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Part-ML and inflating CAMO cost

Why keep on insinuating and propagating that owning/maintaining a typical single mandates procedures like for an Airbus under EASA?

The law changed 24MAR2020! It’s EuroGA, makes sense to know EuroRegulations when discussing them, no?

all this EASA Part-M* debate

A last try:

Planes such as a TB20 CANNOT be maintained acc. to Part-M when flown privately.

As an owner pilot with a plane up to 2730kg mtom you NEVER have to even get near a CAMO.

The difference between FAA Pt. 91 and EASA Pt. NCO is

*EASA wants an AMP (self declared is ok or the MIP) + 100h = annual inspection and ARC renewal.

*FAA needs no AMP + only an annual inspection.

Compare the EASA MIP to FAA… the requirements are very low.

FAA has similar MX requirements to EASA for anything bigger, flight training (100hrs insp.), commercial ops, charter etc… The way a United A320 is maintained is also subject to FARs and not some private sector best practice option.

Keeping a simple SEP like a Pa28, Cirrus, TB20 etc.. N-reg vs. EASA is a draw, with pros and cons canceling out each other.

Do note: I’d move my family over the pond in a heartbeat and enjoy free landings ;)
I’m a bureauCRITIC par excellence, but fairness/objectivity warrants to also give credit where it is due, even if it goes against personal opinion.

always learning
LO__, Austria

Planes such as a TB20 CANNOT be maintained acc. to Part-M when flown privately.

How come nearly everybody in the UK takes their G-reg planes to a Part M Subpart G company, and has done for many years, as their only option?

I wonder if wires are crossed and you mean Part 145?

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

How come nearly everybody in the UK takes their G-reg planes to a Part M Subpart G company, and has done for many years, as their only option?

You have frequently ascribed the reason to what one might call “social factors.” Also lack of knowledge of what the regs actually say, I guess.

I wonder if wires are crossed and you mean Part 145?

He means part-M. A TB20 (unless operated as CAT) has to be maintained according to part-ML, not part-M.

ESKC (Uppsala/Sundbro), Sweden

has to be maintained according to part-ML, not part-M.

I did actually suspect this grammatical hair-splitting was going on but could not quite believe it!

How much forum bandwidth?

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

How much forum bandwidth?

Well, I think the may reason for the wasted (?) bandwidth is that EASA regulations concerning maintenance have changed much the past 5-10 years – this process actually started before part-ML. The conception of how the EASA maintenance system works was firmly established with the first, arguably unreasonable, version of part-M.

After that people have gotten used to how things are done and most haven’t read the new regs. (I guess this in particular applies to N-reg owners who have no reason to read the EASA maintenance regs except for the sake of debate – and not many would find that a good way of spending their time.)

ESKC (Uppsala/Sundbro), Sweden

Labeling the distinction between Part-M and Part-ML as „grammatical hair splitting“ is cheap polemic. Not clearly identifying and distinguishing M vs ML would render this forum completely useless (for anyone who comes looking for answers on how to own, fly and maintain an easa registered light airplane).

Last Edited by Snoopy at 23 May 18:02
always learning
LO__, Austria

is cheap polemic

I don’t agree.

Writing

Planes such as a TB20 CANNOT be maintained acc. to Part-M when flown privately.

is not helpful to the reader. What one should write is e.g.

Planes such as a TB20 no longer need to be maintained acc. to full Part-M when flown privately. It is now called Part-ML.

I could maintain my TB20 (if it was G-reg) under a full 145 regime, if I wanted to waste money. One local sightseeing outfit was doing that with a C172…

Administrator
Shoreham EGKA, United Kingdom

You can’t be serious. I tried to convey exactly that message (If plane < 2730kg + private flying = very liberal maintenance acc. Pt. ML for owner) in dozens of posts.

Referring to Part-M* and ML as the same „over zealous EASA thing“ is what is misleading here, not me pointing out that, for the advantage of the owner pilot, Part-M cannot be used.

EASA probably did that (create an Annex called Part-ML) to have a clean sheet design and make it 100% clear that national authorities cannot screw it up by „national interpretation“. They are legally not allowed to accept a Pt.-ML owner declared AMP for approval.

Last Edited by Snoopy at 23 May 18:48
always learning
LO__, Austria

Snoopy wrote:

EASA probably did that to make it 100% clear that national authorities cannot screw it up. They are legally not allowed to accept a Pt.-ML owner declared AMP for approval.

Well… 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.

ELLX

Of course. The CAA can also inspect your aircraft anytime. What they can’t do is approve an owner declared AMP, because the liability lies with the declarer.

Just declare an AMP and base it on

EASA MIP + ADs + Airw. Limitations. What is there to be non compliant?

always learning
LO__, Austria
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