Part-ML and inflating CAMO cost

I’m billed by my CAMO an hourly rate based on time spent, the same rate as their mechanics. ARC renewals are flat-fee of 395 EUR. The hourly time spent is about one or two hours per year (for AMP annual review), except for special events. The 2018 ARC extension was 270 EUR and the 2019 extension was 395 EUR. I suspect this “works” economically only because they are also my maintenance facility.

Special events is stuff like:

• Work performed to change registration… was a real bill, four digits. The CAA was very thorough and had many requests (and then billed their time for that, too). I was in copy of the requests of the CAA.
• When I specifically asked them to change the maintenance program to make use of new possibilities introduced by Part-ML, they spent a few hours on that, and that led to a bill of a few hundreds of EUR. One-time, not recurring.
• When the CAA asked them to sign a new form, and send a copy of the maintenance program, that led to about 100 EUR bill. One-time, not recurring.

It has less to do with Part-ML and more that, after years behind the other parts (OPS), continuous maintenance organizations now need to prepare safety and compliance management systems (that reflect their authority and liability).

I can confirm

2015 SR22 CAMO 700€ pA
2021 SR22 CAMO 2500€ pA (the „we don’t want your Business price).

Some CAMOs benefit from scale-ability by managing lots of similar types.
Eg *RGV UK is <1000 gbp pA – sadly not EASA anymore
*these guys have fair prices https://www.wartungsbetrieb-krems.com/index.php?id=2

However, some CAMO might offer a lower price especially when it doesn’t prepare a customized AMP for you, and instead applies ML.A.302(e) by simply following the OEM AMP. Something you can do as an owner just as well.

I believe a viable course of action if you need a CAMO is

• either find a 145 that also does CAMO and instead of charging extra for it, they will include it for you as a MX customer.

• find an engaged CAMO/CAO and offset the cost by going Part-66

@PetitCessnaVoyageur I would talk to another CAMO or if you have a good maintenance shop, ask them. Under French law I would have thought that the CAMO would need to be able to justify a 100% price hike and show how part ML is the cause of extra work.
Secondly I would drop an email either to your local DSAC or OSAC to check the answers to your other questions. It would be better if you could go and see them in person, but sadly, at the moment because of Covid they are not making any/many rendezvous. But I still found them very helpful.
The ATO to which you rent should also know the answers but I can’t see anything in the regulations which stop you doing what you want to do.

lionel wrote:

I’m billed by my CAMO an hourly rate based on time spent,

That is an interesting concept for a CAMO that I honestly never have seen til now. Therefore one question: How do they do their “proof of work” for the hours they work on your plane?

Many of the tasks of the CAMO are more “fixed cost” across multiple planes (e.g. monitoring ADs of airframe, engine, etc.) and are heavily software driven (with significant license fees for this software with sometimes “per airplane under management” license models). This is hard to express in hourly rates.

I’m still at about 700EUR/yr with no significant changes in recent years

PetitCessnaVoyageur wrote:

The introduction of part ML (ELA2) regulation this year, was said by the CAMO to have increased massively the paperwork.
As a consequence, the yearly subscription have gone from 750€ without tax last year, to 1300€ w/o tax this year.
This is a huge increase: have you faced such things ?

We’ve seen a similar increase (+60%). Our CAMO says that they had to spend a massive amount of time updating their own manuals to comply with part-ML, but I don’t know if the paperwork involved with continuing airworthiness as such has increased.

Malibuflyer wrote:

That is an interesting concept for a CAMO that I honestly never have seen til now. Therefore one question: How do they do their “proof of work” for the hours they work on your plane?

I’ve found the number of hours reasonable, so I have not challenged them deeply on that. They used to have several of the same plane type under maintenance, now apparently I’m the only one. Something like 0.5 to 1.5 hours for annual review of the AMP. When I changed avionics, a bit of time to update the AMP with the ICA for these new avionics. Having seen the requests of the CAA, I’ve seen the complexity and the sheer amount of work just to fill in the tables requested by the CAA, and the number of hours were reasonable.

I’ve started on 700EUR/yr now, new contract 2021. This includes paperwork and ARC. First time was an extra fee of 200 for amendments to the AMP (price without tax), including the Pilot/Owner parts which are now possible.

I think it’s ok. It is as always, in the beginning you have a bit more trouble with the customer ( = me), until all is settled, but when things are running it’s a printout from the program about the ADs and a check / update if ARC may be issued.

I have set a personal cost limit, but so far I’m glad to have someone at my side to keep the plane up in the air and to learn how to manage a plane and work packages and so on. If it keeps like this I’ll stay in CAMO. I want to keep the plane flying, because there are a lot of planes which have been grounded for one reason or another, and the price for the CAMO is just so cheap in comparison to what it had been say 10 years ago.

Maintenance:
Part-ML is for planes <2730kg that do NCO, it doesn’t imply a requirement for CAO/CAMO, it just gives the voluntary option to use those = „controlled environment“.

Planes >2730kg can be NCO (eg SET), but then require Part-M. Different ball game.

Operation:
Commercial operation („CAT“ AOC) requires Part-M, not Part-ML. Commercial = in exchange for money/goods where the operator is NOT under control of the customer = the person sitting in the plane doesn’t own it (eg a pax flying an airline, a businessperson chartering a jet, a company ordering some aerial survey data etc..).

Exception: Flight training can be for profit, however it is still deemed Part-NCO on single pilot SEP, MEP & SET.
For profit DTO/ATO require a CAMO/CAO contract (controlled environment).

For 99% of EuroGA readers:

Part-ML = pick one

1) you can set up and be liable for your own AMP, maintenance and airworthiness, which needs to follow at least the EASA MIP, the specific type‘s airworthiness limitations and ADs. Everything else is up to you to follow or not. A „mandatory service bulletin“, well that’s just verbiage, for you it’s optional.

2) You can also elect to contract a CAMO/CAO („controlled environment“), then they bear the liability for maintenance/airworthiness = they have a say in and approve the AMP and they give the workorders for maintenance in the shop.

3) Or you follow the manufacturers (DAH) AMM by the dot. You’re still liable for maintenance/airworthiness (eg tracking ADs), but what more than following EVERY instruction by the manufacturer could you have done?

Obviously this is very simplified. PM me and I’ll explain it on the phone.