Irish Aviation Authority Údarás Eitlíochta AERONAUTICAL

The Times Building na hÉireann NOTICE

11–12 D’Olier Street Foirgneamh na hAmanna
Dublin 2, Ireland 11–12 Sráid D’Olier
www.iaa.ie Baile Átha Cliath 2, Éire No. A.91
ISSUE 07
Safety Regulation Rannán na Rialachán
Division Sábháilteachta DATE 01.11.19

EASA PERMIT TO FLY

1. INTRODUCTION

This Notice has been issued to provide guidance to owners/operators of aircraft, approved design,
maintenance and production organisations and licensed aircraft maintenance engineers, on
applications to the Irish Aviation Authority (IAA) for an EASA Permit to Fly (EASA Form 20a) in
accordance with Part 21 Subpart P now in force.

A Permit to Fly is generally issued when a certificate of airworthiness is temporarily invalid, for
example as the result of damage, or when a certificate of airworthiness cannot be issued for instance
when the aircraft does not comply with the essential requirements for airworthiness or when
compliance with those requirements has not yet been shown, but the aircraft is nevertheless capable
of performing a safe flight.

Note: Flight checks required by the manufacturer’s maintenance data following normal maintenance
actions in compliance with the continuing airworthiness requirements referred to in Part
21A.181(a)1 do not require an EASA Permit to Fly. Flights required for fault isolation or trouble
shooting do require an EASA Permit to Fly.

2. APPLICABILITY

This Notice is applicable to Irish registered aircraft that are within the applicability of European
Regulation (EU) No. 2018/1139 (the Basic Regulation EC) with the exception of the following
categories of aircraft which are not subject to European Union Regulations:

Aircraft which are engaged in military, police, customs, search and rescue, firefighting, border control,
coastguard, or similar activities or services.

Aircraft which are within the categories listed in Annex I to Regulation (EU) 2018/1139, unless the
aircraft has been issued, or has been deemed to be issued, with a certificate in accordance with
Regulation (EU) 2018/1139.

Aircraft which have their regulatory safety oversight delegated to a third country and they are not
used by a Community operator.

Commission Regulation (EU) No. 748/2012, Annex I Part 21 makes provision for an EASA Permit to
Fly to be issued for an aircraft to fly when a valid EASA airworthiness certificate is currently not in
force. An EASA Permit to Fly may be issued where it can be shown that the aircraft is capable of safe
flight under defined conditions and for specific purposes as outlined in Part 21 Subpart P

Note 1: For the purposes of this Aeronautical Notice, aircraft that are required to comply with Regulation
(EU) No. 2018/1139 are specified as “EASA Aircraft”.

Note 2: Airworthiness certificates for EASA aircraft are prescribed in Part 21 Subpart H as follows:
a) Certificate of Airworthiness (Form 25)
b) Restricted Certificate of Airworthiness (Form 24)

Note 3: Permit to Fly (Form 20a) is prescribed in Commission Regulation (EU) No. 748/2012, Annex I
Part 21 Subpart P. In addition, Subpart P (Part 21A.708) identifies ‘flight conditions’ which
must be approved in conjunction with an application for an EASA Permit to Fly.

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Irish Aviation Authority Údarás Eitlíochta AERONAUTICAL
The Times Building na hÉireann NOTICE
11–12 D’Olier Street Foirgneamh na hAmanna
Dublin 2, Ireland 11–12 Sráid D’Olier
www.iaa.ie Baile Átha Cliath 2, Éire No. A.91
ISSUE 07
Safety Regulation Rannán na Rialachán
Division Sábháilteachta DATE 01.11.19

2.2. Where there is a need to fly an EASA aircraft when an EASA Airworthiness Certificate is not in
force or a flight is necessary for the issue of such a certificate, an application will need to be
made for an EASA permit to fly, in accordance with the procedures detailed in the subsequent
paragraphs of this Notice.

3. APPLICATION

An application for an EASA Permit to Fly is a two-step process requiring;

Application for approval of flight conditions in accordance with Part 21A.709
Application for a permit to fly in accordance with Part 21A.707

Application for approval of flight conditions;

Applications may be made to;
EASA, or an appropriately approved design organisation, when approval of the flight conditions is related
to the safety of design, or;
IAA, or an appropriately approved organisation that will issue the Permit to Fly, when approval of the
flight conditions is not related to the safety of design.

Examples of flight conditions not related to the safety of design include, but are not limited to:
production flight testing for the purpose of conformity establishment;
delivery/export flight of a new aircraft the design of which is approved;
demonstrating continuing conformity with the standard previously accepted by EASA for the aircraft or
type of aircraft to qualify or re-qualify for a (restricted) certificate of airworthiness.

Application for a Permit to Fly

Applications may be made to the IAA as competent authority for Ireland in respect of this subject. An
application for an EASA Permit to Fly shall be made to the Airworthiness Standards Department, Safety
Regulation Division, Irish Aviation Authority, The Times Building, 11-12 D’Olier Street, Dublin 2. Fax:
+353-1-6793349

The format of the application is provided in Appendix 1 of this Notice.

4. PROCEDURE

EASA Permits to Fly may be issued for specific purposes as outlined in Part 21A.701. The applicant
must establish that the purpose of the flight(s) meets Part 21A.701 criteria and then determine if the
associated flight conditions are related to the safety of the design. If there is any doubt in any particular
case whether or not the flight conditions are related to safety of design, the applicant should consult with
EASA and/or the IAA before making the application. It should be noted that the more common Permit to
Fly applications (e.g. ferry flights for maintenance work, flight test as part of compliance demonstration
etc.) do affect safety of design and must be approved by EASA, or an appropriately approved design
organisation.

In the event that EASA approval of the flight conditions is required the applicant must apply to EASA
using EASA Form 37 and EASA Form 18b. Full details of the application procedure may be found on
http://www.easa.eu.int/home/c_permittofly.html.

Upon receipt of the approved flight conditions as evidenced by a signed and stamped Form 18b by EASA
quoting the EASA approval number, or equivalent evidence of approval from an appropriately approved
design organisation, an application to the IAA for an EASA Permit to Fly may be made by the owner,
operator or designated representative using the application form as shown in Appendix 1 of this Notice.
All parts of the form must be completed. The approved EASA Form 18b, or equivalent from an

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Irish Aviation Authority Údarás Eitlíochta AERONAUTICAL
The Times Building na hÉireann NOTICE
11–12 D’Olier Street Foirgneamh na hAmanna
Dublin 2, Ireland 11–12 Sráid D’Olier
www.iaa.ie Baile Átha Cliath 2, Éire No. A.91
ISSUE 07
Safety Regulation Rannán na Rialachán
Division Sábháilteachta DATE 01.11.19

appropriately approved design organisation, must be attached to the application.

In the event that the flight conditions do not affect safety of design and the applicant requires IAA
approval of the flight conditions, these flight conditions must be listed in box 9 and an application for
approval of flight conditions (boxes 15 to 26) of Appendix 1 of this notice must be completed. The IAA will
approve the flight conditions as part of the Permit to Fly.

The IAA may specify additional requirements, where considered necessary.

The IAA may issue an EASA Permit to Fly when satisfied that the condition of the aircraft has been
properly assessed by the applicant and is in a condition to perform the flight(s) safely.

The permit may contain other conditions and limitations under which the flight(s) may be made.

The IAA may carry out a survey of the aircraft and/or associated records to verify the airworthiness of the
aircraft prior to the issue of an EASA Permit to Fly.

5. CERTIFICATION OF MAINTENANCE

When prescribed as a condition associated with the EASA Permit to Fly, with the exception of a pre-flight
inspection, any maintenance performed on an aircraft whilst operating on such a permit will require the
issue of a Certificate of Release to Service (CRS). The issue of a CRS will be in accordance with Part-
145, Part M or Part 21 (Subpart G, Item 163) as appropriate.

This notice replaces Aeronautical Notice A.91 at issue 06 which should be discarded.

Chief Executive
Irish Aviation Authority

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Irish Aviation Authority Údarás Eitlíochta AERONAUTICAL
The Times Building na hÉireann NOTICE
11–12 D’Olier Street Foirgneamh na hAmanna
Dublin 2, Ireland 11–12 Sráid D’Olier
www.iaa.ie Baile Átha Cliath 2, Éire No. A.91
ISSUE 07
Safety Regulation Rannán na Rialachán
Division Sábháilteachta DATE 01.11.19

Appendix 1
Application for EASA Part 21 Permit to Fly

1. Applicant:
2. Aircraft
nationality and
identification
marks:
3. Aircraft owner:
4. Aircraft manufacturer/type 5. Serial number

6. Purpose of flight (See additional Instructions below)

7. Description of Flight(s) including date(s) for the flight(s) and

duration

8. Aircraft configuration as relevant for the permit to fly (See also

Additional Instructions below)

9. Approval of flight conditions [if not available at the time of application,

indicate request for approval reference - See Additional Instructions below]
Who will approve flight conditions? EASA Design Organisation IAA
Request for approval reference:

10. Aircraft Configuration

Name the person or organisation responsible for release of the aircraft in
accordance with the flight conditions listed on the permit to fly.

Name(s): Location(s):

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Irish Aviation Authority Údarás Eitlíochta AERONAUTICAL
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11. Crew Composition & Qualifications

Specify number(s) of crew and their qualifications to be carried whilst
operating on the EASA Permit to Fly:
Pilots Flight Engineer

Flight Observer Other (Please specify)

Note: Only minimum crew shall be carried on an aircraft operating on an EASA Permit to Fly

12. Declaration
I hereby confirm that with respect to this application as the
Owner/Operator/Representative thereof*, that the information provided above is true
in every respect and that the Conditions of the EASA Permit to Fly sought will be
complied with.

Name:…………………………….. Signature:…………………………
Date: ……………………………

Organisation Name:……………………………… Organisation Approval No………………..

*Delete as appropriate

Return Contact Fax/email:…………………………………..

13. Date 14. Name and signature

[Authorised signatory]

IAA USE ONLY

Permit to Fly No………………………………………… Date of Issue

Aircraft/Records Survey Performed Yes / No

Date: …………………………………

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Irish Aviation Authority Údarás Eitlíochta AERONAUTICAL
The Times Building na hÉireann NOTICE
11–12 D’Olier Street Foirgneamh na hAmanna
Dublin 2, Ireland 11–12 Sráid D’Olier
www.iaa.ie Baile Átha Cliath 2, Éire No. A.91
ISSUE 07
Safety Regulation Rannán na Rialachán
Division Sábháilteachta DATE 01.11.19

Flight Conditions for a Permit to Fly – IAA Approval Form

(This section is not required if flight conditions are approved by EASA
or an appropriately approved Design Organisation)
15. Flight Conditions Approval No: (IAA use only)
16. Applicant:
17. Date of Application:
18. Aircraft Manufacturer/Type:
19. Aircraft Serial Number:
20. Purpose of Flight (See additional Instructions below)

21. Aircraft Configuration (See additional Instructions below)

The above aircraft for which a permit to fly is requested is defined in

22. Substantiations (See also Additional Instructions below)

23. Conditions/Restrictions (See also Additional Instructions below)

The above aircraft must be used with the following conditions or restrictions:

24. Statement
The flight conditions have been established and justified in accordance with
21.A.708. The aircraft has no features and characteristics making it unsafe
for the intended operation under the identified conditions and restrictions.

25. Name of authorised 26. Signature of authorised

representative of applicant: representative of applicant:

27. Date of Approval: 28. IAA Authorised Signatory:

(IAA use only) (IAA use only)

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Irish Aviation Authority Údarás Eitlíochta AERONAUTICAL
The Times Building na hÉireann NOTICE
11–12 D’Olier Street Foirgneamh na hAmanna
Dublin 2, Ireland 11–12 Sráid D’Olier
www.iaa.ie Baile Átha Cliath 2, Éire No. A.91
ISSUE 07
Safety Regulation Rannán na Rialachán
Division Sábháilteachta DATE 01.11.19

ADDITIONAL INSTRUCTIONS

Box 6:
Purpose in accordance with 21.A.701(a). Use the following terminology and add
any additional information for accurate description of the purpose, e.g. place,
itinerary….
(1) Development:
- testing of new aircraft or modifications
- testing of new concepts of airframe, engine propeller and equipment;
- testing of new operating techniques;
(2) Showing compliance with regulations or certification specifications:
- certification flight testing for type certification, supplemental type
certificates, changes to type certificates or European Technical Standard
Order authorisation;
(3) Design organisations or production organisations crew training:
- Flights for training of crew that will perform design or production flight
testing before the design approval and Certificate of Airworthiness (C of A)
can be issued.
(4) Production flight testing of new production aircraft:
- For establishing conformity with the approved design, typically this
would be the same program for a number of similar aircraft;
(5) Flying aircraft under production between production facilities:
- green aircraft ferry for follow on final production.
(6) Flying the aircraft for customer acceptance:
- Before the aircraft is sold and/or registered.
(7) Delivering or exporting the aircraft:
- Before the aircraft is registered in the State where the C of A will be
issued.
(8) Flying the aircraft for Authority acceptance:
- In the case of inspection flight test by the authority before the C of A is
issued.
(9) Market survey, including customer’s crew training:
- Flights for the purpose of conducting market survey, sales
demonstrations and customer crew training with non type-certificated
aircraft or aircraft for which conformity has not yet been established or for
non-registered a/c and before the Certificate of Airworthiness is issued
(10) Exhibition and air show:
- Flying the aircraft to an exhibition or show and participating to the
exhibition or show before the design approval is issued or before
conformity with the approved design has been shown.

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(11) Flying the aircraft to a location where maintenance or airworthiness review

are to be performed, or to a place of storage:
- Ferry flights in cases where maintenance is not performed in
accordance with approved programmes, where an AD has not been
complied with where certain equipment outside the Master Minimum
Equipment List (MMEL) is unserviceable or when the aircraft has sustained
damage beyond the applicable limits.
(12) Flying an aircraft at a weight in excess of its maximum certificated takeoff
weight for flight beyond the normal range over water, or over land areas
where adequate landing facilities or appropriate fuel is not available:
- Oversees ferry flights with additional fuel capacity.
(13) Record breaking, air racing or similar competition:
- Training flight and positioning flight for this purpose are included
(14) Flying aircraft meeting the applicable airworthiness requirements before
conformity to the environmental requirements has been found:
- Flying an aircraft which has been shown to comply with all applicable
airworthiness requirements but not with environmental requirements.
(15) For non-commercial flying activity on individual non-complex aircraft or
types for which a certificate of airworthiness or restricted certificate of
airworthiness is not appropriate.
- For aircraft which cannot practically meet all applicable airworthiness
requirements, such as certain aircraft without TC-holder (“generically
termed orphan aircraft”) or aircraft which have been under national
systems of Permit to Fly and have not been shown to meet all applicable
requirements. The option of a permit to fly for such an aircraft should only
be used if a certificate of airworthiness or restricted certificate of
airworthiness cannot be issued due to conditions which our outside the
direct control of the aircraft owner, such as the absence of properly
certified spare parts.

Note: The above listing is of cases when a permit to fly MAY be issued; it does
not mean that in the described cases a permit to fly MUST be issued. If other
legal means are available to allow the intended flight(s) they can also be used.

For an application due to a change of purpose: reference to initial request and

description of new purpose.

Box 7:
If the flight(s) are to be carried out under an approved Flight Test Programme,
specify on a separate attached report

Box 8:
Same as required in EASA Form 18B, box 5, if applicable.

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Irish Aviation Authority Údarás Eitlíochta AERONAUTICAL
The Times Building na hÉireann NOTICE
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Dublin 2, Ireland 11–12 Sráid D’Olier
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Division Sábháilteachta DATE 01.11.19

8.1 The above aircraft for which a permit to fly is requested is defined in [add
reference to the document(s) identifying the configuration of the aircraft.]
Does the aircraft comply with all applicable type certification and airworthiness
requirements, and if not, the referenced documents should identify the non-
compliances

8.2 The aircraft is in the following situation related to its maintenance schedule:
[Describe status]
Does the aircraft comply with all applicable continued airworthiness
requirements, and if not, the referenced documents should identify the non-
compliances

Box 9:
Reference to:
1. EASA approval, if flight conditions are approved by EASA; or
2. DOA approval form (when applicable), if approved under DOA privilege; or
3. IAA approval request

Attach referenced documents [if not available at the time of application, indicate
reference of request for approval]

If safety of design is not affected list the flight conditions for which IAA approval
is requested (reference Part 21A.708).

Attach referenced documents

Box 16:
Name of the organisation providing the flight conditions and associated
substantiations for IAA approval.

Box 20:
See additional instructions for box 6 above.

Box 21:
Add reference to the document(s) identifying the configuration of the
aircraft.
Box 22:
Add references to the document(s) justifying that the aircraft (as described
in box 21) can perform the intended flight(s) safely under the defined
conditions or restrictions.

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Box 23:
Details of these conditions/restrictions or reference to relevant document,
including specific maintenance instructions and conditions to perform these
instructions.
Box 24:
Not to be filled in. The flight conditions have been established and justified
including any condition or restriction necessary for safe operation of the
aircraft, namely:
• the conditions or restrictions put on itineraries or airspace, or both,
required for the flight(s)
• the conditions and restrictions put on the flight crew to fly the
aircraft
• the restrictions regarding carriage of persons other than flight crew
• the operating limitations, specific procedures or technical
conditions to be met
• the specific flight test programme (if applicable)
• the specific continuing airworthiness arrangements including
maintenance instructions and regime under which they will be
performed
• the method used for the control of the aircraft configuration, in
order to remain within the established conditions.

***

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