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David Roberts
13th Aug 2007, 21:24
AN EASA BRIEFING AND WORKSHOP ON 4TH SEPTEMBER AT THE PFA HQ TURWESTON AERODROME ABOUT THE PROPOSED REVISIONS TO PART M (LIGHT AIRCRAFT MAINTENANCE RULES FOR AIRCRAFT NOT INVOLVED IN COMMERCIAL AIR TRANSPORT)

The original Part M, introduced in 2003, was criticised by Europe Air Sports and other representative bodies as being too high a burden for non-commercial light aviation (below 5,700 kg MTOM).

As a result, the implementation date for Part M was deferred to September 2008. Further, EASA revisited the 2003 Part M Implementing Rules during 2006-07 through two EASA working groups, M.017 and M.005, which have involved experts from various General Aviation Associations, ‘Industry’ and NAAs across Europe.

The result of that work had been published in two parts – a Comment Response Document (CRD 07/2005, April 2007) and one Notice of Proposed Amendment (NPA 2007-08) on 22 June 2007. These can be found on the EASA website at: www.easa.eu.int/home/rm_npa_en.html

Europe Air Sports has facilitated a briefing by EASA will be held on 4th September 2007 Time: 09.00 Registration; start 09.30 – 16.30 local time.

Aircraft owners, pilots, associations and maintenance organisations are invited.

Location / venue: PFA headquarters at Turweston Airfield, Near Brackley, Northants. Capacity is limited to 80-90 places, so first come, first served.

Costs: No cost for the meeting, except the lunch arrangements - pre booking required -will be for each individual to pay for. Travel costs to the event, and any hotel accommodation are the responsibility of delegates.

Booking attendance: Please log in to the EASA website and make your booking on-line on the relevant page at

http://www.easa.europa.eu/home/events_en.html

The EASA website page should be up and running on 14th or 15th August.

We hope you will take the opportunity to attend this event.

David Roberts
Europe Air Sports

vee-tail-1
14th Aug 2007, 20:15
Hey mods! These new EASA rules are going to affect us all in GA
How about making this post sticky for a while?
The workshop will show what we can expect and gives an opportunity to make our own comments :uhoh:

David Roberts
17th Aug 2007, 22:05
The booking form is now - at last - on the EASA website - events page.
First come first served.

mikehallam
18th Aug 2007, 18:03
Gentlemen,

Having already rec'd Dave Wise's kind reminder e-mail, the 'M' he indicated seemed rather too cryptic to have a clue what it meant.
I tried various official Easa & CAA web pages to see what the agenda for this seminar said: 'very obscure' was my conclusion. I don't know if it affects us but as it's held at the PFA HQ must assume it's getting too close for comfort. The CAA web page confines its 'M' description to saying it only affects big planes' maintenance. A scan of all the many UK based firms in another CAA list doesn't mention BMAA or PFA, so I still don't know what it means relative to very light a/c, microlights and flex wing a/c. In fact the complete EASA web page presentation from 2005 of how 'JAR is bad Easa is good', is a marvel of confusion over substance !
However in the hopes that others knew different, the bit from PPrune web forum from the man at Europe Air Sports was distributed elsewhere. It may all be clearer to you than me.

Mike.


EASA Part M Briefing

--------------------------------------------------------------------------------

AN EASA BRIEFING AND WORKSHOP ON 4TH SEPTEMBER AT THE PFA HQ TURWESTON AERODROME ABOUT THE PROPOSED REVISIONS TO PART M (LIGHT AIRCRAFT MAINTENANCE RULES FOR AIRCRAFT NOT INVOLVED IN COMMERCIAL AIR TRANSPORT)

The original Part M, introduced in 2003, was criticised by Europe Air Sports and other representative bodies as being too high a burden for non-commercial light aviation (below 5,700 kg MTOM).

As a result, the implementation date for Part M was deferred to September 2008. Further, EASA revisited the 2003 Part M Implementing Rules during 2006-07 through two EASA working groups, M.017 and M.005, which have involved experts from various General Aviation Associations, ‘Industry’ and NAAs across Europe.

The result of that work had been published in two parts – a Comment Response Document (CRD 07/2005, April 2007) and one Notice of Proposed Amendment (NPA 2007-08) on 22 June 2007. These can be found on the EASA website at: www.easa.eu.int/home/rm_npa_en.html

Europe Air Sports has facilitated a briefing by EASA will be held on 4th September 2007 Time: 09.00 Registration; start 09.30 – 16.30 local time.

Aircraft owners, pilots, associations and maintenance organisations are invited.

Location / venue: PFA headquarters at Turweston Airfield, Near Brackley, Northants. Capacity is limited to 80-90 places, so first come, first served.

Costs: No cost for the meeting, except the lunch arrangements - pre booking required -will be for each individual to pay for. Travel costs to the event, and any hotel accommodation are the responsibility of delegates.

Booking attendance: Please log in to the EASA website and make your booking on-line on the relevant page at

http://www.easa.europa.eu/home/events_en.html

The EASA website page should be up and running on 14th or 15th August.

We hope you will take the opportunity to attend this event.

David Roberts
Europe Air Sports
----- Original Message -----
From: "David Wise" <[email protected]>
To: "Ab-IX Group" <[email protected]>; "Jodel Group" <[email protected]>; "Airfields Group" <[email protected]>; "Mike Hallam" <[email protected]>
Cc: <[email protected]>
Sent: Saturday, August 18, 2007 12:14 PM
Subject: EASA Part M briefing at Turweston Sept 4th


> This is for those of you who are involved in owning, operating,
> building and maintaining light aircraft, and particularly those on
> Permits to Fly in the UK.
>
> A briefing meeting organised by EASA about proposed developments to
> Part M requirements, will be held at the PFA Offices at Turweston on
> 4th September.
>
> http://www.royalaeroclub.org/partM079.pdf
> for further information and to book places.
>
> Members in other countries in Europe should look out for similar
> meetings in their own countries or contact EASA.
>

David Roberts
18th Aug 2007, 20:45
Mike,
Part M (refers to ‘Maintenance’, or in EASA-speak, Continuing Airworthiness), is a EU Regulation for civil aircraft and was introduced for commercial air transport in 2003. Its implementation was deferred for aircraft used in non-commercial aircraft operations, below 5.7 tonnes MTOM, until September 2008. As a result of representations since 2003 from Europe Air Sports, it has been undergoing revision, which is set out in the links provided in the notice above in the first message.
Part M will apply to all aircraft in the UK which are within the scope of EU Regulation 1592/2002 and therefore have or will have a EASA Certificate of Airworthiness, and which are used non-commercially. There are some exempt types of aircraft which are listed in Annex II to the Regulation, and essentially are microlights (below 450 kg MTOM for 2 seater, 300kg for single seater), historic aircraft (broadly those designed before 1955 and which finished production by 1975), and gliders below 80 / 100 kg (i.e. hang gliders and similar) and certain other limited categories.
I am informed by Graham Newby of the PFA that PFA Permit aircraft will also not be subject to national rules and not EU Part M.
So, aircraft affected by Part M are aeroplanes (powered aircraft) over 300kg single seat or 450kg two seats MTOM, sailplanes / gliders, balloons, helicopters.
Regulation 1592 and in particular Annex II will be subject to change in the future and there is a possibility in the medium to longer term that the European ‘system’ of law making may reduce the exempt aircraft categories. If that were to happen, then those communities currently exempt from Part M may wish to get a ‘heads up’ on what may (I emphasise 'may') lie in store for the future.
The EASA briefing is being held at the PFA HQ at Turweston because that (a) has the meeting room facility at a reasonable cost and (b) is convenient to fly into – with PPR.
The EASA briefing on 4th September, for which the agenda is posted on the EASA website link under ‘events’, is intended to provide owners and pilots with an overview of the proposed changes.
Europe Air Sports, which represents some 600,000 members of national aero clubs and pan-European air sports unions across the EU, is focused solely on influencing the EU regulatory framework for light aviation, and has facilitated the establishment of these briefings in 7 countries over the next month.

mikehallam
18th Aug 2007, 21:46
Thanks.
So Permit a/c which includes microlights remain under CAA/PFA or BMAA control I guess. Your warning about creeping legislation is a bit disconcerting though Brian Hope [PFA editor] is sanguine about the impervious nature of the permit (?):-

"Brian Hope Member 26123732
posted 18 Aug.2007 09:38pm
Hi Mike, Part M is the new maintenance and continuing airworthiness regime that Cof A aircraft will change to after September 2008, it is already in place for large commercial aircraft. There are a number of older CofA aircraft that have now been put into Annex 2 (Jodel 1050 and 200 series, Austers, rag wing Pipers and a lot of older DH types plus others) and they will stay on the old UK Cof A system (for now at least), but C150, PA28, DR400 etc types will come into the new Part M. It thus follows that it has nothing to do with Permit to Fly types at all. However, we do have many members operating CofA types that will be affected and we are looking at ways in which we can help them in this new regime. There will be an article about it in the next isue.
The seminar is being held at Turweston but is not a PFA event. EASA officials are coming over to explain the system and answer questions about it."

G-KEST
21st Aug 2007, 17:25
With regard to the applicability of EASA Part M to aircraft operated on the basis of a permit to fly this is not the situation now or in the immediate future. The maintenance arrangements for those aircraft remains with the UK CAA and those organisations such as the PFA and BMAA which hold a CAA approval for their respective maintenance systems.

Who knows what may happen in 5 or 10 years time? It is likely that the UK CAA will move its requirements ever closer to the EASA norm. This to avoid having two totally different maintenance regimes in the UK leading to confusion. Not least within the CAA.

What is certain is the threat of political pressure from the EU parliament and the Commision on EASA should there be some disatrous series of high profile accidents involving permit aircraft especially if third parties are killed. Without doubt they will demand that those aircraft, now termed Annexe II types, come under the direct oversight of EASA should maintenance, construction or design factors be present as a major factor in a tragedy.

Exactly the same situation arose in the UK in the early 1980's with microlights where the CAA had elected to remain well clear of these revolutionary and fragile aircraft. Suddenly a number of folk lost their lives in accidents. Questions were asked in the House by MP's representing their grieving constituents and very quickly the CAA were directed to assume responsibility with all the hassle that entailed for the former "free spirits" who were quite happy with the risk factors.

Those who choose not to study history are destined to repeat it.

Prenez garde, messieurs................!!!!!!!!!!!!!!!!

Cheers,

Trapper 69
:mad::mad::mad::mad:

mikehallam
22nd Aug 2007, 09:49
Apropos the above views, here's a couple fresh worries, from those at the sharp end, posted on the BMAA forum.
Mike.

Keith Negal[BMAA] posted this:-
".........My interest is in under 450 kg
aircraft, specifically microlights. Things do not look good for
microlights inside EASA.
For example, if EASA's first pass at Part
M (continuing airworthiness) is anything to go by we microlight
pilots will be in the deep and smelly very quickly. All talk of a
Lite Part M has yet to be supported by anything tangible. Anyway,
EASA merely recommends, it is the Commission, the Council of
Ministers and the European Parliament that decide and you only have
to look at the insurance fiasco to see what can happen.
>
> The interesting thing is that our own CAA has demonstrated a
desire to reduce regulation beyond that we would have believed
possible 5 years ago. SSDR is simply not on the cards in the world
of EASA. Maybe MDM032 will come up with something better for Europe
but MDM032 is not about microlights. It is about those aircraft
that are not in Annex II. It is about the 450 kg to 1000 kg
categories. My stance (and I have never wavered in this from the
creation of EASA) is that if EASA comes up with something we like,
then we can easily volunteer to leave Annex II and join the EASA
fold."

Paul Dewhurst commented:-
"I met Jan Friedrich yesterday (Czech rep on
MDM032, and prime mover for it), and he is quite negative on
propects at the moment, he fears EASA doesnt have the stomach to
relinquish control to anywhere near the extent we would like, and
says it is looking like they are creating a monster, with complex
procedures, maintenance and licencing. [Mainly because of pressure
form the glider boys to go for 1000Kg rather than a lower limit]. He
thinks it is (sadly) dead right to keep microlights clear of the
regulation at present."

lets hope his fears can be overcome, and we get something useful for
us that can be picked up for microligting, bt at the moment it looks
shaky.

He is supposed to be here on Thursday,

David Roberts
22nd Aug 2007, 21:35
As one of the ‘glider boys’, as Paul describes us, on the EASA MDM.032 group, I think I might comment on the above. And BTW, all 6 of the Europe Air Sports’ appointees on this group represent the interests of ALL air sports / light aircraft owners and pilots, not just our particular interest group.

Firstly, Jan Fridrich has done a very good job, along with several others on MDM.032 over the last 18 months and including Graham Newby (PFA), in developing the ideas for the proposed European Light Aircraft category. It should be remembered that the principle drive for this was the over-prescriptive (and expensive) requirements, including holding a DOA, of Part 21 (ex JAR 21) which is the EU rules for design, certification and manufacture of certified aircraft. EASA recognised this fact, as it adversely affected the light aircraft sector, after the implementation of Part 21 in 2003.

We have come up with proposals, which will be published this autumn, for an alternative to holding a full DOA. The details are still being fleshed out but most likely will be based on the principles adopted for the US LSA category, by using industry-recognised processes such as ASTM standards, which are developed by a well-seasoned consensus process from within industry and interested parties.

Jan, being from the Czech microlight community, was keen to have a European equivalent of the US LSA, which is up to 650kg MTOM, for reasons which are obvious to those who understand the success of Czech microlight manufacturers exporting to the US, but without an equivalent EU market.

The rest of the group however also saw an opportunity to develop this for a larger MTOM range, and EASA agreed. Hence the current proposed 450 to 1000kg MTOM range, which will benefit a wider range of light aircraft design and manufacture than just ‘heavy’ microlights between 450 and 650 kg.

So far as gliders are concerned, we (I am a gliding person) have a perfectly satisfactory design code, CS22 (formerly JAR22), which provides certified gliders up to, now, a max MTOM of 850kg in the case of a two-seater with retractable engine This code was in fact developed over many years primarily by glider industry experts and academics.

One of the side effects of an ELA category, were it to be restricted to the same as the US LSA category at 650 kg, would be to divide the glider design, manufacture, and markets in half, with absolutely no good reason. Likewise, there was no discernable objective safety reason why light aeroplanes (i.e. powered aircraft) up to 4 seats / 1000kg or thereabouts, could not be accommodated within this new proposal. And they will come with EASA Cs of A.

The prime objective is to create a re-generated EU-based design, manufacturing and market opportunity economy for light aircraft, by having more industry-friendly processes and potentially lower certification costs. The existing microlight definition and limits are largely irrelevant to this thinking, as microlights remain in Annex II and therefore outside EASA’s scope (at least for the foreseeable future in my opinion). So the group did not go along with a restricted 'heavy' microlight view of life in developing broader proposals.

The other developments at EASA are on pilot licensing, where there will be a published NPA this autumn to introduce a (European) Light Aircraft Pilots Licence, based very much on the UK NPPL model but with full pan-EU rights, but for aircraft up to 2000 kg MTOM and used non-commercially. This will complement the Part 21 developments. I have also been working on the Ops rules, trying to keep them very ‘light’ and bridging the divide between non-commercial and commercial, bearing in mind the new definition of commercial operations in the current proposed extension of Regulation 1592-2002 to Ops and Licensing.

The main part of the jigsaw that needs to dovetail with all the above is the rules for maintenance – Part M. Hence all the focus we at Europe Air Sports have been making on getting this revised to be more acceptable to the light aircraft communities. So book to come to Turweston on 4th September!

I realise that very few people have the advantage of seeing the overall picture that is emerging, and I for one am able to see that from where I sit. It is by no means yet perfect, but EASA is, on the whole, very well disposed towards our objectives.

vee-tail-1
22nd Aug 2007, 21:56
It's not all bad this proposed Part M. It could result in a much needed shake up in some maintenance workshops.
But if you are the sort of pilot who takes his pride & joy to the trusted engineer for it's annual. Listens to the tale of problems and faults miraculously found and fixed, and you pay the huge bill without query. Then good luck to you and I hope you have not been ripped off too often. :ugh:
I am an engineer, and this is the comment I have posted on EASAs comment response tool.

"I am particularly worried that UK engineers & maintenance organisations may try to continue to use the UK LAMS on EASA aircraft, in preference to an approved manufacturers maintenance programme."

"LAMS is appropriate for Annex ll aircraft but not for sophisticated modern types."

"Use of LAMS is similar to attempting to service a modern BMW car using the workshop manual of a Morris minor as reference. LAMS requires engineers to use their skill & experience to assess what work needs to be done. They are therefore free to do as much or as little work as they see fit. This leads to items being missed, or unnecessary work being done. It also tempts some engineers into extortion, presenting owners with massive bills for work that the owner has no means of verifying."

"In contrast, an approved manufacturers maintenance programme gives a type specific list of work to be done and the times to do it. No items are missed, and successful completion of the wok requires technical competance, not metaphysical intuition. A safe maintenance operation can be performed by the newest mechanic, or even a competant owner, and the owner is able to verify that the required work has been correctly done."

"Use of UK LAMS on EASA aircraft could be a flight safety hazard."

G-KEST
22nd Aug 2007, 22:11
Thanks David for a very clear exposition of the current position in the development of the ELA category up to 1 metric tonne.

An appropriate cut off point, however any such figure throws up anomalies in that most Cessna 172's would fall into the ELA weight band but the latest version does not, by a fraction. Cessna, of course, are a US design and manufacturing company governed by the FAR's not any EASA classification but I wonder if designing to a limiting MTOM for an ELA might give problems in later years. This since product improvement rarely results in weight reduction and thus it would give a reduction in useful load.

I can understand the frustration of your Czech colleague at the failure to accept the US LSA criteria since much of the current export market from Europe is directed at aircraft meeting the LSA category in the USA. Excellent aircraft they are but the manufacturers will lose market share in the EU if we get the ELA category.

I would imagine many flying clubs and schools are a trifle cautious about buying LSA compliant aircraft for use in Europe. Some of them seem rather fragile to suffer the slings and arrows of training.

I would like to echo David's suggestion that folk should make every effort to attend the EASA conference at Turweston on 4th September. I went to the last one on 11th August organised by the RAeC of the UK and found it of huge benefit in my appreciation of what is proposed for Part M and the disturbing financial implications for owners and operators along with existing M3 approved maintenance organisations. Have no doubt, costs will go up.

Cheers,

Trapper 69
:confused:

David Roberts
22nd Aug 2007, 22:58
Two corrections, one to my post above and the other to Trapper 69’s post. In mine I quote 650kg MTOM for the LSA category. It should read 600kg.

Secondly, Trapper above quotes ELA category up to 2 MT. No, it is up to 1 MT (1000kg). The Light Aircraft Pilots Licence will be proposed for aircraft up to 2MT MTOM, used non-commercially.

As regards the marginal anomalies that will occur at the ELA upper break point of 1000 kg, that would happen at whatever limit was set. There would always be anomalies. One has to draw a line somewhere.

As regards flying clubs and schools and use of an ELA category aircraft in the future, remember that the ELA is proposed for non-commercial use, and therefore the unanswered question (which I am in the process at present of addressing at EASA and in the wider EU community) is the interpretation of the proposed new definition of ‘commercial operation’ in so far as it will impact flying training, as just one example. The jury is literally still out on that and will be for some time.