Part-ML and inflating CAMO cost

Airborne_Again wrote:

To me, a CAMO is just an expensive convenience and if I could get a club member with sufficient knowledge/interest and stamina to do the work for free, I would. But in no way can I agree that having a CAMO makes maintenance worse. More expensive, certainly.

As per what I wrote above, the existence of paid staff to plan and execute fleet maintenance and attempting to achieve the same end under a government orchestrated maintenance plan and CAMO system are two different things. The former is better, more effective and more efficient than the latter – which in my view is a horrific concept for the maintenance of private property, and even more so private property designed for condition based maintenance.

The way in which a more “rigorous” system makes, or can make, maintenance worse is because people will work harder to circumvent it.

Everybody knows that…

When I am working on my plane with my A&P/IA, we do all essential stuff, but we do only essential stuff. That means everything that needs to be done gets done, but one isn’t paying over the top.

An old joke from the bottom-end airline business (where the annual AOC cost was a significant chunk of the operating expenses) was that the filament lamps had an “infinite life”. The process of replacing them (creating a work pack, drawing one from the stores, processing the traceability paperwork, installing it, perhaps chewing up some screw (which needs replacing, with another mention in the work pack, and more traceability doc work) signing it off, was such that everybody did it off the books. Or not at all… which is usually fine if you don’t fly at night, or if no warning lights ever need to appear

I actually recall a very special concession, found deep in the UK CAA regs, that an ATPL holder was authorised to change a lamp in the field. But a mere CPL/IR could not.

CAMO doesn’t have to be a huge organization the size of Pentagon.. Quite the opposite, all the CAMO’s I have personally encountered are actually just 1 person.. Probably not the majority in Europe, but still, it doesn’t have to be something mystical.
Even our club with 4 motorplanes and 15 gliders is considering making their own CAMO ..

Silvaire wrote:

As per what I wrote above, the existence of paid staff to plan and execute fleet maintenance and attempting to achieve the same end under a government orchestrated maintenance plan and CAMO system are two different things. The former is better, more effective and more efficient than the latter – which in my view is a horrific concept for the maintenance of private property, and even more so private property designed for condition based maintenance.

???
CAMO is the “paid staff to plan” that maintenance. And what do you mean by “government orchestrated maintenance plan”?
Your whole world rests on trusting a mechanice. Well, some people don’t! And for those people you have two options:
1. Plan it yourself.
2. Ask someone else to do that.
There is not alternative! You either do it yourself, or you ask someone.
Number 1 does not work for many people (don’t know how to, don’t want to know how to), which leaves them with option 2. Which in EASA world called CAMO (if you want them to be actually accountable for something).

So, if I accept to dedicate my renting activity to private flights only (= part-NCO), I’m free to leave the CAMO, self declare an AMP (according to MM to be on the safe side, except few items like propeller / engine time ?) and work with the part66 mechanics of my choice.

Correct. Part-ML gives you the liberty to do what you think is best. EASA conceded this to the owner, and I think it makes a lot of sense to own this liberty and responsibility.

PetitCessnaVoyageur wrote:

The introduction of part ML (ELA2) regulation this year, was said by the CAMO to have increased massively the paperwork.

Airborne_Again wrote:

We’ve seen a similar increase (+60%). Our CAMO says that they had to spend a massive amount of time updating their own manuals to comply with part-ML

lionel wrote:

The CAA is allowed to demand, and inspect, a Part-ML AMP, and (if it is) to find it non-compliant. One CAA of a small country did exactly that, for each and every plane (potentially) subject to Part-ML on its register.

And finally…

arj1 wrote:

what do you mean by “government orchestrated maintenance plan”?

The EASA CAMO operates within a government defined structure per the relevant government regulation for their role, filing paperwork periodically, paying fees, and meanwhile dictating preplanned details of the maintenance of your private property per a mandatory plan for your individual aircraft. Any change in the plan involves negotiation, because if you depart from the maintenance plan you are arguably breaking the law. The CAMO is a further extension of the baseline insanity by which EASA light aircraft are maintained.

For comparison, if you were to similarly employ paid help to organize maintenance on an N-registered plane, the FAA wouldn’t even know the person exists (because its none of their business), no paperwork would be filed with the government, no official maintenance plan would exist for your property, no fees would be paid and the only record would be mechanics logbook entries that are also your property and are not routinely (if ever) seen by government. Vive la différence

The designers and manufacturers of American light aircraft intend for them to be inspected by an authorized individual every year or 100 hours. That, and not the details of how the aircraft is kept airworthy is the government role unless an AD is issued or the owner modifies something to depart from the certified configuration. Otherwise, the designers and manufacturers intend light aircraft to be owned by people who look at them regularly and responsibly as part of their flying routine, to be maintained based on real time condition and to be fixed when they break. When work gets done or inspections are performed its recorded by the guy with dirty hands in a little book that the owner keeps… and nothing more.

Silvaire wrote:

Any change in the plan involves negotiation, because if you depart from the maintenance plan you are arguably breaking the law. The CAMO is a further extension of the baseline insanity by which EASA light aircraft are maintained.

Do we have to go through this again? You do not need a CAMO. With an owner declared AMP you can change it anytime without negotiating with anyone.

I’m getting a bit tired of this. It seems like the self-esteem of some N-reg owners hinges on the superiority of the FAA maintenance regime over the EASA regime.

Yes, it’s obviously much better in EASA land now that the awful CAMO dictate has been made optional. You do however still need an AMP, and it has to be followed. There is no way I’d own a plane or anything else that was subject to that requirement. My maintenance is a continuous self driven process in which you are absolutely right that one can take personal pride and pleasure. It is not a bureaucratic mess.

The CAMO dictate that never actually was a dictate since nobody forced any private owner (directly or indirectly) to hire a CAMO.

Your “continuous self driven process” still has to abide by the manufacturer’s ICA. Same as our AMP really, except you call it a “process” and we call it a “programme”.