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SDMP (self declared maintenance programme) and why some can and some cannot operate it

Alright, so it’s about mandatory CAMO.

Mainz (EDFZ) & Egelsbach (EDFE), Germany

It’s funny that you can operate “NCO” (non commercial other than blabla) commercially in an ATO, thus requiring a camo.
Yes, I know “NCO” is a regulation meant as a category/definition of airplane and use in a specific operating regime, but still, it’s a bit contradictory. In essence a commercial operation (for profit ato training) is taking place under non commercial operation regulations.

Last Edited by Snoopy at 17 Apr 22:51
always learning
LO__, Austria

Yeah, the commercial/non-commercial DTO is simply rubbish. Very unlucky that it ended up there in a very late stage of the rule making process.

When the authorities decides to enforce this, all “commercial” DTOs will simply start a non-profit organization that holds the declaration and then rent the aircraft and instructor from the “commercial” company.

ESSZ, Sweden

I still don’t understand. Could anyone explain it in very simple terms.

Fly310 wrote:

When the authorities decides to enforce this, all “commercial” DTOs will simply start a non-profit organization that holds the declaration and then rent the aircraft and instructor from the “commercial” company.

That wouldn’t fly (ha!) because then the non-profit would wet lease the aircraft and that would make the non-profit “commercial”.

ESKC (Uppsala/Sundbro), Sweden

Fly310 wrote:

Speaking of templates, the Swedish CAA just released a new template for Part-ML:
mall_amp_enligt_annex_vb_del_ml_pdf

It is available in word format(swedish website) here

A similar template is available from the UK CAA here PDF local copy
which is accessible from https://www.caa.co.uk/Part-ML/. I believe they have taken it from the EASA AMC to Part-ML.

EGTF, EGLK, United Kingdom

Bathman wrote:

I still don’t understand. Could anyone explain it in very simple terms.

It is all about what maintenance regime to apply. A non-commercial flight school

  • does not need to employ a CAMO or CAO to manage the maintenance of their aircraft
  • can use an owner-declared maintenance programme
  • does not need to use a maintenance organisation but can use independent (part-66) mechanics.

While a commercial flight school

  • has to employ a CAMO or CAO
  • can’t use owner-declared maintenance programmes
  • has to use a maintenance organisation (F/145/CAO)

So the question is what makes a flight school commercial or non-commercial.

The Guidance Material, while not binding, has the following criteria for the organisation running a non-commercial flight school

  • The organisation must be created with the aim of promoting aerial sport or leisure aviation (e.g. what is usually called an “aeroclub”)
  • The organisation is non-profit
  • The aircraft used are owned by the organisation or dry leased (i.e. leased without crew)
  • The school only offers its services to members of the organisation, save for marginal activities (e.g. trial lessons)

Then there are some special cases where aircraft temporarily operated by an commercial flight school can still use the same maintenance regime as if the flight school was non-commercial

  • If the aircraft is owned by the student and used for the student’s own training.
  • If the flight school needs an aircraft with specific abilities or equipment
Last Edited by Airborne_Again at 18 Apr 09:16
ESKC (Uppsala/Sundbro), Sweden

AA thats really nice of you.

Thank you very much.

How does this tie in with the UK CAA interpretation local copy ?

Last Edited by Bathman at 18 Apr 09:38

Airborne_Again wrote:

That wouldn’t fly (ha!) because then the non-profit would wet lease the aircraft and that would make the non-profit “commercial”.

I find that hard to believe since many aero clubs rent aircraft and property. Why would that make them commercial?

Last Edited by Fly310 at 18 Apr 10:07
ESSZ, Sweden

Fly310 wrote:

I find that hard to believe since many aero clubs rent aircraft and property. Why would that make them commercial?

The rules say nothing about renting property. As regards aircraft, the key word is “dry”. I don’t think any aeroclub has wet leased aircraft. In your example, it would certainly be wet lease as the instructor was included in the lease.

ESKC (Uppsala/Sundbro), Sweden
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