Public or Private C of A Advantages and Disadvantages

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Demonduck
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Public or Private C of A Advantages and Disadvantages

Post by Demonduck » Wed Apr 18, 2012 1:10 pm

Public or Private C of A Advantages and Disadvantages

Does any know the main differences between a Public or Private C of A Advantages or Disadvantages?

I looked through some forums but its not that clear.
Is it true that you cannot even perform the 50 hour yourself or legally even change a tyre?

William

StrikeCommand
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Re: Public or Private C of A Advantages and Disadvantages

Post by StrikeCommand » Wed Apr 18, 2012 10:04 pm

There are no Certificates of Airworthiness any more. They have been replaced by an Airworthiness Review Certificate which is reviewed every year, usually at Annual Inspection time. It lasts 2 years but is reviewed and extended after year one.
Re 50 hour checks:
Under CAA rules, a PPL who is also the owner of the aircraft could do a 50 hour check on his aircraft.
Under IAA rules this was only allowed subject to following conditions:
Must get prior written approval of IAA.
Must have the latest version of the aircraft maintenance manual available.
Must be recommended to IAA (as competent to do it) by a licensed engineer.

Everything is now under auspices of EASA. Now obliged to keep aircraft in a "Continuing airworthiness environment". That means signing a contract with an approved maintenance organisation. That contract or agreement will have a schedule of tasks approved for carrying out by the owner - which is usually "NONE"! (and rightly so).

dreamer1
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Re: Public or Private C of A Advantages and Disadvantages

Post by dreamer1 » Wed Apr 18, 2012 10:19 pm

StrikeCommand wrote: That contract or agreement will have a schedule of tasks approved for carrying out by the owner - which is usually "NONE"! (and rightly so).
Care to elaborate.

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Re: Public or Private C of A Advantages and Disadvantages

Post by Earhart » Thu Apr 19, 2012 9:47 am

While I am sure that StrikeCommand didn't mean it literally, the Certificate of Airworthiness still remains in vogue. For EASA aircraft, these are augmented by an Airworthiness Review Certificate (ARC). The CofA, along with the ARC where applicable, form part of the 'Documents to be carried on board.'

With regards to Pilot-Owner Maintenance, the information below is available in EASA Part M - which you can read and interpret yourself, but this is just some useful information that may provide guidance.

For Privately operated non-complex aircraft under 2730kg MTOM:
Any person maintaining an aircraft which they own or jointly own, provided they hold a valid pilot licence for that aircraft, may perform limited pilot-owner maintenance tasks.(AMC M.A.402) The tasks which can be carried out are listed in Appendix VIII to Part M (they usually include everything up to a 50FH Check and this doc is worth reading).

To qualify as a Pilot-Owner, in any EASA Member State, you must:
Hold a valid pilot licence (issued or validated by a Member State for the aircraft type or class rating) and
Own the aircraft, either as sole or joint owner (M.A.803)

The names of the Pilot-owners competent and designated to perform Pilot-owner maintenance must be included in the Maintenance Programme. This is approved by the authority - so criteria to establish that you are competent may vary e.g. signed off by an engineer, assessed by the authority, completed a course or randomly audited by the authority in the performance of some task(s). The scope of what you may perform should also be included in the Maintenance Programme. (M.A.803)

The pilot-owner is always responsible for any maintenance that s/he performs. Before carrying out any tasks, s/he must satisfly themselves that they are competent to do the task. It is the responsiblity of the owner to familiarize themselves the the standar Mx practices for the aircraft and with the Mx Prog. (Appendix VIII to Part M)

The Pilot-Owner may ONLY certify work they have performed themselves. Remember that the wording for this CRS is different to that which your Mx Org signs (M.A.801 (f)).
'certifies that the limited pilot-owner maintenance specified except as otherwise specified was carried out in accordance with Part M and in respect to that work the aircraft is considered ready for release to service.'

The owner of a privately operated aircraft (under 2730kg MTOM) is not obliged to enter into a contract for managment of the continuing airworthiness management and may develop their own Maintenance Programme - should they so choose. (M.A.201 (a)) You are obliged to contract a maintenance provider (Part 66 licence holder, Part M Supbart F organisation or Part 145 organisation) to carry out any maintenance beyond that listed as pilot-owner maintenance in your maintenance programme.

The fact that limited pilot-owner maintenance is carried out does not mean that your aircraft is not in a controlled enviroment (if you contract a CAMO). (AMC M.A.901 (b)) provided that you tell your CAMO within 30days.

For Commercial Operations (Aerial Work)
The aircraft must be maintained by an organisation approved under Part M Subpart F or Part 145 (this may be where the question originated)

For Commercial Air Transport
The aircraft must be maintained by an organisation approved under Part 145.

As always, these opinions are my own.

StrikeCommand
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Re: Public or Private C of A Advantages and Disadvantages

Post by StrikeCommand » Thu Apr 19, 2012 11:55 pm

Earhart is quite correct about it being possible to draw up your own maintenance programme. I have looked at the templates provided for doing so and while it is possible to do it, it must then be approved/accepted by the IAA for implementation. You could take an existing MP for another aircraft of exactly the same type and apply it to yours. That might be easier now than it was when the requirement was first introduced. I would guess that it would be risky in that IAA might not accept it initially and you might have to go through several iterations. One might not have the time or more importantly the expertise to do that in a reasonable time and still keep your aircraft flying legally.
The big difference and advantage of this system as compared to the previous set up (and I know this is not what the original question was about), is that now you have an approved maintenance organisation who are managing your maintenance. They will be telling you (not that that should be necessary as you should make sure that you know) when your next 50 hr check etc is due and will be expecting you to deliver the aircraft to them in time for it to be done. Previously, owners were managing their own maintenance and airworthiness and some were taking shortcuts and just not doing the scheduled maintenance on time or at all in some cases. They could do this without anyone necessarily knowing about it.

Re the elaboration requested by dreamer1:
I know that many aircraft owners delight in bringing car loads of nice shiny red toolboxes with extensive collections of tools along to the airfield and then tinker in the hangar with their aircraft. I am not one of them. No doubt they are very competent in lots of ways and may know a lot about what they are doing (or at least think they do). I have plenty of tools and all sorts of engineering equipment too but I never bring any of it anywhere near my aircraft. I have 2 degrees in Mechanical/Aerospace Engineering and could talk at length about stress analysis, fatigue, aerospace alloys, modal analysis, thermodynamics etc etc and that could fool me into thinking that I would know what I would be doing if I went tinkering too. However none of that qualifies me to maintain my aircraft. I have not served an apprenticeship and am not a licensed engineer etc. So therefore I stick to things like checking the engine oil level and topping it up and keeping the aircraft clean etc. Everything outside of that - even changing a landing light bulb - is left to the people who are qualified. There are too many ways to get things wrong when it comes to aircraft. If owners/pilots know so much about it and are so competent then why aren't they wokrinat it full time and making their living from it? No doubt all of that will upset a lot of people but it's just my personal view and I'm sticking to it. :)

Demonduck
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Re: Public or Private C of A Advantages and Disadvantages

Post by Demonduck » Fri Apr 20, 2012 12:55 pm

Many Thanks for the information to you both and the PM's.

William

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