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#1615375
As I understand it, for aircraft not involved in CAT (less than 5,700kg(?)):

1) Upon initial construction, an aircraft is issued with a non-expiring CofA, valid for 12 months.

2) A maintenance schedule/programme is drawn up by a Part M Subpart G approved CAMO for a specific aircraft, which includes such things as 50/100 hr checks, annual inspections, etc. The CAMO also ensures all SBs/ADs are implemented, etc.

3) A Part M Subpart F Organisation (apparently also a Part-145(?)), which may be the same organisation as the CAMO, is employed/subcontracted to carry out the maintenance work (except for those maintenance tasks which may be performed by the owner).

4) Provided the maintenance schedule as stipulated by the CAMO is adhered to, the CofA is revalidated after 12 months with an ARC. The ARC is not a check in itself (but might be signed off for at the same time as the aircraft's annual), but rather paperwork which confirms that all maintenance tasks as stipulated by the CAMO have been carried out correctly.

5) The aircraft "operator/owner" is responsible for ensuring all of the above takes place (i.e. responsible for signing up with a CAMO)

Firstly: Is this correct?

Secondly, some caveats/questions to the above:

- For ELA1 aircraft under 1,200kg, as I understand it, the owner need not employ a CAMO but may draw up his own maintenance schedule that meets the requirements of the EASA MIP (Minimum Inspection Programme). This formerly fell under LAMP (Light Aircraft Maintenance Programme).

- Does the term 'controlled environment' refer to the adherence of the CAMO schedule (i.e. the aircraft has been attached to the same CAMO and operated in accordance with its schedule)?

I've been trying to find a bite-sized summary of non-CAT GA maintenance (i.e. for those people who may wish to consider ownership in the future or who are just interested) but have been struggling through the mass of EASA documents (some of the CAA ones were more helpful).

Many thanks.
#1615956
Judging by the lack of responses, either this is a very easy question which no-one can believe has been asked, or it's so complex, no-one knows the answer. I'm betting on the latter - but I'll give it a go!

VOZzer wrote:As I understand it, for aircraft not involved in CAT (less than 5,700kg(?)):

I'll assume you mean a certificated aircraft - the rules are different for home-builds, orphaned, microlight and several other classes of aircraft.
1) Upon initial construction, an aircraft is issued with a non-expiring CofA, valid for 12 months.

It's non-expiring, so it's valid forever unless rescinded, however it is rendered valid for 12 months by having an ARC issued at the same time.
2) A maintenance schedule/programme is drawn up by a Part M Subpart G approved CAMO for a specific aircraft, which includes such things as 50/100 hr checks, annual inspections, etc. The CAMO also ensures all SBs/ADs are implemented, etc.

The owner is reponsible for drawing up the maintenance programme, not the CAMO, however many people pay their CAMO to do this for them.
3) A Part M Subpart F Organisation (apparently also a Part-145(?)), which may be the same organisation as the CAMO, is employed/subcontracted to carry out the maintenance work (except for those maintenance tasks which may be performed by the owner).

All tasks can be carried out by the owner, however many require signing off by a licenced engineer before the aircraft can take to the air.
4) Provided the maintenance schedule as stipulated by the CAMO is adhered to, the CofA is revalidated after 12 months with an ARC. The ARC is not a check in itself (but might be signed off for at the same time as the aircraft's annual), but rather paperwork which confirms that all maintenance tasks as stipulated by the CAMO have been carried out correctly.

The CAMO or a sub-part G organisation can extend the ARC by 12 months on two occasions if they are happy that the maintenance has been documented correctly. Every third year, a physical inspection is required of the aircraft before a new ARC is issued.
5) The aircraft "operator/owner" is responsible for ensuring all of the above takes place (i.e. responsible for signing up with a CAMO)

The aircraft owner is responsible for everything, including the standard of the maintenance and paperwork. Paying a CAMO doesn't absolve the owner of this responsibility.
Firstly: Is this correct?

Close - but only if my understanding is correct! My comments above are worth exactly what you paid for them - i.e. nothing!
Secondly, some caveats/questions to the above:

- For ELA1 aircraft under 1,200kg, as I understand it, the owner need not employ a CAMO but may draw up his own maintenance schedule that meets the requirements of the EASA MIP (Minimum Inspection Programme). This formerly fell under LAMP (Light Aircraft Maintenance Programme).

Not sure - that's a subtlety I haven't looked into mainly because my shareoplane is used for training and this exemption (if it exists) doesn't apply.
- Does the term 'controlled environment' refer to the adherence of the CAMO schedule (i.e. the aircraft has been attached to the same CAMO and operated in accordance with its schedule)?

It means all work undertaken by licensed engineers under the authorisation of the CAMO - no pilot maintenance.
#1615987
Many thanks for your response. My main purpose in asking this is to further my own knowledge; as a hirer I'm not as sharp on these things as perhaps, say, an owner.

One thing: If the owner can completely declare his own maintenance schedule, and the CAMO does not actually carry out repairs, then it seems that the CAMO's only function is that of a 'maintenance manager' which could surely just be carried out also by the owner themselves?

Another question, with hopefully an obvious answer (please forgive!):

If the owner draws up his own maintenance schedule (and somehow doesn't include an annual check in it), and the aircraft need only be physically inspected every 3 years, where is the actual legal requirement for an annual? Is this found in a 'minimum requirements for a maintenance schedule' document or is it laid down by the aircraft manufacturer and thus must be adhered to by the owner. Or is it simply a case that such a maintenance schedule would never be approved? I'm aware of the MIP but this seems only to apply to 'non-complex ELA1 aircraft'; is there an equivalent for say, a PA28R? Or must one simply wade through the Part M documentation?

Many thanks once again.
#1615994
The owner is responsible but can delegate that responsibility to a CAMO under contract, which is what we do.

For an ELA1 aircraft (under 1200 kg MTOM) the owner now MUST create a SDMP, that must meet some basic criteria either based on the manufacturer's recommended maintenance schedule or on a minimum inspection programme available from EASA.

For ELA2, which includes PA28, LAMP still applies in the UK.
#1616047
VOZzer wrote:As I understand it, for aircraft not involved in CAT (less than 5,700kg(?)):

1) Upon initial construction, an aircraft is issued with a non-expiring CofA, valid for 12 months. .


Not helpful to say valid for 12 months. The CofA doesn't expire. If certain actions are not taken the CofA could become invalid, but that doesn't mean it is only valid for 12 months.

VOZzer wrote:2) A maintenance schedule/programme is drawn up by a Part M Subpart G approved CAMO for a specific aircraft, which includes such things as 50/100 hr checks, annual inspections, etc. The CAMO also ensures all SBs/ADs are implemented, etc..


As already mentioned the CAMO doesn't have to write the programme, you can do it yourself, but you may have a tough time persuading a maintenance company to use it. Most MPs will be based on the manufacturer's recommended prog. Those who put their badge on LAMP are taking the lazy way out.

VOZzer wrote:3) A Part M Subpart F Organisation (apparently also a Part-145(?)), which may be the same organisation as the CAMO, is employed/subcontracted to carry out the maintenance work (except for those maintenance tasks which may be performed by the owner)..


Again the terms you use aren't helpful. The owner selects a maintenance organisation to maintain the aircraft. This may be a company approved under Part 145, or under Part M sub-part F. In either case the company must have your type of aircraft on its approval list. In reality there isn't much difference (except perhaps their charges) , they will both do the work called up by the camo. Yes, most maintenance organisations are also CAMOs. No the whole CAMO thing doesn't make much sense for small aeroplanes, but that's what you have to do. Pilot/owner maintenance is another issue all together. Agree up front what work you want to do - there is a long list of what you are permitted to do. Most owners are not as competent as they think and don't end up saving themselves much.


VOZzer wrote:4) Provided the maintenance schedule as stipulated by the CAMO is adhered to, the CofA is revalidated after 12 months with an ARC. The ARC is not a check in itself (but might be signed off for at the same time as the aircraft's annual), but rather paperwork which confirms that all maintenance tasks as stipulated by the CAMO have been carried out correctly..


No. A valid ARC must be in place at all times. For a new aircraft one is issued with the CofA. Following a successful Airworthiness Review a new Airworthiness Review Certificate can be issued by the camo. The AR doesn't have to coincide with a maintenance check, but often does. There is quite a lot of stuff checked during an AR, including a survey of the aircraft.

VOZzer wrote:5) The aircraft "operator/owner" is responsible for ensuring all of the above takes place (i.e. responsible for signing up with a CAMO).


Yes, the owner is responsible, but there is no need to 'sign up', see below about controlled environment.

VOZzer wrote:Firstly: Is this correct?

Secondly, some caveats/questions to the above:

- For ELA1 aircraft under 1,200kg, as I understand it, the owner need not employ a CAMO but may draw up his own maintenance schedule that meets the requirements of the EASA MIP (Minimum Inspection Programme). This formerly fell under LAMP (Light Aircraft Maintenance Programme).

- Does the term 'controlled environment' refer to the adherence of the CAMO schedule (i.e. the aircraft has been attached to the same CAMO and operated in accordance with its schedule)?

I've been trying to find a bite-sized summary of non-CAT GA maintenance (i.e. for those people who may wish to consider ownership in the future or who are just interested) but have been struggling through the mass of EASA documents (some of the CAA ones were more helpful).

Many thanks.


A controlled environment refers to the maintenance oversight and assumes the owner has signed an agreement with the CAMO. The CAMO issues work instructions for all maintenance required. The pilot/owner can do those tasks on the P/O list but must supply worksheets to the CAMO. Work done away from base (eg puncture repair while on a trip) can be done by any approved org, with your aircraft type on their capability list, when instructed by the CAMO, again worksheets are required. If the aircraft is maintained in a controlled environment the ARC may be extended twice, and so only renewed every 3 years. If you change CAMO the next ARC will have to be a renewal, not an extension.

I have never found a 'bite sized' explanation of light aircraft maintenance. It can be unnecessarily complex at times.
#1616155
Thanks very much for your help chaps!!

I'd again just like to ask the question regarding the aircraft's annual: Where does the (legal) requirement for this actually come from? Is it from (a) the pilot's declared maintenance programme (i.e. his/her programme would never be approved unless it contained an annual check as part of it) or (b) something directed by the CAMO to be performed on an annual basis?
#1616176
The requirement for an annual comes from the maintenance programme, that can be no less onerous that the MIP defined by EASA (Google it). An SDMP does not need to be approved. However, the person who certifies the aircraft as airworthy following the annual may insist on expanding the inspection if more work is required to ensure airworthiness. Most CAMO/maintenance organisations are unlikely to work to a programme you have invented without involving them.
#1616517
So after a search around, am I to understand that this:

https://www.easa.europa.eu/sites/defaul ... M%20Part-M).pdf

Is the appropriate EASA document detailing minimum inspection standards?

One thing: In section M.A.302 (which seems to detail MIP requirements), apart from a MIP template which applies to all 'non-complex motor power aircraft', all of the inspection information tables and associated intervals seem to only apply specifically to ELA1 aircraft & sailplanes.

One other thing: The document also states that the MP can only be approved directly by the owner for the case of ELA1 aircraft, otherwise 'indirect approval by the CAMO' or 'direct approval by NAA' is required - I was led to believe from some of the above responses that an owner could self-declare even for a non ELA1 type aircraft (or maybe they can write the programme, but not approve it). Sorry if I have misunderstood!
#1719677
Holy thread resurrection!

Correct - you need both a valid ARC and have completed an Annual Inspection within the last twelve months (which can be extended up to thirteen months in some circumstances) for an aircraft to be deemed legally airworthy. At a year plus 6 weeks since the Annual Inspection, the aircraft must be beyond the one month extension, and thus should not be flown without a specific Permit to Fly being issued.
#1719681
I've just discovered this useful document on the EASA website:

Easy Access Rules for Continuing Airworthiness

I'm not sure I'd call it "easy access" at 826 pages, but it's a darned sight more readable than any other document I've seen recently on Part-M. Caveat emptor: it was published in April, it probably deviates from the final Part-ML wording in key places. I suspect it's probably still the best way "into" the quagmire of the regs, however.