@mh wrote:
Part ML is always applicable when you do not fly commercially and the aircraft is not listed on an AOC.
I hate to correct your otherwise excellent post, but the first part isn’t right. If you e.g. operate commercially under part-SPO, then part-ML still applies. Having the aircraft listed on an AOC or not is the criterium.
Snoopy wrote:
My understanding is before Part-ML the UK didn’t allow Props on condition.
They should have as owner-declared AMPs were introduced in part-M some years before part-ML.
Peter wrote:
Others will judge you from your manner
@Peter was impressed with the polite reply, takes some wise moderation
I hate to correct your otherwise excellent post, but the first part isn’t right. If you e.g. operate commercially under part-SPO, then part-ML still applies. Having the aircraft listed on an AOC or not is the criterium.
Well then don’t ;)
Article 3 of the Cover regulation explicitly mentions aircraft listed on an AOC, so it is the criteria (I cited it). Commercial SPO don’t have an AOC, but an SPO Authorisation, as mentioned in ORO.GEN.110(1) and 1008/2008. So you are right: commercial SPO operations need a CAO/CAMO contract, but are maintained within Part ML.
I think this is a really interesting topic and just shows the mess this has sadly become.
And AA I really appreciate your knowledge and patience and to me you’re an absolute shinning light on this subject and you give me great hope. But sadly, as so often is the case in the UK, its interpretation is proving to be inconsistent and problematic.
I also worry what lies ahead EASA really seem to be moving in the right direction on this. I just can’t see the UK following.
Bathman wrote:
I also worry what lies ahead EASA really seem to be moving in the right direction on this. I just can’t see the UK following.
Same worry for me. Including as well BIR, Part-21 light, NPA 2020-02, etc.
RobertL18C wrote:
@Snoopy that is also possible in the UK, and the private owner can then use the Maintenance Manual as the model, and yes, the owner can elect to keep components on condition.
Indeed it is all possible, but the practical challenges are that you need to find a maintenance shop that:
1) Is happy to work on your plane in a non-CAMO arrangement
2) Will still work on things quickly and reliably rather than pushing you to the back of the queue in favour of CAMO customers
3) Is not the sort that says “don’t tell me how to do my job” as soon as you ask a question
4) Knows the type
5) Knows how to get parts and can get them quickly
6) Has availability and wants the business
7) Doesn’t expect blank cheques
8) Is at an airfield that isn’t too far away
9) Is at an airfield with sensible opening hours
10) Is at an airfield with a suitable surface for your aircraft
I could probably list more factors, but the gist is that you’ll probably have to compromise somewhere on that list!
Thank you @mh for the solid answer with reference to the texts, it will be a good basis when (if) I trigger a conversion.
mh wrote:
So you are right: commercial SPO operations need a CAO/CAMO contract, but are maintained within Part ML.
Does SPO operations need a CAMO contract only, or a fully controlled environment ?
(My understanding is that with a CAMO, you can elect
Am I right ?)
For French reader, a seminar organized by OSAC (2019) on the topic
@Snoopy wrote:
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.
The concept of responsibility is interesting.
Obviously, the CAMO justifies his price tag, because he feels much responsibility on his shoulders. The question is: what kind of responsibility are we talking about ?
When in charge of airworthiness of an aircraft, with a Maintenance Program, you obviously have to perform maintenance “on time”, and make sure that what is written in the program is executed. We could call that the “form”. Write what you say, and do what is written.
Then comes the “content”.
I understand you can go can go from full Maintenance Manual down to MIP + AD and whatever in between. If an accident happens, can you be blamed for what you chose ?
Let’s take the infamous AP servo clutch; you could declare that they will be bench tested every 5 years instead of every year. It would seem reasonable, didn’t it ? Or extend the propeller life between overhaul by a few years. If the engine stops (unrelated event), would you be blamed for having cut on maintenance ?
In general, if choosing to deviate from MM, is there a means / necessity of justifying the choice for having done so ?
