I’m in the process of transitioning from LAMP to part-ML. My maintenance shop and I are on the same page, so I don’t expect much trouble.
I’m transitioning from Part-M with CAMO to CAMO-approved Part-ML AMP. The process is rather smooth with respect to all the deviations from DAH ((S)TC holder) official maintenance programs and ICAs that are considered, except for one item that led to a lot of discussion. While being aware that I could switch to an owner-declared AMP in case we didn’t get to an agreement, I found it useful, to enlighten my decision, to challenge the CAMO, make them justify their disagreement and take several opinions and explanations, including from the DAH, the CAMO, other Part-66 mechanics with experience with the airframe or part in question, etc.
lionel wrote:
While being aware that I could switch to an owner-declared AMP in case we didn’t get to an agreement
Not if you want to keep your CAMO. The option of having a CAMO managing an owner-declared AMP disappeared with part-ML.
What is the status of the inspection/maintenance items that are not mentioned at all in the MIP in the AMC? Does that mean one can not do them at all (if one, in good faith thinks they are not necessary) or more rarely than “manufacturer recommendation” or “12 month / 100 h” (if one in good faith thinks they are not useful that often), or does that mean that one has to follow the manufacturer recommendation, unless one has hard data / other external source to justify a deviation?
Concrete examples are the battery capacity test for aeroplanes, the fuel injector of a an injected piston engine or the cleaning of the fuel nozzle of a turbine engine. My CAMO argues that one has to stick to manufacturer recommendation (unless hard data / component manufacturer maintenance manual / similar external source as justification), but I (try to) argue these be set at whatever sounds technically reasonable based on one’s own judgement, because the law doesn’t require them at all.
E.g. the manufacturer of my battery recommends a capacity test every 6 months until down to 90% capacity then every 3 months. I think at the annual (every 12 months) only is very reasonable, at least until the battery becomes marginal (at which point I would replace it pre-emptively anyway).
Weirdly, the AMC MIP for ELA powered sailplanes includes a battery capacitance test, but not the one for aeroplanes.
lionel wrote:
What is the status of the inspection/maintenance items that are not mentioned at all in the MIP in the AMC?
If these items are in the Airworthiness Limitations section of the ICA (Instructions for Continued Airworthiness) for the given type, then they are mandatory, otherwise they are not. However, some items may not be mandatory but still strongly recommended. In particular, Czech CAA issued tables of such recommended items for all Czech-designed aircraft.
lionel wrote:
Weirdly, the AMC MIP for ELA powered sailplanes includes a battery capacitance test, but not the one for aeroplanes.
This is perfectly logical: the mission profile of powered sailplanes includes soaring with engine off, when battery is not charged and serves as the sole source of power. For aeroplanes, the battery only remains the sole source in emergencies.
Ultranomad wrote:
This is perfectly logical: the mission profile of powered sailplanes includes soaring with engine off, when battery is not charged and serves as the sole source of power. For aeroplanes, the battery only remains the sole source in emergencies.
I see. Thanks.
From here
Peter wrote:
On EASA reg the 50hr is mandatory; on N-reg it isn’t so while an oil change at least needs to be done for obvious reasons, you have flexibility as to when.
A 50 hr-check is not mandatory on EASA reg, just as a CAMO is not mandatory on EASA-reg. And, as UdoR writes, if you want a 50 hr-check you can do it yourself,.
A 50 hr-check is not mandatory on EASA reg
That cannot possibly be the whole story!
I have resigned myself to the fact that I won’t be flying any further afield than Scotland (or maybe the Channel Islands) until travel rules are largely back to what they were pre-pandemic.
I am planning a ~20hr trip to Italy and Croatia and will take the hit on the return quarantine, which AIUI is 5 days if you do the tests.
Peter wrote:
That cannot possibly be the whole story!
Well, if you choose to use a CAMO, then the CAMO may insist on a 50 hr check if the manufacturer recommends one. EASA doesn’t require it and you don’t need to use a CAMO. EASA does require a 100 hr/annual check. It’s all in ML.A.302 including AMC/GM.
That cannot possibly be the whole story!
It is if you refer to AMC1 ML.A.302(d) that defines an acceptable MIP for airplanes below 2730kg MTOM.
