Although I’m not as directly involved with the maintenance of certified aircraft as I used to be, I think some words of guidance are needed here to avoid some of the apparent misinterpretation and misunderstandings written in this thread.
G-AWFZ holds an EASA Certificate of Airworthiness and in the UK this entitles it to be maintained to the Self Declared Maintenance Programme (SDMP). At 1021 kg MTWA, it is classed as an ELA1 aircraft (non-complex, sub 1200 kg).
The maintenance tasks that a pilot/owner can carry out on their aircraft are clearly defined in Part-M, Appendix VIII: ‘Limited Pilot Owner Maintenance’. Part-M can be tricky to find on the EASA website, it has to be said. There is an excellent Swiss training organisation called QCM through which you can gain access to the EASA documents (including Part-M) free of charge: https://www.qcm.ch/en/
As per the CAA’s CAP 1454 SDMP ‘Guidance Document’ there are effectively three options for its Maintenance Programme:
1. An MP approved by the CAA (or a CAMO with appropriate approvals)
2. Manufacturer’s Maintenance Programme
3. EASA Minimum Inspection Programme
Note: The EASA MIP is broadly similar to the FAA FAR ‘Appendix D to Part 43’ inspection and in that regard, is now broadly similar to FAA rules.
From the EASA website, FAQ n.43423 includes the following statement:
‘In accordance with Part-M Appendix VIII point (b)(9), the tasks that are part of the annual or 100h check contained in the ‘Minimum Inspection Programme’ do not qualify for pilot-owner maintenance referred to in M.A.803.’
‘…the declared AMP shall not be less restrictive than the ‘Minimum Inspection Programme’ (MIP) referred to in point M.A.302(i).’https://www.easa.europa.eu/faq/43423
This means you cannot do less than is called up in MIP. Dress it up how you like but MIP is pretty much the same as any manufacturer’s maintenance schedule or the old CAA LAMS/LAMP – you have to take bits off to look inside then put the bits back on etc. MIP does it in less pages by having fewer individual tasks but it’s still the same.
The aircraft owner has always been responsible for ensuring that their aircraft has been maintained ‘correctly’, ie in accordance with the requirements. That’s not so say they are responsible for the ‘standard’ of maintenance (that remains the responsibility of the signatory of the Certificate of Release to Service (CRS)) but that maintenance has been carried out at the correct times.
Airworthiness Directives as published by the State of manufacture and the appropriate regulating authority for the State of registration (ie for the UK registered EASA CofA aircraft – EASA), remain as they always have been, legally mandatory.
Airworthiness Limitations which are covered in Chapters 4 and/or 5 of the aircraft’s Maintenance Manual are also legally mandatory.
Service Bulletins and other such continuing airworthiness data should be technically assessed and complied with as deemed necessary.
The SDMP ‘template’ (as linked in CAP 1454) is a template but actually perfect for the job it is designed to do. No one can complain that your SDMP data is incorrect if you’re using the CAA’s template.
The required signature for the ‘approval’ of the SDMP is either the owner or a contracted CAMO or the competent authority (CAA) – not all of them, only one is required. The SDMP is not approved by the CAA but of course they may come across it if they choose the aircraft for an ACAM survey at some stage.
FAA and EASA Airworthiness Directives are available free of charge. Some manufacturer’s provide all of their manuals and continuing airworthiness data FOC as well: Diamond, Tecnam, Extra, Lycoming, TCM and Rotax to name a few. Others choose to charge for the privilege of seeing the manuals, such as Cessna and Piper although SBs etc may be available FOC. Normally you can find current revisions of manuals from ‘unapproved sources’ if you look hard enough.
The signatory of the Airworthiness Review Certificate (ARC) is not responsible for ‘saying the aircraft is airworthy’. The signatory of the CRS for maintenance or a check signs to say that the aircraft is fit for release to service but not the ARC signatory. The ARC is, as its name suggests, a review of the maintenance carried out since the last ARC issue or extension. A new ARC also requires an inspection of the aircraft but not the complete aircraft – it’s more of a sampling exercise. The ARC signatory may not even be a licenced engineer.
Maintenance is a necessary evil that owners don’t like to pay for – it’s not the same as spending hard-earned cash on new avionics or paint etc. As some have said on this thread, there is a lot of background work involved in keeping the aircraft ‘airworthiness’ up to date, ie paperwork, ADs, SBs etc as well as pumping up the tyres and changing the oil and that labour input has to be paid for if the owner isn't confident in doing it themselves.
Hopefully, that clears some points up. Not all engineers are out to shaft owners – there are some very honourable ones out there. If in doubt, there are enough aircraft owners on this Forum to question as to how they get on. I know for a fact that many are quite happy with their engineering support. Find a good engineer, work with them to maintain your aircraft and it’ll pay dividends in the long run.
Lastly, if anyone has any other questions and is going to AeroExpo, the CAA have a stand there….