Bathman wrote:
How does this tie in with the UK CAA interpretation
I wouldn’t know… But it’s surprising that the UK CAA refers to the 216/2008 Basic Regulation, as it has been superseded by the 2018/1139 Basic Regulation and the definition of “commercial” is different.
Ok, I think it will be fairly easy to work around that part. It might be worth quite a lot of money so it will be done if needed.
What does “wet” and “dry” mean in this context? To me “wet” means with fuel, “dry” means without, so I would assume a plane + instructor but no fuel included in the price would be “dry”.
Over the 20 years I’ve been flying I have heard many claims – by self appointed lawyers – that a dry lease is legal or a wet lease is legal, etc, in the context of renting your plane to somebody, but never found any genuine reference to any of these, relevant to GA.
This is the first time I have ever seen one of these terms used in any GA regulation.
Has a definition been provided?
They have well defined meanings with airliners. A dry lease is not just renting the plane to somebody without fuel. It has a specific meaning which includes what happens with the pilots, cabin crew etc.
In simplest terms dry lease means the entity receiving („renting“) the plane functions as the operator.
So plane XYZ is owned by A but operated by B (and B is named on insurance, operating certificate etc..).
Wet lease implies you rent an airplane operated by the one renting it to you. For instance Lufthansa can wet lease an aircraft operated by British Airways, flown on the BA AOC, with BA crew etc… Lufthansa is in charge of selling the tickets, provides the flight number etc…
Talked to a few pilot/owners at our airport. Many if not all where “waiting” for years to see part-ML implemented. Cheaper, faster, better ? right ? Now they report their first sad experience. Shops and inspectors are dragging their feet, extra paperwork everywhere they say. Delays and downtime. The main problem, nobody wants to be held responsible.
What’s your experience ? (If I missed a recent post on the subject … please let me know. I couldn’t find it).
Has anybody here already created his own AMP based on part-ml?
I have. The place where I get work done wasn’t the CAMO anyway so they don’t mind, and are happy enough to issue the ARC when the time comes as they know the aircraft and the history. Pretty straightforward process. If you can find a Part 66 that can issue the ARC then you’re almost at the American system.
I suspect a lot of aircraft owners are simply grounded at the moment, and flying and maintenance is not their biggest fish to fry.
