ELA1 / ELA2 maintenance (merged)

Peter wrote:

I have just replaced all the firewall-forward hoses for £500, plus £500 for one metric one. One TB20 owner emailed me recently that his company billed him £2500 for the hoses, all purchased from Socata.

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….

I usually decide what little project I’d like to take on prior to the Annual, and mail order most of the parts, oil, filter etc in preparation.

FWIW, we maintain our club planes in-house, but the CAMO part is outsourced, to different providers to boot (dependent on type). All planes are SP-reg, so EASA.

The private owners of a local ELA2 plane involve a CAMO in a setup similar to what Peter is looking for: the CAMO does the paperwork, a local Part66 guy does the work. The CAMO signs off the ARC two out of three years. Once every three years the plane will need to be looked over by another company, who will issue a new ARC, which will get revalidated by the CAMO the following two years. I’m pretty sure the mechanic specs all the parts purchases (and probably even orders them) but the invoices go to the plane owners, because that is the way they want it. I’m sure the CAMO has nothing to do with any work or parts.

Peter, I can only offer what the Dutch CAA told me a few months ago: “expected before the end of 2017, and basically the same rules as for ELA-1”

Thanks, Aart; that will be interesting. These are the people who pay the most money to keep their planes in the air.

The private owners of a local ELA2 plane involve a CAMO in a setup similar to what Peter is looking for: the CAMO does the paperwork, a local Part66 guy does the work

Well, I can see this can take several forms, but all the time there is a “company” involved you are

• paying for it (see some recent posts where a CAMO was charging a couple of k) but there is no need for the function because the EASA66 guy is perfectly capable of using his brain to perform the service, and
• the CAMO has a veto on a lot of stuff (see posts by e.g. wigglyamp here) and this raises costs – e.g. some demand EASA-1 forms for everything when an 8130-3 is good for new parts. Only today I have had emails with an old contact who actually can’t get the parts he needs with an EASA-1 form; only an 8130-3.

For the other stuff and for the avoidance of doubt, the posts I deleted were off topic and basically moaning nonsense, plus some which were starting new threads about old threads. Contrary to claims, I don’t delete technical dissent. I try hard to keep EuroGA reasonably informative (and I know enough about GA to keep things focused) but at times it gets out of hand and things have to be cleaned up otherwise a thread would go off the rails. Historically it was one poster who created most of my work there (and he’s back under a 4th reincarnation) and lately it seems to have become two. Of course we will now have a little storm in the background (so a bunch of people will get emails and PMs slagging me off) but that will pass. All a part of the job

Peter wrote:

Well, I can see this can take several forms, but all the time there is a “company” involved you are

For the lasts 15 years, we never have involved a company (no CAMO, no approved maintenance organization for usual maintenance) for our ELA2 and it works just fine.
As said earlier, it requires a fair amount of involvement but there is nothing magic about it…

How exactly do you run an ELA2 with a freelance engineer and without a CAMO, @Guillaume?

This is under the DGAC regime, correct?

Peter wrote:

How exactly do you run an ELA2 with a freelance engineer and without a CAMO, @Guillaume?

This is under the DGAC regime, correct?

Per EASA Part-M.
I’m doing continued airwothiness management myself. My father is Part 66 and releases his work.

There is no such thing as DGAC regime for F-reg annex I aircraft.
There is little DGAC involvement.
For my ELA2 the DGAC mandates (beyond EASA requirements) :
- Avionics check every 2 years at an approved maintenance organization for IFR ops.
- Additional engine checks (about 4 hours of labor) at an approved maintenance organization every year when the engine is being run beyond TBO.

Just to add another data point…

• I own an ELA2 aircraft
• I am the CAMO
• I use a Part 145 company for maintenance, they in turn have a Part 66 licensed engineer certify the work. In addition, they perform an annual review and issue the ARC and documentation in support of the work performed which is then entered into the aircraft, engine and propeller logbooks.
• I provide any parts necessary, with guidance as necessary from the Part 66 engineer, with whom I have a great working relationship. The Part 145 company would be happy to supply parts if I wanted them to, but they actually advised me to source them myself (and have recommended sources in some cases) in order to keep my costs down. I feel they understand the plight of the sole owner.
• Invoices are routinely reviewed with the owner of the Part 145 company and the Part 66 engineer. Adjustments are made when necessary.
• The Part 66 engineer and I are about to start development of a Self-Declared Maintenance Programme (SDMP) in preparation for the introduction of Part-M Light. My intention is that I will be ready to transfer to the SDMP as soon as it is possible to do so.

I am very happy with this arrangement. It works well and I think Part-M Light will make it even better.

Peter wrote:

the CAMO has a veto on a lot of stuff (see posts by e.g. wigglyamp here) and this raises costs – e.g. some demand EASA-1 forms for everything when an 8130-3 is good for new parts. Only today I have had emails with an old contact who actually can’t get the parts he needs with an EASA-1 form; only an 8130-3.

You’re mis-representing my comments again Peter. The post you point to with my name is nothing to do with a CAMO having a veto – it’s about the legality of otherwise of using TC data (maintenance manuals, IPCs etc) as the basis of modifying an aircraft.

Incidentally, in many cases an FAA 8130-3 is perfectly acceptable for an EASA aircraft , just as an EASA Form 1 is good on an N-reg aircraft. You need to read the bi-lateral agreement where it’s all laid out very clearly. Simply put for EASA aircraft, new parts are good to go with a straight 8130-3. Used or repaired parts need a dual-release 8130-3 where the FAA repair station has EASA-validation.

Finners wrote:

I am the CAMO

Do you mean that you really are a CAMO or that you do the CAMO work?

Part-ML is expected to come into force earliest Q4 2017 or latest Q1 2018. There has been some delays due to technical issues in the legal department in Brussels, as far as I have understood it has nothing to do with the text in Part-ML but only internal affairs.

When Part-ML is in force you may:

• Use a Part-66 person to do an annual inspection (just like today)
• The same Part-66 person can, if he/she has the necessary authorisation from the CAA, do the ARC renewal

This means that you do not need to go through any company to keep your aircraft airworthy.