Jujupilote wrote:
the said person will PROB99,99 notify to the authority if there is no 50hr inspection
Given that it is explicit in part-ML that the AMP may be based on the EASA MIP (see my post above) which does not include 50 hr inspections, I find that very unlikely.
the person qualified for the mustreport to the authority if something misses in the DMP
Do the French regs actually say exactly that? Because part-ML says something which is subtly, buy very importantly, different.
ML.A.302(c)(9): […] If the review shows deficiencies of the aircraft linked with deficiencies in the content of the AMP, the AMP shall be amended accordingly. In this case the person performing the review shall inform the competent authority of the Member State of registry if he does not agree with the measures amending the AMP taken by the owner, CAMO or CAO. The competent authority shall decide which amendments to the AMP are necessary, raising the corresponding findings and, if necessary, reacting in accordance with point ML.B.304.
In other words, first, the AMP needs to be amended only if the review shows that the AMP has actually (not potentially) been ineffective. Second, the reviewer shall report to the authority only if (s)he and the person/organisation responsible for the AMP don’t agree on the appropriate amendment.
Peter wrote:
I know A_A is not disingenuous
Well, thank you. 
Your arguments rest on an expectation that CAMOs and maintenance shops do not accept what is actually written in the regulations. That is certainly true in some cases, but what can we, as aircraft owners and operators, do other that press the issue? If we don’t, the possibilities that EASA has given back to us in part-ML will never have the intended effect of simplifying GA aircraft ownership and operation.
So here is my data point. You may say it is UK and not EASA, but up until very recently it was EASA and unless something major has changed in the last few months…
Our TB10 resides at White Waltham and we fly to Thurrock for maintenance. The (excellent) General Aero Services are our CAMO and I could not ask for any more – 50hr checks are done while we wait (often at very short notice) and the annual takes a week or less. They once discovered a crack cylinder during a 50hr and replaced it while I waited.
What other options do we have? Engineering at White Waltham doesn’t want to work on anything that isn’t Piper or Cessna, and we aren’t allowed to bring in our own freelancer, so any other solution still involves flying away and to avoid using a CAMO we would have to synchronise a freelancer with somewhere to work. It’s just too much hassle – the freelancer goes on holiday, the hangar is full, etc.
We rationalise it in that part of what we pay for with the CAMO is an ‘always available when we need them’ arrangement, and they pretty much are. While I am delighted with our present arrangements (perhaps the only way it could be improved is for GAS to move to Waltham ;-) I do object, on a philosophical level, to being essentially forced to use a company.
Airborne_Again wrote:
That is certainly true in some cases, but what can we, as aircraft owners and operators, do other that press the issue? If we don’t, the possibilities that EASA has given back to us in part-ML will never have the intended effect of simplifying GA aircraft ownership and operation.
If you start telling (most) maintenance companies what the regulations do and don’t require then it usually results in being told to take your business elsewhere.
Any regulatory change that increases revenue is immediately and vigourously implemented. Anything that reduces revenue is studiously ignored for as long as the market will tolerate it.
Graham wrote:
Anything that reduces revenue is studiously ignored for as long as the market will tolerate it.
So we should not tolerate it.
Airborne_Again wrote:
So we should not tolerate it.
Unfortunately we see in a lot of consultations about relaxing regulations “businesses may object/lose business”. It is our duty to reply to these consultations and remind the regulators that regulations do NOT exist to prop up business models, and when relaxing regulations, businesses that rely on customers being forced to come to them due to some burdensome regulation need to be told with all due respect that the regulations don’t exist to deliver them business.
gallois wrote:
if you are having these problems and limited to one CAMO, I feel for you.
We have ar least 6 within an hours drive of my home. We have several Part 66 engineers on our airfield alone, some ex military. We are obviously lucky.
@gallois Perhaps I was not clear. We have no problems whatsoever and are delighted with our CAMO. There is indeed plenty of choice of CAMO in the area, but sadly not one at our field because the field/club/engineering is all under the same ownership (which in many other ways is a good thing) and they do not want to look after a Socata.
My complaint is a philosophical one rather than a practical one, which is that we are all-but-forced, by circumstance, to employ a CAMO. The sector is stitched up quite well to limit one’s ability to use a freelancer.
Airborne_Again wrote:
So we should not tolerate it.
Which is an excellent philosophical viewpoint, one that I wholeheartedly support. However, one’s ability to actual do it (and remain flying) in this instance is quite limited.
alioth wrote:
It is our duty to reply to these consultations and remind the regulators that regulations do NOT exist to prop up business models
Oh but they do. The whole system is based on this.
I am about to drop a couple of hundred quid in total (including £8 to the CAA for the privilege of filling in an online form myself) on having a chap check the presence of some paperwork and recognise that I don’t appear to be unwell. This whole system hangs around (and will always hang around) because folks make some nice extra money from it, so why should maintenance be any different?
