tmo wrote:
So by default it is all “on condition”, if one can convince the CAA to agree, correct?
GM M.A. 302(h)
However, when issuing a declaration for the maintenance programme, the owner assumes full responsibility for any deviations introduced to the maintenance programme proposed by the contracted organisation. The organisation which developed the maintenance programme is not responsible for such deviations. These deviations do not need to be justified by the owner.
So, no, you don’t need to convince the CAA as this complies with Part-M 
.
JnsV: I am very tempted to try the ELA1 / MIP route, but I do not want to be the first – I anticipate national-CAA to ask all kinds of questions, check manual references etc etc.
On the other hand there are some annoying things in the present AMP from CAMO, like starter not on condition and a few other things. I have worked with my Part145 and agreed with them on a reasonable low season pricing for annual/100h – so a couple of extra SBs and inspections is perfectly to live with.
G
GaryStorm wrote:
JnsV: I am very tempted to try the ELA1 / MIP route, but I do not want to be the first – I anticipate national-CAA to ask all kinds of questions, check manual references etc etc.
The CAA is not involved at all.
I am aware the CAA should not be involved, BUT you will have to notify CAA you indeed have an owner declared AMP for the aircraft? – and I bet a round of beer they will came back and ask for a copy of the MIP. Then, they will find something formal they are not satisfied with and here we go again…
It would probably be wise to stick to the published MIP in order to refrain from discussions.
I will keep you posted. I was hoping someone already had one MIP declared that the CAA had looked into, but accepted by the CAA.
G
I don’t follow your logic. It is a self declaration, the CAA has no power to demand to see it and approve it. Therefore they should have no interest in it.
The UK CAA issed a document on the MIP.
http://www.caa.co.uk/docs/224/20150729%20Minimum%20inspection%20programme.pdf
To which they included a Template on how to do this..
The Hungarian CAA has published its “interpretation” about the 2015/1088/EC regulation:
http://www.nkh.gov.hu/web/legugyi-hivatal/hir/-/hir/996372/tajekoztato-a-legi-jarmu-karbantartasi-program-kidolgozasarol-es-hatosagi-jovahagyasarol
(Hungarian only)
They have (mis)translated “maintenance program declared by the owner” as “tulajdonos által bejelentett karbantartási program”, actually meaning “maintenance program submitted by the owner”, as in submitted to the CAA. They even included the following sentence in their publication:
“A karbantartási programot függetlenűl attól, hogy milyen módon történik a jóváhagyása, teljes formájában be kell nyújtani a Hatóságnak.”
meaning
“The maintenance program, regardless of the route of its approval, must be submitted to the Authority.” (English traslation mine)
In the official Hungarian version of the EC regulation, the word “declare” is correctly translated as “nyilatkozik”.
Also, the whole document is worded as if the MIP was something in addition to the already existing requirements for the maintenance program for light aircraft not involved in commercial operations.
Have a look at EASA website.
You may be able to complain to EASA that the Hungarian CAA are misinterpreting the rules, particularly when the rule is translated into Hungarian.
https://easa.europa.eu/document-library/rulemaking-programmes/rulemaking-proposal
or send an email to querying how EASA deal with translation issuers..
AOPA uk issued this.
Sounds good. Quite pragmatic and to the point.
The only bit which might get “interesting” is obviously this:
The maintenance programme itself will also be subject to a review by the maintenance organisation to ensure it is appropriate.
