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ELA1 / ELA2 maintenance (merged)

I have a hopefully relevant data point, for a freelance engineer doing what is today CAMO work.

For a TB20, it is 10-15hrs one-off and then a couple of hours each Annual. A TB20 is relatively free of ADs however. For some other types it could be 2x or 3x that. One extreme example given was the Bulldog which is riddled with ADs.

This guy uses a computer package which costs about £150, to track the schedule.

I don’t know what EASA does about SBs… always been a hot topic.

Stuff in Chapter 4 is mandatory regardless and e.g. an SR22 has a number of items there e.g. the chute life limit.

Obviously a user who doesn’t want to get involved needs to stay with the company route, and continue to use a CAMO.

Administrator
Shoreham EGKA, United Kingdom

http://ad.easa.europa.eu/ is labelled as a “List of Mandatory Continuing Airworthiness Information” so I guess whatever is mandatory is there, no?

tmo
EPKP - Kraków, Poland

tmo wrote:

http://ad.easa.europa.eu/ is labelled as a “List of Mandatory Continuing Airworthiness Information” so I guess whatever is mandatory is there, no?

No. The link goes to a list of Airworthiness Directives (ADs). These are mandatory instructions issued by an aviation authority to address critical issues that have come up after type certification.

There can also be mandatory maintenance instructions given by the type certificate holder. Those will not show in an AD list.

ESKC (Uppsala/Sundbro), Sweden

There can also be mandatory maintenance instructions given by the type certificate holder.

What would be mandatory if

  • it is not an AD and
  • does not appear in Chapter 4 of the MM?

SBs are not mandatory, under FAA or EASA.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

does not appear in Chapter 4 of the MM?

That’s what I meant. The TC holder publishes the MM, right?

ESKC (Uppsala/Sundbro), Sweden

Sure, but unless it is under airworthiness (chapter 4) it is not mandatory for maintenance (as far as the MM itself goes – the maintenance still needs to be done to some schedule, in EASA-land).

Just because the aircraft MM says something has to be done doesn’t mean it legally has to be done to maintain airworthiness. If that was the case, every GA plane flying would be illegal. Almost nobody does the full MM (on piston aircraft; on turboprops it’s different and owners usually pay readily any size bill).

MMs are packed with stuff, a lot of which is just revenue generation.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

Sure, but unless it is under airworthiness (chapter 4) it is not mandatory for maintenance

Again, that’s what I meant.

tmo asked if the AD list on the EASA website was the complete list of mandatory items. I explained that it was not without going into any detail because no detail was necessary to answer the question.

ESKC (Uppsala/Sundbro), Sweden

I was doing some admin (thread merging) and though the first post here is an interesting point of view, and fortunately not from me because I would nowadays be hung drawn and quartered if I wrote that

The second post is also interesting and I wonder why, if it is so trivial to avoid a CAMO, one of the most prominent German posters here over the years uses a UK CAMO for his G-reg SR22

Administrator
Shoreham EGKA, United Kingdom

I think the post you mention is:
– 4 years old, in the 4 years a lot has changed for the better for light GA in EASA
– shows that, as with all business partners, one should choose their CAMO carefully and with due dilligence

Case in point – a few years ago people would move their planes away from SP-reg to be allowed to go past TBO on their engines (or, I guess, from G-reg to avoid time-based forced prop overhauls); a few weeks ago I talked to some owners who have the 12 years coming up on their engine, and their CAMO is designing an non-intrusive inspection (borescope, oil analysis, etc) regiment that will allow them to hopefully have them continue to run things as if nothing had happened. Yes, there is paperwork involved, and thus cost, but they chose to go with a CAMO because their time and peace of mind is worth it to them, and I understand that attitude. Sure, it would be nice if such a procedure was “approved by default” but I think they would still ask their CAMO to manage the process, just because it is easier and more convenient for them. Also, all the work on that plane, apart from avionics issues, is, as far as I know, done by an effectively freelance Part-66 guy, whose only relationship with the CAMO is that they “approved” him for maintaining the plane. The owners picked the guy and told the CAMO to “approve” him, with no pushback nor alternative suggestions from the CAMO.
I agree, this is all “someone I know” not “I myself” but I have no reason to doubt what I was told, and I do have a horse in the race as a prospective owner wondering if going N-reg is worth it (or if a plane being on N-reg is a plus or minus).

tmo
EPKP - Kraków, Poland

tmo wrote:

Case in point

My case in point would be that I enjoyed adding some time yesterday to my mid-time Lycoming, 46 years since manufacture, never overhauled. It runs well. I might overhaul it some day, maybe before retirement in a few years so I never have to bother with it again.

tmo wrote:

I do have a horse in the race as a prospective owner wondering if going N-reg is worth it (or if a plane being on N-reg is a plus or minus).

On N-register my A&P mechanic and I are friends who maintain our personal machinery seriously, not ‘business partners’ wasting time and money on pointless nonsense unimaginable to the people who designed and built my planes.

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