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What has EASA actually done for us?

redRover wrote:


Calling each turn seems excessive, but at least in busier areas it seems worthwhile to make an occasional call on the local CTAF that you’re maneuvering X miles north of the airport, or talk to flight following. Obviously you don’t have to, but I’ve always found self announcing your presence and general plans on CTAF to be the polite thing to do.

We do that a lot locally, blind calls on CTAF as a courtesy for other pilots, but what I was referring to was mandatorily coordinating or requesting clearnace for aerobatics from ATC. In some places, happily nowhere me, I understand that is the practice.

Peter wrote:

I think the specific ban is on all pilot maintenance on any plane used for remunerated training. I reckon you will find this is widespread, for obvious reasons, despite some saying their country does not have it. One recent post reported it for French aeroclub planes too.
I wonder what the regulatory basis for that ban is. As far as I have seen, there is nothing in part-M that prevents it and national authorities can’t simply invent their own rules.

It would be IMHO mad risk management to allow pilot maintenance on a plane used for open rental, let alone training unrelated people.

That depends on who the “pilots” are. Pilot/owner maintenance doesn’t mean that any pilot can do maintenance on the aircraft. The names of pilots allowed to to maintenance must be written into the maintenance programme. (Or you could maintain a separate list in which case the maintenance programme must describe how this list is maintained.)

My club is seriously considering pilot/owner maintenance even on aircraft used for training, but of course we wouldn’t let just anyone do it and we would make sure that the pilots on the list have been properly trained in the maintenance procedures they are allowed to do.

Last Edited by Airborne_Again at 28 Feb 15:53
ESKC (Uppsala/Sundbro), Sweden

That depends on who the “pilots” are. Pilot/owner maintenance doesn’t mean that any pilot can do maintenance on the aircraft. The names of pilots allowed to to maintenance must be written into the maintenance programme. (Or you could maintain a separate list in which case the maintenance programme must describe how this list is maintained.)
My club is seriously considering pilot/owner maintenance even on aircraft used for training, but of course we wouldn’t let just anyone do it and we would make sure that the pilots on the list have been properly trained in the maintenance procedures they are allowed to do.

That is just playing with words

It means pilot maintenance is not allowed. It means that an engineer (a pilot who received suitable training could be described as such; somebody with a PhD and a career in ancient languages and who took 150hrs to get their PPL is probably not going to be great with a spanner) is required, except that he/she doesn’t need to be EASA66 qualified.

In practice, how would this “qualification” be defined? What national CAA is going to create a syllabus for training this “non EASA 66 engineer” to become sufficiently trusted to do the service? Or is some aeroclub President going to judge who can do it, perhaps based on some arbitrary system of favouritism (e.g. wearing, or perhaps not wearing although I see that as highly unlikely to be helpful, a short skirt to Club social functions)? What prevents the President declaring himself to be competent enough and thus make a mockery of the system? What prevents the sole owner of a flying school declaring himself good enough and doing the maintenance?

There is no aircraft maintenance qualification below the EASA66 level. The pilot maintenance concession, along with many others such as the entire homebuilt system, is based on the argument that (a) 3rd party risks in GA are very low and (b) somebody who flies his plane exclusively is going to be more careful.

I am all for less regulation but in this case I can’t see how this could possibly work. If I was a renter I wouldn’t touch such an aircraft with a 20ft bargepole.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

Or is some aeroclub President going to judge who can do it, perhaps based on some arbitrary system of favouritism (e.g. wearing, or perhaps not wearing although I see that as highly unlikely to be helpful, a short skirt to Club social functions)?

Peter, please! You are mocking people who are spending lots of their unpaid free time trying to run an infrastructure providing an affordable way for people to fly.

ESKC (Uppsala/Sundbro), Sweden

To quote the draft DTO guidence for aircraft maintanance from the CAA

Where the DTO functions as a ‘Commercial Operator’ they must maintain their aircraft fleet in accordance with Part M, Para MA201, with maintenance conducted by either a Subpart F or Part 145 compliant organisation and the management of maintenance under the oversight of a Subpart G Continuing Airworthiness Maintenance Organisation (CAMO)

So my take of that is that if you are a school you can’t do self maintanance but if you are a non profit club you can

Bathman wrote:

So my take of that is that if you are a school you can’t do self maintanance but if you are a non profit club you can

An ATO or RF operated by a non-profit club and offering flight training only to members is not a commercial operator according to the Swedish CAA. I would be very surprised if they took a different view of DTOs.

ESKC (Uppsala/Sundbro), Sweden

Again to quote the CAA guidance

Last Edited by Bathman at 28 Feb 18:21

That sounds like any rental requires Part M.

An aeroclub is a rental organisation, which has to make a sufficient profit to cover its outgoings (otherwise it must eventually collapse).

A syndicate (where every flyer is a shareholder in the aircraft) isn’t, partly due to the definition and partly because a deficit can be carried forward so long as new members are regularly recruited, but AFAIK most aeroclubs aren’t syndicates.

But surely the overriding thinking behind this UK interpretation is that a renter has a certain expectation of the maintenance standard – regardless of whether he/she has paid a club membership fee.

Administrator
Shoreham EGKA, United Kingdom

Bathman wrote:

which is available to the public or, when not made available to the public, which is performed under a contract between an operator and a customer, where the latter has no control over the operator.”
Yes. And the Swedish CAA interpretation is that a flying club member is not “the public”. Flight sharing, even through web sites such as Wingly, is clearly not seen as commercial operations by EASA so even the act of signing up to Wingly is apparently enough to make someone not be part of “the public”.

ESKC (Uppsala/Sundbro), Sweden

Peter wrote:

An aeroclub is a rental organisation, which has to make a sufficient profit to cover its outgoings (otherwise it must eventually collapse).

It has to have sufficient income to cover its outgoings — not profit. Anyway, an organisation can make a surplus and still be regarded as non-profit as long as the surplus is reinvested in the organisation itself.

ESKC (Uppsala/Sundbro), Sweden
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