Part-ML and inflating CAMO cost

Part-M, owner declared AMP existed but approved by authority. Deviations/on condition were wildly varying subject to national authorities.

Irrelevant to this thread though.

Peter wrote:

is not helpful to the reader.

but it is true.

Peter wrote:

Planes such as a TB20 no longer need to be maintained acc. to full Part-M when flown privately. It is now called Part-ML.

That would be false.

Straight from the horse’s mouth:

Article 3 Continuing airworthiness requirements
Regulation (EU) 2019/1383
1. The continuing airworthiness of aircraft referred to in point (a) of Article 1 and components for
installation thereon shall be ensured in accordance with the requirements of Annex I (Part-M),
except for aircraft listed in the first subparagraph of paragraph 2 to which the requirements of
Annex Vb (Part-ML) shall apply.
2. The requirements of Annex Vb (Part-ML) shall apply to the following other than complex motorpowered aircraft:
(a) aeroplanes of 2 730 kg maximum take-off mass or less;
(b) rotorcraft of 1 200 kg maximum take-off mass or less, certified for a maximum of up to 4
occupants;
(c) other ELA2 aircraft.
Where aircraft referred to points (a), (b) and (c) of the first subparagraph is listed in the air
operator certificate of an air carrier licensed in accordance with Regulation (EC) No 1008/2008,
the requirements of Annex I (Part-M) shall apply

In other words: There is no choice. You are doomed to use the lighter rules. Even if that goes against your will.

You are doomed to use the lighter rules. Even if that goes against your will.

This is getting silly. If I ask the maint. company to chuck away my 12 URHM38S spark plugs at each service, just for a laugh, they can’t do it?

Peter wrote:

This is getting silly.

Indeed. You are silly.

If I ask the maint. company to chuck away my 12 URHM38S spark plugs at each service, just for a laugh, they can’t do it?

Sure they can if you ask them to do so. You can even repaint your aircraft after every flight if you wish to do so. And if you are strong enough, you can lift a horse.

Why not go for something proper like

• buying a new TBM (that’s actually and additionally a solution for everything)

• flying it NCO (no need to play cheap like the Citation AOC crowd that charter their planes out to drunk VIPs)

• maintenance according to Part-M, to the highest standard

• which is orchestrated by a CAO (CAMO) to make sure that only the most expensive facility gets to work on the plane

• only interacting with Part-ML planes when you flip them on their backs using your propwash

;)

@silvaire

QuoteWhy then does it need to be orchestrated as a government regulated system versus a commercial service offered by companies to willing buyers?

In the case of eg a SEP, that’s precisely the case. For SEPs, a CAMO is an optional „service“ that can be enjoyed by willing buyers.

Archer-181 wrote:

The very best person to come up with my risk based maintenance programme was myself (who has done 7 years of owner assisted annuals) and also my incredibly experienced Engineer.

I know my Aircraft inside out, I know the environment it lives in (outside). I do realise that not everybody is like me and some Aircraft are far more complex.

My previous engineer was scathing of the CAMO system “a load of old boll**ks as they don’t trust the Engineer to do his job”

Perhaps I have been influenced by these “old school” guys but my real world experience puts me in their camp. I have also heard of a CAMO controlled Aircraft which flew around with Slick mags that hadn’t been inspected for 900 hours. Not something you’d want to do with Slick Mags :-(

Exactly what you mentioned was the problem, and it has been identified and fixed with ML since 24MAR2020.

A_and_C wrote:

There is a difference between theory and practice, in theory EASA offers more freedom to travel but the system EASA introduced increased expense for no safety benefit and so priced many out of the light aviation arena if they can no longer afford the freedoms that EASA offers then the political objectives of keeping the masses in place is achieved.

At the airfield I was based the number of aircraft and flying training companies has halved since EASA oversight arrived and if you asked those who have withdrawn from aviation the over regulation of EASA would be a significant factor in them giving up flying.

Archer 181

Having held a maintenance licence since 1979 I have seen the level of practical knowledge and experience trumped by theory and book learning when it comes to EASA maintenance licence issue. I have a few war stories about those graduates of maintenance schools from Southern Europe who had not the first idea of how to perform basic maintenance tasks, the old U.K. CAA required a technical interview before the issue of a maintenance type rating filtered out those who’s practical experience was lacking.

Fully agree. Which is why ML was a major step forward for light GA.

Peter wrote:

Trust is vested in organisations (not individuals), and similar structures. So we can debate how to best work around these artificially imposed restrictions.

Part-ML allows maintenance (owner, mechanic) and ARC issue by persons, no organizations required anymore.

If you switch your TB20 to EASA reg, I’ll write your AMP for free! Unfortunately, due to brexit, G-regs will not be able to enjoy Part-ML.