A despirate search for answers!
 

Guys

My head is hurting trying to find an answer to my question in EASA land so I would like to pose the question here to see if anyone can point me in the right direction.

Firstly the scenario: I am a British military avionics engineer who many years ago gained a BCAR licence in Radio/Radar. A change in career plans meant I stayed in the military however I did convert my licence to B2 (with restrictions) but have not as yet used it in anger. Soon to leave the military, I am however no longer looking to start another career working for an airline or the sort but I do keep getting asked if I could carry out, ad-hoc, radio and transponder routine testing. Apparently there isn’t many people doing that sort of thing for GA in my neck of the woods.

Aside from not currently having any appropriate test equipment, not insurmountable, I can’t find any info on what sort of approval I would need to carry out such freelance work in this modern EASA world on GA aircraft. A part 145 approval seems a bit over the top for a one man band with all it’s requirements but I can find nothing else in the regs that says what I would need.

Is there anyone out there, maybe already doing this sort of work, as I know there are some, who could point me in the right direction?

Regards

Jim

Light Aircraft Component Maintenance
 

WARNING: I only have first-hand knowledge of maintaining large aircraft.

From what I can see (Google), it is dependent on: type / size of aircraft and if it is operating on an EASA C of A, National C of A or a Permit to Fly.

Less than 300kgs has different rules again.

Please bear in mind that removing and refitting a component from an aircraft is considered aircraft maintenance, whereas testing on a bench is considered component maintenance – different approvals may apply.

I would start with the CAA website – General Aviation, take a look at EASA Part M, parts E and F as well as the Light Aircraft Association.

The EASA appendix II document referred to on the CAA website as listing EASA types, is no longer produced as there is a definitive list of EASA types on the EASA website.

IIRC, the European regulations are published by the commission and hosted on the euro-lex website, with links to them from the EASA website. These are European law.

The Acceptable Means of Compliance (AMC) and Guidance Material (GM) are published by EASA and available on their website directly, which they refer to as soft law.

I’m sure someone with appropriate knowledge and experience will be along soon to answer the question more succinctly.

Hi Jim,

The freelance option is no longer available. A certificate of release to service is now required for all maintenance. To issue this you have two options.

1. Start (or join) a 145 organisation, requires an exposition, some sort of QA oversight, SMS, training etc.

2. Start (or join) a Part M subpart F, similar requirements as above, but you're paperwork burden is slightly reduced along with the scope of work you can accomplish.

In addition, you would also need to hold the appropriate type or group approval on your licence (Group 2a/b or 3).

don't forget the 6 in 24 rule as well

Thanks all who have responded before.

QA1 – I am only interested in GA so EASA and Annex II light aircraft and gliders on a combination of CofAs and Permits. I am also only talking about testing installed equipment so component maintenance isn’t a consideration.

LME – There are definitely still guys out there doing freelance work so whether they have found a loop hole or are working under some legacy arrangement I don’t know but obviously if I ask the local guy, self preservation will prevent him detailing how he does it. I am already a member of a Part M Sub F organisation but don’t currently do this range of tasks within that organisation and they look after predominately gliders anyway. I’m guessing the glider part would be fairly easy after a chat with the guy in charge; it is the other GA that has got me beat at this time.

BluFin. – ?

Jim

Think this may give you what you are looking for, at least for EASA light aircraft. I would confirm the interpretation of this with your local CAA surveyor.

Regulation No 1321/2014 (Appendix I Part M) amended by:
Regulation No 2015/1536. Part M-A 801(b) refers.

It appears you can issue a CRS based on your B2. You need to keep all records to support any maintenance performed.

Now my brain hurts as well - good luck.

You need to have an approval from a Part 145 maintenance organisation which provides the maintenance to the Aircraft. To get an approval you need the type on your licence.

No negotiations no buts ands or ifs . Thems the rules.

It stopped add hock radio annuals etc in there tracks.

I don't know where Lowfat gets his information from but it is not accurate.

If the aircraft are not being used for commercial purposes there is no requirement for 145 approval. The Light Aircraft Maintenance Program (CAP 766) Section 3 is the guide here.

I normally carry out the B1 part of an annual myself and subcontact a B2 for the radio work.

The main issue is not certifying the inspection work but ensuring that the paperwork can be presented and is accceptable for an ARC.

I produce a package including the B2 work which goes to the organisation issuing the ARC which does need an approval. In theory I suppose I could apply for the approvals myself but as the volume of work is low and I have a great working relationship already it seems not worth the expense or trouble.

I have carried out work in this manner since light aircraft maintenance went over to the EASA system without a problem.

In addition 50 hrs and fault rectification are also covered in the same way. Keeping the paperwork in order is the key and that is actually the operators responsibility.

IS your CAMO not part 145?
I presume you are the owner/pilot and exercising the rights of your pilots license?
How does your B2 satisfy the CAMO issuing your ARC...

One thing you need to bear in mind if your going to certify ga stuff is your going to need a group rating for your b2. They only way you can get this is through an oral exam after submitting experience sheets. There are no type courses for your Cessnas and pipers etc. This was the case last time I enquired. Contact the new ga unit at the CAA and see if it's still the case. If they can't help try your luck with engineer licensing.
As for LAA and BMAA aircraft there is no real call for radio annuals. If they have an avonics defect then they either fix it themselves or find a b2 at their local ga maintenance facility.
Camo is a separate approval from 145. The camo in the case above would be responsible for issuing the work pack and auditing the company or engineers performing the work. The case above would be an aircraft that is maintained outside the controlled environment.