Gents,
I´m still new to light aircraft ownership and learning.
My aircraft is under part-CAO with a Portuguese company and the aircraft is on F-reg.
My AMP has Weight and Balance validity of 48 months (Reg. 965/20212). It is not clear to me if there is a requirement for this – any inputs?
Equally I have the McMurdu 220 PLB (ELT) inspection marked down for 12 months inspection. Any input on this?
Your aircraft is under Part-ML I presume, and you have a contract with a CAO which approves your AMP.
Part-ML, when using the MIP, stipulates
Review weighing record to establish accuracy against installed equipment.
Weigh the aircraft as required by Part-NCO or Part-SPO, as applicable.
If using the DAH AMM ICAs instead of the MIP, it will say something similar (e.g. new weighing record required when something is modified).
NCO.POL.105 Weighing
Regulation (EU) 2018/1975 stipulates
(a) The operator shall ensure that the mass and, the CG of the aircraft have been established by actual weighing prior to the initial entry into service of the aircraft. The accumulated effects of modifications and repairs on the mass and balance shall be accounted for and properly documented. Such information shall be made available to the pilot-in-command. The aircraft shall be reweighed if the effect of modifications on the mass and balance is not accurately known.
(b) The weighing shall be accomplished by the manufacturer of the aircraft or by an approved maintenance organisation.
GM1 NCO.POL.105 Weighing
ED Decision 2018/003/RGENERAL
(a) New aircraft that have been weighed at the factory may be placed into operation without reweighing if the mass records and, balance records have been adjusted for alterations or modifications to the aircraft. Aircraft transferred from one EU operator to another EU operator do not have to be weighed prior to use by the receiving operator, unless the mass and balance cannot be accurately established by calculation.
(b) The mass and centre of gravity (CG) position should be revised whenever the cumulative changes to the dry operating mass exceed ± 0.5 % of the maximum landing mass or, for aeroplanes, the cumulative change in CG position exceeds 0.5 % of the mean aerodynamic chord. This may be done by weighing the aircraft or by calculation. If the AFM requires to record changes to mass and CG position below these thresholds, or to record changes in any case, and make them known to the pilot-in-command, mass and CG position should be revised accordingly and made known to the pilot-in-command.
In short, there is no requirement for such a short validity in your AMP.
Regarding the ELT, check the ICA (instructions for cont. airworthiness) if there are any provisions… and note the difference between a functional check and operational check.
OPERATIONAL TEST AND FUNCTIONAL TEST
An operational test (or operational check) is a task used to determine that an item is operating normally. It does not require quantitative tolerances.
A functional test (or functional check) is a quantitative check to determine if one or more functions of an item performs within the limits specified in the appropriate maintenance data. The measured parameter should be recorded.
An operational test once a year of an ELT would be to activate it for less than 30 seconds
A functional test would involve avionic bench testing equipment.
Curious: To which part does the “No” in your answer apply?
Unless your airplane is more than 2730kg or used in an AOC (air transport), Part-ML applies.
One thing is an ELT, fixed to and a documented part of the aircraft equipment, another is a PLB, which I assume is not fixed to the aircraft and does not appear as part of the equipment in the aircraft documentation. If the latter applies you’re free do do what you want in terms of maintenance I would say.
Don’t PLB’s have maintenance details in the operating instructions in the package it comes in?
Eg Change battery every 12months or 24months.
Yeager wrote:
No, my aircraft is part-CAO managed, and they´ve created an AMP.
Then request that they remove the biannual weighting requirement!
Snoopy wrote:
Curious: To which part does the “No” in your answer apply?Unless your airplane is more than 2730kg or used in an AOC (air transport), Part-ML applies.
Hi @Snoopy,
The “No” was referenced to the part-ML. I could easily be wrong, but I was under the impression that to use the aircraft, which is less than 2730kgs, for PPL flight instruction and receive remuneration in a DTO/ATO environment, I would need to have the aircraft under a part-CAO airworthiness management and accordingly part-CAO or part-145 maintenance? – therefor I thought part-ML was not an option. Did I get that wrong? Cheers man.
aart wrote:
One thing is an ELT, fixed to and a documented part of the aircraft equipment, another is a PLB, which I assume is not fixed to the aircraft and does not appear as part of the equipment in the aircraft documentation. If the latter applies you’re free do do what you want in terms of maintenance I would say.
That´s what I am trying to establish.
Snoopy wrote:
In short, there is no requirement for such a short validity in your AMP.Regarding the ELT, check the ICA (instructions for cont. airworthiness) if there are any provisions… and note the difference between a functional check and operational check.
I will have a closer look at this. Good point, thanks.
Airborne_Again wrote:
No, my aircraft is part-CAO managed, and they´ve created an AMP.Then request that they remove the biannual weighting requirement!
I will most certainly do so, as soon as I have establish that in fact this is not a legit requirement from their side.
This is what the part-CAO replied to me:
“..Weight and Balance:
In Portugal we use the CTI 00-01 that is a 60 Months periodicity
I think that the most reasonable is a 48 Months check ( EU Reg. 965/2012 )
The regulation that you present is true, but is only part of it. The GM1 NCO.POL.105 Weighing, only referred conditions for weighing the aircraft.
Resuming: weighing
1. every 48 Months or
2. changes to the dry operating mass exceed ± 0.5 % of the maximum landing mass, or
3. the cumulative change in CG position exceeds 0.5 % of the mean aerodynamic chord.
My suggestion: Change from 60 Months to 48 Months
SECTION 3
Mass and balance C H A P T E R 1 M o t o r – p o w e r e d a i r c r a f t
CAT.POL.MAB.100 Mass and balance, loading (a) During any phase of operation, the loading, mass and centre of gravity (CG) of the aircraft shall comply with the limitations specified in the AFM, or the operations manual if more restrictive.
▼B 02012R0965 — EN — 25.09.2019 — 015.001 — 174 (b) The operator shall establish the mass and the CG of any aircraft by actual weighing prior to initial entry into service and thereafter at intervals of four years if individual aircraft masses are used, or nine years if fleet masses are used. The accumulated effects of modifications and repairs on the mass and balance shall be accounted for and properly documented. Aircraft shall be reweighed if the effect of modifications on the mass and balance is not accurately known…"
@Yeager
Regarding the CAO requirement.
If the DTO/ATO is non-commercial, eg. an aero club, there is no requirement to have a contract with a CAO management or maintenance.
If however the DTO/ATO is commercial, a company earning money, there is a need for the CAO services that you are getting now.
