giloc,

Thanks for the info.
As an aircraft owner myself, it means more unjustifiable costs and paperwork for yet another no-gain in safety or effeciency.
As a maintenance facility owner, it means more unjustifiable costs and paperwork for yet another no gain in safety or effeciency, coupled with another EASA reason for owners to whinge at increased costs. Problem is, it is easier for them to whinge at me than the source of the problem. Some days I just love my work.

I received a response from my surveyor advising me that LAMP was under review, but he wasn't aware of any decisions yet.

camlobe

You can. Or you can just look at them for condition. Or you can pointlessly replace them -the choice is yours, just write it in your LAMP.

Because no-one has been bothering to do that, thats perhaps one reason why the LAMP is found not sufficiently easa compliant??.

If the CAA have been requiring you to comply with regulations which were not lawful or unapproved then it seems to me you have a case for claiming compensation as the CAA must have been acting outside their authority. Perhaps soemting for the likes of AOPA to take up?

If it is a mandatory life limit you have to comply with it.....

I queried this and was told at the time by my surveyor that you would have a hard time getting a lifed item extended through the CAA against the Type Cert holders requirements.

Suggest you read this and look at the flow chart at the bottom..

http://www.caa.co.uk/docs/33/2011062...mentOfLAMP.pdf


Also shows how Lamp will become GMP... think's they have missed the I out of that acronym.... :E

To fully comply with current situation you have to fill in the worksheets for the airframe and the engine as laid out in the maintenance manual servicing section and also fill in LAMP.
Compiling a maintenance programme whilst time consuming will reduce the amount of time the CAMO will have to spend filling in paperwork. Also most radio manufacturers do not have any continuing airworthiness requirements which means you can take the radio check out of the annual check.
Also what you have to remember is that most manufacturers are !!!! at updating manuals and issue service bulletins instead and these all need to be addressed and if recurring included in the maintenance programme.

Cessna do not make the law, no matter what they might like to think. Even if they say its MANDATORY to eat 8 Jaffa Cakes prior to flight you dont need to, but you can if you want to.


Airworthiness Directives - mandatory - add to LAMP
Airworthiness Limitations - mandatory - add to LAMP


Cessna/Piper whoever is the TC holder recommendations - not mandatory - evaluate and add to LAMP as required or desired. Even says EVALUATE in that flowchart I just re-read.

Ask your surveyor again & get his reply in writing.

As for GMP, youre right! We'll be back to the GPMS of many years ago yet!

So where do you get the mandatory Airworthiness and life limitations from if they are not from the manufacturer?? and they are down as ADD ( ie mandatory )

I quote the Lamps Schedule

Section 3, Page 2
CAP 766 Light Aircraft Maintenance Programme – Aeroplanes

5 Airworthiness Life Limitations (Retirement/Scrap Lives)

5.1 Airworthiness life limitations shall be those published by the state of design type certificate holder and supplementary type certificate
holders.


Section 4

2 Permitted variations may not be applied to Airworthiness Directives, CAA Generic Requirements, airworthiness life limitations or
overhaul and test periods.

CAA / FAA/ EASA /....... Type Certificates Data Sheets

i.e. Stuff given out by the law-makers agencies.

But the Design Type Certificate is held by the manufacturer of the aircraft and LAMP clearly states theirs is the limits you have to adhere to, no one elses, and it's not evaluate, it is add.

The only way it is varied is as in the case of Engine TBO where the CAA issue a GRN to allow the TBO to be extended.

Somethings being lost in translation here.
Take the Cessna seat belt issue - lets say a 1977 Cessna 172.

The Cessna 172 Service manual states it is Cessna who have established the 10 year life. Not the FAA. Its therefore a TC holders recommendation and as such subject to evaluation for inclusion in LAMP just as your flowchart says.

There are no Airworthiness limitations or Life Limitations for a 1977 Cessna 172 either in the service manual or in the TCDS.

Take another for instance - American Champion 8KCAB Dekathlon.

This does have an Airworthiness Limitation in the Service Manual for the wing strut fittings being lifed at 1000 hours. However, without any FAA mandatedness it really means nothing & could be ignored as a manufacturers recommendation if desired, so the FAA include it in the TCDS to make it mandatory, and thus that one is required to be added to LAMP.

I think you (or your surveyor) are confusing CAA/FAA/EASA mandatedness with a manufacturer just saying mandatory to cover his backside.

In return for a manufacturer getting a Type Certificate, he effectively surrenders control of being able to vary future maintenance requirements, to the authority which issued that TC.

That is how aviation certification works.

That is why for example Cessna's "requirements" for some lifetime limit on some component are not mandatory (under Part 91). The FAA has the final say on that, instead.

And over decades the US aviation scene has developed in that way.

And it has worked very well. The manufacturers publish a list of stuff, but as it is not mandatory, they have not been exactly restrained in what they throw in.

The problem we have here in Europe is that the gravy train riders in EASA, and in the national CAAs before them, have been taking these manufacturer requirements at face value and enforcing them. The system was not designed to work that way, but these people are too dumb to understand, so they enforce life limits on stuff which has got no inherent degradation mechanism, or which is more likely to fail if messed with than if left alone.

There is a letter out there from the head of Socata, confirming that the only stuff which is mandatory under FAR Part 91 is what is in the Airworthiness section of the maintenance manual.

Actually Europe does not have a monopoly on money grabbing. Reading the US pilot forums, the practice of using disinformation is widespread over there too.

And that is the crux of what I was saying, like it or not you have to adhere to the life limits...... as they are the European governing body interpreting and laying down the requirements to replace them on the life limits.

Cessna 172 & Piper PA28 Owners
 

I would advise as a matter of urgency that owners who own these type of aircraft look at the 'consultation' document and voice their concerns with regard to proposed GMP which is due to close on the 16th March 2012. This yet another nail in the coffin for people that own this type of aircraft.
See http://www.caa.co.uk/docs/2263/20120...20Aircraft.pdf
and in particular the GMP Guidance

This document was dated 16/02/2012 consultation closes 16/03/2012 and was NOT sent to owners.

A little common sense has prevailed, at least for a while:

http://www.caa.co.uk/docs/33/Informa...ice2012062.pdf

Halleluiah! It must be the spring sunshine.
At last someone in the CAA must have seen that with EASA regulations, jumping last and avoiding gold plating is by far the best course ... :hmm:

Can we hope for a simple European permit system (like the LAA) for simple single engine light aircraft? :D