I have much sympathy with the views of Archer-181 the CAMO is largely a product of EU thinking, IE paperwork = quality.
Twenty years back my late wife suggested that the EU did not like the personal freedom that is one of the advantages of light aviation and that as a way of channeling all citizens into easily contained travel channels safety could be used as an excuse for making personal aviation very difficult.
@Airborne_Again
No problem, I thank you for your input.
It’s highly probable, even if rules are ambiguous, that renting an aircraft would be considered as commercial by the authority. Let’s wait what the OSAC says.
120£ would not provoke the same kind of reaction :-)
A_and_C wrote:
Twenty years back my late wife suggested that the EU did not like the personal freedom that is one of the advantages of light aviation and that as a way of channeling all citizens into easily contained travel channels safety could be used as an excuse for making personal aviation very difficult.
Sorry but that doesn’t make sense. Travel freedoms are far greater since the EU exists, also for light GA. My EASA pilot license allowed me to work and fly in Austria, Germany, UK, France and Spain without any bureaucratic hassle. What made light GA / Aviation remain very difficult were narrow minded national bodies that fought of EU harmonized rulesets.
What’s my effort to fly from Austria to / within / on a plane registered in
Germany
Italy
Slovenia
Croatia
Hungary
Slovakia
Czech Republic
etc..
?
None. I can just fly.
What’s the effort to do the same for the UK? Hassle.
For CAMO it’s not black and white.
Archer-181 wrote:
The whole CAMO thing is appropriate for Airliners but for GA is just a way to extract money from customers and in my experience undermines the engineers working on the aircraft.
I disagree. A worthwhile CAMO (controlled maintenance environment) with underlying safety management is beneficial to safety. Having said that, the relation of cost vs. service/benefit needs to be proportional.
3000€ for a CAMO copying the DAH AMP → useless
900€ for a CAMO creating a bespoke AMP based on risk analysis → useful
Is it required for owner pilots? No.
Is it a disadvantage? No.
PetitCessnaVoyageur wrote:
highly probable, even if rules are ambiguous, that renting an aircraft would be considered as commercial by the authority. Let’s wait what the OSAC says.
Imho it’s impossible to consider it as such and causing any other ops requirement other than NCO.
If it were considered a commercial activity NCO couldn’t be applied.
Snoopy wrote:
A worthwhile CAMO (controlled maintenance environment) with underlying safety management is beneficial to safety. Having said that, the relation of cost vs. service/benefit needs to be proportional.
I’m not at all sure that paradigm has proven to be valid, as always when introducing procedures and people to improve anything, there is a trade-off between the potential benefits of increased organization and the ever present opposing downside of having more people involved, more links in the chain to fail, and less flexibility in allowing knowledgeable people to react without restraints to real situations as they actually occur. Another possibility is that every penny given to the CAMO is buying you problems and decreasing safety.
For the sake of argument let’s say the added organization does produce a net benefit. Why then does it need to be orchestrated as a government regulated system versus a commercial service offered by companies to willing buyers? I think the answer is that it’s a bureaucrat invented impractical answer to a question that nobody asked, promoted now only by the financial beneficiaries who try to manipulate the unknowing into using their paid services. As such it’s ended up being a government sponsored disservice to GA as a whole, a threat not a benefit. The best thing people can do to promote GA is spread that word that the threat has been mitigated by more recent regulation that allows something more like conventional practice for light aircraft owners maintaining their own property.
For me having CAMO is just convenient..They doublecheck my paperwork, and I’m guaranteed to get an ARC or ARC extension.. The cost of annaul ARC review varies from 500 to 900 EUR in my neighbourhood for “not in controlled environment” planes.. Of course, there is also a possibility to get ARC from local CAA, but they might say that they don’t have manpower and happily offer you to perform the review sometime during the next 6 months ..
ARC renewal is another example of a process with no benefit, other than to the financial beneficiaries. My last FAA annual inspection was $400 including logbook entries to a guy who makes his living working as a light aircraft A&P (not a friend in this case), with no additional paperwork or associated cost.
The very best person to come up with my risk based maintenance programme was myself (who has done 7 years of owner assisted annuals) and also my incredibly experienced Engineer.
I know my Aircraft inside out, I know the environment it lives in (outside). I do realise that not everybody is like me and some Aircraft are far more complex.
My previous engineer was scathing of the CAMO system “a load of old boll**ks as they don’t trust the Engineer to do his job”
Perhaps I have been influenced by these “old school” guys but my real world experience puts me in their camp. I have also heard of a CAMO controlled Aircraft which flew around with Slick mags that hadn’t been inspected for 900 hours. Not something you’d want to do with Slick Mags :-(
To me, N-reg, and working closely with a freelance A&P/IA, all this EASA Part-M* debate looks like rearranging the chairs on the Titanic 
Looking at how private flying in the US is so devoid of “organisational supervision/management”, the whole N-reg scene ought to be covered in wreckage. Why isn’t it? Can anyone objectively think of why not?
I recall a debate with an instructor in one of our Zoom meet-ups. He was concerned that the FAA 6/6 IR rolling currency must result in unsafe pilots. I made the same point to him: why isn’t FAA-land (particularly the US) covered in wreckage? There was no answer.
But there must be an answer!
The answer is probably just circular. That’s how Europe does it. Trust is vested in organisations (not individuals), and similar structures. So we can debate how to best work around these artificially imposed restrictions.
But, always remember the Titanic.
Snoopy.
There is a difference between theory and practice, in theory EASA offers more freedom to travel but the system EASA introduced increased expense for no safety benefit and so priced many out of the light aviation arena if they can no longer afford the freedoms that EASA offers then the political objectives of keeping the masses in place is achieved.
At the airfield I was based the number of aircraft and flying training companies has halved since EASA oversight arrived and if you asked those who have withdrawn from aviation the over regulation of EASA would be a significant factor in them giving up flying.
Archer 181
Having held a maintenance licence since 1979 I have seen the level of practical knowledge and experience trumped by theory and book learning when it comes to EASA maintenance licence issue. I have a few war stories about those graduates of maintenance schools from Southern Europe who had not the first idea of how to perform basic maintenance tasks, the old U.K. CAA required a technical interview before the issue of a maintenance type rating filtered out those who’s practical experience was lacking.
