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Long distance maintenance G-reg / another reason for N-reg?

Peter wrote:

What % of GA owners in Europe are on SDMP and able to delete the 50hr services?

I have no idea. Do you?

Most maintenance companies won’t touch SDMP-operating owners with a bargepole.

Is this your guess or do you have hard data? Let me just say that my club hasn’t any problems with making a part 145 company do maintenance on an aircraft on a owner-declared AMP.

Last Edited by Airborne_Again at 26 Nov 07:31
ESKC (Uppsala/Sundbro), Sweden

Some misconceptions in this thread concerning EASA and maintenance.

Let me try and clear it up. Applicable for privately owned and operated planes up to 2730kg MTOW.

AMP: Aircraft Maintenance Program
MIP: Minimum Inspection Program
DAH: Design Approval Holder (Manufacturer)
AMM: Aircraft Maintenance Manual issued by DAH
CAMO: Cont. Airworthiness Management Organisation
CAO: Basically a CAMO, but with less authority requirements for it’s organisation (Safety Management etc..)

1. The pilot owner declares (no approval required) the AMP for his airplane.

2. The AMP can be based on either
a) the MIP according EASA Part-ML
or
b) the AMM of the DAH
or
c) is not required if following all DAH instructions

3. Except for Airworthiness Limitations (eg the Parachute on a Cirrus) and ADs, you can deviate from any time limits mentioned in the AMM. Things cannot be less restrictive than the MIP (so on condition basically means inspect at least every 100 hrs or 12 months). Not a constraint at all.

Example:

DAH AMM Time Limit (not an airworthiness limit!, legally only a recommendation!):
Task: Overhaul Engine
Interval: 12 years/2000hours

changed in Pilot Owner AMP to :
Task: Compression Test, Boroscope, Oil Filter Inspection etc..
Interval: 100 hours/12 months whichever earlier.

4. A Pilot Owner has extensive rights to perform and sign off maintenance

5. The ARC can be extended by
a Pt. 145 (organisation)
a CAMO/CAO (organisation, do not mistake this with Pt. 6)
the NAA (organisation, Authority)
independent review staff (Pt. 66, a person)

6. A Pilot Owner can also voluntarily contract a CAMO or CAO. Contrary to the above, he is then not responsible for the maintenance and airworthiness of his plane, the CAMO/CAO is (a liability topic).

Then the AMP needs to be approved by the CAMO/CAO and they issue workorders and extend the ARC. Pilot Owner Maintenance and deviations – Pt. 3 above – are still possible, subject to the CAMO/CAO.

7. Conclusion: EASA NCO Pt.-ML is almost identical to FAA Pt. 91

Quick recap of options for owner pilots:

1. Contract a CAMO/CAO → same options as ever before
The CAMO can either approve an individual AMP or follow the DAH AMM to the letter.
Advantage: Responsibility for airworthiness lies with the CAMO. This can be a liability factor in case things get really ugly in court.

2. Declare your own AMP → new options for pilot owner
See steps above.

3. Declare your airplane will be maintained exactly according to the DAH AMM, then you do not need to create an AMP. → new option for pilot owner

Attached:
List of Pilot Owner Maintenance Items
EASA MIP

Last Edited by Snoopy at 26 Nov 14:41
Freelance IRI / CB-IR Instructor
LOWG | Worldwide

Snoopy wrote:

EASA NCO Pt.-ML is almost identical to FAA Pt. 91

…if the pilot-owner does the paperwork to create an AMP, and finds an individual or organisation willing to sign off the ARC paperwork based on that…

Last Edited by Cobalt at 26 Nov 14:00
Biggin Hill

We’ve done this before

Part 91 is generally much easier to run than Part-ML because an FAA A&P is generally freelance while an EASA66 is generally not freelance. In terms of airport politics this is a dramatic difference, and the successful management of airport politics is what makes planes fly and makes owner-pilots happy (it isn’t aerodynamics or free avgas ). Most EASA-reg owners can’t find a freelancing EASA66 and if they do he will be looking over his shoulder to make sure his day job employer doesn’t see him freelancing. It is a bit of a catch-22 but most EASA66 mechanics would not find enough freelance work to make a living.

Administrator
Shoreham EGKA, United Kingdom

What do you mean by airport politics?

Freelance IRI / CB-IR Instructor
LOWG | Worldwide

Cobalt wrote:

…if the pilot-owner does the paperwork to create an AMP, and finds an individual or organisation willing to sign off the ARC paperwork based on that…

Most NAAs already approved owner pilot AMPs and TBO/calendar extensions already before Part-ML. No problems with the ARC.

Freelance IRI / CB-IR Instructor
LOWG | Worldwide

But I don’t understand. Let’s say you launch on a long international trip. For various reasons, it takes 75hrs rather than the 50 initially planned due to whatever. You come back to do the 50hr inspection – are you guys saying the mechanic has a duty to report you to the CAA? I very much doubt that. He’ d do the 50hr inspection and nothing else would come of it.

It’s like on my plane – I inadvertently flew 140hrs over the cycle limits on one of my engine components (rotables) because the log I had was incorrect. It only got discovered during a deeper look into logbooks. The mechanic has no duty to report that to the FAA. They just can’t sign it off until it’s been fixed.

I can’t tell you what the exact procedure within an EASA Part M company would be if a customer turned up for a service, with 75hrs since the previous service. The problem is that if the mechanic does nothing and just performs the service and ignores the 75hrs, he is putting his name to some unairworthy flying activity, and he can’t pretend he didn’t notice. Basically the plane was flying illegally for 25hrs (20hrs if the customer applied for the max extension) and he is now returning it to service. I am sure he is required to report the owner to the CAA, but who knows? The simplest thing would be to quietly tell the customer to use the next company down the road. Maybe someone (@antonio ?) knows what the maintenance company is required to do upon discovery of illegal operations.

The plane may have been on an SDMP on which 50hr checks are optional but from what I see around here very few are on an SDMP simply because most owners use a company (rather than a freelance EASA66 mechanic) and most companies won’t maintain an SDMP plane because they see it as a revenue reducing move.

On an N-reg there is no issue because all inter-Annual checks are optional (time based ADs are a different thing; they override everything including what you can do under pilot privileges).

Administrator
Shoreham EGKA, United Kingdom

And in my experience the CAMO declares the AMP then when the CAMO has its annual inspection and the NAA representative says it’s not happy with the AMP and tells the maintenance organisation to change it. And if the maintenance company refuses they lose their approval.

So we’re still on 6 year prop overhauls and 2000 hour engine TBO’s regardless of component condition.

@bathman
No. A camo/cao isn’t declaring anything. A camo can approve an AMP if an owner (optionally) elects to contract a camo.

Unless an airplane is used in a for profit (non club) ATO, going with a camo is optional. It is certainly more comfortable and can have some advantages for liability reasons, but it is entirely optional.

So we’re still on 6 year prop overhauls and 2000 hour engine TBO’s regardless of component condition.

Not with non complex NCO airplanes up to 2730kg.

I tried:
PART-ML

Last Edited by Snoopy at 28 Nov 20:35
Freelance IRI / CB-IR Instructor
LOWG | Worldwide
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