Part M - important news for owners/ operators

[EGBKFLYER]

Mods - feel free to merge this with other appropriate threads.

If your aircraft comes under the new EASA Part M regulations for Airworthiness, you know that the new rules apply from 28 Sept 2008. There was a strong possibility that the rules were going to be delayed until Sept 2009 but this has not happened.

Thee CAA has ruled that if your aircraft needs an ARC renewal before Jan 2009, you can continue to get the relevant paperwork from your M3 or Part 145 maintenance organisation. Thereafter and you will need to find a Subpart G-approved company to issue the ARC and manage your maintenance. At present, this could prove difficult as very few companies working on GA aircraft have the necessary approvals. 2009 could be a mess for a lot of GA as a result - well done CAA...

Check out Information for Owners/Operators | Airworthiness | Safety Regulation (http://www.caa.co.uk/arc) for more information.

[jxk]

I wish all M3 organisations would refuse to have anything to do Part G for at least 5 years by then hopefully it might be sorted.

[NutLoose]

CAA will be able to issue an Arc for you.

[jxk]

I don't want the CAA to issue my ARC - I'd rather have my current M3 do it as I think they've got more experience with light aircraft.:O

[EGBKFLYER]

Nutloose - you're quite right, although the CAA are trying to avoid this (will enjoy watching them try!) and will make it expensive.

jxk - unfortunately we're long past the point where holding out against the change is going to work. I recommend all maintenance organisations that want to be approved get a move on and sort out their applications asap - CAA surveyors are going to be very busy and it will be first com, first served...

[jxk]

It would be nice to get a move on but the goal posts keep moving. So, should the M3 organisations chase around like a scolded cats or wait until there's a clear spec? I would like to see what the French do - I simply can't believe they're going to implement all these rules and regs. Perhaps, we could wait until one of the other countries are on board and copy them.

[A and C]

As you might expect the CAA is responsable for a great deal of the delays with this part M introduction, they have been very slow in commenting on the part M applications so the whole process seems to drag on for ages.

The first part of the the companys application was done before xmas and the approval has yet to get the approval with the deadline now only weeks away!

I would think that there must be panic in aviation house as this fiasco unfolds.

[EGBKFLYER]

A nd C - I hope there is a panic at the Belgrano! They've caused it after all. Even the surveyors were clueless - one told me the deadline would definitely move to Sept 09 and another that it would not! That was about a month ago.

jxk - this is where being British is a disadvantage, since we always seem to play by the letter of the rules! I can imagine several other countries opting in to the deadline move and delaying til next year while we all thrash about here, trying to get things sorted.

[robin]

Oh Great...

Looking at the list of approved organisations there is no-one within 100 nm of home base and those that are do not have the approvals for my type.

Who do I sue for distraint of trade........?

[dragqueen120]

Hi, just bought a CofA aircraft lastweek (Cessna 120), read ya thread but am not ofay with the jargon being new to ownership etc. What do I need to do? is it set up a maintenance contract with some one or am I barking up the wrong expensive tree!

Many thanks in advance:ok::ok::ok:

[robin]

Yep - that is pretty much the case.

Start off with the company that is currently doing the work, if it isn't too far away, but if not start looking.....:ugh:

[vee-tail-1]

Go to the EASA website and you will get all you need from the horses mouth.

See "Guidance for Owners of Private Aircraft of 2730 kgs MTOM & Below"


Rulemaking | Rulemaking archives (http://www.easa.eu.int/ws_prod/r/r_archives.php)

Scroll down to: COMMENT RESPONSE DOCUMENT (CRT) ARCHIVES
then click on CRD 2007-08 Go to page 357 of 457

There you will see in print along with references to part M that:
(a) THE OWNER is responsible for the continued airworthiness of his aircraft. (c) NO NEED TO CONTRACT WITH A CAMO. The OWNER may manage the continuing airworthiness of his aircraft under his own responsibility. And much more of interest. :ok:

Not sure how the French will react to part M as it is very similar to their present system. The GSAC recently published a guide for small maintenance workshops wishing to implement part M sub parts F,G,&I . It showed how a CAMO would function in practice and seems to indicate that one person could be the CAMO and another the maintenance organisation.
Important to realise that EASA requires the administration of continuing airworthiness (the paperwork) to be quite separate from the maintenance (nuts & bolts & servicing) of the aircraft.

[jxk]

Important to realise that EASA requires the administration of continuing airworthiness (the paperwork) to be quite separate from the maintenance (nuts & bolts & servicing) of the aircraft.

BUT I WONDER WHY?
This sounds like airline practice where there's a 'rolling' type of maintenance.
I've always been happy with my maintenance organisation which has done a thorough job with all the AD and SID research and at the same time done a good job with the nuts and bolts. Why do we need two (or 3) separate departments? How about joined-up maintenance. eg M3.

[vee-tail-1]

I guess it's a flight safety matter, rather like dual inspection of flying controls. The person who did the work might genuinely believe he did a good job. But an inspector unconnected with the aircraft or mechanics can find faults that the others missed.
Certainly my experience is that an aircraft fresh out from servicing is highly likely to have some technical requirement missed.
Having someone dedicated to manage ADs, maintenance programme updates, time limited items, service bulletins, mods, next required servicing, recording of data, archives, etc, makes sense. The mechanics/engineers can then get on with the technical stuff which they do best.

[dragqueen120]

Thanks people for your words of wisdom. I shall sort it out.
then perhaps I can do what was intended and hop in and fly away some where sunny. Headcorn this weekend if I get my finger out!

Ta:cool:

[EGBKFLYER]

Couple of points here:

1. The new rules apply only to Annex I aircraft - those being administered by EASA. Annex II aircraft come under state (UK CAA for us in the UK) control and will continue to be maintained and administered under the old state rules (BCAR etc). To find out if your aircraft is Annex I or II, see this document:

http://www.caa.co.uk/docs/33/CAP747.PDF

Section 1 carries the list. Dragqueen - your C120 is Annex II so your maintenance will be carried out under BCARs by an M3 organisation or similar. You don't need to worry about EASA (lucky you!)

2. A maintenance company can be Subpart G and F approved, which means that the same person may manage your aircraft's airworthiness and also do the work on it when required. You can have the aircraft managed by one company and worked on by another, but I think this will be unlkely in practice. Most companies I know want to keep the whole operation in house as thety do now.

[vee-tail-1]

."" A maintenance company can be Subpart G and F approved, which means that the same person may manage your aircraft's airworthiness and also do the work on it when required. Most companies I know want to keep the whole operation in house as they do now."

Not so! the organisation can manage continuing airworthiness, and the same organisation can do the servicing & maintenance. But the person doing the servicing is not allowed to carry out management & review of continuing airworthiness. No time to dive into my copy of part M and the relevant MA... but airworthiness review staff in an organisation have to be separate from the servicing and maintenance people.
You could have a maintenance organisation that has the minimum of just two people, one does the dirty work and the other does the paperwork.
Edited to say the relevant MA is AMC MA 707 in NPA No 2007-08 and as it has been translated from the original French it is bl***y hard going! :bored:

[EGBKFLYER]

I'll try to find the Part M section too but I beg to differ Vee-tail. I work with an organisation that has been G approved and F approved, with the Chief Engineer as the only Airworthiness Review Staff and licenced engineer for Sub F work.

I'm thinking about small organisations - maybe the rules differ here?

[vee-tail-1]

Reading the MA 707 there seems to be a distinction made between staff carrying out continuing airworthiness management and those carrying out airworthiness reviews for issue of an ARC.
The GSAC guide I mentioned in an earlier post is more specific. Giving examples of a combined CAMO / Maintenance Organisation set-up, where the Cessna supervisor is required to do airworthiness examinations on Robin aircraft, and vice versa for the Robin supervisor. The general principle of the inspector of the paperwork being different to the person who did the servicing still holds.
If only it was all written in plane! English. God knows how people whose native language is not French or English get on with part M :eek:

[giloc]

But the person doing the servicing is not allowed to carry out management & review of continuing airworthiness.
That's not what M.A.707 says. In fact, it specifically says that in Subparts F,G, and I-approved organisations the maintenance staff may be nominated to conduct airworthiness reviews even where they have been involved in the maintenance of the aircraft, as long as they haven't been involved in the maintenance management.

[jxk]

OK, so what's to stop with a two man business: op 1 doing the maintenance management on aircraft A and op 2 doing the physical part and then op 2 doing the mm on aircraft B and op 1 doing the spanners bit. Seems like a real waste of time. This is all going to cost owners a hell of a lot of more money and drive GA further into the mire. It seems that creating this two tier system is another way for those who don't want to get their hands dirty to sit in office and make money. Part M seems over beaurcratic and what are facts to support this way of working: is this going to make continuing airworthiness any better, I don't think so. How many incidents are down to maintenance; usually manufacturing design problems eg valve, cylinder and casting failures.

[vee-tail-1]

Hmmn probably the only way to make sense of it is to read the French original.
The English version is clear as mud. Possibility for confusion: The French for maintenance (as in servicing) is entretien. The French for maintenance (as in continuing airworthiness) is maintien, and this is used a lot in part M. The French have also adopted the English word maintenance as in "organismes de maintenance" which refers to "operations d'entretien" A CAMO in French is "l'organism de gestion du maintien de la navigabilite"
Sorry I am not trying to be clever, it's so difficult to actually understand what the intention of part M is when the wording is so convoluted.

We have a French forum on pprune, I wonder if our French colleagues understand Part M better?

[giloc]

I agree that much of Part-M is close to impenetrable, but I think M.A.707 is actually pretty clear. In fact, it makes sense to me that the person conducting an airworthiness review should not have been involved in the maintenance management, since what they are reviewing is largely the documentation for which the maintenance management person has been responsible. Otherwise, they would essentially be reviewing their own work.

[jxk]

1. But why is supervising your own work bad? Currently, you have to sign for your own work anyway and are thus responsible for it.. Who will be responsible in future the manager or the mechanic? And if say an owner has done some work on their aircraft and you sign the aircraft off subsequently, who's responsible then?

2. It's very interesting to read that there appears to be a difference between the English and French interpretation of some of the terms used in Part M.

[EGBKFLYER]

Dear All,

I agree that the wording of AMC MA707 is not the best and reading it again v your commments made me wonder what the situation is really.

I've just got off the phone to one of my CAA surveyors, who has clarified it for me:
AMC MA707(4) says:

To hold a position with appropriate responsibilities means the airworthiness review staff should have a position in the organisation independent from the airworthiness management process or with overall authority on the airworthiness management process of complete aircraft.

The bold bit is the key. So far as CAA is concerned, they interpret this as meaning the Airworthiness Review Staff should be EITHER independent OR fully responsible - i.e. no halfway house. I already have one Subpart G approval under my belt done on this basis (CAM is also the only ARS:)), with another to follow in Sept, so it seems that is really how things are being seen.

Hope that helps! I love European legislation.:\

[vee-tail-1]

Thanks EGBK
only another 457 pages to dicipher :uhoh:

[IO540]

What would really interest me (if I was flying a Euro reg plane) is how easy/difficult it will be to get a 1000-1999kg plane maintained by a freelance engineer.

They are generally the best people for getting a decent job done (because the buck stops right there) and this is one of the advantages of N-reg ownership. It's easier for the owner to be pro-active on maintenance and use different people for different tasks according to their different skills and honesty.

[giloc]

I still don't see why M.A.707 is so hard to interpret. It actually gives a list of examples of what "independence from the airworthiness management process" means. One of those examples is the case where the engineer that does the maintenance also does the airworthiness review.

[giloc]

They are generally the best people for getting a decent job done (because the buck stops right there) and this is one of the advantages of N-reg ownership. It's easier for the owner to be pro-active on maintenance and use different people for different tasks according to their different skills and honesty.
I agree. That is how I currently maintain my aeroplanes, and how I would like to continue to do so under Part-M. Assuming the latest EASA amendements are passed in to law, and non-commercial use, I'm hoping it will work like this:

I, the owner, am responsible for the airworthiness management of my aircraft.
I engage a Part-66 licenced, independent engineer to carry out the maintenance required under the LAMP.
Every year for aeroplanes >1000Kg and <2000Kg, and every third year for aeroplanes < 1000Kg I need to take the aeroplane to a CAMO with sub-part I privileges.
The CAMO conducts an airworthiness review and recommends the re-issue of the ARC for another year.
For the <1000Kg aeroplanes my Part-66 engineer conducts the 1st and 2nd year airworthiness reviews.
The CAA re-issues the ARC on the basis of the CAMO/engineer recommendations.

Part-M calls this an uncontrolled environment, but in reality I'm doing the controlling.

[EGBKFLYER]

Giloc,

Sounds OK to me.

A couple of points - CAA are saying LAMP is not enough. A maintenance programme has to be developed (MA302), which includes the manufacturer's recommendations, ADs, SIBs, SINs, SBs etc etc. LAMP will be a good base on which to build but doesn't include all the sources of data 'they' want to see. As an owner, you can also add things to the programme (e.g. a more regular spat inspection for operations off rough surfaces)

As the aircraft is outside the formally -defined 'controlled environment', each review will be the 'full' version (i.e. not just an extension). I guess time will tell how expensive that is compared with being in a controlled environment.

[giloc]

A maintenance programme has to be developed (MA302), which includes the manufacturer's recommendations, ADs, SIBs, SINs, SBs etc etc
Indeed, but this is no different from what we have in place already. And it helps that once the LAMP has been customised by the owner/operator for an individual aircraft it can then be considered CAA approved without any requirement to submit it for formal approval.

I guess time will tell how expensive that is compared with being in a controlled environment.
Exactly. However, hopefully a fair amount of competition will emerge in this area from new organisations, including from some in France.

For my aeroplanes I am expecting that no more than a day's work for each will be required to complete an airworthiness review.

[vee-tail-1]

EGBK giloc The CAA won a BIG concession from EASA when they renamed LAMs and called it LAMP. LAMP is a generic maintenance programme, and the French system on which part M is based uses Type Specific Programmes. These programmes are issued by aircraft manufacturers and are specific to mod state, engine type, equipment, ADs, etc. They use the ATA 100 numbering system and are intended to be used by owners as well as non licensed people. So they say EXACTLY what has to be done and when to do it, and require no interpretation. So any competent mechanic can achieve full and safe servicing of the specified aircraft. If you operate a French manufactured aeroplane the type specific maintenance programme for your aircraft will be on file with GSAC, and may well be available in English from the manufacturer.
This use of Type Specific rather than Generic is quite a cultural change for Brits.

[giloc]

If you operate a French manufactured aeroplane the type specific maintenance programme for your aircraft will be on file with GSAC, and may well be available in English from the manufacturer.

I have a French manufactured aeroplane, and I have the English version of the maintenance manual. I don't like it, and I use the LAMS/LAMP instead. The main problem with it is that it makes assumptions about the level and type of utilisation that are not appropriate to my operation. The LAMS/LAMP allows a level of discretion in deciding what should be done and when, that I think is better suited to the hugely variable operating conditions that may apply to a particular GA type.

[EGBKFLYER]

Vee-tail. One of the companies I work with has a number of Robins in its scope of work - I'll make them aware of the GSAC thing (we have the luxury of access to a fluent French speaker too) so it may help. Thanks for the info.

Giloc - agree re the maint progs but under the old system, I wonder howm many folks actually amended LAMS to suit their own requirements?

[A and C]

One of the biggest problems with EASA part M is that once committed having the aircraft maintained by a sub-part G & F company the owner is more or less committed to stay with them or step out into the "uncontrolled environment" and face more expense.

This is a recipe for commercial disaster with company's giving poor service because they have the aircraft owner over a barrel and unreasonable owners claiming that engineering companies are abusing there position to generate work.

For this reason we are setting up a sub-part G company to manage aircraft maintenance for owners, this way the aircraft owner can take the aircraft to any sub-part F company for maintenance and stay inside the controlled environment.

It will also rid the part F company of 99% of the paperwork and give them an independent person to deal with the more unrealistic expectations of some owners.

I will announce the company in the aviation press once the EASA approval is in place.

[EGBKFLYER]

Good luck with that A and C :ok: - I wonder how many others will do the same?

[NutLoose]

It was going to be that the Engineer certifying the ARC would have been an independant Engineer within the company or that of a separate company such as happens now with Airlines.

But I believe it was realised that this would be untenable for one man Companies or those stuck out in the back of beyond to attain this...... The CAA would of had to attend those companies in the likes of the wilds of Scotland, and they simply do not have the staff to do that.

We original looked at having a Company on the next Airfield carry out our ARC issues and I would return the favour.. but was then informed that it would be ok for me to both Issue the ARC and carry out the work on the Aircraft as well, and as such our approvals are progressing with the system set up to do it this way in agreement with the CAA.....

So yes you can have one person responsible for both, after all is that not what we have already? the CAA previously issued the Certificate of Airworthiness based on the say so of the Nominated Engineer, who would possibly have also carried out the work required, without in 99% of cases ever seeing the Aircraft involved.

All the new system does is takes the CAA further out of the loop whilst further reducing their greatest fear....... Getting Sued

[jxk]

Why couldn't owners be asked what kind of maintenance organisation they would like? I assume that owners will still be ultimately responsible for seeing that their aircraft is airworthy. AND, if I were a Part G (nuts & bolts) I would expect the Part F to put their signature on the work as it will be them who decides what should done.

[NutLoose]

jxkWhy couldn't owners be asked what kind of maintenance organisation they would like? I assume that owners will still be ultimately responsible for seeing that their aircraft is airworthy. AND, if I were a Part G (nuts & bolts) I would expect the Part F to put their signature on the work as it will be them who decides what should done.


Actually I think you are misreading the rules..... All the part F does is releases the Aircraft back to service and determines the minimum requirements of that work...... they neither carry out the survey as such or sign for the work carried out on the aircraft, the simply oversee and manage the check.... true they may clear it after inspecting it and issue the ARC, but the Licenced Engineer that has signed for the work under Part G is still ultimately responsible for the work he has carried out. And that is where the buck will eventually stop... so regardless of what the part F maintenance company says, I would never sign an aircraft off I was not personally 100% with.

[IO540]

I must confess this stuff goes way above my head. I went to a presentation on Part M a while ago and it went over my head then too. Reading about it now, and having spoken to a few maintenance firms recently, it is obvious that interpretations of the regs vary so widely it is a bit of a joke at times.

The one thing I do understand however is airfield / maintenance politics. Whatever system is adopted it needs to be realistic. Currently, many (many) owners do not use the company based on the airfield for various reasons. It might be no good, or it might be OK but you cannot give them any work (other than trivial) in case there is a dispute in which case you will have trashed the one band which can give you a release to service signature in an AOG situation.

My experience is that the happiest owners who keep their planes in the best condition are ones who have the freedom to pick and choose who does what (and yes a disproportionate % of those are N-reg because doing exactly that is easier on the N-reg). I am one of these but it took a while to suss things out.

Large chunks of the maintenance scene are nothing short of a disaster, but if you are not careful you will end up over the barrel belonging to one of these companies.

[EGBKFLYER]

Hopefully I can clarify slightly (we'll see in a paragraph's time!)...

As an owner/ operator, signing a contract with a Subpart G organisation means that THEY, not you become responsible for the aircraft's airworthiness - it's MA 201 (a) and specifically (e) to look at here. That's is in essence what you're paying for and why there is a contract.

Someone has to ensure the aircraft is maintained in accordance with a maintenance programme. In a 'controlled environment', the G organisation has that responsibility. As the owner/ operator, you can have a say about what goes into the programme but it is the job of the organisation managing the aircraft to ensure all items are covered and the work is done correctly (MA708b)

As an owner/ operator, you can instruct your managing company (the Subpart G organisation) to get maintenance performed anywhere and everywhere, so long as it's done by an appropriately approved organisation (i.e. Subpart F or Part 145) and released in accordance with Subpart H - that's MA 708b again.

There - clear as mud!:}

[jxk]

Nut Loose
Then what do we need a Part F for? Because as you say it will be someone else's responsibility to do the survey and eventually put their signature on it. This is precisely what an M3 organisation does today and will do for annex 2 aircraft.
Why not straight bananas whilst we're at it!

[smarthawke]

I'm used to surveyors having their own ways of interpreting things but this can you/can't you bit about being the CAM, ARS and signing the CRS takes it a bit far!

My surveyor came up on Wednesday for my (M3) audit etc and to discuss the 'future'.

Quoting from the CAA 'Acceptance of nominated Part M Airworthiness Review Certificate (ARC) signatories' guidance letter (March 08) that he supplied me with:

"M.A. Subpart G organisations with Part 145 / M.A. Subpart F approval, may nominate maintenance personnel from their Part 145 / M.A. Subpart F organisation as airworthiness review staff as long as they are not involved in the airworthiness management of the aircraft. These personnel should not have been involved in the release to service of that particular aircraft to avoid possible conflicts of interest."

My interpretation of the above is that you can't be the CAM, ARS and CRS issuer all on the same aircraft. Surely that goes against what others have been told and approved, or are those examples previously mentioned operating as 'one man very small organisations'? The next paparagraph says:

"In the case of a one-man organisation, since such a person has overall authority they can be nominated as airworthiness review staff."

My surveyor takes it that to qualify as a 'one man band' you can't be Sub Part F and therefore release aircraft on your licence a la M3.

Are you guys saying that you can have a 'one man Sub Part F' where one person can issue the CRS and ARC and be the CAM when Sub Part G and F are the same company?!

[EGBKFLYER]

Are you guys saying that you can have a 'one man Sub Part F' where one person can issue the CRS and ARC and be the CAM when Sub Part G and F are the same company?!

Smarthawke - yes we are! Again - to be clear: Subpart F would issue a CRS, Subpart G would do CAM and issue the ARC (if it had subpart I priviledges).

Your surveyor may be correct in saying 'one man' organisations would have trouble attaining Subpart F, due to all the other requirements (facilities, management structure etc etc) but there is nothing to prevent it if all requirements are met.

Be aware that this legislation is new for everyone - including the CAA. Knowledge levels vary among surveyors and it's always worth pressing for written justification (via the AMC or Part M itself) if you have a query.

[smarthawke]

Hi thanks for that, I've emailed my surveyor to add to his confusion with what has been said here!

It was more of the 'one man band' is required if you want to do CAM, ARC and CRS because one person can't do all three under Sub Part F - that's what his view was!

We intend to go for Sub Part F (as well as G and I) and are fortunate to have all the other boxes ticked (ie facilities etc).

Ho hum, back to the CAME writing - surveyor says a new 'Anybody's CAME' will be out 'at some time' but to use the old one because no one knows when it will appear. He hadn't even seen the letter we were sent last week by the CAA about the 05 Jan 09 Sub Part G extension.

As you say, the CAA don't know all the facts either which makes it a tad difficult for them to pass on accurate info to the industry.

[EGBKFLYER]

:{ I sympathise Smarthawke - makes a hard job even harder eh? Sent you a PM btw.

[irish seaplane]

Think IO-540 hit the nail on the head here:

My experience is that the happiest owners who keep their planes in the best condition are ones who have the freedom to pick and choose who does what (and yes a disproportionate % of those are N-reg because doing exactly that is easier on the N-reg). I am one of these but it took a while to suss things out.

Large chunks of the maintenance scene are nothing short of a disaster, but if you are not careful you will end up over the barrel belonging to one of these companies.

I just visited a Sub Part F/G firm who I wanted to talk to about keeping my C180 G-Reg machine on the G-Reg post EASA rules in Sept. They showed me a C150 they had taken in for an Annual - so far they spent 900 HOURS on it... I know it was in bad order, but thats twice what the AC is worth. I see the N reg being the lesser of two evils - come what may in Sept..... The only thing thats certain about the pending EASA rules is that maintenance organisations will ride you Ten Stone Eight! :ooh:

[A and C]

I have much sympathy for Irish Seaplanes point of view but has he considered what the maintenance companies think of part M?

Most of us just want to get on with the day to day job of maintaining customers aircraft, all that this paperwork is doing is getting in the way! It is taking senior staff away from the hanger floor to produce tons of paperwork that has very little effect on flight safety. These staff would be much better employed inspecting aircraft and directly supervising the work.

I can't help thinking that part M will push up prices and reduce the safety standards because the paperwork will distract people from the important job of inspection.

I would be most interested to see what is happening in France over all of this and would look with interest at the way pat M is administered.

[jxk]

I know this particular thread only represents a small sample of engineers and owners but I get the impression that most people don't want all the extra bureaucracy associated with Part M. I always believed that the CAA's job was to look after the interest of us poor punters, much as they do for airline travellers; are they listening?

[EGBKFLYER]

I think you're right jxk, but CAA is ultimately a government agency and even the government's hands are tied. The consultation has been done, the laws written and all but implemented. The only way to change things now is through long and arduous lobbying at European level, with any significant change taking years to show as a benefit at our level. Wish I could be more cheerful about it but I think we just have to get on with what we've got and try to make the best of it...

[IO540]

The only way to change things now is through long and arduous lobbying at European level

or by creatively interpreting the EASA rules, which will be done by the

French
Italians
Spanish
and in fact probably everybody south of the Alps

Only the UK, and perhaps Germany, will interpret strictly.

[EGBKFLYER]

:D Yes you're quite right IO. Chaos rules!

[vee-tail-1]

Ten years of maintaining my French registered / UK based, Robin make me think that "Creative Interpretation of the Rules" has a lot going for it.
Brits however sometimes seem more concerned with following the letter of regulations, rather than achieving the intentions behind them.
Perhaps an appreciation of what EASA is trying to do would make the convoluted rules more understandable. Certainly under the French system I have been able to do all necessary work on my aeroplane to achieve safety, and then adjust the paperwork to fit. That was under the existing French system , and I anticipate very little difference with part M.
Indeed under part M it seems I can be my own CAMO and do much of the hands on servicing under Appendix VIII, and issue a CRS. What I have been doing for the past 10 years is about to become fully legit.

[IO540]

This could mean large numbers of people re-registering in other EASA countries.

With JAA licenses, the registration does not matter.

I know some people do it already but I have never found a clear list of the benefits of being on say a D-reg.

The only thing is the letter of ANO article 140 which bans any aerial work in a foreign reg plane, and while the DfT will give you permission to receive training in one, and some other stuff, this is a hassle. It incidentally also bans the traditional PPL Cost Sharing scheme - the passengers may not contribute a single penny towards the flight. I vaguely recall somebody having got a letter from the DfT saying Art 140 does not apply to EU-reg but have never seen a reference.

If there is an enforced move from N-reg to EU-reg, anybody doing that will naturally shop around for the most appropriate nationality. I should think some new EU members e.g. Romania might provide interesting options. There will be thousands of pilots in Europe doing this - if it happens.

[vee-tail-1]

IO540
I certainly would'nt recommend the G register! It seemed logical to transfer from French registration when I bought my Robin. But the ludicrous requirements of CAA surveyors became almost comical before I pulled the plug and abandoned the whole exercise. For example: They have a generic requirement for a starter warning light. So I duly reactivated a redundant warning light circuit to provide it. But this was considered to be a mod and required full investigation and approval by EASA. Next they considered that my then recent top overhaul was not properly documented and needed to be investigated by a licensed engineer. When they started talking about removing some of the fabric wing covering to investigate the wood structure ..I told them to get lost! Like I say some Brits love rules rather than results :*.

[Hoof-Arted]

Veetail That starter warning requirement was cancelled in 2005, so if you were told to do it after this date you were given duff gen.Check out CAP 747.

[IO540]

When my TB20 was new in 2002 and going onto the G-reg, the CAA inspector

- insisted on EXIT stickers on the doors
- insisted on a "VFR ONLY" placard on the IFR GPS (which already had a BRNAV certification from the DGAC so good for IFR enroute)
- insisted that the IFR features in the GPS were disabled
- insisted on an INOP placard on the prop TKS de-ice operating switch

Great stuff, which really enhanced my safety.

Then, when 3-4 years later the CAA wonders why there is so little participation in their GPS approach trials, they are suprised that so few had the required certified equipment. Today, only N-reg owners, and a miniscule handful of G-reg owners (probably under 10 in all of the UK) have approach certified GPSs.

Britain has a particular tendency to generate large numbers of little men who love implementing regulations. In my business (electronics) I come across them too, constantly lobbying the Govt and the EU for new regs on which they can "offer consultancy services".

The more southern countries also love paperwork (Greece and Italy being really bad) but they ignore the regs they don't like, just as long as there is enough paperwork left over to create the expected jobs. The content of the paperwork itself is not important, so long as somebody gets paid for it.

[jxk]

I remember Gwyneth Dunwoody (now no longer with us) chairing a parliamentary committee regarding EASA - the committee found EASA 'not fit for purpose'. Does anyone know what has happened since?

[robin]

It makes no odds - they also gave the CAA a sort of clean bill of health and blamed all the rest on the EU. As it is part of the EU gravy train, there is nothing the HoC can do about it.

Oh, and since the review of the CAA by the Transport Committee, there has been mega-silence from the CAA despite their promises to engage with us regularly. We haven't had the long-promised second GA conference yet

[Johnm]

I'm resisting the temptation to cancel my insurance, tear up all my paperwork and switch off my transponder, for now at least:*

[camlobe]

I have read this thread with great interest, not just for entertainment, but like most of us on here, this place is one of the better areas to get helpful and factual information. Our ever-helpful Civil Aviation Authority haven't been too good at disseminating information to aircraft owners/operators in recent years, especially regarding Part M Sub Parts G and I. Their standard response is still 'well, it is on our website'.

For personal and professional reasons, the 28 September 2008 will have an effect on me. As well as owning/running my own Part 145, I am also an aircraft owner.

You could be forgiven for thinking that because of my association with professional and approved maintenance, I would have all the knowledge required to move smoothly forward with Sub Parts G and I. Well, actually I am quite uncomfortable with most of it, for what I consider good reasons.

With regard to my AOC commercial customers, I feel that Part M Sub Part G is right. If you are carrying passangers for hire or reward, then the standards of operation and maintenance must be of the highest order. I have no problem whatsoever with this notion. The extra level of administration is even, in my humble opinion, justifiable, providing all EASA AOC operators are subject to the same, stringent requirements. No exceptions. No exemptions. The utopian level playing field. After all, that is what we all have been told will be happening.

To take stringent, restrictive, and financially burdonsome commercial requirements, drawn up around the airline industry, and force them onto non-commercial light aviation is not right, nor is it appropriate.

For many years, non-commercial light aviation has been maintained and certified by professional and well motivated engineers. Within an organisation, one appropriately licenced and approved engineer has been able to raise all paperwork, clear and certify that paperwork, issue a CRS, complete Log Book entries, update the history file for the aircraft, and for non-commercial 'Public Transport' type operations such as flying school aircraft, issue a Certificate of Maintenance Release or CMR. The CMR is a statement from the engineer confirming that over the last three to twelve months (as applicable) all appropriate maintenance and mandatory inspections and modifications have been carried out and complied with.

It has now been deemed that the sole certifying engineer can no longer be trusted with this responsibility. EASA wants the three tasks, a) raising and recording of workpacks and history files; b) certifying aircraft by issuance of CRS; c) issuing the CMR under a new name - Airworthiness Review Certificate; all to be carried out by three seperate individuals. And they wanted all three to be licenced engineers or graduates. This scenario is straightforward for the airlines with large admin and tech record departments.

The authority has made noisy complaints about the light aviation industry not having acted yet, being as they have had four years to prepare and apply for Sub Parts G and I. The authority hasn't, however, listened to the same industry who advised said authority that, following the fiasco of JAR's the industry would wait until the 11th hour as the authority would, without fail, move the goalposts. As we all can see following recent events, letters and LTO's, this is exactly what has transpired.

The CAA became so concerned that the industry wasn't bothering to apply for Sub Parts G and I that they even reduced the initial application fee - to £41. They have also stated that for the smallest organisations, one individual may carry out all three tasks. The CAA are making loud noises about the 160+ Part 145 Approved Maintenance Organisations that have now applied for Sub Parts G and I. The industry has told the CAA, all that is happening is organisations are merely registering an intent. If it is decided to be too administrativly and financially burdonsom, the industry will simply cancel their 'register of intrest' and write off what amounts to be less than one man-hour labour charge.

Is it too burdonsom?
From the financial point; for a small organisation, the authority will allow one person to carry out all three tasks. But because the Sub Parts G and I will be its own seperate approval, the CAA want paying for issuing and renewing this new approval. So in reality, the small organisation can continue to do what they have been doing for years, only now they will have to pay for the pleasure. The Sub Parts G and I will also have to have regular external audits in the same way as any other approved organisation, and this will have to be paid for. These costs will have to be passed onto the owner/operator. The Sub Part G, or CAMO (Continued Airworthiness Maintenance Organisation) will have to initially create a 'back-to-birth' history for each and every aircraft they will be managing. For a two-year old Cessna 172 or Piper Archer, this will be straightforward. Only most privately owned aircraft arn't two years old. How many of you have a thirty year old aircraft with only one or two Log Books going back ten years? How are you supposed to retrace the first twenty years of that aircrafts life? This initial investigation will not be cheap. Another cost to the beleaguered owner. These costs will have to be added to by ensuring your new LAMP meets the CAA requirements by the 28th of September 2008. How many owners/operators will be able to do this to the required standard without input from their maintenance organisation?

From an administrative point; there will have to be a new book raised by the Sub Part G detailing what they will be doing and how they will do it. This is similar to an MME or an MOE, and is titled a CAME (Continued Airworthiness Maintenance Exposition). This will have to be approved by the authority. The premisis for the Sub Part G, which literally can be a broom cupboard, will have to be approved by the authority. External audits will have to be responded to. Authority audits will have to be responded to. For an existing Part 145 approved organisation, this is a considerable increase in what is already percieved to be a grossly excessive beurocratic excercise which detracts from the original mission of maintenance of aircraft. This final point is seen by many small organisations as proof that light aircraft maintenance is less safe under EASA than under previous umbrellas. The stated reason for this is simple. It requires an experienced engineer to be able to deal with the ever-increasing reams of EASA generated paperwork. The more time this experienced engineer spends on paperwork, the less time he or she is able to spend on supervising maintenance. The professional and dedicated junior or less experienced engineering staff will continue to give their best, but the eye and voice of experience will not be there to advise them 'don't disconnect that yet or this will leak everywhere' or 'if you move this first, that will not get bent'. Experience isn't written down in the manufacturers maintenance manuals.

So, with regard to my earlier comment about my discomfort. After all this administration and financial cost, will any of it make your privately operated aircraft any safer? I suspect that my own personal views are sure to be echoed by many others here.

There is another point that has been brought to my attention recently by someone who has far more grasp of the whole Sub Parts G and I picture than myself.
At present, if the certifying engineer, who really is a human, misses an Airworthiness Directive or other mandatory requirement, the CAA will give him or her a hard time and advise them of the error of their ways. Official letters will be written and the lesson will hopefully be learnt.
Apparently, under EASA, if the Sub Part G and Sub Part I individual(s) miss an AD or other mandatory requirement...

it is a criminal offence.

So, following a human factors issue, a licenced engineer ends up with a criminal record. Now try and get a job in aviation with that behind you, especially in these times.

As an aside, the CAA's published list of Sub Part G approved organisations makes interesting reading, if only for the wrong reasons. Two thirds of the organisations presently approved are approved for either turbine aircraft or helecopters only.

Well, after digesting the above, how many of you will move across to the LAA or 'N' reg before January 2009? How many of you are going to be stuck with type certified 'G' reg aircraft that you can't sell and are too expensive to maintain? And how many of the Part 145's will actually follow up their 'register of intent' and gain Sub Part G approval?

Oh, forgot to mention, I haven't applied.

And, most importantly, do remember. A Continued Airworthiness Maintenance Organisation has absolutely nothing to do with maintenance. It is only an administrative organisation.
Real maintenance is carried out by engineering staff in a MAINTENANCE ORGANISATION such as an M3 or a Part 145.

camlobe

[EGBKFLYER]

:ok: Great post Camlobe. I think it sums up what an awful lot of people involved in GA are thinking. I'm hoping this thread will keep running and that owners and maintenance staff alike will post their experiences after 9/28 so we can all see if it's actually the problem we think it's going to be right now.

One tiny point:

Continued Airworthiness Maintenance Organisation has absolutely nothing to do with maintenance. It is only an administrative organisation.
Real maintenance is carried out by engineering staff in a MAINTENANCE ORGANISATION such as an M3 or a Part 145.

Please may I add a Subpart F-approved organisation to that?:)

[jxk]

Camlobe
A great post: I believe most owners are completely oblivious to these changes. And although the initial issue fee of £41 is a one off, what about the future; I've heard figures of £2700 for each part (F & G). So, if true this adds £5400 to the costs of an average M3 organisation, FOR WHAT?. Grrrrrrrrrr!

[smarthawke]

Another 'well done' for Camlobe's post from me. I passed on some of the info from this thread to my (Gatwick-based) surveyor and he's gone off to compare notes and find out what constitutes a 'one man' 'very small organisation' - literally one man or...?

Out of interest, EGBKFLYER, how many people work in the organisations you've been working with and what split licensed/unlicensed?

I've had a few owners ringing me today concerned about the CAA letter regarding Subpart G/F etc and what it means to them.

I do find it strange that the CAA sends out letters to maintenance organisations and owners addressed to 'Dear Colleague'!

[IO540]

Very interesting post, thank you.

And they wanted all three to be licenced engineers or graduates.

I don't wish to appear flippant but surely that one is easy. Almost everybody who can record an MP3 file on their laptop can get a degree in Multimedia. If you can knock up a website you can get a Masters in Multimedia (Univ of Sussex, my 1970s stomping ground...)

Is it really worded that way?

[Malcom]

This whole debacle is a Human Factors Issue!

Its got so many people wound up / perplexed / uncertain of position / lacking in current information that it is a HF analysists dream.

I'm not applying for CAMO status yet either - why should I when the rules are in place and might / might not change with less than a month to go? This is something the CAA just dont want to grasp! Extending the deadline to January 2009 wont change anything unless and until the rules are finalised and in place.

As for making 5-1-09 the new deadline instead of September 2009 so as to avoid commercial losses to those CAMOs who already made the leap, surely these people did so fully knowing changes to Part M are / may be in the offing? Now we all have to leap before the landing ground is ready,while other EU countries will probably have another year to deal with this - nice level playing field play on.
The real reason must be the CAA cant cope with the workload, and has no system to deal with it. A maintenance company must have sufficient staff for the work it does or it is not in compliance with the rules, gets told off and shut down. Should this not work the other way too?

When it is sorted then I might apply - the NPA made slightly better reading than the original Part M, but I might just get an FAA IA instead and re-register the plane N reg just to get away from this mess.

[robin]

Got a nice letter from [email protected] today teling me the CAA line

I'm so p*ss*d off I've fired off a letter to my MP and to the Chair of the Transport Select committee as well as telling her what I think about the way the CAA (uniquely within the EU) has decided to act.

What is is to have an organisation that cares about you.........:{

[David Roberts]

Camlobe,

I also endorse the others and compliment you on a very perceptive post, which got to the heart of the matter.

Suffice to say that I have been making these noises to EASA and the CAA for some time in my capacity as a so called 'expert' on GA regulatory matters. I have had a - very polite - conversation very recently with one of the Belgrano senior people and he has written to me explaining the reasons for their decision re timing of implementation of the revised Part M (despite it still being stuck in the Commission / EU Parliament process). I hope to get his permission to make his reply more widely available, but time has not been on my side this week. In the meantime though I am told there will be a more extensive explanation on the CAA website very soon - like in the next week.

I agree with another forumite that for EASA / the EU political process to make a breach of the regulations by a person carrying out the tasks a criminal offence is absolutely outrageous. I see the natives rebelling soon....

Over the last few years I have been converted from a fairly conformist sort of individual to an absolute rebel and libertarian, by my experience of dealing with aviation rulemaking first hand. I never knew I could swear so much!

[jxk]

AND, wasn't there supposed to be a COST JUSTIFICATION for making such changes within the EU before any rule making could take place? I know originally they (the commission) argued that because some countries had already started the process ie JAA that the need had been already established. It sickens me that as an aircraft owner I have no say in how my aircraft should be kept airworthy and yet I'm ultimately responsible for it. Do they (the CAA) believe by increasing the costs (30% year on year) to maintenance organisations and hence to their customers this promotes better airworthiness. Grrrrrr again!

[camlobe]

Hopefully my earlier post was considered informative and accurate in its content. There is the usual situation of individual interpretation by surveyors that will add further 'fun and games', as well as further potential movement of goalposts.

jxk, regarding your posts, I tried to ascertain what the costs would be for combined Part 145 and Sub Part G and I at renewal time next April. This was of particular interest to me as, like all other Part 145's, my approval renewal fee in April 2008 was somewhat higher than I was expecting. Foolishly, I expected an increase of inflation plus 6% (what we all have been told will be the standard CAA pricing updates to maintain their self-funding capability), giving around 10% max. Boy oh boy, did I get it wrong. The way I do maths, £2100 to £2786 is just under 30%.

I have been told by CAA Policy dept that the fees will be going up approximately 3% compared to the 2008 rates. And that the fee increases are decided 18 months in advance. Well, if they are decided 18 months in advance, the industry could be informed 18 months in advance, assisting in financial planning. He didn't tell me what the combined approval fee would be though. Also, I haven't been told how much extra the CAA will want in order to add another type or types to the Sub Part G approval. I am guessing that each and every addition will be classed as a 'variation' and they arn't cheap to obtain. Have a look at the CAA ORS series scheme of charges. So, more money to be found by the organisation and billed again to the customer.

Gives you a warm feeling to know EASA are only concerned with your safety, not their pension plan.

EGBKFLYER, my apologies for my omission.

smarthawke, I would be very interested to hear what your surveyor comes back with.

IO540, re the wording, I am at home at the moment and not near the EASA Part M Sub Part G, Sub Part I or Part 145. However, the content of the EASA documents do state such. I will try and locate the specific paragraphs when back in the office. As a quick breakdown, For the certifying engineer in the Part 145, he doesn't have to be an experienced engineer. The printed words are clear. A graduate with an 'appropriate' degree and a few months in an 'aviation enviornment' can gain and hold hold a Part 66 'C' licence allowing base maintenance certification. Tech records departments, battery servicing bays and seat maintenance bays are all classed as an 'aviation enviornment'. The reality is you could have a graduate with absolutely no live aircraft experience certifying aircraft as fit to fly following deep and heavy maintenance. Now doesn't that make you feel good next time you take your family away on an airliner?

The EASA M.A documents for Sub Part G and I do state the positions held will be either a licenced person or a graduate.

Malcolm, I totally agree, it is a serious Human Factors issue. Unfortunately, I don't see the situation improving for small organisations.

robin, please let us know what replies you get.

David Roberts, like yourself, I have tried to be a conformist. Like yourself, I am running out of patience, even to the point of considering dropping my Part 145, complete with its unjustifiable costs, and concentrating on 'N'reg.

camlobe

[jxk]

Does anyone from the CAA read these posts or care that there is such a jumble of complete confusion existing for aircraft owners and maintenance organisations???
Even the documents they do send out to me just seem like so much gobbledegook! I wonder if we could set the people from the TV programme WATCHDOG on to them? Taking you aircraft for maintenance should be no more difficult than getting your car MOT'd.

EU Regulation 2020/8130 Part 12 Chapter 7 Paragraph 1066 subparagraph xii or Grrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrrr.

[vee-tail-1]

camlobe you have moved the discussion from theoretical to practical and it stinks! :ugh:
Thanks for your posts :ok:

[EGBKFLYER]

Smarthawke. The organisations I work with are split as follows:

Org 1: One Part 66/ BCAR engineer/ 2 full-time 'technicians' (i.e. not 66 or BCAR qualified). One accountable manager, one accountant and a quality manager (me!). This organisation is Subpart F and G approved, with I privileges.

Org 2: One part 66/ BCAR engineer who is also the accountable manager. 1 full-time technician, 2 admin staff and a quality manager (me again). This organisation is well into the process of getting F and G with I privileges.

Org 3: 2 Part 66/ BCAR engineers/ 2 (I think) technicians, accountant, accountable manager, quality manager. This organisation has just been Subpart F and G approved with I privileges.


As far as qualifications for ARS (Airworthiness Review Staff - you can tell the first language is not English with that acronym...): M.A.707(a):

To be approved to carry out airworthiness reviews, an approved continuing airworthiness management organisation shall have appropriate airworthiness review staff to issue M.A. Subpart I airworthiness review certificates or recommendations.
In addition to M.A.706 requirements[general stuff], these staff shall have acquired:
1. at least five years experience in continuing airworthiness, and;
2. an appropriate Part-66 licence or an aeronautical degree or equivalent, and;
3. formal aeronautical maintenance training, and;
4. a position within the approved organisation with appropriate responsibilities.

Note point 2. IO540 - I think the degree in Knitting will not suffice!

Camlobe -

The reality is you could have a graduate with absolutely no live aircraft experience certifying aircraft as fit to fly following deep and heavy maintenance.

Not as far as I can see - there are several statements to the effect that the certifying staff must have understanding of what they are certifying before they do so (M.A. 607(a):

In addition to M.A.606(g), certifying staff can only exercise their privileges, if the organisation has ensured:
1. that certifying staff can demonstrate that in the preceding two-year period they have either had six months of relevant maintenance experience or, met the provision for the issue of the appropriate privileges; and,
2. that certifying staff have an adequate understanding of the relevant aircraft and/or aircraft component(s) to be maintained together with the associated organisation procedures...

One of my tasks as Quality Manager is to ensure that certifying staff (who are formally approved by me as it says above underlined) understand what they will be signing off!

[ericferret]

The back to birth history requirement is an interesting one. Our Cessna was built in 1967 and has 10'000 hours. The log books go back to 1983 and the 7000 hour point.. Therefore 16 years and 7000 hours of it's life are missing. Anybody know what will happen when it comes up for ARC renewal? We have operated it without question for 14 years and 6 C of A renewals.

[EGBKFLYER]

Ericferret,

There is no specific back-to-birth history requirement, although I can see where some people may get that idea. The bit of Part M you're interested in is M.A. 710:

M.A.710 Airworthiness review
(a) To satisfy the requirement for an M.A.902 airworthiness review of an aircraft, a full documented review of the aircraft records shall be carried out by the approved continuing airworthiness management organisation in order to be satisfied that:
1. airframe, engine and propeller flying hours and associated flight cycles have been properly recorded, and;
2. the flight manual is applicable to the aircraft configuration and reflects the latest revision status, and;
3. all the maintenance due on the aircraft according to the approved maintenance programme has been carried out, and;
4. all known defects have been corrected or, when applicable, carried forward in a controlled manner, and;
5. all applicable airworthiness directives have been applied and properly registered, and;
6. all modifications and repairs applied to the aircraft have been registered and are approved according to Part-21, and;
7. all service life limited components installed on the aircraft are properly identified, registered and have not exceeded their approved service life limit, and;
8. all maintenance has been released in accordance with this Part, and;
9. the current mass and balance statement reflects the configuration of the aircraft and is valid, and;
10. the aircraft complies with the latest revision of its type design approved by the Agency.

(c) Through the physical survey of the aircraft, the airworthiness review staff shall ensure that:
1. all required markings and placards are properly installed, and;
2. the aircraft complies with its approved flight manual, and;
3. the aircraft configuration complies with the approved documentation, and;
4. no evident defect can be found that has not been addressed according to M.A.404, and;
5. no inconsistencies can be found between the aircraft and the paragraph (a) documented review of records.

The person doing the Airworthiness Review will therefore examine all available records to determine the above. If there is a question over a particular part of the documentation (e.g. missing ADs in a missing logbook), inspections will be carried out as required and the CAA informed (MA710(h)). CAA will ultimately decide what, if anything, needs to be done to solve the problem.

I think in your case you'll have no problem.

[ericferret]

Bugger,

I was hoping that it would be cast into the darkness that is the LAA, meaning I would never have to darken the CAA's door again.

For a while now I have been proposing that older light aircraft say over 15 should be allowed to transfer over to the LAA system. This would be a one way journey at the owners choice and the aircraft would never be eligible for a CofA at any time in the future. The owners of these aircraft would benefit from reduced costs although there would also be a drop in hull value. The airworthiness authorities would benefit as a large number of aircraft would move outside the normal regulatory process.

Many older light aircraft e.g Cessna 150 have a low hull value that would suffer little from such a transfer. If offered I would certainly take this option.

[robin]

As someone flying a type identical to a Permit one, I'm p*ss*d off at not being able to transfer before I run out of money......:ugh:

[smarthawke]

EGBKFLYER

Thanks for the staff info - something I can report to my surveyor if I need to. Not exactly 'one man bands' which he told me are the only people who can apply to wear all 3 hats (ARC, CAM and CRS) and only then if they are NOT Subpart F, ie signing on your license (like M3).

I've applied to go on the Subpart G and I CAA courses which the surveyor told me I had to do to meet the requirements (not that that is mentioned in Part M) despite having been recommending CofA renewals for 18 years....

[jxk]

Part M (for Muddle)

I’m finding it difficult to understand why Continuing Airworthiness is proving so difficult for the European bureaucrats to understand. Remember, that in general we are talking about little aircraft not Boeing 747s or Airbus 380s.
Today light aircraft are subject to 50hr, 6 month and annual inspections; in some cases this is more than the manufacturer’s maintenance schedule and requirements (but that’s by the by).
The maintenance requirements are determined by analysing airframe, engine, and propeller times in relationship to ADs (Aircraft Directives), SBs (Service Bulletins) and LAMS or LAMP (Light Aircraft Maintenance Schedule/Program). This data is recorded in the appropriate log books with a licensed engineer finally signing to say the work has been carried satisfactorily. Now, please explain why we need to introduce all these extra job titles to do what is a relevantly simple task?
This is not rocket science, come on let’s have some pragmatism and commonsense.

[A and C]

The idea of the EEC level playing field for aviation is on the face of it a good one but the administration of this is totally out of proportion to the task in question.

We now have aircraft that are much more basic in construction an all modern cars maintained by an administrative system that is designed for the maintenance of large airliners and overseen by a bunch of beauraucrats that can't or won't see that the system that they are setting up is so totally disproportionate that it will kill with red tape the industry that they are charged with overseeing.

It is quite typical of the bureaucrat that they can't see that they will administer them self's out of a job.

The CAA has by overbearing administration had a large part in destroying aircraft construction industry in the UK and now with the help of EASA they have the maintenance industry in the UK in the way they are introducing part M to the UK.

As to turning "missing" an AD into a criminal offence.......... you might as well build another prison for all the licenced engineers in the UK because with the way the AD system works all engineers will miss a minor AD once in a wile.

Still I could look on the bright side at least in prison I will get three meals a day.......... I won't get that if EASA simply drives me out of business!

[jxk]

I expect the aircraft owners amongst us have probably recently received in the post 2 letters from the Airworthiness Strategy and Policy Department with regard to Regulation (EC) 2042/2003. Firstly, the letter says 'Dear Colleague'; well I don't recall being part of the CAA or even part of the consultation process so how can I be addressed like this? Secondly, the letter says 'Affected owner/operators must therefore make arrangements to ensure an appropriately approved CAMO is contracted by this date'; can this be a verbal contract or should one get a lawyer to draw up this contract, what will be the legal situation if something goes wrong? Has anybody got a pro-forma type of document for this contract?

[EGBKFLYER]

Dear Colleagues,:rolleyes:

A contract must be written and there is indeed an example, given in Appendix I of Part M. I have produced it here:

Appendix I
Continuing Airworthiness Arrangement
1. When an owner contracts an M.A. Subpart G approved continuing airworthiness organisation in accordance with M.A.201 to carry out continuing airworthiness management tasks, upon request by the competent authority a copy of the arrangement shall be sent by the owner to the competent authority of the Member State of registry once it has been signed by both parties.
2. The arrangement shall be developed taking into account the requirements of Part M and shall define the obligations of the signatories in relation to continuing airworthiness of the aircraft.
3. It shall contain as a minimum the:
— aircraft registration,
— aircraft type,
— aircraft serial number,
— aircraft owner or registered lessee's name or company details including the address, M.A. Subpart G approved continuing airworthiness organisation details including the address.
4. It shall state the following:
The owner entrusts to the approved organisation the management of the continuing airworthiness of the aircraft, the development of a maintenance programme that shall be approved by the airworthiness authorities of the
Member State where the aircraft is registered, and the organisation of the maintenance of the aircraft according to said maintenance programme in an approved organisation.
According to the present arrangement, both signatories undertake to follow the respective obligations of this arrangement.
The owner certifies, to the best of their belief that all the information given to the approved organisation concerning the continuing airworthiness of the aircraft is and will be accurate and that the aircraft will not be altered without prior approval of the approved organisation.
In case of any non-conformity with this arrangement, by either of the signatories, it will become null. In such a case, the owner will retain full responsibility for every task linked to the continuing airworthiness of the aircraft and the owner will undertake to inform the competent authorities of the Member State of registry within two full weeks.’
5. When an owner contracts an M.A. Subpart G approved continuing airworthiness organisation in accordance with M.A.201 the obligations of each party shall be shared as follows:
5.1. Obligations of the approved organisation:
1. have the aircraft's type in the scope of its approval;
2. respect the conditions to maintain the continuing airworthiness of the aircraft listed below:
— develop a maintenance programme for the aircraft, including any reliability programme developed,
— organise the approval of the aircraft's maintenance programme,
— once it has been approved, give a copy of the aircraft's maintenance programme to the owner,
— organise a bridging inspection with the aircraft's prior maintenance programme,
— organise for all maintenance to be carried out by an approved maintenance organisation,
— organise for all applicable airworthiness directives to be applied,
— organise for all defects discovered during scheduled maintenance or reported by the owner to be corrected
by an approved maintenance organisation,
— coordinate scheduled maintenance, the application of airworthiness directives, the replacement of life limited
parts, and component inspection requirements,
— inform the owner each time the aircraft shall be brought to an approved maintenance organisation,
— manage all technical records,
— archive all technical records;
3. organise the approval of all and any modification to the aircraft according to Part-21 before it is embodied;
4. organise the approval of all and any repair to the aircraft according to Part-21 before it is carried out;
L 315/28 EN Official Journal of the European Union 28.11.2003
5. inform the airworthiness Member State of registry whenever the aircraft is not presented to the approved maintenance organisation by the owner as requested by the approved organisation;
6. inform the airworthiness authorities of the Member State of registry whenever the present arrangement has not been respected;
7. carry out the airworthiness review of the aircraft when necessary and fill the airworthiness review certificate or the recommendation to the Member State of registry;
8. carry out all occurrence reporting mandated by applicable regulations;
9. inform the authorities of the Member State of registry whenever the present arrangement is denounced by either party.
5.2. Obligations of the owner:
1. have a general understanding of the approved maintenance programme;
2. have a general understanding of Part-M;
3. present the aircraft to the approved maintenance organisation agreed with the approved organisation at the due time designated by the approved organisation's request;
4. not modify the aircraft without first consulting the approved organisation;
5. inform the approved organisation of all maintenance exceptionally carried out without the knowledge and control of the approved organisation;
6. report to the approved organisation through the logbook all defects found during operations;
7. inform the authorities of the Member State of registry whenever the present arrangement is denounced by either party;
8. inform the authorities of the Member State of registry and the approved organisation whenever the aircraft is sold;
9. carry out all occurrence reporting mandated by applicable regulations.

Your CAMO should have its own version based on this...

Jxk - Please note that I will not be charging for contributing to 5.2(2) above!:)