As per CAP 1454 from the link above.
Under the revised regulation,an owner may develop an AMP for their aircraft that does not require an approval from the CAA.
This is called a SDMP. The owner may decide to base the SDMP on the manufacturer’s recommendations or the EASA published Minimum Inspection Programme (MIP). In all cases the SDMP must not be less restrictive than the MIP
So how did the CAA get involved…
I wonder if somebody asked the wrong question of the CAA. Did you/your maintenance company inform the CAA of your new SDMP, or did you ask them to approve it? Might just be as subtle as that.
Fly310 wrote:
Is it the UK CAA that are not accepting the SDMP?
I would also be interested in the answer to this question.
Many thanks for all your replies but we are still getting no where.
“I am not familiar with the maintenance manual of the Cessna 150 but does it say anywhere in there that you shall do a 50 hour check?
If not, ask them to present some evidence for their statements.”
The CAA don’t work like this. Its not for them to tell us how to comply. Its for us to tell them how we should comply. They just reject it saying it doesn’t comply.
Thank you for the name of the guy at the CAA as this something we may have to look in to.
“an owner may develop an AMP for their aircraft that does not require an approval from the CAA”
My maintenance company are looking at using our SDMP as the basis of there maintenance for all the Cessna’s they have on their books. They also intend to modify this for all the other aircraft types they maintain. Hence the CAA involvement.
“6 year mandatory prop overhaul on a fixed pitch prop? What happened to the proportionate and risk-based approach we were supposed to be getting after the Red Tape challenge?”
“I don’t get it – I thought it was a “self-declared maintenance program”, and the authority is not in a position to reject it”
This is why I’m trying to get hold of someones MIMP that has been approved. As we are being told that we simply don’t understand how this SDMP/MIMP works and that a lot of what is being posted on the internet isn’t actually true. Hence why I’m trying desperately to get hold on an approved maintenance program.
The only headway I have made is having spoken a PA28 operator who wanted to do similar to myself and their maintenance company also wanted to use their SDMP as a template for all the other aircraft that they maintain. They ran into exactly the same problems that we have with the 100 hour check being the same as as a current annual. They have decided to stay on LAMP until September and what and see what happens then.
In light of all the time and effort we have put in and got no where we are thinking of doing the same.
Bathman wrote:
They have decided to stay on LAMP until September and what and see what happens then.
They may not actually be allowed to stay on LAMP until September. From CAP1454:
Note: All ELA1 aircraft eligible to use the SDMP (provided in (EU) 2015/1088) must transition onto a maintenance
programme that complies with Regulation (EU) No 1321/2014 at the next ARC review after 1 October 2016
Very sad to hear the outcome of all this. This is not a correct interpretation nor the intention of the rule. The maintenance company should probably not have contacted the CAA in the first place. If they would like to use this AMP as guidance for the rest of their fleet they can of course present it to the aircraft owner who can then choose to declare/sign it.
I recommend you to contact the guy I mentioned and ask if he can get things sorted. It seems as we, or you, do not have the whole picture of why they are denying you this AMP, which they really cannot do. Are you in direct contact with the CAA or is the maintenance company the middle man in this communication?
The SDMP should just be between you and you maintenance company as per CAP1454..
So who is speaking to the CAA they should not be..
And obviously the person at the CAA seems not to be up to date on the current SDMP process.
Hence i suggest you need to contact Steve Horton…
try emailing him
Also try speaking to Martin Robinson at AOPA UK he may able to help..
Having finally sorted out the maintenance program for my Cessna 152’s we have 100 & 200 hour checks as per the Cessna manuals. The service manual also has component manufacturers limitations such as Lycoming’s 50 hour oil change & some minor SI ’s.
The other thing is you must follow the whole of the Cessna maintenance program so that includes the SID’s checks, these are run on a progressive basis. Also required is the old Radio annual check from LAMP with some items removed to comply with the self testing function of some modern avionics ( IAW the manufacturer data ).
Those above who criticise the prop overhaul limits on the McCauley props fitted to the C150/152 should note that one of the props fitted to my aircraft had cracks propagating from the bolt holes and was scraped at OH, and so IMO is not a check I would like to gloss over.
As my Cessna aircraft are used as trainers on a flying club it is difficult to justify moving too far away from the manufacturers maintenance program but for my privately owned Robin DR400 I can see a number of items such as the landing gear that are over maintained for my long distance touring mission and are clearly intended for aircraft working in the training or glider towing role and so there is room for moving away from the manufacturers data in this case.
Wogglyamp the CAA have said to us (and the pa28 based outfit) that they are happy for us to run on Lamp until everything is sorted out.
FLy310 and Trevor again thanks for replying. I know everyone keeps saying that the CAA don’t need to get involved with this. But they have said that we don’t understand MIMP/SDMP and that people on the internet don’t understand it either. Hence I am trying to find out someone who has done it and get a copy of their SDMP.
Thanks A and C its good to here someone has managed to get it through. My Cessna’s is actually complaint with the Cessna SIDS and it would appear that your 50 hour oil change. 100 and 200 hour checks it what we are after. Fingers crossed we will get there to. But as I have said we are kicking this into touch for a few months. To much work no return.
OK we have made some progress the CAA inspector for the maintenance company we use has said that we are infact correct and that we can self declare our own maintance programme. And if the maintenance company is not happy with the proposed mainteance programme then all they can do is refuse to issue the ARC.
So at last we are making progress and we are going to sit down with our maintenance company and sort something out in the near future.
I would like to use the FAA maintenance regime as its probably the most widely adopted scheme in the world.
Great news @Bathman, good to see that you persistence seems to be paying off.
Later this year, when this new regime is expected to become applicable for my kind of aircraft I intend to go the same route.
I would hate to just having to throw away 2 perfectly working and well cared for engines just because the manufacturer (then Thielert) decided about 15 years ago that you need to do just that after 12 years/1500 hrs.
Plus I expect to save on other stuff, airframe related.
