Air Operations

CAT III FO with DH<50ft and RVR75 - does the rule EU 965/2012 make any sense regarding this point? Isn't it wrong and dangerous to imply such operation? I would appreciate some thoughts...Especially when having an A/C related min DH of lets say 25ft, to fixing a min RVR of 75m?
Mostly the 'line of sight' will not give the possibility to judge the runway lights within the remaining few meters over the A/C nose...the RVR will allways include a part covered by the nose. Even more with 130 kts and coming out of vmc/clouds/fog at 25ft.

This is my opinion the correct way of understanding. read carefully.:

a CAMO (Continuing Airworthiness Management Organization) does not have the privilege to decide on the applicability or status of an Airworthiness Directive (AD). The applicability of an AD is determined solely by the airworthiness authority that issued it (such as EASA, the FAA, or other regulatory agencies).

The Role of a CAMO
Ensuring Compliance:
A CAMO is responsible for managing the continuing airworthiness of aircraft, which includes ensuring compliance with all applicable ADs. They are tasked with:

Identifying applicable ADs for the aircraft under their management.
Ensuring that the corrective actions specified in the AD are carried out within the prescribed timelines.
Applicability of ADs:
The decision about whether an AD applies to a particular aircraft, component, or system is not made by the CAMO. It is based on:

The aircraft type and serial number.
Specific criteria outlined in the AD itself (e.g., affected components, configurations, operational conditions).
Assessment and Recommendations:
While CAMOs do not decide on the applicability of ADs, they may:

Review the ADs to determine their relevance to the managed aircraft.
Consult with the Competent Authority (e.g., EASA or the State of Registry) for clarification if there is ambiguity.
Propose solutions to achieve compliance.
Regulation and Legal Framework
In Europe, under EASA Part-CAMO (Annex Vc to Regulation (EU) 1321/2014), CAMOs are explicitly required to ensure compliance with ADs, but they do not have the authority to determine their applicability independently.

The responsibility to issue and enforce ADs remains with the airworthiness authorities like EASA or the FAA.

In Summary:
A CAMO cannot decide whether an AD applies or not.
Their role is to ensure proper identification and compliance with applicable ADs as required by the regulations.
If there are questions regarding the applicability of an AD, the matter should be clarified with the Competent Authority (e.g., EASA).

Dear community members,
Our current CAMO policy is that all ADs are received and assessed by CAMO Engineering personnel. Then if AD is considered as not applicable for whatever reason, CAMO Engineering personnel declared it as not applicable in maintenance information system (computerized software). But some of our consultants say that all ADs even it is clear that it is not applicable have to be reviewed and certified by a licensed engineer of contracted AMO (Part-145 organisation). They say that CAMO staff does not have the privileges to evaluate the AD and make a final decision on the status of the AD.
Could you please let us know your position on this? Is this statement is correct?