Well fifeken, I don't have to be any kind of expert to come here to MSE and question areas in which I have a long-standing interest, and I don't have to give you my unique CV so you can see where I come from!
For the avoidance of doubt, I am not employed as a licensed engineer, nor as licensed commercial pilot, nor have I ever been either, nor am I a journalist, nor do I have any agenda other than improvement in the industry for the benefit of theconsumer. However, I am used to reading documents including aviation documents and understanding broadly what is going on with the aircraft at every stage of every flight I take. That's a lot more than most MSE'ers and the general public, unless they are airline managers, aviation engineers or pilots.
Personally, as a regular passenger at 11 and 12km up who has in the past been involved in two or three separate branches of aviation as a day job, I am disappointed to find airworthiness certification apparently reduced to self-certification year after year by MA901 given that we know that some aircraft like those in question are operated specifically for mixed short term use for different airline principals. How is the maintenance control achieved if the aircraft is away? Perhaps the control is via the pilots, because at least they work for the CAMO?
I think in such an operation I'd much prefer to see full renewal certification every year, especially if many parties get involved with maintaining the aircraft on the line in the course of the 365 working days of each intervening 12 month period - or does the blessed thing return to Riga to roost every night?
By my reading between the lines, the (up to) three year cycle of re-certification by extension does not appear to me to have been intended to be used as a norm other than for the major consistent operators. It appears to be an allowable
exception if compliance can be certified with MA901 - an exception allowed for aircraft which are operated under a consistent continuous maintenance regime involving only one
CAMO (sorry that's in German but Google Chrome will translate) for the entire 12 months prior to any period of extension - is that correct?
Even large airlines like Ryanair cannot justify their own line engineers at every destination - far from it, but at least they have a closer interest in the day to day operation of the aircraft via their own SOPs and flight profile monitoring, and they have multiple bases. But how does an ACMI outfit deal with the problem of likely discontinuity of maintenance control whilst aircraft are away for weeks? Is there some kind of mandatory continuous operational review that demands a second signing by the main CAMO of every piece of maintenance done away at the earliest opportunity after the aircraft returns to CAMO base? Do they perhaps rely on their own pilots to maintain better than average control of fault reports and to obtain better than average fault rectification documentation from third party line engineers?
If this was BA I wouldn't be asking in quite the same way, would I? With them, we kind of assume that their own maintenance arrangements at Heathrow and elsewhere are fully integrated with the day to day operations of their own aircraft, and that they are not anywhere near so much reliant on other maintenance organisations - but I appreciate that there are many flavours of outsourcing in any international airline business in 2017.