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ELA1 / ELA2 maintenance (merged)

@achimha – where is the place (company) you get your annual for your G-reg in? IOW, can CAMO for one EASA reg easily be located in another country?

tmo
EPKP - Kraków, Poland

My CAMO and Part 145 (located in the same building, owned by the same person, manned by the same staff) are in Bavaria. For an EASA aircraft, you can use any CAMO, any Part 145 and any freelance Part 66 that has an EASA license. They can be in 2 different countries with the registration of the aircraft being in a third. The beauty of the EASA system. My shop does around 50% foreign aircraft registrations in my estimation so this system is actually very business friendly. I know several German aircraft operators that go to the Czech republic because the hourly rate there is lower and the Czech Republic has a very long tradition of aviation and good workmanship.

The only caveat is that your CAMO (not necessarily the Part 145) should be familiar with the CAA of your country of registration. The forms and procedures are slightly different in every country. Sometimes the CAMO might not be interested in handling your case because it would involve dealing with a previously unknown CAA. I actually brought the first G-reg to my CAMO (convincing them that more would come to the Cessna SID issue with LBA at the time) and there was a certain learning curve with some friction but now it’s entirely smooth.

Like Airborne_Again said — I’d never separate the CAMO from the Part 145. Two people that have to make a point about who’s smarter, potential CYA behavior, etc. No need for this artificial complication in my view. For GA aircraft, the CAMO/Part 145 distinction should be completely invisible to the operator.

I’d never separate the CAMO from the Part 145.

I have zero problems with that. The CAMO sends the work order to the shop, they complete the checklist ready, Since both the CAMO and the SC are Cirrus Service Centers it is completely clear what has to be done. Zero problems in 4 years.

But of course it can be a problem when the constellation is different.

I believe the badmouthing of CAMO among GA pilots is mostly undeserved

That misses the main point however…

Administrator
Shoreham EGKA, United Kingdom

tmo wrote:

IOW, can CAMO for one EASA reg easily be located in another country?

Yes; our plane is french registered, based in Germany and has a dutch CAMO.

EDL*, Germany

Peter wrote:

However, getting your maintenance programme approved by the CAA is not at all the same thing as the really big thing in ELA2

Why do you keep referring to (presumably) Part-M Light as “ELA2”? ELA1 and ELA2 are classifications for the purpose of Part-21 (design). They were introduced to allow some alleviations for manufacturers at that end of the scale.

Part-M was adapted in two stages — the first stage, a modification of Part-M and already in law, was chosen to apply only to ELA1. But Part-M Light when it eventually comes will apply below 2730 kg — more than ELA2.

achimha wrote:

Like Airborne_Again said — I’d never separate the CAMO from the Part 145. Two people that have to make a point about who’s smarter, potential CYA behavior, etc. No need for this artificial complication in my view. For GA aircraft, the CAMO/Part 145 distinction should be completely invisible to the operator.

I very much agree with this. I have similar arrangement with my Part 145/CAMO that you described in this post and so far I have been very happy with it. I can’t imagine doing it any other way.

Hajdúszoboszló LHHO

Why do you keep referring to (presumably) Part-M Light as “ELA2”? ELA1 and ELA2 are classifications for the purpose of Part-21 (design). They were introduced to allow some alleviations for manufacturers at that end of the scale.
Part-M was adapted in two stages — the first stage, a modification of Part-M and already in law, was chosen to apply only to ELA1. But Part-M Light when it eventually comes will apply below 2730 kg — more than ELA2.

OK; true. I tend to view this stuff in the narrow manner of whether totally-freelance maintenance is or will be permitted – because that is where the biggest benefits will arrive for GA owners.

All the time one is tinkering with procedures implemented by companies nothing will change because a company has to make the same money no matter how they shake around, so if you make one function simpler they will just load up costs onto another one, so e.g. a TB20 basic Annual will always be 2.5k+VAT (that’s the “75% of what the RTS says was done was actually done” case ). The CAMO issue is a side issue, for this reason.

One may as well debate whether a school should charge for airborne time, or brakes-off to brakes-on. They have to recover their costs, plus a margin, so in the former case they will just load it onto the hourly rate.

I can see that my view on this topic is inflammatory to the industry, because freelance maintenance in the vital 1200kg-2000kg band has the potential of damaging some % of it.

Administrator
Shoreham EGKA, United Kingdom

One of the assumptions behind lowering the cost of maintenance was that it would encourage more flying, so in the end the maintenance companies would not lose out at all. In theory this makes sense.

Private field, Mallorca, Spain

This stuff is driving me nuts already. I have my Mooney 3 months and still haven’t got maintenance organised. I gave the documents to the Part 145 shop at my base and they said they’d do the maintenance but recommended keeping the CAMO in France because they didn’t have a great handle on the quirks of the French system or the language.
They said they would need some documents (maintenance program and approval from French CAA) from the CAMO which is the same place I bought it from in France. I was going to let him continue to do the CAMO and issue the ARC etc but he hasn’t been responsive on email.

He had said previously that he would be willing to do this, but someone who drops in and out of communication on email (and also doesn’t speak much English) is making me think twice. Annual isn’t due until February and ARC until June, so at least I have a little bit of time.

EIMH, Ireland
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