EASA has recently published the SIB 2020-05 to support owners of old airplanes and Authorities in the definition of the items to be included in the "Aircraft Maintenance Programme" when Part-ML is applicable.
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In my opinion SIB 2020-05 cover not only the old airplane, but explain the philosophy for the correct set-up of an "Aircraft Maintenance Programme" , explaining that TCDS instruction, MCAI, ICA Bulletins of Manufacturers are binding.
Also Declared Aircraft Maintenance Programme must cosider this
In my opinion, the text is based on complaints from some national CAAs. They hardly accept the fact, that some historic aircraft dont have anticipated TCDS chapters in their maintenance manuals and do not need to comply with some ridiculous TC holder requirements. These CAAs are not able on the other hand to ensure quality of these suppliers (TC holders)! Some engine TC holders are not even able to produce spare parts, but they are impudent enough to issue short calendar TBO limits only to get money from owners of historic aircraft and to provide slow and poor service. These calendar limits are not based on any accident, incident nor scientific fact...
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General Aviation