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Apologies for missing this one from before. I have contacted the colleagues in this area for some advice to get you a reply. Will update you as soon as possible.
Hi Andrew, the answer from our maintenance colleagues is as follows - hope this helps:
"Under Part-ML regime, the person or organisation responsible for the aircraft continuing airworthiness has the choice to develop the aircraft maintenance programme (AMP) either on the basis of ICA issued by the Design Approval Holder, or else on the basis of the Minimum Inspection Programme (MIP) proposed by the Regulation (ref. ML.A.302(c)(2)). When the MIP is used as basis, as its name suggests, no deviation is allowed.
When the ICA are used as AMP basis however, deviations to these ICA are possible under the responsibility of that person or organisation, under the condition that the resulting task is not less restrictive than in the MIP (ref. ML.A.302(c)(3))
It seems that in the case described, choosing the ICA as the basis for the AMP would be more advantageous in respect of the functional test of the pitot system, because the 2 years interval could be kept in the AMP. But it remains to be evaluated for other tasks.
So we invite you to consider developing an AMP on the basis of the ICA, taking into account points ML.A.302(c)(2)(b) and ML.A.302(c)(3) of the Regulation. Please also consult ‘GM1 ML.A.302(c)(3)’ which provides guidance how to approach deviations to ICA, if needed."