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What is the best way to control the cost of maintenance work, and DIY CAMO?

Out of curiosity, how much approximately would an overhaul of a Beech gear actual motor cost, in Europe?

Mainz (EDFZ) & Egelsbach (EDFE), Germany

This cooperation between owner and maintainer creates a closer understanding of all issues and requirements under a planned maintenance programme, drafted in accordance with the Handbook.

That is certainly true in relation to the closer understanding being reached, but I see no need to sugar coat the reality of an FAA annual inspection to make it more palatable to those who like bureaucracy. Under FAA regulations there is no pre-planned or approved maintenance program for a light aircraft and an annual inspection is done by reference to the manufacturers maintenance manual, in accordance with FAR 43 Appendix D, a very straightforward document that puts the responsibility on the individual IA to figure out the details.

Link

The result is an excellent safely record on N-register.

Last Edited by Silvaire at 29 Apr 20:24

Silvaire
The document your link references is similar to the UK’s LAMP or LAMS schedule and was devised for aircraft where no Maintenance Manual was written.

jxk
EGHI, United Kingdom

You compare a freelance A&P/IA with a full service Part 145 company. It’s not fair to compare those

I don’t think you quite meant to say that because the bodges here (sorry to keep posting that link but it illustrates the point well) were done by a “full service Part 145 company” – FAR 145 & EASA 145 & EASA 21 & Part 4 Subpart F and G

I would have an A&P/IA working for me, in a rented hangar, over any “full service company”.

Jesse – we may be talking “wires crossed” in some areas, but let me lay out some basics, and let’s see if we can agree or disagree on these.

Yes it’s true that an A&P working in my hangar is similar to an EASA66 working in my hangar.

It is the other stuff where the differences are:

  • If the A&P has an IA, he can sign off the Annual and that’s it. Job done. Just the one individual. That option is not available under Part M, where you have to use a Part M Subpart G (which has to be a company, with specific posts held by multiple different people) to sign off the ARC. Do you agree? If not then we are looking at an implementation difference because you do have to do that in the UK.
  • The A&P/IA can work in my hangar, 100.000% legitimately. There is no interaction with the FAA or anybody else. The A&P/IA alone has the authorisation to do the whole job. But can the Part M Subpart G company send a man to visit my hangar when the job is done, inspect the plane, and sign it off, 100.000% legitimately?
  • Under Part M there are mandatory component life limits etc. The effective cost inflation due to this depends on the aircraft, its age, etc but in most cases it is very substantial. Is there a process to get around this? There have been noises that there might be (in the UK) but difficulties appear to continue.

I don’t know the definitive legal answer to point 2 but I believe in the UK this is not legal, and that directly leads to having to use a company for the work, which creates all the other problems mentioned. There is a route, mentioned previously, but my understanding is that the Subpart G company has to be slightly economical with the truth about where the work was done. Can any UK Part M people offer their view on this? I know there are several here.

Last Edited by Peter at 29 Apr 21:41
Administrator
Shoreham EGKA, United Kingdom

The document your link references is similar to the UK’s LAMP or LAMS schedule and was devised for aircraft where no Maintenance Manual was written.

FAR 43 Appendix D applies to annual inspections of all FAA registry light aircraft, with only the Limitations section of the maintenance manual (if it exists for the type) being applied mandatorily. As long as the A&P IA complies with that FAR, the Limitations section of the MM, and any ADs the inspection is legal.

Outside of what was required for type certification in the Limitations section of the type maintenance manual, light aircraft on N-register do not have any approved maintenance program or ‘schedule’ on record with the FAA. The details of maintenance are an ongoing project between owner and A&P, with airworthiness approved annually by the IA in accordance with the ultra simple requirements of FAR 43 Appendix D. It works fine.

Last Edited by Silvaire at 29 Apr 21:17

I don’t think your A&P / IA can sign of your IFR checks is he?

Correct….it needs to be done by an FAA Part 145 Repair Station….

YPJT, United Arab Emirates

Need to be careful here with terminology.

There is no “IFR check” on an N-reg. Like most registrations, the capability to fly IFR derives from

  • Type Certificate [lack of] limitations, and
  • meeting the equipment carriage requirements of the airspace in question

The annual German “IFR Certificate” is a completely bogus ripoff.

Yes you need a FAR 145 Repair Station to sign off the bi-annual static/altimeter check, but again “the man” will travel. No need for any approved premises etc. It costs about €70 per instrument, plus any travel charge.

The German-style “IFR certificate” doesn’t apply to N-reg, or G-reg.

Administrator
Shoreham EGKA, United Kingdom

The altimeter checks are often referred to as “IFR checks” in the US….usually done at the same time as the Transponder…which is required for IFR and VFR….both need to be done at a Repair Stn as far as I can determine..,

YPJT, United Arab Emirates

Yes – the check includes all instruments connected to the static system e.g.

  • altimeter(s)
  • transponder
  • altitude encoder(s)
  • airdata computer

They don’t check the autopilot because the static connection goes only to an internal barometer used for altitude hold (following initial altitude capture, which uses an encoding altimeter) and there is no absolute altitude display available.

The pitot (ASI) instrument(s) i.e. the airspeed accuracy is not checked. I normally get it checked at the same time for no charge, though a much better way to check the ASI is using the three GPS ground speeds method.

Administrator
Shoreham EGKA, United Kingdom

The situation is directly comparable.

You suggest these aircraft are quite rare. Most rare aircraft or older aircraft, do not fall under EASA regulations, but national rules. For example a Piper Cub does not fall under EASA control, so EASA regulations do not apply to these aircraft.

EASA, mandatory overhaul, regardless of condition. This affects a number of major gears and motors. We are looking at the owner and his IA taking measured and logical, safe decisions to ensure that the aircraft keeps flying, safely. This is not possible under current EASA mandates.

This information is just not true. On a NON AOC aircraft, you could have on-conditions maintenance as well. For AOC aircraft you can’t. (But that might be for FAA commercial aircraft).

If the A&P has an IA, he can sign off the Annual and that’s it. Job done. Just the one individual. That option is not available under Part M, where you have to use a Part M Subpart G (which has to be a company, with specific posts held by multiple different people) to sign off the ARC. Do you agree? If not then we are looking at an implementation difference because you do have to do that in the UK.

I a do agree, but I do have to put a note that you will need repair station for the “IFR” check, so you will have to get in one company. Under EASA the B2 engineer could do the IFR check, but you will need the ARC inspector to inspect the paperwork and general condition of your aircraft. He does not need to perform an “annual” . The cost for this would be around 600 Euro. All works and parts could have been supplied by yourself, and work could have been done under “supervision” of the Part 66. No need to worry about poor lubrication, as you can keep your eyes at it all the time.

The A&P/IA can work in my hangar, 100.000% legitimately. There is no interaction with the FAA or anybody else. The A&P/IA alone has the authorisation to do the whole job. But can the Part M Subpart G company send a man to visit my hangar when the job is done, inspect the plane, and sign it off, 100.000% legitimately?

Agree on A&P/IA part, apart from the repair station. The Part 66 engineer could also work in your hanger legitimately. No interaction with anyone else. The ARC inspector could travel to your aircraft and inspect it there, this could be done legally.

Under Part M there are mandatory component life limits etc. The effective cost inflation due to this depends on the aircraft, its age, etc but in most cases it is very substantial. Is there a process to get around this? There have been noises that there might be (in the UK) but difficulties appear to continue.

This information is again partially incorrect, for AOC aircraft the life limits are hard limits, for non AOC aircraft they are not.

Can any UK Part M people offer their view on this?

This is EASA, no need to stay with a UK EASA company, just switch to another country, no problem.

The German-style “IFR certificate” doesn’t apply to N-reg, or G-reg.

Sure the German IFR certificate does not apply to N-Reg of G-reg, but you will have to do some mandatory testing of your avionics and pitot static instruments under ANY regulation.
- Altimeter, encoder, transponder, VOR under FAA
- Altimeter, encoder, transponder for Belgium VFR
- All avionics and pitot static for Belgium IFR
- All avionics and pitot static for German IFR
- All avionics and pitot static for Netherlands
- All avionics and pitot static for UK.

It is just misleading to say that only Germany has a strict regime, clearly it is not. Again EASA, so you can change the inspector if you want.

JP-Avionics
EHMZ
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