Hello,
I have not looked closely in the corrigendum but I would count on it being fully integrated by the 24th of March.
Here is a good template to use that has been made by the Swedish CAA(with english text as well):
Swedish AMP Template Part-M
And they have also made an explanation to help write the AMP:
Swedish AMP Template Explanation
However! This is not designed for a Self Declared AMP, but it is a very good start for the main parts of the AMP. I think I have seen(not sure) another template for a self declared but I can’t find it now. But I think the above one can easily be modified to be one.
The EASA GA Roadmap provides this summary of part-ML
Owners of light aircraft can get prepared for the improvements in the rules for maintenance in Part-M Light (ML). …
The key deliverables are:
• Based on the Minimum Inspection Programme (MIP), owners of light aircraft* can write their own maintenance programme.
• There is no need to have the maintenance programme reviewed by your Civil Aviation Authority or by a Continuing Airworthiness Management Organisation (CAMO).
• Any independent EASA-licensed engineer can do the annual inspection.
• Possibility for the pilot / owner to defer defects
• Guidance for Time Between Overhaul (TBO) extensions
…
Part-ML simplifies existing maintenance rules, and offers a less prescriptive and burdensome approach to maintenance programmes, airworthiness reviews, defects deferments and TBO extensions. It also provides more privileges for pilot, owner, independent certifying staff and small maintenance organisations. Be prepared to benefit from the change, the transition measures will also be facilitated!
*************************
Would anybody have enough insight into the details of the law text (CELEX) for part-ML to judge whether the new rules will / can really deliver the promoted benefits ? Or will “the system” take a log time to adjust, if at all ? I guess that a CAMO who invested for years into the heavy part-M administration (paperwork, certification, ink and stamps …) would hardly be delighted to let their engineers do cheap work in the field and forgo their main business.
just repeating the last paragraph of my previous post, in order to see if anybody may have overlooked it
AJ wrote:
Would anybody have enough insight into the details of the law text (CELEX) for part-ML to judge whether the new rules will / can really deliver the promoted benefits ? Or will “the system” take a long time to adjust, if at all ?
AJ wrote:
Would anybody have enough insight into the details of the law text (CELEX) for part-ML to judge whether the new rules will / can really deliver the promoted benefits ?
For aircraft that are not ELA1, yes. For ELA1 there is not so much difference compared to (the latest revision of) the old rules, but there are some. E.g. the pilot can decide if the aircraft is airworthy with some equipment u/s, without having to use a MEL.
I think it will be able to deliver. However, how fast this change will happen (in theory should be instantly) will depend on the knowledge of the involved people. If, for example, the mechanics do not become aware of their new privileges, it might take a few years until they adapt. In my opinion it all depends on how fast everyone becomes aware of the legal changes. Unfortately I heard of authorities who do not want to inform about alleviated rules due to safety concerns (the root cause being they don’t understand the concept of “acceptable level of safety” of non-commercial activities vs. commercial). Overall I’m hopeful, though.
What is wise and what is not ?
Years of maintenance has let me see a fair slice of the goings on in UK aviation and the one thing that stands out is the number of people who fail to understand preventative maintenance and the cost savings it will bring.
One of the posts above makes reference to a 500 hour Mag overhaul, as I know of no Magneto that has a 500 hour overhaul I will guess this is referring to the Slick SB that requires a replacement of the contact breaker points .
A long time back I worked for a company that took the view that unless it was AD they did not do it and so ran the slick mags until they failed.
The reason given was cost saving but the aircraft with +500 hour mags became noticeably more difficult to start and of course eventually failed usually at the most inconvenient time, there was also the issue of extra load placed on starters and batteries resulting in premature failure.
In my opinion the policy of not getting the SB done cost more money than it saved.
As a private owner the cost saving is dependent on what sort of flying you do, if you just fly locally then a Mag failing is not going to cost too much but what of the cost of an engine not starting on a Sunday morning half way down France ? The costs will mount quickly and make the 500 hour SB look like a bargain.
There are places that savings can me made, the Cessna requirement to change the seatbelts at ten years is not an issue for commercial operators because the bels won’t last that long but in private service a seatbelt could be safe for a great deal longer so it would be reasonable to inspect the belts annually using some approved data as a guide.
SDMP should be seen as a chance to do the maintenance appropriate to your type of aircraft operation and saving money by wise decisions NOT as a way of culling anything that costs a bit of time and effort.
“One of the posts above makes reference to a 500 hour Mag overhaul, as I know of no Magneto that has a 500 hour overhaul I will guess this is referring to the Slick SB that requires a replacement of the contact breaker points”
What I would actually like to do is get rid of BOTH mags having to be overhauled at 500 hours. Do one at 500 hours the other 50 hours later.
Splitting component changes is not a bad idea and across my Cessna fleet than happened but quite by accident.
I had a Magneto fail prematurely and the loss of revenue waiting for the Magneto to be fixed resulted in me buying a new Mag, the old mag was overhauled and having a spare allowed mag changes for the 500 hour SB to be done at my convenience. Yes I initially did take a loss of some running time on the Mags but it did result in almost always having a spare on the shelf.
The final bit of money saving was to fit the whole fleet with SLICKSTART ignition boosters, this device boosts the power of the Spark by 300%+ while the engine is cranking and the engine will fire with a very sub-optimal fuel mixture. The result is the engine will start even in the hands of the most inept student pilot. The savings in starter motors and batteries paid for the Slickstart ( and are no doubt still saving the new owners money ).
It is a whole big discussion as to how best to control costs while maintaining maintenance quality.
Many previous threads…
Without a doubt, the best way is a freelance engineer working inside “your” hangar. Then you are not paying company overheads, probably not paying VAT on the labour, he works for you and not for some “company policy”, etc. But this arrangement is currently possible only on ELA1 (below 1200kg) or on an N-reg (also doable on a 2-reg IIRC) and is anyway impossible for most owners due to airport political factors (usually, no work permitted in hangars – at least not officially). And most owners don’t want to get involved anyway with their plane / aren’t technical / don’t want to get into techy stuff, which finishes this option totally. Then you have the issue of A&P/IA availability and – much worse – freelance EASA66 availability…
Then, because you have not maintained a relationship with any based company, if you need help urgently you won’t get it. So in reality you still need to work on that. If this goes wrong, you will end up like so many owners: having to fly somewhere for any maintenance. At the average airfield with maintenance companies on it, perhaps 50% of based planes fly away…
So it’s a good Q as to what an SDMP achieves. It is politically obvious that if you are using a company to do the work, they won’t take you on if they don’t like what you are doing. They don’t have to give reasons. So what exactly are you trying to achieve?
For those – the great majority – who need to use a company, obviously you need to work with the company to agree how to go about it. I think financial savings will be marginal, except for the removal of really nutty things like the 6 year prop overhaul, and the 150hr service which is almost an Annual and which really hits many syndicates. On a G-reg, can you really drop these two things, totally?
