ELA1 / ELA2 maintenance (merged)

I’ve just caught up on this and quite frankly find it extremely confusing.
I’m considering purchasing what would be an ELA2 aircraft, ideally it would be N reg as that is what I’m used to and seems a much more sensible system. However, there are more of the type I’m looking at for sale on the G reg rather than N at the moment. If there was an option for it to be maintained with my involvement, a freelance engineer and no other company that would be very tempting.

Last I heard (UK FTN newsletter I believe) is that ELA2 and the “totally freelance” option has been delayed till 2019. The reason cited was technicalities with the drafting of the reg. There would have been massive complaints from the maintenance business, however.

N-reg remains the present solution to this – with the usual drawbacks

• FAA papers
• FAA medical (can be harder than EASA medical)
• need an A&P for maintenance (or to supervise owner maintenance, etc) and an A&P/IA to inspect and sign the Annual
• need an FAA 145 company every 2 years for the €500-€1000 altimeter check
• in Europe, difficulties doing non-STC-backed mods
• can’t park long-term in Norway or Denmark
• will eventually need duplicate EASA papers and medical
• a few other small ones

Two remarks :

FAA Medical for 61.75 piggy-back operators ? I was under the impression that any ICAO Class 2 Medical exam was legal .

“FAA papers " – Are you referring to FAA Registration “papers” and the need for non-US citizens to use a Trust ?

Yes the EASA medical is ok for 61.75.

Pilot licenses, ratings and the trust.

All the usual stuff

That is for N reg, not EASA reg which is covered by the ELA / Part M regs.

I have to admit that I’m abit clueless with EASA Mx regs, so here’s a Q:

Under the current EASA regs, can an “independent” mechanic that holds say B1 & B2 licences perform Mx work on an EASA reg’d aircraft as long as there is a CAMO managing the work ?

For non commercial ops, non-complex aircraft , there is no need of a CAMO. The owner can be the one who manages the aircraft airwothiness.
Regarding maintenance work, a B1/B2/B3 can release to service any work on an ELA1 not involved in commercial operations (within their license privileges).
For aircraft with MTOW>1200kg, only non-complex tasks can be performed by independent part 66 staff.
Complex tasks are defined in COMMISSION REGULATION (EU) No 1321/2014 Appendix VII.

And would I be correct in thinking that Flying Instructin is non commercial operations?

Guillaume wrote:

For non commercial ops, non-complex aircraft , there is no need of a CAMO. The owner can be the one who manages the aircraft airwothiness.
Regarding maintenance work, a B1/B2/B3 can release to service any work on an ELA1 not involved in commercial operations (within their license privileges).
For aircraft with MTOW>1200kg, only non-complex tasks can be performed by independent part 66 staff.
Complex tasks are defined in COMMISSION REGULATION (EU) No 1321/2014 Appendix VII.

Then there’s not much of a gap from the existing regulation and the proposed , except perhaps for “commercial” ops ?

zuutroy wrote:

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.

Mooney and France would suggest to use Troyes Aviation. They are a MSC and CAMO, they do know Mooneys and the French system.

I can see the use of CAMO in that situation, where you would have to deal with a CAA in a foreign language and different procedures, even though under EASA procedures SHOULD be stanardized but obviously are not…

The proposed regulation will allow :

• Maintenance program to be declared (and no longer approved)
• Deviations from DAH / TCH maintenance recommendations under owner responsibility.
• Airwothiness review by independent Part 66 for aircraft up to ELA2 (currently limited to ELA1 not involved in commercial ops). Current regulation requires either an airwothiness by the national authority or a CAMO+ (CAMO with airwothiness review privilege) for ELA 2.