Subject: Guidelines for Aircraft Storage and Return to Service (RTS)

1. INTRODUCTION.

1.1 The primary purpose of an aircraft storage program is preservation. Storage

programs are intended to preserve the aircraft in a known state through methods,
techniques and procedures designed to mitigate or eliminate the adverse effects of
the storage environment and non-operation of the aircraft. An effective storage
program will allow the operator to readily return the stored aircraft to an operational
status.

1.2 This AAC provides guidelines to Aircraft Operators for development of storage
program and related procedures for preservation and de-preservation of an aircraft
as an integral part of Aircraft Maintenance Program (AMP). The guidelines can
also be used for development of storage program of aircraft of private operators,
State Government, flying training etc.

2. DEFINITIONS.

For the purposes of this AAC, the following definitions apply:

A. Storage (General). An air operator’s aircraft is considered stored when it is

removed from active/ operational status for any reason, while the aircraft
remains on the operator’s Operations Specifications (Ops Specs). The level of
preservation depends on the length of storage, the aircraft design features, and
the storage environment (inside/ outside a hangar).

B. Short-Term Storage. An aircraft is subject to short-term preservation

procedures when it is removed from operational status for less than 60 days.

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 C. Intermediate-Term Storage. An aircraft is subject to intermediate-term
preservation procedures when it is removed from operational status for more
than 60 days but less than 120 days.

D. Long-Term Storage. An aircraft is subject to long-term preservation

procedures when it is removed from operational status for 120 days or more.

3. GENERAL.

A. Out of Service (OTS). Occasionally and for a variety of reasons, an operator takes
an aircraft OTS for a period of time. Depending on the circumstances, the time
period can be a few days to a number of years to an indefinite period.

B. Level of Preservation. The level of preservation depends on variables such as the

planned length of storage and the storage environment. For example, a large
transport category aircraft taken OTS due to some reason and stored for an
indefinite period outside on the ramp at an airport having dusty environment shall
have more comprehensive level of preservation than an identical aircraft taken OTS
for storage and placed in a relatively less dusty environment.

4. AIR OPERATOR’s AIRCRAFT STORAGE PROGRAMS.

4.1 Aircraft storage programs are intended to mitigate or eliminate the effects of a non-
operational status by implementing various levels of preservation.

A. Maintenance Function: Preservation is included in the scope of the

maintenance function along with inspection, repair, overhaul, and the
replacement of parts.

B. Requirements: Aircraft storage programs should be developed based on the

aircraft / engine manufacturer recommendation and may be documented as an
integral part of the Aircraft Maintenance Program (AMP) or managed
separately. The program should be developed for each type of aircraft
depending upon storage environment and operational needs.

C. Procedures: The aircraft storage programs shall have procedures for

a) placing the aircraft in various levels of preservation,

b) de-preserving the aircraft when returning it back to service,
c) accomplishing inspections or other maintenance, designed to mitigate or
eliminate the effects of preservation/ de-preservation,
d) documenting all these actions.

D. Recommended Storage Programs: Some aircraft manufacturers have

recommended storage programs. An operator may use these
recommendations while developing their own specific storage program.
However, it is important to
 note that some manufacturers may have specific airworthiness requirements
based on proper storage/ preservation and the operator must address these
requirements when returning the aircraft to an airworthy condition.

E. Approval of the Storage program. The operator’s aircraft storage program

along with the documented procedures shall be submitted to the RAO/SRAO
for approval. The program shall be reviewed by RAO/SRAO and approved as a
part of AMP.

5. AIRCRAFT OPS SPECS LISTING.

5.1 An aircraft that is removed from service and preserved in accordance with the air
operator’s storage program should remain on the operator’s Ops Specs, however if
the operator places an aircraft in a non-operational status but doesn’t preserve it to
an appropriate level in accordance with its storage program, then that aircraft
should be removed from the Operator’s Ops Specs due to the safety concerns of
creating an unknown airworthiness status. In such circumstances, the operator
should approach DGCA (Hqrs) for removal of the aircraft from the Ops Specs. The
aircraft shall not be used for air transportation until the operator demonstrates the
required airworthiness status to the satisfaction of DGCA and is endorsed on the
Ops Specs.

6. AIR OPERATOR’S SCHEDULED MAINTENANCE REQUIREMENTS.

A. Maintenance as per AMP: Compliance of AMP for ensuring continuous

airworthiness of aircraft is mandatory for operational aircraft only. Aircraft placed in
storage, with or without a storage program, are not intended for operation; and
therefore, they do not fall under the requirements of the compliance of AMP until
the operator intends to operate the aircraft.

B. Other Maintenance Requirements Related to Storage Program: The storage

program may include other scheduled maintenance requirements or other required
actions that are particular to the storage environment and to the level of storage.
For example, engine ground runs may be required on a weekly basis for engines
that have not been preserved, servicing dehumidifying equipment/ material on a
scheduled basis, moving the aircraft from one side of the ramp to the other and
turning it 180 degrees every 3 months etc. In any case, in addition to the
procedures implemented to preserve the aircraft and placing it in storage, the
storage program should contain a schedule for accomplishment of all tasks
required to maintain the aircraft in the intended level of preservation.

7. STATUS OF CERTIFICATE OF AIRWORTHINESS (C OF A) OF STORED

AIRCRAFT.

7.1 The C of A of an aircraft shall remain valid subject to the conditions detailed in
Para 4 of CAR Section 2 Series F Part III. The conditions for the C of A to remain
valid includes continued maintenance of aircraft as per AMP, compliance of ADs/
 Mandatory Modifications, possession of a valid ARC etc. The C of A is issued to an
aircraft with non-expiry date. While the C of A of a preserved and stored aircraft is
not to be considered revoked or suspended, however, since the conditions for the
C of A remaining valid are not met, the C of A is considered deemed to be
suspended.

7.2 The validity C of A of a preserved and stored aircraft is restored when all
maintenance required by the operator’s AMP including the compliance with ADs/
mandatory modifications are complied with and the aircraft has a valid ARC . The
operator’s storage program should have procedure for ensuring that all of the
maintenance program requirements as well as the appropriate regulatory
requirements are complied with, before return to service.

7.3 Depending on the level of preservation, intended length of storage, and the
security of the aircraft, the operator should consider removing the C of A, the C of
R and other documents on board, from stored aircraft for safekeeping.

8. UTILIZATION OF PARTS FROM AIRCRAFT IN STORAGE.

8.1 It is a common practice to remove parts from aircraft that are in storage regardless
on Ops Spec or not. The responsibility lies with the operator/ installer (AMO) to
determine that all parts used on type-certificated (TC) products are acceptable for
installation. The major concern is maintenance becoming “overdue” on parts that
have been installed on aircraft while in storage. The operator must detail the
procedures to ensure this responsibility in accordance with CAR 145.A.50

9. AIRCRAFT MOVEMENT WHILE IN STORAGE STATUS.

9.1 Movement (operation) of a stored aircraft from one place to another by air, with the
intention of keeping it in storage, should be an unusual event. However, before any
operation of an aircraft that has been preserved and stored in accordance with the
operator’s storage program can take place, the operator must complete procedures
for de-preserving the aircraft and accomplish those maintenance actions
necessary to return the aircraft to an airworthy status. The storage program should
clearly outline these procedures and maintenance actions.

A. Overdue Airworthiness Directive (AD)/ Mandatory Modifications: If the

aircraft is not being moved to accomplish maintenance, movement of a
preserved and stored aircraft can become complex if AD/ Mandatory
Modifications and scheduled maintenance requirements are overdue. The
RAO/ SRAO should pay close attention to while processing special flight
permit requests and impose suitable restrictions.

B. Procedures and Actions. The procedures and actions required for operating
a preserved and stored aircraft from one storage place to another should not
be significantly different from those for returning the aircraft to a full
operational status.
10. RETURN TO SERVICE FOLLOWING STORAGE.

10.1 Storage programs are meant to preserve an aircraft and do not require the
accomplishment of normal scheduled maintenance. Operator must ensure that the
aircraft conforms to applicable airworthiness requirements and limitations of their
maintenance program and the regulations. It must be understood that especially
calendar time accrued while in storage, must be accounted for when determining
the scheduled maintenance due for the aircraft for establishing maintenance
requirements for return to service.

10.2 In case, an aircraft is not preserved in accordance with the operator’s storage
program/ manufacturer program, the operator/ owner must approach the airframe/
engine manufacturer for providing work package for return to service of such
aircraft. The work package received from the manufacturer shall be applied only
after approval from RAO/SRAO.

11. DOCUMENTATION OF PROCEDURES.

A. The Operator Procedure Manual. The operator’s Engineering Procedures

Manual (EPM) or other document should define adequate procedures to
preserve aircraft while in storage. The areas of preservation in the paragraphs
below, will prevent the deterioration of the airplane, engines, structure, finish,
and/ or system components. The operator may adopt all or some of these, or
even additional areas in their manual, based on the complexity of their aircraft
and the length of storage. The operator must consider the location where the
aircraft will be stored; i.e., inside and protected environment, or outside, in
which case environmental conditions must be considered (high winds,
humidity, dust etc.). The need for repetitive inspections to ensure preservation
methods are adequate, must also be considered. The areas of preservation
may include the following:

1) Airframe. This may include:

• Installation of protective coverings and blanking of all external openings;

• Suitable Parking /mooring;
• Installation of safety pins;
• Removal of corrosion and cleaning of airplane surfaces before
applying corrosion preventative compound;
• Washing of aircraft including wheel wells and landing gear (may be
repetitive);
• Landing gear strut servicing, lubricating and protection of the oleo;
• Tire inflation, rotation and covering;
• Fuel system decontamination;
• Gust locks;
• Primary and secondary flight control cycling and lubrication;
 • Protection of windows;
• Procedures for the removal of parts or components;
• Inspection of seats and carpet for moisture/ mildew (if stored in humid
environment);
• Preserving interiors, galleys, lavatories and draining of water;
• Opening of closets, cabinets, and interior doors to supply ventilation
and to prevent mildew;
• Draining of water from the drain lines of the Air Conditioning packs;
• Dis-arming of Escape Slides; and
• Addressing the issues emerging out of excessive humidity.

2) Engine/Auxiliary Power Unit (APU). This may include:

• Procedures to operate the engine/APU on an established interval;

• Complete preservation of the engine/APU; and
• Procedures for the removal of parts or components.

3) Electrical. This may include:

• Opening/closing of circuit breakers;

• Battery servicing/disconnection;
• De-activation of ELT;
• Removal of batteries from emergency devices, such as megaphone,
flashlights, power supplies for emergency lights, emergency beacons,
etc.; and
• Procedures for the removal of parts or components.

Note: In case of sufficient blanking/ covers for protecting AOA sensors,

Pitot probes etc. not being available, Manufacturer’s guidance may
be sought for using alternative methods.

4) Operational Checks. This may include:

• Procedures to transition the aircraft from preservation to a state

acceptable for engine operations and operational checks of systems,
back to the preserved state; and
• Operational checks of hydraulics, electrical, engine, fuel systems,
avionics etc.

B. Contracts with Operator’s Maintenance Providers.

A maintenance provider may be used to store and preserve the aircraft. These
providers are required to perform all functions in accordance with the
operator’s manual and be monitored by the operator’s Quality System. The
contracts should be reviewed by RAO/SRAO to ensure that the operator’s
manual procedures are followed.
C. Procedures for Movement of the Aircraft in a Storage Status.

Occasionally, operator may need to fly an aircraft that is in storage to another

location to perform maintenance. The operator must have procedures in place
to ensure that an aircraft which does not meet its TC conditions, is in a safe
condition for the intended flight. The manual must include procedures to:

1) Ensure that flights conducted under this provision are conducted in

accordance with Special Flight Permit issued by DGCA.
2) De-preserve the aircraft based on preservation methods used during
storage.
3) Conduct inspections or operational checks necessary to ensure the aircraft
is safe for the intended flight.
4) Ensure that the aircraft is evaluated for inoperative systems or removed
components/ accessories and their effect on the intended flight. This
includes determining Weight and Balance (W&B) changes on the aircraft.
5) Determine that ADs/ Mandatory Modifications, which must be complied
before flight, are complied with.
6) Obtain approval from DGCA for authorizing the movement of aircraft in
storage status.

D. Procedures for Returning the Aircraft to an Airworthy Condition.

Regardless of what procedure an operator has in its manual on preserving an

aircraft in storage, the manual must have procedures on how to return an
aircraft to airworthy condition once taken out of storage. These procedures
must include a record check and compliance audit of the maintenance
program. All time- limited items, that went overdue during the storage period,
must be brought back.

The manual should include procedures to:

1) Define lines of responsibility and authority for personnel involved in

ensuring the aircraft is returned to service properly.
2) Audit the current status of the aircraft to the maintenance program and
comply with required tasks, including ADs/ mandatory modifications, life-
limited components, Certification Maintenance Requirements (CMR),
avionics databases, etc.
3) De-preserve the aircraft based on the preservation methods used during
storage.
4) Conduct other inspections and operational checks, as deemed necessary,
based on the period of time the aircraft was in storage and the environment
to which it was exposed.
5) Conduct any operational check flights or test flights prior to return to
service as considered appropriate.
 6) Procedures for cleaning & disinfecting the aircraft to be adopted to address
extraordinary situations such as wildlife infestation, virus/ bacteria etc. prior
to return to service.

12. ROUTINE AUDITS BY OPERATOR.

12.1 The Quality Manager of Operator should develop procedure to carry out periodical
planned and unplanned audits to ensure proper implementation of the above
procedures.

12.2 A report should be raised each time an audit is carried out describing what was
checked and the resulting findings against applicable requirements, procedures
etc.

12.3 If any finding of serious nature (Level-1) is detected during the routine audits, the
same should be intimated to the concerned RAO immediately. The responsible
manager should take appropriate action to mitigate the finding. The root cause
analysis along with the measures taken to prevent such finding in future should be
intimated in writing by Quality Manager to RAO

12.4 In case there is any violation of the approved procedures, the Quality Manager is
required to investigate the same and take necessary action under intimation to
RAO.

13. OVERSIGHT BY DGCA.

13.1 The respective Regional/ Sub-regional Airworthiness office will carry out planned
and unplanned surveillance inspection to ensure proper compliance of the above
procedures as part of AMP.

13.2 A report should be raised each time an audit is carried out describing what was
checked and the resulting findings against applicable requirements, procedures
and products.

13.3 In case there is any violation of the approved procedures, the RAO should
investigate the same and take necessary action as per the procedure detailed in
the Enforcement Policy and Procedure manual.

14. MAINTENANCE OF RECORDS.

14.1 The concerned RAO/ SRAO should maintain the records related to approval of
storage program and documents related to oversight of the organisation.