Peter wrote:
There is no such thing as “non-profit”; every operation has to make enough return to continue operating, and the impossibility of defining this (short of running a club/school as some form of a Registered Charity like they do in e.g. Italy which then causes other problems e.g. blocking the club/school from selling fuel to foreigners visitors, forcing them to do it under the table, for cash payments) is perhaps what allows the UK to avoid implementation.
The “non-profit” concept is well understood. It means that the organisation is not run for the purpose of providing a profit — particularly not to external parties such as shareholders. (And also that it actually doesn’t, of course.) That doesn’t mean that there can’t be an excess which is reinvested.
In Sweden there is the well-defined legal concept of an “allmännyttig förening” — literally “public benefit association”. Virtually all flying clubs fall into this category. This is not something you apply to be, but something you simply are (or not) depending on your activities and how your statutes are written.
What is the exact wording of the regulation?
Unfortunately, part-M is the worst written of all the EASA regs and the differences between commercial and non-commercial ops are spread all over. But I can give you one example:
M.A.803 Pilot-owner authorisation
….
(b) For any non-complex motor-powered aircraft of 2 730 kg MTOM and below, sailplane, powered sailplane or balloon, that are not used in CAT, or not used in commercial specialised operations or not used in commercial ATO operations, the pilot-owner may issue a certificate of release to service after limited pilot-owner main tenance as specified in Appendix VIII
…which means that pilot-owner maintenance is possible for aircraft used by a non-commercial ATO. (Note that “non-complex” means something entirely different here compared to FAA regs.)
I think the main reason it hasn’t been challenged is that the CAA state that if on the SDMP then the next check is in 100 hours or annual.
So some schools will have to pay for an annual check every couple of months.
Bathman wrote:
I think the main reason it hasn’t been challenged is that the CAA state that if on the SDMP then the next check is in 100 hours or annual.
How is that different from an approved maintenance programme? All our SEP Cessnas and Pipers on approved programmes have 50 and 100 hr checks according to the manufacturers instructions.
Sorry I worded it badly. Every 100 hours you have to have an annual.
For private owners that’s probably not a problem but for a flying school whose aircraft fly 600 hours 6 annuals a year is going to cost a fortune.
A service every 100hrs, approaching an Annual in scope, is what you have in the FAA system, for planes used to train people for money.
I’m of the understanding that in FAA land aircraft with a high utilisation can move onto a high utilisation maintainace program. Which doesn’t involve an annual every 100 hours.
I don’t actually know if this is true but that’s what my maintenance company tells me.
There is the rolling maintenance programme (generally called “programme”) which is used for airliners, and some stuff below that e.g. higher-end bizjets, but info I have from the USA is that nobody has got the FAA to agree it on say a TB20 or a Cirrus. They have done it on stuff like Cessna twins used for medical evacuation. It avoids an Annual at a fixed date which creates a long downtime.
Obviously, rolling maintenance requires a continuously available engineering facility, and usually it involves working at night. For example nearly all short haul airline stuff is done at night. The busy US schools also maintain at night; where I did my IR (KCHD) everything was done at night. Looking at the typical UK GA maintenance scene I am not sure they would be toooo willing 
Bathman wrote:
Sorry I worded it badly. Every 100 hours you have to have an annual.
This is were I don’t follow you. From my perspective there is no difference between 100 hr service and “annual”. The aircraft we have on approved maintenance programmes don’t have annuals — they just have 100 hr services. For me, an “Annual” is something you do if the aircraft flies less than 100 hrs/year.
Peter wrote:
There is the rolling maintenance programme (generally called “programme”) which is used for airliners, and some stuff below that e.g. higher-end bizjets, but info I have from the USA is that nobody has got the FAA to agree it on say a TB20 or a Cirrus. They have done it on stuff like Cessna twins used for medical evacuation. It avoids an Annual at a fixed date which creates a long downtime.
Cessna has something similar — for more recent aircraft at least. Cessna 172R/S can be maintained using a progressive service programme with maintenance every 50 hrs. Certainly nothing on a specific date every year.
One would therefore think that this would have been widely adopted, but has it?
