boscomantico wrote:
The owner, however, is fully responsible for any deviations from the DAH recommendations” What does that actually mean? Responsible for what? And to whom?Exactly what I thought, it will be interesting to observe the evolution of insurance rates for plane owners. Hopefully it can go down a little for the manufacturers.
Maybe being a bit vague is done on purpose? If they had been more specific, maybe this regulation would never have been passed? I am not a lawyer, but I can see some future courtcases revolving around this point, so from the regulator’s point of view, it might make sense to include this wording.
What is the latest on ELA1/ELA2 and specifically when is it likely that an EASA-reg TB20 (1400kg) could be maintained by a freelance EASA66 engineer, away from any company?
In my ELA1 maintenance program it is stated that Part66 can do annual on aircraft.
Arc needs to issue someone else (institution), but work on aircraft, including annual can be done by freelance Part66:
Arc needs to issue someone else (institution), but work on aircraft, including annual can be done by freelance Part66:
Yes; that has been the position for years.
The basic point is that a “company” cannot presently be avoided, in this weight range. If one could use a freelance engineer to do everything, one would make big savings, but we aren’t there yet, hence my question above:
“What is the latest on ELA1/ELA2 and specifically when is it likely that an EASA-reg TB20 (1400kg) could be maintained by a freelance EASA66 engineer, away from any company?”
I wonder if anyone knows the likely timescale for ELA2.
As is often the case, I am asking this question on behalf of another aircraft owner, not to fight with people like Jesse who answer questions which have not been asked but answer them in a way which sounds like they are answers to the questions which were asked…
ermajn wrote:
but work on aircraft, including annual can be done by freelance Part66:
That’s my understanding too – and anecdotally I hear plenty of CAMOs are happy to act just as CAMOs.
Maybe I’ve been lucky to find a maintenance setup that is good and that I trust and which does both CAMO and maintenance work.
Peter wrote:
So, of your 3 methods for doing the ARC, #1 is the CAMO, #2 doesn’t exist for the stated question, and #3 doesn’t exist for practical purposes.
Peter wrote:
The basic point is that a “company” cannot presently be avoided, in this weight range. If one could use a freelance engineer to do everything, one would make big savings, but we aren’t there yet, hence my question above:
Although not true, what kind of savings are you thinking of? For sure it wouldn’t be anywhere near 1000 Euro, if the freelance engineer does a proper job. You must understand that an ARC renewal inspection is not the annual inspection of your aircraft. As such the annual inspection, and all other inspection, repairs etc could be done by Part 66.
jwoolard wrote:
anecdotally I hear plenty of CAMOs are happy to act just as CAMOs.
This is true, and I know many that do use it. Use of the CAMO can be for two occasions, ARC renewal (not all CAMO’s), or keeping all the paperwork, and organise all maintenance. There isn’t an requirement to use a CAMO for either of the two.
There are also CAMO’s performing CAMO work, as in managing aircraft, without CAMO contract, where the owner is responsible.
OK; the above is mostly more of the usual fuzzy goalpost moving.
what kind of savings are you thinking of? For sure it wouldn’t be anywhere near 1000 Euro
As I said earlier, it depends on how involved the owner is. Uninvolved owners will save little because the business will find ways to recover the same income, so any loss of CAMO fees will get billed elsewhere. But an involved owner can make big savings. For example I have just replaced all the firewall-forward hoses for £500, plus £500 for one metric one. One TB20 owner emailed me recently that his company billed him £2500 for the hoses, all purchased from Socata. That’s just the start. The freelancer will also cost a lot less per hour than a company rate – probably about 50%. Also the freelancer doesn’t want to make a margin on the supply of materials, because to do so will just push him into mandatory VAT registration, so he doesn’t really want to buy anything (other than trivia like exhaust gaskets).
Obviously a “company man” will denigrate this route. But smart owners will love it. When we get ELA2, it will be great for GA – for those owners who are switched on. The others… will pay like they do now 
Does anyone know the likely timescale for ELA2?
Peter, what you describe as the situation for an “involved” owner is standard practice for aircraft owners in the US. Most aircraft owners except a very narrow fraction numerically are not wealthy, and a good number of those who are wealthy got that way by not wasting money. Very few people drop their aircraft off for service at a facility and wait for a phone call. Virtually everybody buys their own parts directly, very often from out of state to avoid sales tax. The work might be done in the owners hangar or the mechanics hangar, but if it’s the latter it’s often the mechanic’s personal hangar and his own plane gets pushed out on the ramp while a customer plane is in the hangar. It’s obviously a market situation that has evolved to eliminate every possible overhead and tax cost.
Peter, I can only offer what the Dutch CAA told me a few months ago: “expected before the end of 2017, and basically the same rules as for ELA-1”
Peter wrote:
As I said earlier, it depends on how involved the owner is. Uninvolved owners will save little because the business will find ways to recover the same income, so any loss of CAMO fees will get billed elsewhere. But an involved owner can make big savings.
I don’t understand….. Really…
So this company will bill you elsewhere, because they lost on CAMO fees? You just mentioned the only “useable” route is to use CAMO. Even that that is not true, if you would do that, you can have the ARC only be the CAMO (if it hase ARC privileges), and have all other work, including annual inspection done by Part 66.
Peter wrote:
For example I have just replaced all the firewall-forward hoses for £500, plus £500 for one metric one. One TB20 owner emailed me recently that his company billed him £2500 for the hoses, all purchased from Socata.
What stops you, or the one on behave you write all of this, from doing the same under EASA?
Peter wrote:
The freelancer will also cost a lot less per hour than a company rate – probably about 50%. Also the freelancer doesn’t want to make a margin on the supply of materials, because to do so will just push him into mandatory VAT registration, so he doesn’t really want to buy anything (other than trivia like exhaust gaskets).
I don’t understand why there would be any difference between your freelance A&P or your freelance Part 66. It can even be the same person. Why would he charge you more for these hoses + mounting under FAA then doing the same work under EASA? All totally legal?!
So where are you going to massively safe money, over the current legal situation, even where you use the CAMO for ARC? All other works is identical!?
