On a NON AOC aircraft, you could have on-conditions maintenance as well.
That must be a national implementation variation, because it isn’t true in the UK (G-reg).
There is, AIUI, a procedure whereby one can apply to he CAA for a different approved MM, but nobody I know has ever succeeded.
There have been specific exemptions I have read about e.g. lifting the seat belt life limits, on certain types, but I don’t recall details.
Basically, life limits are enforced on G-regs. This tends to result in people removing a perfectly good part and installing some decrepit old one, perhaps from a crashed aircraft, but one which comes with a form confirming it has been “overhauled”. Not a good situation on an aircraft which is say under 20 years old because (if hangared) much of the internals will be in a very nice condition.
The ARC inspector could travel to your aircraft and inspect it there, this could be done legally.
I will try to check that, for the G-reg case. Another possible national implementation difference. I have asked a few people in the business but thus far nobody has offered any comments 
The price for a “back of a van” ARC signoff is a few hundred GBP, plus travel.
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.
True, but the FAA static check is not coupled to the Annual release to service. So you can get it done anytime before or after, when convenient. This makes a big difference because you are not held over a barrel, with the aircraft not legal to fly. Plus it is every 2 years. I used to pop up to Cranfield every 2 years (IAE) but now get it done in my hangar (FAA 145 company).
A million reasons for going experimental
Anyway, for certified aircraft, people here often go with the aircraft to the repear stations. They do most of the work themself, thinks like opening panels and similar, and let the “pros” do only what is needed. I don’t really see the big problem of having a company do the stuff instead of an individual.
It seems to me it is more important for some to justify their choices than to tell the facts straight up.
They do most of the work themself, thinks like opening panels and similar, and let the “pros” do only what is needed. I don’t really see the big problem of having a company do the stuff instead of an individual.
Exactly. It all comes down to finding a Part 145 shop you trust and that trusts you. The inspector is responsible for the airworthiness and whether I bolt on the cylinder or one of his staff, doesn’t really make a difference from a legal/regulation point of view because neither his staff nor I hold any formal qualification for working on aircraft. Everything is possible.
I am a bit late to this thread. Can I make a couple of points?
It is not mandatory for all aircraft to use a Part M for the ARC. ELA aircraft can avoid a Part M if they use a Part 66 engineer approved to make the ARC recommendation. I don’t know much about the process but I do know that option is available. Maybe this option will be extended to more aircraft in the future. So for an ELA aircraft, it is possible to use just one man, just like an FAA A&P/IA.
The mandating of “recommendations” from the maintenance manual is a national authority thing, not EASA. The only mandated things are AD’s and chapter 4 airworthiness limitations. However, it is far easier for your CAMO to write a maintenance programme that includes all recommended items because that will easily pass scrutiny by the NAA at audit. It is acceptable to have a maintenance programme with all “recommended” items on condition and monitored, just more difficult to get it past the NAA. This is true in the UK with the SIDs on Cessna singles where the SIDs are treated as recommended, not mandatory. In Sweden, however, I understand that the NAA requires all SIDs to be in compliance for an ARC to be issued.
In fact, in theory it would be possible to have a maintenance programme approved that did not follow the manufacturer’s maintenance manual at all. In the UK almost everyone uses LAMP for light aircraft yet it is based on, for want of a better phrase, best practice, not the recommendations of any particular manufacturer.
There is, AIUI, a procedure whereby one can apply to he CAA for a different approved MM, but nobody I know has ever succeeded.
CAMOs can write their own MP’s and I am working on obtaining this privilege at the moment.
I don’t think the EASA system stops owners getting involved in maintenance (look at the list of pilot owner maintenance one can carry out) but it does come down to finding a shop that will allow you to work on your own plane under their supervision.
CAMOs can write their own MP’s and I am working on obtaining this privilege at the moment.
In Germany the supervision of that is extremely strict. The CAMOs can only approve what the CAA has told them they may approve. No thinking of their own allowed. When some CAMOs announced they would approve maintenance programs that made the Cessna SIDs voluntary, the German CAA publicly stated that they will withdraw their license with immediate effect should they do that and at the same time announced they will perform focused inspections on compliance.
Very interesting post, KevinC.
ELA aircraft appears to be any SEP below 1200kg which ought to cover most PA28s for example. Clearly not many people know about this! But a 1400kg TB20 is outside.
Maybe the ultimate limiting factor here is that the “single guy in a hangar” option is available only to people who have, ahem, a hangar
I don’t think the EASA system stops owners getting involved in maintenance
Indeed, and I used to do some work myself when I used a company. However, in my case, this did not reduce the “fixed price £2500 Annual” fee I found it more effective to instead organise and supervise some avionics work done at the same time. Basically we took advantage of the heated hangar (January!) to do avionics work. Most firms won’t allow a freelance avionics guy to work on the plane, however, IME.
So much damned politics in this business…
the German CAA publicly stated that they will withdraw their license with immediate effect should they do that and at the same time announced they will perform focused inspections on compliance.
I wonder why Germany doesn’t have a much bigger N-reg community.
In the UK, in the last 10-20 years, just about everybody with more than a quid or two and wanting an IR, has gone N-reg.
Maybe it is a cultural thing. I know a German pilot (doesn’t post here but he does read it so I need to be careful 
) who bought an N-reg TB20 and transferred it immediately to D-reg. He flies Citations and TBMs etc and has all the FAA papers too, so I asked why the hell did he do that (cost him thousands, obviously, and masses of hassle). He said in Germany, being N-reg is not liked and people go round saying that you must also fiddling your taxes.
The CAMOs can only approve what the CAA has told them they may approve.
Same in UK. Again, this is up to the NAA to interpret and decide how much they will allow the CAMO to think on their own.
I don’t think the EASA system stops owners getting involved in maintenance (look at the list of pilot owner maintenance one can carry out) but it does come down to finding a shop that will allow you to work on your own plane under their supervision.
And that is the nub of the debate. Everyone appears to understand the system, how each works, (EASA/FAA), I have never come across a PartM company, that would allow the owner to ‘participate’, in the annual/ARC process. Maybe they exist, I dont know, but the main comment was about what happens when the owner, is not there. Coming back to the old ‘rip off’, scenario.
If you are wholly controlling, and involved in the process, you release the aircraft to service in full knowledge of what has happened, and confident that the log books have been updated accordingly. When I moved to FAA, I was astonished to find major omissions from the logs, which in turn caused me no end of grief in the transfer process. The omissions were by PartM, organisations. As was mentioned previously, several people, all doing their bit, within the organisation, generally screw up. The owner then left to sort out the mess.
I even had a Part M company, who had carried out an internal refit, then did not log it, deny that they had done it. I showed them the invoice, and showed the invoice to the CAA, to be told it was a genuine error, and again, as owner, it was my responsibility to ensure that my logs were up to date. Agreed it was my responsibility, but I paid the CAMO, sub group of the Part M, 600.00 to do this.
Basically all aircraft, to be legally issued an ARC, must have complete and concise traceability carried out by either a Part M approved company, or surveyed by the CAA.
I wonder why Germany doesn’t have a much bigger N-reg community.
About 30% of the fleet. That is a lot. And the explanation is very simple: the USA are your former colony, not ours. They speak your language, not ours. Most aircraft owners are 60+ and often their English skills and willingness deal with US administration are limited.
He said in Germany, being N-reg is not liked and people go round saying that you must also fiddling your taxes.
That’s nonsense. N-reg is too widespread for that. There is no tax aspect to being N-reg, to the contrary you have to always prove this “free circulation” thing.
Germany’s LBA has always been very reasonable and pilot friendly. Not so much incentive to look for regulatory arbitrage. Only with this EASA crap, things have started to go down the toilet.
I am not proud of leaving D-reg, I have always been of the opinion that a citizen should live within the legal and regulatory framework of his country. The fact that it is possible to move to N-reg is one reason why we have such a shitty framework in Europe. The people who could (and should) influence the framework are the ones that say good bye and no longer care. If EASA are now realizing what damage they have done, it may be too late. At least for Cessna owners.
I don’t really see the big problem of having a company do the stuff instead of an individual.
I find the absence of invoices and government involvement/fees, and the ability to do the work outside of a company, for zero cost, quite beneficial.
I think the best hope for European over regulation of aircraft and pilots is the persistent counter example that comes from the US – which has chosen a different direction on the basis of principle.
