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ELA1 / ELA2 maintenance (merged)

tomjnx wrote:

They probably will, but who cares, it is still law even in Switzerland

Apparently the implementation date in Switzerland is the first of February 2016.

However I am with Shorrick, there are multpiple options in the ELA1 texts which will allow the national authorities to bring back their political views onto the owners through the back door, such as via ARC renewal and so on. I’ve come across one formulation which might render ELA1 in terms of TBO and Service Bulletins useless for Swiss registered airplanes.

Das Mindestinspektionsprogramm muss z. B. auch Folgendes berücksichtigen:
“- Instandhaltungsempfehlungen, beispielsweise die Zeit zwischen Überholungen (TBO), die durch Kundendienstmitteilungen, Schreiben und sonstige fakultative Serviceinformationen empfohlen werden.”

This would mean the Swiss CAA will still insist that any recommendation including TBO, Service Bulletins e.t.c. need to be “taken into account” while defining the minimum inspection programme. “Taken into account” in their way of reading so far means: taken as written law. If that is how they will implement it, ELA1 will not really be much use of us here.

There is a good article on this in Pilot und Flugzeug, stating more or less that the formulations in the ELA1 docs are such that unwilling CAA’s will easily be able to bring in all their pet gold plating back via the back door. Let’s hope that is not how it turns out but from recent experience it would surprise me.

Last Edited by Mooney_Driver at 22 Oct 21:35
LSZH(work) LSZF (GA base), Switzerland

The innocent expression “taken into account” was used by LBA to force the SIDs. The Part M law says that manufacturers’ instructions shall be considered in the maintenance programs and their reading of it equals to “fully implement by the letter”.

However, with ELA1 you write the maintenance program and you approve it yourself. The only difficulty is that you have to find a CAMO to issue your ARC based on your program and if they get heat from the CAA, they might not do it.

Last Edited by achimha at 23 Oct 06:25

Exactly Achim. And this leaves the national authorities to poay as they wish. The formulation is interpreted exactly like that in their opinion any recommendation is to be regarded as LAW. Somehow I don’t see how ELA1 will change that.

LSZH(work) LSZF (GA base), Switzerland

achimha wrote:

CAMO no longer required

AFAIK CAMO as such is not required. There should be three options, two include CAMO and the third one doesn’t. In that case an inspector gives recommendation to the NAA (of the state of registry) whether they should issue your plane an ARC. One could say the NAA then is your CAMO but I don’t see it that way.

Yes, already today you can get an ARC without a CAMO. In the UK that’s quite common, in Germany it is possible but rare. However, in that case the CAA would review your maintenance program and apply its own discretion directly with the full power of their cover-my-a** bureaucracy. Do you think that would be advantageous over using a CAMO which normally is the same people as your Part 145 making money with your plane and therefore have a high motivation to get you what you need?

achimha wrote:

However, in that case the CAA would review your maintenance program and apply its own discretion directly with the full power of their cover-my-a** bureaucracy.

Exactly. I was thinking of adding that this option might not be appealing, that anyone would probably rather deal with CAMO and be grateful for being allowed to have a CAMO instead. But I didn’t want to insult anyone. Point being, the option is there.

Is here anyone who has used the new owner declared maintenance program route under the new regulations in any of the affected countries? Our national CAA seems to have an “interesting” understanding of the law, basically saying that all such maintenance programs must comply with TBOs unless otherwise advised by the manufacturer. This is their second (completely different) answer in 1 month; the first one was even stranger (ELA1 = homebuilt).

Last Edited by JnsV at 16 Nov 21:17
Hajdúszoboszló LHHO

I’ve been told a few days ago that our local CAA in Poland will allow one to go over a calendar TBO but not over the usage TBO.

The EASA doc I could find references to going over TBO explicitly exempts IFR planes from going over TBO: Part-M / AMC Amendment 10

Help! :-)

tmo
EPKP - Kraków, Poland

tmo wrote:

The EASA doc I could find references to going over TBO explicitly exempts IFR planes from going over TBO: Part-M / AMC Amendment 10

You are looking in the wrong direction. Amendment 10 was cancelled by amendment 11 3 months after it’s implementation. So it never really existed.

Check my post for relevant material regarding ELA1 alleviation.

Last Edited by Guillaume at 16 Nov 22:39

Thank you @Guillaume – especially for the links to the source itself.

So under AMC M.A. 302 subpart i (MIP for ELA1 aircraft used for NCO) there is no mention of TBO anywhere. So by default it is all “on condition”, if one can convince the CAA to agree, correct?

tmo
EPKP - Kraków, Poland
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