@Airborne_Again Okay if you wish to put it this way, you could say it has an impact on maintenance, my point was rather that the CAMO in it original task is a paper machine and does not perform maintenance tasks and the corresponding paperwork is not maintenance in the sense of turning wrenches and playing with grease, but rather the documentation of these maintenance tasks.
Anyway, if I remember correctly, even if the pilot/owner issues an ARC, he does it on the behalf of an airworthiness management organisation. But I need to consult PartM for that.
mh wrote:
my point was rather that the CAMO in it original task is a paper machine and does not perform maintenance tasks and the corresponding paperwork is not maintenance in the sense of turning wrenches and playing with grease, but rather the documentation of these maintenance tasks.
Yes, that’s true, but the responsibility of the CAMO is much greater that you might expect. My club used to have a maintenance shop which was also the CAMO. Now we have separate CAMO and maintenance and I was surprised to learn that the CAMO literally tells the maintenance shop exactly everything they should do. (But not how do to if, of course.)
If a landing light has burned out, the CAMO will tell the shop to replace it — they don’t (can’t) do it on their own initiative.
I asked the LBA the question back in November, if I could resign from CAMO and mama be myself. Here is what they said
a) It is correct that you don’t need a contract for managing the
airworthiness of an airplane which was not used in an ATO or
commercially.
b) If you resign the contract the maintenance programme will become
invalid because it has been approved to the CAMO. In this case to you
have to file a new application for the approval of a new AMP which then
will be approved to you with new costs of 400,-€.
We now issue the ARC ourselves and send it to LBA. Of course I need to keep track of what needs to be done when, but the great advantage is that I don’t have a CAMO instructing themselves to do more maintenance for our money without our control (we had a couple of minor issues that completely snowballed and they decided on own initiative to replace half the aircraft in bits).
I’m curious… how is an owner able to issue an ARC themselves? I understand the private operations only part. Where is this defined in Part M?
We have to use the right terms here. The owner can never ISSUE the ARC. He can however, as @mmgreve describes, issue a recommendation(filling out the form) and send to the CAA which then issues the ARC. @mmgreve, it seems as you have moved the responsibility from the CAMO to the LBA and not to yourself. That’s why they charge you 400 euros to approve your AMP. And they will also charge you some annual fee to review it? At least as I have understood it.
Many CAAs/NAAs are unwilling to do this since it increases their workload. That’s why they raise their fees. :)
From Part-M:
M.A.901:
(g) By derogation from points M.A.901(e) and M.A.901(i)2, for ELA1
aircraft not used in commercial air transport and not affected by
point M.A.201(i), the airworthiness review certificate may also be
issued by the competent authority upon satisfactory assessment,
based on a recommendation made by certifying staff formally
approved by the competent authority and complying with
provisions of Annex III (Part-66) as well as requirements laid
down in point M.A.707(a)2(a), sent together with the application
from the owner or operator. This recommendation shall be based
on an airworthiness review carried out in accordance with point
M.A.710 and shall not be issued for more than two consecutive
years
There used to be a PDF that explained this quite nicely. It was easy to find but now I can’t find it (I think the website is being reconstructed and they pulled all their PDFs).
Airborne_Again wrote:
but the responsibility of the CAMO is much greater that you might expect. My club used to have a maintenance shop which was also the CAMO. Now we have separate CAMO and maintenance and I was surprised to learn that the CAMO literally tells the maintenance shop exactly everything they should do. (But not how do to if, of course.)
There is a difference between controlled and uncontrolled environment. It sounds like your club has aircraft in controlled environment.
mmgreve wrote:
We now issue the ARC ourselves and send it to LBA.
You can’t issue an ARC (assuming you’re just a pilot/ owner). Writing something like that only confuses things. IIRC only an NAA or a CAMO (under certain conditions) could issue an ARC. NAA can do so either by having their personnel do the review, or by assessment of a recommendation (and you can’t issue that either AFAIK; you just send in the application with the recommendation). Now, for ELA1, Part 145 or Subpart F MO can do it as well (as part of an annual; and again, under certain conditions).
However, I’m not current in this and all is AIUI. Anyway, what CAMO does is in M.A.708.
