Peter wrote:
Thanks for the info. Is this CAA approval route well established, especially in the UK and Germany, and roughly what does it involve?
Well established? Unfortunately not. This will be decided more or less by the CAA. I guess we will have to wait and see how it plays out…
Airborne_Again wrote:
Finners wrote:I am the CAMO
Do you mean that you really are a CAMO or that you do the CAMO work?
Ah, yes, I could have been clearer.
I do not hold CAMO approval, but I perform the CAMO work for my own aircraft and therefore I do not require an approved CAMO. The work is not difficult, it just requires time, thought, diligence and attention to detail. I quite enjoy it – up to a point. I cannot do it for others, though it was suggested to me by another Part 66 engineer that I should go about getting approval although I’m not terribly interested in doing so.
Finners wrote:
I do not hold CAMO approval, but I perform the CAMO work for my own aircraft and therefore I do not require an approved CAMO.
Do you mean your arrangement officially counts as controlled maintenance environment? It would be of no real importance for private flying, but e.g. for a flying school it would make a difference.
Ultranomad wrote:
Do you mean your arrangement officially counts as controlled maintenance environment? It would be of no real importance for private flying, but e.g. for a flying school it would make a difference.
Non-commercial flying schools do not need a controlled environment. That is clear from part-M.
(There was actually an amusing “incident” in Sweden a year or so ago. The CAA made a routine inspection of a club flight school (not mine) and found that a part 66 engineer had done limited work on the aircraft, meaning it was no longer in a controlled environment. The club asked for an exemption. After a while — apparently having read part-M more carefully — the CAA replied that an exemption was not needed since the aircraft didn’t have to be in a controlled environment.)
Ultranomad wrote
Do you mean your arrangement officially counts as controlled maintenance environment? It would be of no real importance for private flying, but e.g. for a flying school it would make a difference.
I don’t have the regulations to hand but my understanding (and what I do in practice) is that it is uncontrolled (see note) and therefore a full airworthiness review is required every year. I don’t consider that to be a significant concern, I prepare the paperwork for inspection and it takes the Part 66 engineer about an hour to look through it. It took two hours the first time because I was still learning.
Probably of greater importance for you is that to my knowledge this route is for Private NCO only, so that would preclude a flying school from doing this. If I wanted to use my aircraft for commercial operations, I just need to put it back into a controlled environment.
Note – I know of one instance where someone is doing something similar and their Part 66 engineer considers it to be a controlled environment and only does the full paper trail exercise every three years.
Finners wrote:
so that would preclude a flying school from doing this.
Only if the school is commercial.
Airborne_Again wrote:
and found that a part 66 engineer had done limited work on the aircraft, meaning it was no longer in a controlled environment. The club asked for an exemption. After a while — apparently having read part-M more carefully — the CAA replied that an exemption was not needed since the aircraft didn’t have to be in a controlled environment.)
Aircraft used under AOC can only be maintened by a company, and are not allowed to go outside the controlled environment. For private aircraft, or the club, you can keep it within the controlled environment, if you want the once in three year full ARC renewal. When an Part 66 engineer works on it’s, it gets outside the controlled environment and it would need a full ARC renewal each year. Could it be correlated with this? That it didn’t mind, but you did loose the 3 year ARC possibility?
Silvaire wrote:
For that job on my plane I purchased the hose in bulk, reused most of the existing fittings and assembled the hoses in the A&P IAs personal hangar, using his tools, under his supervision. A couple of the fittings weren’t reuseable and that cost $100 extra at $30 per fitting… ouch I do a lot of that stuff myself during every annual, and the hoses were completed last year. When we’re done he makes the logbook entries for both the maintenance work and the inspection and the combined cost is typically hundreds, not thousands. There are no invoices, records or paperwork except the logbook entries and 3-ring binder for parts receipts that I maintain….
This would be possible in Europe, under EASA regulations as well, it is just not as common as in the USA I would say.
Jesse wrote:
Aircraft used under AOC can only be maintened by a company, and are not allowed to go outside the controlled environment. For private aircraft, or the club, you can keep it within the controlled environment, if you want the once in three year full ARC renewal. When an Part 66 engineer works on it’s, it gets outside the controlled environment and it would need a full ARC renewal each year. Could it be correlated with this? That it didn’t mind, but you did loose the 3 year ARC possibility?No, it was quite clear that they simply hadn’t considered the possibility that under part-M aircraft used by a noncommercial training organisation could be outside a controlled environment. The reason is likely that while EASA regs make the distinction between commercial and noncommercial operations, the pre-EASA Swedish regs made the distinction between operations that required a permit and those that did not. Noncommercial flight schools require a permit so the CAA staff was still in the “permit” mindset.
In fact there was different opinions within the CAA with the section overseeing training organisations having a more relaxed view than did the section overseeing airworthiness. The latter actually claimed that by definition a training organisation was always commercial! Fortunately the Swedish CAA has now officially accepted that aircraft used for noncommercial training can be outside a controlled environment. Not all CAMOs have yet accepted that, however…
Jesse wrote:
Remember that ARC and Annual are not the same
Obviously they the same thing are on N-registration. Or perhaps more precisely the FAA Airworthiness Certificate never expires, so there is no periodic activity except an annual inspection and logbook entries by the authorized mechanic.
I wonder if the Earth’s axis has tilted more than usual in the last 12 months? Too many crazy things happening. It can’t be a coincidence. 
