And… I would say, yes. Otherwise known as common sense. “AH slow to erect”. Ok, that thing isn’t up to snuff. Day VFR – couldn’t care less. Hard-core IFR at night with weather at minimum, limited alternate, and with known dodgy AI – well, you decide.
Indeed, I think that’s a good way of looking at it. Actually, Day VFR is not the problem, as the AH is not required equipment. But it’s the difference between the Hard-core IFR you mention and a quick climb or descent through a layer.
Airborne_Again wrote:
So you mean that under the current rules, every written observation that a mandatory piece of equipment is not performing 100% to expectations means that the aircraft is no longer airworthy? In that case I would except everyone to operate illegally.
Indeed the current rule, if interpreted literally, is broadly flouted, and its only effect is to discourage useful communication. And not just in GA. If you look at the accident report on the Metroliner at Cork in 2011, you find an almost defect-free aircraft for a year or so. If someone had written down the torque split issue (without the effect under Part-M that it immediately grounded the aircraft with the closest engineering support 1000 miles away) then one can speculate that it might have been looked at before the accident flight and the third go-around might have been normal rather than catastrophic.
I am currently working on the AMP of the aircraft that I have recently purchased. While I am working together with the maintenace organisation where she has always been maintained and where I plan to continue to do the maintenance in the future as well, the AMP will be officially declared by me as an owner-pilot, so I want to make it as beneficial for my operation as possible. I have a couple of questions that I would like to hear your thoughts about.
Thanks for any opinions in advance.
I’m also planning for a owner-declared AMP. I haven’t got so far as to actually start writing, so I can’t say anything about most of your questions, but a few things I know.
JnsV wrote:
If I am the owner-operator, who would actually issue the annual extension of the airworthiness certificate? I understand that the AMP will have to reviewed each year by a maintenance person/organisation.An ARC extension is only possible in a controlled environment. Having an owner-declared AMP or pilot-owner maintenance don’t preclude a controlled environment (AMC to M.A.901(b)), but of course the CAMO would have to agree and possibly also have approval for handling owner-declared AMPs.
Otherwise there are four options for issuing an ARC yearly: A suitably approved CAMO can do it (M.A.901(e)), the NAA can do it on recommendation by suitably approved maintenance staff who have done the actual airworthiness review of the aircraft (M.A.901(g)) but only two years out of three (AMC to M.A.901(g)), the NAA can do it after having done the airworthiness review themselves (M.A.901(i)(2)), or a suitably approved maintenance organisation can do it (M.A.901(l)).
The problem here is the approval. The CAMO or maintenance organisation/staff may not be interested in getting such an approval. They may feel that they have enough business without having to do extra administrative work and costs in order to get the approval. In that case you are left with the NAA.
Which tasks may be added to the Part M / Appendix VIII list of pilot-owner maintenance tasks? I probably will not do too much maintenance myself, but I would like to keep this option as open as possible.
Do you mean what tasks from that list may be added to the AMP? You can add every single one of them (as long as they are relevant for the aircraft).
Is there really no current version of the Part M in a single document?
There is one here. That version does not include the very latest revision, but that revision does not come into force until August 25 this year.
Great to see that you are investing some time to learn and use this privilege!
Although I am not an expert I will try to give you my honest opinion on your questions:
1. OK to delete parts that do not apply?
I would say YES when it comes to very obvious sections, such as balloon-stuff for example.
2. What to write if “on condition”?
If I were you I would simply put “Not adopted”. The compression checks are already part of the Minimum Inspection Programme which means that you do not have to write that there as well, unless you intend to do it more often than once a year/every 100 hrs. But I think you should just leave it out.
3. Where to write extra inspections?
If you do not find a suitable place to put these inspections you could probably just copy/paste the columns from the TBO-section and rename it to “Aircraft specific inspections” or similar. The template is just a draft so it should not be a problem to add something in there.
4. Including oil changes and similar?
Yes, if you have a specific interval for it I would recommend that. But remember that it is also allowed to do maintenance that it is not listed in the AMP. :)
5. Should the details of each task be included in the AMP?
No, but it is good to have a reference in the AMP, just the way that the template has made a reference to the MIP in section 2, if you have that information. If everything is done according to the maintenance manual you probably do not need references like that.
6. Who issues the ARC?
The ARC should be issued by the CAA, CAMO or Part-145 if they are approved for it. When Part-M Light enters into force it can be issued by an independent Part-66 mechanic. Same goes for the AMP review.
7. More tasks to Appendix VIII?
I am not sure but I think that it will evolve. You can add stuff to this part of the AMP and still have a mechanic or another competent person do the task, it is all a matter of who is signing the release back to service.
8. No current single document version of Part-M?
Unfortunately it is a bit of a mess but I would say that the consolidated version is the best to go for + the AMC/GM.
Good luck with the AMP! Looking forward to hear more about your experience with this.
I am working on this as well. Despite understanding other parts of EASA regulations being my day job I am struggling with it as well. I’ll try to post something useful soon.
Airborne_Again wrote:
An ARC extension is only possible in a controlled environment. Having an owner-declared AMP or pilot-owner maintenance don’t preclude a controlled environment (AMC to M.A.901(b)), but of course the CAMO would have to agree and possibly also have approval for handling owner-declared AMPs.
This is interesting. I will see what they say about this.
The problem here is the approval. The CAMO or maintenance organisation/staff may not be interested in getting such an approval. They may feel that they have enough business without having to do extra administrative work and costs in order to get the approval. In that case you are left with the NAA.
Deviations from TBOs for ELA1 aircraft would be very useful for many owners (the maintenance company/school included), so there is a clear interest, but less the ideal level of understanding of the topic. Not that the Hungarian CAA helps with their interesting translations / iterpretations of the regs, but currently they seem to understand them in the intended way. They threw in some unnecessary things that will have to be included, and they require all owners to send the AMP to them, but not for approval. (It is not clear if they have the option to reject it, but I guess they do.)
There is one here.
Fly310 wrote:
Unfortunately it is a bit of a mess but I would say that the consolidated version is the best to go for + the AMC/GM.
Thanks to both of you for the link. I was fooled by the fact that in Hungary the consolidated versions run under the original identifier and title, unless the law is completely rewritten.
Good luck with the AMP! Looking forward to hear more about your experience with this.
Thanks for the encouragement and the useful comments! I will surely post about what I could put together and what the maintenance company and the CAA says about it.
Joe-fbs wrote:
I am working on this as well. Despite understanding other parts of EASA regulations being my day job I am struggling with it as well. I’ll try to post something useful soon.
I’m looking forward to reading your input.
Would like to see what the finished AMP looks like. And if you had any issues with your CAMO.
trevor_s wrote:
Would like to see what the finished AMP looks like.
Once I’m finished with it I will see how much of it can be posted publicly.
And if you had any issues with your CAMO.
I have not had isses with them so far regarding the maintenance programme. They are happy with the situation that the main responsibility is mine and advise me about the possible effects of deferring component overhauls. The basic principle that we are applying is that I keep most of the condition checks as proscribed by the TC holder, but only exchange expensive parts if an actual defect is found.
This is as far as I have got with summarising the current position, comments welcomed. I am also working on lists for a programme for my shareoplane (a basic AA5) and a list of what we can do on it as pilot-owners. I’ll share those when done.
This covers maintenance of EASA aircraft (so not those on permits). This was done very badly by EASA and is slowly being rectified, specifically in our world by Part M Light. This is a changing set of regulations. The current set is summarised below. Further changes are in the rule-making process at EASA (an “opinion” was published in April 2016 but is not yet law so is not included in the summary below).
Large commercial aircraft are covered by Part-145 which need not concern us.
What follows is the current situation and is extracted from the basic regulation EU 1321 / 2014 as amended up to and including EU 2015 / 1536 (effective 25th August this year, it includes phase 1 of Part M Light but does not include the proposed future changes published in April 2016 as an EASA Opinion which is phase 2 of Part M Light) and is for non-commercial ELA 1 aircraft which for aeroplanes is non-complex and MTO mass 1200 kg or less.
1. The PiC is responsible for satisfactory accomplishment of the pre-flight inspection which must be done by a pilot or another qualified person.
2. The owner is responsible for the continuing airworthiness of the aircraft.
3. Under M.A.201(i)(2) we are allowed (but not required) to manage the continuing airworthiness under our responsibility without contracting an approved CAMO
4. Managing continuing airworthiness means that we are allowed to do the following:
a. Identify which Airworthiness Directives apply to the aeroplane
b. Plan maintenance. The programme must take account of the TC owner’s instructions for continuing airworthiness. There is a long list of other documents which “must be taken into consideration” when defining the maintenance programme but only applicable AD are compulsory. At ELA 1, the programme need not be approved by the local national authority. There is a template which I have downloaded and am adapting.
c. Update the maintenance records.
d. Anyone with insomnia, the CAA summary of events is here
https://www.caa.co.uk/General-aviation/Aircraft-ownership-and-maintenance/Minimum-Inspection-Programme/
5. We must grant access to anyone authorised by the Competent Authority access to any facilities or documents related to this.
6. Maintenance can be done by independent mechanics outside of maintenance organisations. The qualifications for these mechanics are set nationally i.e. not by EASA.
7. As owners we are (subject to our individual capabilities) allowed to do certain tasks as set-out in the Part-M appendix VIII Acceptable Means of Compliance. I have extracted this list and am producing a version relevant to our aeroplane.
8. There must be a periodic review of what we do by a CAMO at the annual or 100 hour inspection. For ELA 1, the national authority need not be involved. From 2017, this review may be done by independent mechanic.
9. Pilots are allowed to defer defects as long as the owner agrees.
10. So the question is do we want and are we capable of reducing what we pay for maintenance by:
a. becoming our own CAMO
b. doing the maintenance which is allowed ourselves? We may decide that we would rather for both peace of mind and availability of spare time not to do any of it.
Joe-fbs wrote:
So the question is do we want and are we capable of reducing what we pay for maintenance by: becoming our own CAMO
Most of the world’s (i.e. US) aircraft owners wouldn’t know what a CAMO is, nor would they have an Approved Maintenance Plan. Reading all this stuff is amazing from the US perspective. Small aircraft are just not that hard to maintain.
