Originally Posted by
Whopity
Do you have a reference for this? As I have searched everywhere for this information and drawn a blank I asked the only person I know who is actually doing it. I was referred to the CAMO who will assess the maintenance situation.
I couldn't find an answer in the available information so I wrote to the CAA in 2016 for clarification and received the following response:
CAP1335 tried to paint the picture of how the two legal frameworks of EASA and ANO will be brought together, for example the abolition of the ANO term ‘aerial work’. The changes to the ANO do not directly affect EASA aircraft, since these are under the legal authority of the EASA regulations.
Anyway to try and explain how the changes in maintenance regulations might help you:
- Most EASA aircraft were caught by the GRs because under the original Part-M requirements it they were wrapped up in the CAA’s approval of maintenance procedures for light aircraft as the competent authority for Part-M – the LAMP being the main one. One idiosyncrasy of that was that although the application of such requirements were under the legal authority of EASA’s Part-M, they used terms such as aerial work, which confusingly as a term comes from the nationally regulated system under the ANO. This had the effect of capturing group owners paying for instruction in their aircraft.
The plan going forward is for EASA light aircraft to transfer away from those arrangements above to those described in the recent amendments to Part-M, and further into the future, Part-M Light. Going over to MIP is part of that, and the current MIP arrangements may be used by aeroplanes up to 1200kgs, when used “non-commercially”. The CAA does not believe that the case of group members, who are simply receiving flight instruction on their own aircraft, meets the definition of commercial operation, therefore it would be considered to be non-commercial. All the background for the transition to EASA terminology is in CAP1335 as no doubt you’ve found.
EASA’s definition of commercial is: “any operation of an aircraft, in return for remuneration or other valuable consideration, which is available to the public or, when not made available to the public, which is performed under a contract between an operator and customer, where the latter has no control over the operator”.
There are more details of the MIP and the transition to it the CAA’s GA pages. In general MIP does give more freedom to declare a maintenance programme that deviates from recommendations like TBO periods, but the CAA’s advice to owners is very much to carefully consider the airworthiness needs of their particular aircraft/engine because some of the permissible alleviations are clearly more suitable for some types that others. So I would look into the MIP arrangements for your aircraft and determine whether you can come up with a sensible and compliant maintenance programme under it
It doesn't speak to ab-initio directly, but if the only restriction is on TBO's and that is written out of the maintenance programme it stands to reason ab-initio training becomes possible. It was never more than a recommendation from the manufacturer and gold-plated into a requirement by previous non-evidence-based rules.