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SDMP (self declared maintenance programme) and why some can and some cannot operate it

IOW, it is not the whole story and is something most people can’t make use of Here we go again…

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

IOW, it is not the whole story and is something most people can’t make use of Here we go again…

In what sense is it something “most people can’t make use of”? Everyone who owns an airplane with an MTOM not above 2730 kg and do not use their aircraft either for CAT or to train other people at a commercial flight school can make use of it. What proportion of GA owners are not in that category?

You’re maintaining your N-reg TB20 obviously without a CAMO. If it was EASA-reg, you could still maintain it without a CAMO and without having to do 50 hr inspections.

Again, there is nothing anywhere in part-ML that says a 50 hr inspection is required. Nothing. Anywhere.

It’s true that if you employ a CAMO then the CAMO will most likely demand 50 hr inspections, but I can’t see how that is a disadvantage compared to maintenance of aircraft operated under FAA part 91. The FAA doesn’t even have the concept of a CAMO. In EASA land a CAMO is for the vast majority of light aircraft owners an option. Something you can choose to have or not have. Sure, if you choose not to have a CAMO, then you’re responsible for making sure that necessary maintenance is done, AD etc. are complied with. How does that differ from the FAA system? How do you maintain your TB20?

Last Edited by Airborne_Again at 18 May 20:00
ESKC (Uppsala/Sundbro), Sweden

In my aeroclub we have three aircraft that do not have a 50 hr inspection. Two Rotax powered aircraft and one Aviat Husky with Lycoming.

What AA says is true, you can choose to only have 100 hr inspections if you have a self declared AMP(or a brave CAMO).

As a matter of fact, the Husky does not even have a 50 hr inspection in the maintenance manual, only the Lycoming Engine has it.

ESSZ, Sweden

We have done the “SDMP” thing many times. [threads partially merged into this one]

Most owners can’t make use of it due to airport / maint company politics, because it reduces revenue.

Obviously some can, and they always write about it, not least because I always point out that most owners can’t make use of it due to airport / maint company politics, because it reduces revenue

Diversity of input is good. The challenge is to get across the message that airport politics gets in the way, and how to deal with it. Most owners can’t really deal with it, because most can’t change airports, or maintenance companies.

Administrator
Shoreham EGKA, United Kingdom

Airborne_Again wrote:

Sure, if you choose not to have a CAMO, then you’re responsible for making sure that necessary maintenance is done, AD etc. are complied with. How does that differ from the FAA system?

The FAA requires no documented maintenance plan, and therefore you can change your practice on your plane at any time without telling anybody, as long as you are compliant with government ADs that are typically checked annually.

I don’t know what a 50 hr check is, my maintenance of my plane is continuous and not written down (yes, I do remember everything) but my approach to an oil change while on a trip would be:

Buy an oil container and 2 ft length of hose at an auto parts store.
Buy the oil and filter from an FBO or have them shipped to hotel.
On the ramp: drain the oil and change the filter (no cowling removal required) and refill.
Make notes for a logbook entry and store them.
Drop off full oil container at the auto parts store for recycling, they have to take it by law, telling them they can keep or toss the container.
Throw old oil filter, oil containers and length of hose in the trash.
Fly plane.

Exactly how I’d do it on a motorcycle except I’d likely need a rental car and wouldn’t do in the hotel parking garage.

Last Edited by Silvaire at 18 May 21:14

Peter wrote:

Most owners can’t make use of [owner-declared AMP] due to airport / maint company politics, because it reduces revenue.

Obviously some can, and they always write about it, not least because I always point out that most owners can’t make use of it due to airport / maint company politics, because it reduces revenue

I’m sure you understand the situation in the UK very well, but I don’t think you really understand how it works in the rest of Europe,.The recurring discussions about aeroclubs are evidence of this. So you really have no basis for the claim that “most owners” in EASA-land can’t make use of owner-declared maintenance programmes because of “airfield politics”.

Last Edited by Airborne_Again at 19 May 07:12
ESKC (Uppsala/Sundbro), Sweden

AA is legally right but implementation differs across Europe.

In French regs,

  • the declared maintenance programme must be reviewed every year at the ARC renewal.
  • the person qualified for the mustreport to the authority if something misses in the DMP
  • this person is either from the authority, from a CAMO or a mechanic personaly authorized to perform ARC renewals (there must be a handful at best)
  • the said person will PROB99,99 notify to the authority if there is no 50hr inspection
  • the authority will question you about that, you will be in the radar (they will come do your renewal for the next 3 years etc…)

In the US I believe it is called “circling back to the point”.

When government has a power, it doesn’t like losing it.
I am glad our swedish friend enjoy the letter of the law

LFOU, France

Everything works in Sweden (and of course Norway) 100.00000000% compliance with EASA, zero airport politics, maintenance companies have so much money that they don’t need to worry, they allow customers to free issue parts (and don’t charge extra to make up for the loss of the 25% margin)… I lose the will to live sometimes. I know Europe has a rich mixture of cultures but it isn’t that rich

I am not going to further derail this good thread, and I am definitely not going to spend ages merging all the SDMP related posts here with the other (multiple) threads, but to take just one small thing: you can’t do an SDMP which is lesser than the manufacturer’s maintenance manual. I will leave it as an exercise to the reader (there’s a phrase from my univ days) to locate the Socata TB one Actually I will save you the trouble: TB20_Inspection_Checklist_pdf

I know A_A is not disingenuous but a lot of this stuff could be read by someone at some future point as the height of disingenuity – especially if they buy a plane and think 50hr checks are optional, etc. Do people really do that? YOU BET THEY DO! I have come across so many cases. The biggest was one chap read some license related thing on a forum, bought a plane, then had to sell it. Did he post it on a forum? What do ya think? Another bought a G-reg, read something, went to N-reg, read something, went back to G-reg… cost 10k+.

I would confidently state that the % of aircraft owners who are, or can be local-politically, on an SDMP, is in single digit %. The % of flying schools will be rather closer to zero, which is quite relevant to somebody doing a long trip in a school rented plane.

Administrator
Shoreham EGKA, United Kingdom

@Jujupilote makes the whole thing sound very complicated here. I have not found it to be so and has never added to downtime for the ARC.
I also think that the politics of working on your aircraft is more a UK thing, although I don’t know about airfield politics in other countries.
Here, doing your own maintenance is no problem whatsoever, in fact it’s seen as a normal part of aircraft ownership. That includes International Airports like La Rochelle LFBH and small airfields like LFFK and LFBN.
The maintenance outfits have plenty of work and most actually encourage you to get involved and get your hands dirty.
So perhaps, like me, it’s your use of the word “most” that is the problem and.should be changed to “most in the UK”

France

Peter wrote:

you can’t do an SDMP which is lesser than the manufacturer’s maintenance manual.

Yes you can. Part-ML gives you two options for developing an SDMP (or any AMP).

ML.A.302(c)(2): The AMP […] shall include, alternatively:
(a) the tasks or inspections contained in the applicable minimum inspection programme (‘MIP’) referred to in point (d);
(b) the instructions for continuing airworthiness (‘ICA’) issued by the design approval holder (‘DAH’)

The MIP is EASA’s own Inspection Programme which only has 100 hr/annual inspections.

Even if you choose to use the manufacturers maintenance instruction, you can remove things as long as you don’t go below the MIP.

ML.A.302(c)(3): […] Alternative maintenance actions to those referred to in point (c)(2)(b) shall not be less restrictive than those set out in the applicable MIP;

Last Edited by Airborne_Again at 19 May 09:04
ESKC (Uppsala/Sundbro), Sweden
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