Specific Airworthiness Specifications (SAS)

Commission Regulation (EC) 1702/2003 requires products, parts and appliances to be issued with certificates as specified in Part 21. Aircraft without a valid type certificate holder cannot comply with Subpart B of Part 21 and cannot therefore hold type certificates. The Specific Airworthiness Specification (SAS) is the replacement document. Specific Airworthiness Specifications are issued to aircraft without a valid Type Certificate Holder (Orphan aircraft) or for certain aircraft non-EASA General Aviation types that have been certificated outside EASA but not validated.

Currently, this information only covers the applicability of Specific Airworthiness Specifications for non-complex (1) types employed in non-commercial operation.

The eligibility of the proposed product should first be reviewed. Annex II aircraft, for example, cannot qualify for SAS as they are outside of the remit of the Agency. If a Type Certificate Holder (TCH) still exists, the preferred path to certification of the product is through a Type Certification or Type Validation. If the current Certification Specifications cannot be met, the option of a Restricted Type Certificate can be offered.

If the aircraft Type Certificate Holder is no longer in business (Orphan TC) the application for SAS can be initiated by the operator/owner. It should be emphasized that the SAS should not be seen as a mechanism for avoiding type certification in accordance with Part 21. For General Aviation types the SAS has been used to integrate in the EASA system aircraft that had not been certificated in accordance with Part 21 but which were already on the registers of EU member states on accession to the EU.  In the event that there is no engine or propeller TC, the engine and propeller are covered by the aircraft SAS.

Before the creation of EASA, some orphan aircraft had been allowed to operate on non-ICAO level certificates of airworthiness (Permit to Fly, CDNR, etc) and these examples cannot usually be returned to Restricted Certificate of Airworthiness standard. The SAS applicability will identify those individual aircraft that are eligible to an R C of A based on that SAS. Aircraft not eligible may continue to qualify for EASA Permit to Fly under 21A.701(15). There is no intention to permit aircraft to voluntarily default to Permit to Fly if they otherwise conform to the appropriate SAS.

The SAS consists of:

  • The original State of design TCDS in EASA format
  • Airworthiness Directives
  • Instructions for reporting continued airworthiness occurrences
  • Environmental protection data when appropriate
  • Any additional limitations including a prohibition from commercial activities

SASs are numbered sequentially for each product type. The numbers protocol are:

See Article 5 (4) of the Basic Regulation and Regulation (EC) 1702/2003 Part 21, 21A.184

Orphan Aircraft

An aircraft becomes orphan when:

  1. The legal person holding the TC has ceased to exist. The TC automatically becomes invalid by law because there is no one to be in compliance with the TC holders responsibilities (21A.51 (a) 1 and 21A.44); or
  2. The TC holder no longer complies with his regulatory obligations. A typical case is when the TC holder loses his DOA, or fails to comply with 21.A.14 before 28.09.05. This makes the TC invalid (21A.51 (a) 1)
  3. The TC holder has surrendered the TC. This also makes the TC invalid (21A.51(a)2).

Under the current Part 21, orphan aircraft cannot be issued a Certificate of Airworthiness, which requires that a TC holder takes responsibility for the continued oversight of the design. They can therefore only continue to be operated if they hold a restricted certificate of airworthiness or a permit to fly. These documents can only be issued on the basis of a design approved by the Agency.

(1) Non-complex aircraft is a writing convention for aircraft not classified as complex motor powered aircraft in the Basic Regulation