@Snoopy
Ok, great, thanks for the clarification on that! Appreciated.
I then end up at Part-ML for maintenance (I wrongly thought that was called maintenance part-CAO as well), and part-CAO for airworthiness then, with the part-CAO manager approving my AMP
Then the original subject question remains if there is a legal requirement, for my type of prospect operation (remunerated/commercial DTO/ATO) , for Weight and Balance every 48 months and PLB (ELT) operational check every 12 months?
Airborne_Again wrote:
Yes. Part-M applies if the aircraft is used under an AOC. An ATO/DTO does not require an AOC and usually does not have one. Thus part-ML is not only an option, it is mandatory.
@Airborne_Again
Yes, got it, tacker. As mentioned above, I confused maintenance part-CAO with part-ML, wrongly thinking they were two different categories.
I see, your misunderstanding is believing it is ML or („vs.“) CAO. They both do not exclude each other.
1. First is <2730kg
Yes-ML No-M
2. For profit NCO operation
Yes-CAO AMP No-Voluntary CAO AMP or SDMP
Both commercial training and non profit training are regulated in Part-ML for maintenance rules.
Only commercial training aircraft require a CAO to approve their (Part-ML) AMP.
Yeager wrote:
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?
Yes. Part-M applies if the aircraft is used under an AOC. An ATO/DTO does not require an AOC and usually does not have one. Thus part-ML is not only an option, it is mandatory.
Peter wrote:
@Yeager I have merged your multiple posts. There is an Edit button, usable for up to 2hrs. So you don’t need multiple posts.
@Peter Sorry, yeah I see. Got ya, thx
@Fly310 wrote:
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.
What your saying, is precisely my understanding as well.
In my case it´s a company earning money (commercial transaction with invoice issued to the client (student)).
Hence, I´m trying to understand if the part-CAO produced AMP, for my <2730kgs non-complex SEP, in fact has to include the W&B and PLB (ELT) validity periods, considering it´s a commercial DTO/ATO. Thanks for your input!
@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.
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 wrote:
No, my aircraft is part-CAO managed, and they´ve created an AMP.
Then request that they remove the biannual weighting requirement!
Don’t PLB’s have maintenance details in the operating instructions in the package it comes in?
Eg Change battery every 12months or 24months.
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.
