM 66.20 (b) 5, now AMC 66.20 (b) 4 because the
Appendix 1 knowledge is disproportionate to the need.
Response: JAR 147 already proposes the delegation of training and examination and as for the
relationship with Appendix 1, this will be further reviewed in the light of this comment and others
to ensure that it is right. As a result of this comment and several other comments it has been
agreed that category A will be issued as a licence by the Authority without any tasks or types
specified. The JAR 145 will issue the JAR 145 certification authorisation based upon appropriate
task training.

(102) 2 Euro assns complained that it was bureaucratic to also retain records in the “Authority” and
place the same requirement on 147 orgns.
Response: This is agreed, particularly as the need for the “Authority” to keep records is covered
by a JAA Procedure and ther is no intention to duplicate. Old AMC 66.25 (c) deleted.

(103) 1 Euro assn and 1 Nat assn pointed out that university degrees should only be accepted in so far
as they cover the Appendix 1 syllabus and therefore proposed some text.
Response: Intent agreed - new AMC 66.25 (c) 1.

(104) 1 Euro assn proposed that knowledge gained in other arenas such as military aviation and civilian
apprenticeships should be credited.
Response: Intent agreed - new AMC 66.25 (c) 2.

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 NPA 66

33 comments on AMC 66.30 were received addressing the following issues;

(105) 3 JAA-NAAs, 2 Euro assns, 1 Nat assn and 1 JAR 145 orgn made 10 comments to the affect in
AMC 66.30 (a) that experience does not have to follow training as it can be combined or preceed
such training. All proposed text changes.
Response: Agreed - “following” replaced by “and” with further explanatory text added.

(106) 1 Euro assn found that use of the phrase “operating aircraft confused the issue between JAR 145
and JAR OPS and therefore proposed deletion of “operating”.
Response: This was not the intent but to make the expression clear a new explanatory para has
been added to AMC 66.30 (a) 1.

(107) 1Euro assn commented that the examination record retention should be in AMC 66.30 (a).
Response: There is no such reference in this para.

(108) 1 Euro assn and 1 JAR 145 orgn proposed that the absolute minimum experience should be 2
years and not 1 year plus the Euro assn proposed that category A experience should be revised
from 1, 2 and 3 years to 2, 3 and 5 years.
Response: No evidence was provided to support these proposals and when the JAR 147 training
course for category A is added to the 1 year experience plus the 21 year minimum age, it is
considered adequate. The proposal is not agreed.

(109) 1 Euro assn and 1 Nat assn proposed that category A and B must complete approved training and
thereby prevent the self starter.
Response: This repeats comment (53) and is not agreed. However the present text in AMC 66.30
seems to suggest that it is about applicants without any technical background when it is about no
formal technical training. There are people who have a good technical aptitude but due to
personal circumstances missed out on training or could not afford to pay for training.

(110) 1 Euro assn pointed out that under AMC 66.30 (a) (1) personnel qualifying for category B1 or B2
should be allowed experience the credit of category A.
Response: The present wording does not preclude this possibility but a more positive statement
has been added.

(111) It is clear from a number of comments that AMC 66.30 (a) 1 causes confusion because too many
sb-divisions are in the same para.
Response: Para 1 has been seperated out into 3 different paras to improve clarity.

(112) 1 JAA-NAA proposed that the AMC 66.30 (b) 1 (c) I text re conversion B1/B2 to C needed
clarification to ensure that the 3 years experience was related to certification of maintenance.
Response: This is agreed but provision needs to be made for supporting the cetegory C in base
maintenance. Text amended.

(113) 1 JAA-NAA commented that the examination criteria for category C is missing and who decides
B1 to C, the “Authority” or the JAR 145 orgn.
Response: The examination process is not covered by this “experience” para and the application
process is covered by a new JAR 66.13 para. Having said this,JAR 66.25 ( b) and (c) cover the
basic examination process for category C when this is needed.The “Authority” will decide.

(114) 1 Euro assn proposed the deletion of all reference to category C as stated in earlier comments by
the same assn. 1 JAA-NAA and 1 JAR 145 orgn proposed deletion of hands on experience
whereas 1 Euro assn proposed hands on be reduced to 3 months 1 Nat assn proposed it be
increased to 12 months and for non aeronautical degree holders maintenance experience should be
4 years rather than 3 years. 1 JAR 145 pointed out that their National law required a 5 year course
aeronautical degree.
Response: The university graduate entry route for category C still causes much concern and in
particular the need (or not) for hands on experience. It is however clear that the role of the
category C is different than the category A and B1 or B2 as stated in the response to comments

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NPA 66

(60) and (70). The text has therefore been amended to align with the C category duties in that
hands on experience has been replaced by supervisory experience.

(115) 1 JAA-NAA and 1 Euro assn suggested that AMC 66.30 (a) 5 needed amendment as NPA 145-7
will call up the category B1 and B2 in base maintenance. 1 Euro assn proposed an amendment to
make it clear that base supervisory staff must be category B1 / B2 qualified.
Response: This is a JAR 145 issue and the para has been deleted.

(116) 1 Nat orgn pointed out that as written AMC 66.30 (b) penalised those personnel who may be
suddenly and temporarily unemployed or ill for a short period “immediately prior” to the date of
application.
Response: It was not intended to have such a literal interpretation of the text - text amended ref
AMC 66.30 (d).

(117) 1 Euro assn proposed an additional para to explain “typical” aircraft.

Response: Intent agreed - text amended ref AMC 66.30 (e).

(118) 1 JAA-NAA stated that AMC 66.30 (c) 1 civil maintenance time limits were not acceptable and
proposed 6 months for category A and 12 months for category B1 / B2.
Response: Intent agreed - text amended ref AMC 66.30 (e)

(119) 1 Nat orgn proposed that the AMC 66.30 (c) 1 civil maintenance time limits should not apply to
those military personnel who are experienced on comparable aircraft and maintenance systems.
Response: The commenter does not seem to understand the objective which is to ensure sufficient
exposure to the civil aircraft maintenance culture which is different to the military culture. The
proposal is not agreed.

(120) 1 JAA-NAA proposed that AMC 66.30 (c) 2 re non-civil maintenance be amended to make it
clear that such maintenance should be aircraft maintenance.
Response: Agreed - text amended ref AMC 66.30 (e).

23 comments on AMC 66.40 were received addressing the following issues;

(121) 14 comments from 4 Euro assns and 2 Nat assns could not find any reason for renewing the JAR
66 aircraft maintenance licence, claiming it to be bureaucratic without safety benefit. 1 JAR 145
orgn took the opposite point of view but proposed 3 year renewal periods.
Response: Having the possibility to revoke the licence in particular circumstances seems to
make the case for renewal un-necessary. Renewal of the licence has been deleted and more text
has been introduced into JAR 66.40 to define the new continuity process.

(122) 1 Euro assn and 1 Nat assn made 6 comments in which it was proposed that the type rating needed
to be revalidated on a regular basis by repeat examination on all types endorsed on the licence /
authorisation if the licence / authorisation has expired and at least 1 repeat type examination for
staff in current practise.
Response: The JAR 66 aircraft maintenance licence makes it clear when the type was endorsed
and it should remain a JAR 145 organisation issue regarding the need for retraining / re-
examination particularly as the licence is a qualification. In reviewing JAR 145, this issue will
be considered.

(123) 1 Euro assn and 1 Nat assn made 4 comments to the affect that validity of the JAR 145
certification authorisation should be dependent in part on having received recurrent / continuation
training.
Response: JAR 145 already addresses this subject.

(124) 1 JAA-NAA proposed transfer of AMC 66.40.3 re the JAR 145 certification authorisation validity
to JAR 145 and proposed changes to para 4 re relevant experience to partly expand the scope and
restrict the amount of non certification experience.

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 NPA 66

Response: AMC 66.40.3 has been deleted because it relates to JAR 145. The intent of expanding
the scope has been accepted but not the restriction as it makes a complicated situation even more
complex without clear safety benefit ref AMC 66.40.2.

(125) 1 Euro assn made 3 proposals for different criteria to ensure continued validity of the JAR 145
certification authorisation.
Response: It is clear that much of the text in AMC 66.40 addresses the continued validity of the
JAR 145 certification authorisation which may conflict with JAR 145. The text has therefore been
amended to restrict the text to the JAR 66 aircraft maintenance licence validity and JAR 145 will
be reviewed in the light of the imminent arrival of JAR-66.

(126) 1 Nat assn proposed that AMC 66.40.3 be deleted because the JAR 145 certification authorisation
must be given by the JAA.
Response: This is not correct, the “Authority” will only issue / amend the JAR 66 aircraft
maintenance licence whereas the JAR 145 orgn will issue / amend the JAR 145 certification
authorisation.

(127) 1 Nat assn commented that the AMC 66.40 validity criteria considered too many situations and
should be simplified.
Response: This is agreed and the fundamental basis of experience recency transferred to JAR
66.40 in respect of the licence. JAR 145 will be reviewed to ensre that it has adequate
requirements for the authorisation.

(128) 1 Euro assn and 1 Nat assn proposed deletion of AMC 66.40.6 re the need for re-examination in
the case of a non-valid licence because of their comment (122) proposal for revalidation of type
ratings.
Response: The proposal cannot be accepted because the issue of type re-examination is mainly
for the JAR 145 orgn to consider whereas the text was about non valid licence renewal options
from an examination point of view. The text has been deleted anyway because of comment (127)
and the fact that the text did not provide any guidance.

20 comments on AMC / IEM 66.45 were received addressing the following issues;

(129) 1 Euro assn and 1 Nat assn proposed in AMC 66.45 (a) that the A category after training should
have both an examination and assessment.
Response: The present text provides a reasonable basis for checking out the category A and
there is no reason to insist upon both methods.

(130) 1 Euro assn proposed in AMC 66.45 (b) that type training include a reference to the type
maintenance documentation.
Response: This is already included in the text in para 2.

(131) 1 JAA-NAA, 3 Euro assns, 2 Nat assns and 1 JAR 145 orgn pointed out that the practical training
specified in AMC 66.45 (b) 4 was invariably of 1 to 2 weeks duration and not 1 to 4 months for
staff with previous satisfactory experience.
Response: The intent is agreed for staff with sufficient experience on similar aircraft. this would
also cover the new type aircraft first entering service. Text amended.

(132) 1 JAR 145 orgn complained that AMC 66.45 (b) 4 was too bureaucratic in needing a programme
and recording all actions whereas 1 Euro assn pointed out that keeping records was a JAR 145
and 147 requirement.
Response: The intent of the comments is agreed, particularly as it is not practical to follow a
programme because some tasks may not occur during the relevant calender period. Text
amended.

(133) 1 Euro assn proposed text to cover the practical experience problem of a new aircraft type.
Response: The comment is agreed and the new AMC 66.45 (b) 4 should provide the flexibility to
cover such situations. Comment (5) addresses the same issue.

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NPA 66

(134) 1 JAA-NAA queried if AMC 66.45 (b) 5 examination meant both theoretical and practical and if
so, must the theoretical be carried before the practical, which could prove inconvenient. 1 Nat
assn proposed a reference to engine run etc practical assessment.
Response: The reference to examination was intended to mean theoretical and therefore
examination has been amended to “knowledge” examination and engine run added.

(135) 1 Euro assn and 1 Nat assn proposed that AMC 66.45 (c) should include the necessity for
category C to hold a valid aircraft type rating.
Response: The new JAR 66.45 (c) addresses this issue.

(136) 1 Euro assn and 1 Nat assn proposed a new AMC 66.45 para to address the examination pass
mark and the assessment of knowledge / competence by using the aircraft or synthetic training
devices.
Response: Examination pass marks are covered byJAA procedures and are not appropriate for
the JAR. The use of aircraft and / or training devices is a matter for JAR 145 and 147.

4 comments on AMC / IEM 66.50 were received addressing the following issues;

(137) 1 Euro assn and 1 Nat assn proposed that IEM 66.50 was in fact AMC material.
Response: Agreed - text amended.

(138) 1 JAA-NAA pointed out that IEM 66.50 para 1 reference to National law had nothing to do with
the condition of certifying staff and should be deleted.
Response: Agreed - text amended.

(139) 1 Euro assn proposed deletion of IEM 66.50 para 3 because it was simply restating National law.
Response: Agreed - para 3 deleted with small addition to para 2.

9 comments on AMC 66.55 were received addressing the following issues.

(140) 1 JAA-NAA proposed that AMC 66.55 should include the possibilty of delegating issue of the
licence to the JAR 145 orgn.
Response: The JAR 145 may only prepare the JAR 66 aircraft maintenance licence for issue by
the “Authority”. This means at minimum that the “Authority” official will sign the licence on
presentation by the JAR 145 orgn. The text of new JAR 66.13 (c) covers the subject.

(141) 2 JAA-NAAs, 2 Euro assns, 1 Nat assn and 1 individual made various comments ranging from
changing the AMC title to “authorisation”, deleting reference to appendix 3 and transfering the
text to JAR 66.55.
Response: The title proposal is not appropriate, text transfer is agreed and the reference to
appendix 3 deleted.

(142) 1 JAA-NAA commented that “authorised person” in AMC 66.55 should be defined.
Response: Agreed - text amended.

(143) 1 Euro assn proposed reference to certifying staff qualification document (the old title) and
certifying authorisation and recommended that the document only be issued on request for
certifying staff as per the meeting with JAA in Dec 94.
Response: This comment has been overtaken by two NPAs which is the official manner in which
the JAA consults the public at large and fails to accept that the JAA full member Authorities were
not at the Dec 94 meeting and have spent many hours since that time to arrive at the present day
position.

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 NPA 66

3 comments to AMC 66.65 have been received addressing the following issues;

(144) 1 JAA-NAA and 1 Euro assn proposed minor text improvements to AMC 66.65 whereas 1 Euro
assn proposed deletion because the list was not complete and precluded the “Authority” from
revoking the licence in other situations.
Response: The proposed text changes are agreed and the complete para transferred to JAR 66.65
because the revocation of a licence is a serious matter and the powers of the “Authority” need to
be properly defined in the requirement. Deletion of the list could not be contemplated due to the
importance of the matter. See also comment (84).

130 comments on Appendix 1 were received addressing the following issues;

(145) 1 JAA-NAA, 2 Euro assns and 5 JAR 145 orgns commented that the category A knowledge
requirements of Appendix 1 were excessive, burdensome and would not improve safety. Various
proposals were made to delete category A from appendix 1 or at least reduce the depth of
knowledge to level 1. 1 Euro assn (from comment (8)) opposed category A because the the
knowledge was insufficient.
Response: It seems that on the one hand some commenters argue that category A is task specific
and the knowledge level therefore limited and focussed yet want category A to also be flexible
and certify minor line checks. The opposing view is that category A is not sufficiently qualified to
certify such checks. Category A will be retained but wherever possible limited to level 1 except
for those subjects relevant to minor line maintenance checks which will be at level 2. It should
also be noted that as category B1 can certify all category A tasks the JAR 145 does not need to
employ any category A staff if they so wish.

(146) 1 Euro assn pointed out that many JAR 145 orgns have staff trained for single tasks and the new
category A would cause major economic problems if such staff had to meet all the category A
criteria.
Response: Nothing in the requirement stops such staff from continueing to carry out these single
tasks so long as they do not release the aircraft. Of course, if they release the aircraft then
compliance is required with category A.

(147) 1 JAA-NAA, 3 Euro assns, 1 Nat assn and 2 JAR 145 orgns proposed changes to the level 1, 2
and 3 objectives ranging from; that level 1 does not involve understanding whereas level 2 is
about limited understanding; that level 3 is beyond the needs of category B1 / B2 ; that only
category C justifies level 3. Two commenters suggested that level 3 was only needed for
engineers, instructors and trouble shooters. One commenter did not agree with the level 3
objective of working without the manufacturers instructions.
Response: The intent of the comments is agreed apart from the reference to level 3 being outside
the category B1 / B2 needs. The B categories are the aircraft type specialists dealing with trouble
shooting, whereas category C is more a management function. Minor text amendments have been
made.

(148) 1 Euro assn and 1 Nat assn proposed minor text improvements to the note at the end of appendix
1 para 1 introduction and 1 Nat assn said that the cross reference to procedures chapter 23 was
incorrect.
Response: The text has been amended but the reference to chapter 23 was correct.

(149) 1 JAA-NAA proposed that provision be made in the modularisation table of appendix 1 for an
avionic category A.
Response: This was not part of the NPA and is inappropriate at this stage with the problem of
sorting out the mechanical category A. Nothing however prevents an avionic mechanic or a
category B2 from qualifying in the presenr category A. If the commenter was thinking of simple
avionic certification then this would be the first time someone has seen a need.

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NPA 66

(150) 1 JAA-NAA found the opening sentance of the appendix 1 para 2 modularisation confusing,
asking if this was the licence or the authorisation and who would issue.
Response: The text is both confusing and un-necessary because JAR 66 explains the licence and
the authorisation and who may issue what. The first sentance has been deleted.

(151) 4 Euro assns, 3 Nat assns and 2 individuals submitted a total of 76 detailed comments proposing
changes to the appendix 1 subject by subject levels of knowledge.
Response: All comments have been analysed on the basis of need to know focus with the result
that principally the category A has been re-evaluated to be mostly level 1 with some level 2 and
few level 3. Category B1 / B2 have in general been reduced from level 3 to level 2 in a few
circumstances.

(152) 1 JAA-NAA, 3 Euro assns, 1 Nat assn, 1 JAR 145 orgn and 2 individuals submitted 30 proposals
for about 4 new subjects plus minor improvements to about 10 existing subjects.
Response: All comments have been analysed and some minor text changes made to subject
matter. Much interest was shown in human factors with few specific proposals.

(153) 1 Euro assn proposed the re-introduction of the old knowledge requirements for non-avionic
systems to be added to the list for category B2 avionics.
Response: The category B2 avionic person is a specialist in avionics and does not need to have
such knowledge other than electrical and instruments which are now common to both B1 and B2.

(154) 1 Euro assn proposed that the propeller module should be an option for staff who only certify jet
turbine aeroplanes.
Response: Nothing prevents the “Authority” from issueing a licence in category B1 excluding
propellers.

14 comments on Appendix 2 were received addressing the following issues;

(155) 3 JAA-NAAs, 2 Euro assns, 2 Nat assns, 1 Nat committee, 2 JAR 145 orgns and 1 individual
made various comments to improve the JAR 66 aircraft maintenance licence format, make the
design more flexible and to list the aircraft type ratings possible. Several made points about the
possibility of category C qualifying to category A and / or to avionics. 1 commenter pointed out
that the airship category was inconsistent with JAR 66.
Response: Most of the comments have been adopted but it is not appropriate to redesign the
document having previously received many proposals from NPA 65-0 several years ago. The
most important comment reflected the flexibility needs and the use of computer generated
documents. This document should suit all users.

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