An RVSM maintenance programme is not a generic schedule with “RVSM” stamped on the header page. It is a defined body of work, drawn from the type certificate holder’s instructions for continuing airworthiness, that keeps an aircraft’s height-keeping performance inside the tolerances the airspace was designed around. It is also the one part of the RVSM picture that sits squarely with the CAMO — even though, as we will show, the approval itself does not.

The approval belongs to the operator. The evidence belongs to the CAMO.

A great deal of published commentary gets this backwards, so it is worth being blunt. Regulation (EU) No 1321/2014 contains no reference to RVSM at all. Not one. If you have been told that RVSM is a Part-M, Part-CAMO or Part-145 requirement, that is not where it lives.

It lives in Part-SPA of Regulation (EU) No 965/2012, and it is addressed to the operator. SPA.RVSM.100 provides that aeroplanes and helicopters shall only be operated in designated airspace where a reduced vertical separation minimum of 300 m (1 000 ft) applies between FL 290 and FL 410, inclusive, if the operator has been granted an approval by the competent authority.

SPA.RVSM.105 then lists what the operator must provide evidence of: that the RVSM airworthiness approval has been obtained; that procedures for monitoring and reporting height-keeping errors have been established; that a flight crew training programme has been established; and that operating procedures exist covering equipment and MEL entries, crew composition, flight planning, pre-flight, pre-entry, in-flight and post-flight procedures, incident reporting and regional procedures. Not one line of that list is addressed to a CAMO.

Now read AMC1 SPA.RVSM.105, which describes what the application actually contains. Item (h), under the heading “Continuing airworthiness”, is a single line: “Aircraft maintenance programme and continuing airworthiness procedures in support of the RVSM operations.” That line is the whole argument. The operator holds the approval and files the reports — but it cannot obtain the approval, and cannot keep it, without a maintenance programme and continuing-airworthiness procedures that somebody in continuing airworthiness has actually built. A thin RVSM programme is a thin operator application. The commercial position is stronger than the myth it replaces: the CAMO is not the duty-holder, it is the reason the duty can be discharged at all.

Where the RVSM content comes from

M.A.302(a) of Annex I to Regulation (EU) No 1321/2014 requires that maintenance of each aircraft shall be organised in accordance with an aircraft maintenance programme, and M.A.302(b) that the programme and any subsequent amendments shall be approved by the competent authority. That gives you the vehicle and the approval route. It gives you no RVSM content, because 1321/2014 has none.

The content arrives from two other places:

• AMC3 SPA.RVSM.105(a) — the aircraft maintenance programme should include the instructions for continuing airworthiness issued by the type certificate holder in relation to the RVSM operations certification in accordance with AMC1 ACNS.A.GEN.010. The tasks are the TC holder’s: not yours to invent, not the operator’s to negotiate.
• AMC1 ACNS.A.GEN.010(b) — four expectations that shape the programme. All RVSM equipment maintained in accordance with the component manufacturers’ maintenance instructions and the performance criteria of the RVSM approval data package. Repairs not covered by approved maintenance documents that may affect the integrity and accuracy of the altimeter system subject to a design review acceptable to the competent authority. Airframe geometry or skin waviness checks performed following repairs or alterations which have an effect on airframe surface and airflow. And an autopilot maintenance and inspection programme ensuring continued accuracy and integrity of the automatic altitude control system.

Those four items are the skeleton of the RVSM section of your programme. The airworthiness criteria behind them sit in CS-ACNS Issue 5, Subpart E, Section 2 — Reduced Vertical Separation Minimum (RVSM), points CS ACNS.E.RVSM.001 to .035, consolidated in the EASA Easy Access Rules.

The procedures, which most organisations underestimate

AMC3 SPA.RVSM.105(b) asks for continuing airworthiness procedures that establish a process to assess any modification or design change which in any way affects the RVSM approval; to evaluate any repairs that may affect the integrity of the continuing RVSM approval, for example those affecting the alignment of pitot/static probes, repairs to dents, or deformation around static plates; and to ensure the proper maintenance of airframe geometry for proper surface contours and the mitigation of altimetry system error, surface measurements or skin waviness as specified in the instructions for continued airworthiness, to ensure adherence to RVSM tolerances.

Those are process requirements, not task cards, and they belong in your exposition. If you are drafting that documentation, our guidance on how to write a CAME and on building a CAMO management system shows where an RVSM modification-and-repair assessment route slots in alongside the change management and occurrence processes you already run.

AMC3 SPA.RVSM.105(d) adds that the operator should ensure that maintenance organisations use test equipment adequate for maintenance of the RVSM systems. Note who that is addressed to, then note who will have to answer it. In our experience it lands on the CAMO as a contracted-organisation assurance item: for every organisation touching your RVSM systems, what equipment is used, and how is its calibration controlled?

Training: read the wording carefully

AMC3 SPA.RVSM.105(c) says additional training may be necessary for continuing airworthiness and maintenance staff to support RVSM approval, in aircraft geometric inspection techniques, test equipment calibration and use of that equipment, and any special instructions or procedures introduced for RVSM approval. May, not shall. Anyone selling RVSM maintenance training as a mandatory requirement is overstating the text — and that is not an argument for skipping it. In our experience competent authorities expect a reasoned position: either those three competencies appear in your training matrix, or you can explain why they are not needed for the work you perform. Our RVSM maintenance training for CAMO and Part-145 personnel course is structured around exactly those three headings.

Who does what

The last row matters more than it looks. Statistical altimetry system error tracking for a group of aircraft — the mean-plus-three-standard-deviations work — is production-side, performed by the aircraft constructor with N and M agreed by the competent authority. A CAMO that believes it should be computing fleet ASE statistics has misread the framework. What the CAMO tracks is task compliance, repair and modification assessment, and the RVSM serviceability status of individual aircraft.

Where programmes actually fail

Almost never in the equipment tasks. The SPA.RVSM.110 fit — two independent altitude measurement systems, an altitude alerting system, an automatic altitude control system, and an SSR transponder with altitude reporting connectable to the altitude measurement system in use for altitude control — is visible and hard to forget. Programmes fail at the joints instead. If nothing calls up an airframe geometry check after a repair in the wrong place, the workshop will not perform one — not through negligence, but because nothing scheduled it. We take that apart in skin waviness, static ports and the hidden geometry of RVSM and follow it to its conclusion in the static-port repair that costs an aircraft. For the wider argument, see why RVSM is a maintenance problem, not just an operations one and RVSM height monitoring and error reporting.

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