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ELA1 / ELA2 maintenance (merged)

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

As I often say, the biggest benefit – to a specific group or pro-active aircraft owners – is the avoidance of any maintenance company. Using a freelance EASA66 engineer saves a few k right away, and he cannot pass the buck and hide behind a “company approval” so quality and customer service should improve.

This is not to say there aren’t very good companies out there, and they should have enough business because most owners don’t want to get involved at all and those that do cannot because they aren’t allowed to do any work in their hangar.

Administrator
Shoreham EGKA, United Kingdom

Michael wrote:

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?

A qualified guess is YES as long as we are talking private operations. For commercial operations a Part-145 workshop would be required.

Bathman wrote:

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

That depends a bit on the member state unfortunately. In Sweden we now have a statement from the CAA that flight training at a flying club is non-commercial.
When the new rules come into play, Part-M Light, it will be a lot more obvious that aircraft for flight training can use the full set of alleviations.

ESSZ, Sweden

Fly310 wrote:

That depends a bit on the member state unfortunately. In Sweden we now have a statement from the CAA that flight training at a flying club is non-commercial.

It’s clearly defined as non-commercial in current EU law. No discretion for CAAs.

Mooney_Driver wrote:

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…

Yea they would make sense, but when they quoted €2.5k + VAT for a pre-purchase inspection (1k docs, 1.5k ‘non exhaustive’ technical) they moved to the back of my mind somewhat! Hopefully the former owner will come through. He did send me a cost breakdown for his services and I asked him at the time of purchase, but has been hard to get a hold of since.

EIMH, Ireland

achimha wrote:

It’s clearly defined as non-commercial in current EU law. No discretion for CAAs.

In some places, Part-M mentions “commercial ATO” but never “non-commercial ATO”. For most people the mention of “commercial ATO” implies that an ATO can be non-commercial, otherwise the qualification would not be needed. However, there was a faction in the Swedish CAA that held the view that flight instruction is by its very nature commercial. Fortunately that faction lost the internal battle.

One reason for this view could be a mindset relating to previous national regulations — the important distinction maintenance-wise was not between commercial and non-commercial ops, but between operations needing approval and operations that didn’t. Since an ATO (and the RF before that) requires approval they had to use the same maintenance regime as AOC ops.

(It is interesting that AFAIU this faction was found among the people overseeing maintenance, not among the people overseeing ATOs…)

Last Edited by Airborne_Again at 22 Oct 19:06
ESKC (Uppsala/Sundbro), Sweden

If my aircraft was being managed by a CAMO in France, should it be possible to get the Maintenance Program and approval cert from OSAC? The new CAMO said it would make life much easier for them.

I found this word document which my pigeon French and Google Translate seem to suggest can be used to request any missing documents upon change of ownership.

[ local copy ]

EIMH, Ireland

I wonder what the latest UK situation is on this?

I spoke to one EASA66 guy yesterday and even on ELA1 (<1200kg) you reportedly have to involve a Subpart-M or G (I can’t remember which) every 3rd year. All the rest of the time the freelance engineer can do the whole lot.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

I spoke to one EASA66 guy yesterday and even on ELA1 (<1200kg) you reportedly have to involve a Subpart-M or G (I can’t remember which) every 3rd year. All the rest of the time the freelance engineer can do the whole lot.

Every 3rd year is Part M subpart G, i.e. CAMO. This is about reissue of ARC (as opposed to extension, which can only be done twice, hence every 3rd year), and it’s a pure paperwork exercise, all the physical maintenance can be done by a freelancer.

LKBU (near Prague), Czech Republic

zuutroy wrote:

If my aircraft was being managed by a CAMO in France, should it be possible to get the Maintenance Program and approval cert from OSAC? The new CAMO said it would make life much easier for them.

If you PM me your email address, I will send you a copy of our approved Aircraft Maintenance Programme for our F registered Cirrus Sr20, you could use that for the basis of your maintenance program plus the email address of the person within OSAC we dealt with…..

EDL*, Germany

Every 3rd year is Part M subpart G, i.e. CAMO. This is about reissue of ARC (as opposed to extension, which can only be done twice, hence every 3rd year), and it’s a pure paperwork exercise, all the physical maintenance can be done by a freelancer.

How much should a Subpart G charge, and do they need to do any due diligence whatsoever (i.e. see the aircraft)?

Administrator
Shoreham EGKA, United Kingdom
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