Written by lawyers for lawyers.
Silvaire wrote:
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.
…I think, if I read it right, from 2017, a CAMO or Approved Maintenance Plan won’t be required at all for aircraft below a certain weight.
JAA then EASA got things very very wrong for light aviation in almost every single part of the endeavour, from licensing to maintenance and beyond. Finally, they are starting to fix things. Reading the stuff which went before it was amazing from any perspective, not merely the US perspective, especially for those it was imposed upon.
I was talking about this ELA1/ELA2 with an owner of a PA28-140 today who has just paid 6k on his Annual… he is in the same position as nearly every owner i.e.
This is as expected.
So while this is a brilliant step forward, for a significant number of owners to benefit, a number of changes will need to take place
Which takes us back to exactly why homebuilders/etc save money 
They have all this sorted.
I now need to find a way to clone the easa66/A&P/ia engineer I work with
Peter,
the potential savings (not only in terms of money, but also in terms of hassle and downtime) for owners are much bigger, and not only for those who are “hands-on”.
A lot of “stuff” is being replaced, overhauled etc. on many EASA-reg. light aircraft these days, without technical necessity, just because they are “due” as per the maintenance program. Hoses, valves, suction pumps, filters, batteries, props, engines, etc. Particularly if you look a little more south. Those CAAs so far tend to be very strict and base everything on (or even go beyond) the “manufacturer’s instructions” (read: non-chapter 4 recommendations). A nightmare, as an operator.
And yes, I am aware that in some cases of the above components, it does actually make lot of sense to follow the manufacturer’s recommendations…
alioth wrote:
JAA then EASA got things very very wrong for light aviation in almost every single part of the endeavour, from licensing to maintenance and beyond. Finally, they are starting to fix things.
The next steps in my mind will be to eliminate requirement for private owners to pre-register with government how they plan to maintain their property (in the form of a “Maintenance Programme”) and to eliminate the concept of “Design Approval Holder (DAH)” for Type Certified light aircraft. Other than that completely unnecessary protocol, to me the oddest thing the CAA document specifically is this statement: “The owner, however, is fully responsible for any deviations from the DAH recommendations” What does that actually mean? Responsible for what? And to whom?
The whole thing strikes me as a bunch of nonsense. Maintenance on conditon, at minimum supervised by certificated mechanics who sign off the work, plus an annual inspection, is all that is warranted for private property… and certainly any property that I’ll ever own.
Sure; anything that gets one away from a company is a good thing.
What latitude does the ELA1/ELA2 owner have when it comes to disregarding life limited parts in the mfg MM?
I quoted the important bits above. Chapter 4 (Airworthiness Limitations) items need to be ovserved, along with ADs and ICAs. The rest does not necessarily need to be observed. Like as per Part 91.
boscomantico wrote:
Chapter 4 (Airworthiness Limitations) items need to be ovserved, along with ADs and ICAs. The rest does not necessarily need to be observed. Like as per Part 91.
In other words, maintenance as per the intent of everybody involved in manufacture and certification except the bystanders in European government. If that’s what they mean, it obviously leads to the question of why filing a maintenance plan for an individual aircraft is required or warranted. Especially when submitted to the uninvolved.
Because “they” don’t want to take the responibility for it. With the self-declared maintenance programs, the owner/operator signs that he takes responibility for any omissions.
All this exercise we are seeing here is ultimately not to give a benefit to GA. It is politics and legal fine-tuning / CYA action.
The owner, however, is fully responsible for any deviations from the DAH recommendations” What does that actually mean? Responsible for what? And to whom?
Maybe being a bit vague is done on purpose? If they had been more specific, maybe this regulation would never have been passed? I am not a lawyer, but I can see some future courtcases revolving around this point, so from the regulator’s point of view, it might make sense to include this wording.
boscomantico wrote:
Because “they” don’t want to take the responibility for it. With the self-declared maintenance programs, the owner/operator signs that he takes responibility for any omissions.
In what form would a government agency otherwise take responsibility? Cash payments resulting from a successful individual lawsuit against the government agency for failing to force an individual third party to responsibly maintain his property? When government does require passing a periodic condition inspection. Really?
I can’t decide whether the process by which government disengages from areas in which it has no business being involved is painful to watch, or humourous to watch
