EASA part M......... Q & A

[A and C]

Having just about got the EASA part G,I & F I might be in a position to help aircraft owners decide what is the best course of action for them.

I will be happy to answer questions but it must be remembered that the local CAA offices have large diferences in the way that they are interpriting the new regulations, however I hope that I can help shed some light on the issues and point aircraft owners in a direction that best meets individual needs.

[IO540]

You should write an article on this A&C.

I've spoken to loads of people about this, and even went to one presentation, but I am still none the wiser as to the real options available to an owner who wishes to be pro-active and who has to work it all with airfield politics which often dictate using one firm for "some" work.

It looks like some options are very interesting but would be politically hard to arrange.

And, as always, doing all possible maintenance under pilot privileges saves a lot of money because many companies charge around £500 for the 50hr check. This has to be worked into the process.

[A and C]

As I see this the biggest problem with Part M is if you have a disagreement with your maintainence company simply because it will cost a lot to come out of the "controled enviroment" due to all the CAA fees that will be required to issue the ARC (annualy).

It may well be best for owners to use a Part G & I company to do the paperwork and another Part F company to do the maintenance work.
This may seem a bit complicated but for a relitively small fee it will keep the aircraft within the "controled enviroment" and at the same time let the owner shop around for the aircraft maintenance work.

The advantage of this is that the aircraft owner won't be "over a Barrel" when it comes to the expensive part of the maintenance and if the Part F company knows that the owner can move the work away without leaving the "controled enviroment" they may well be a lot more carefull about the way they treat the owner.

Owner maintenance is part of the Part F remit and as I see it the Part F company has first to make sure that the owner is able to carry out the 50 hour check to a satisfactory standard, they would then in effect issue the owner with a Company approval to do the 50 hour check or any other simple task that they see fit.

I can see this being a cause of much friction as there are some owners that I would not let work on a roller skate and others that work to a very high standard who I would be more that happy to let work to the full limits of the LAMP owner maintenance requirments. As "checking out" an owner would take time I would expect companys to charge for this training/checking before issuing an aproval for the owner to do 50 hour checks.

[IO540]

There is a thread on Flyer on this, with some interesting angles - may be of interest but I don't really understand enough to judge.

[jxk]

Owner maintenance is part of the Part F remit and as I see it the Part F company has first to make sure that the owner is able to carry out the 50 hour check to a satisfactory standard, they would then in effect issue the owner with a Company approval to do the 50 hour check or any other simple task that they see fit.

I thought it was the Part G organisation that could authorise an owner to do some maintenance tasks (stand to be corrected). However, this does bring into issue whether this work could be considered to be in a "controlled environment " and specifically what kind of work would be allowed. The last time I looked at this, it would be the responsibility of the owner/pilot (what about a group owned aircraft) to issue a CRS (release to service). So, how does the owner do the AD research etc.. and lots of other ifs & buts.

Some people believe that Part M is going to improve standards, improve their maintenance and reduce costs. I hate to disillusion them!

[EGBKFLYER]

This may seem a bit complicated but for a relitively small fee it will keep the aircraft within the "controled enviroment" and at the same time let the owner shop around for the aircraft maintenance work.

A and C: How do you see this working in practice? A lot of the subpart G organisations are also Subpart F approved right now, so how would you get round any reluctance on their part to permit work to be done elsewhere?

Secondly, you mention a 'relatively small fee' - with the extra work involved in incorporating other Subpart F organisations into the Sub G company's Quality System, would the fee not be rather larger than you infer?

Lastly, can you give us any evidence of the 'large difference' between surveyors' interpretation of Part M?

Very interested to hear more about your experiences/ plans.:)

[A and C]

I am still trying to get my head around the owner maintenance issue as it is rather a long way down the list of things to do.

However I wholehartedly agree with your last paragraph, all this extra paper is keeping the senior engineers in the office NOT in the hangar keeping an eye on the progress of aircraft checks. In short more paper- less inspection.

[EGBKFLYER]

Jxk - Pilot-owner maintenance forms part of the aircraft's Maintenance Programme. The management of the Programme is a Subpart G activity but it's likely to be developed with the input of the involved Subpart F companies. You're quite right in saying that the person performing the maintenance must be judged competent (AMC 803). Add to this that they must comply with the Programme and the Part M maintenance standards (Subpart D). What the AMC doesn't say is how competence will be judged...

The scope and limitations of what a pilot/ owner can do is well defined in Part M (Appendix VIII). No AD searching etc is required for these tasks and in the case of a group-owned aircraft the Pilot/ owner could be anyone in the group, so long as they have a valid licence (MA 803a).

[EGBKFLYER]

A and C - I think your point about engineers being stuck in the office is very valid. My view is that it will get better eventually as everyone gets used to the new methods and bits of paper, though I think there will be more desk-driving than before unfortunately.:{

[vee-tail-1]

It helps to know that Part M is not really new, it's a modified version of the present French system which works well. Part M brings in new opportunities for SOME UK owners to get involved with maintenance and save money. However if you simply fly your aeroplane and never open the cowlings, & pass it to the engineers for all servicing; then it's going to cost more.
But for those pilots with an engineering background who enjoy getting their hands dirty, part M gives you the chance to look after some (not all) certified EASA type aircraft in much the same way as LAA members do for their permit types.
However the aircraft has to be a simple single engine non-commercial type below 2730 kgs, it has to have a type specific maintenance programme, (generally only available to French & German aircraft), and you need to be working in the "Uncontrolled environment". Your ARC will need to be renewed every year, but this can be done by ANY part G & I company in ANY EU member state. (Choose the state with the lowest regulatory costs)
Much of your time will be spent on keeping documentation updated, it is not for nothing that EASA considered it advisable to create a separate part G organisation to manage the paperwork. Indeed if your aircraft is not a very simple type, don't even think of going the uncontrolled route, it's not worth the hassle. But for some aircraft it is possible for a competant owner to carry out 50 hour and Annual checks using the detailed instructions (what to do and when to do it) in the type specific maintenance programme. Always keeping an eye on the pilot/owner task list in Appendix VIII Like I said, it's not for everyone, and you still have to get a LAE to sign up the ADs, and deal with items of servicing beyond your level of competance. Above all don't just sit back and moan about part M, it gives possibilities for perfectly legal creative interpretation of the regulations.

[Mickey Kaye]

Does that mean as a one man band flying instructor with one aircraft i would be able to do some of my own maintenance? Change oil, filters etc

[vee-tail-1]

Mickey Kaye
No if it is a commercial operation. But you could try to get a definite opinion from the CAA. :ugh:

[IO540]

Vee-tail

However the aircraft has to be a simple single engine non-commercial type below 2730 kgs, it has to have a type specific maintenance programme, (generally only available to French & German aircraft), and you need to be working in the "Uncontrolled environment". Your ARC will need to be renewed every year, but this can be done by ANY part G & I company in ANY EU member state. (Choose the state with the lowest regulatory costs)
Much of your time will be spent on keeping documentation updated, it is not for nothing that EASA considered it advisable to create a separate part G organisation to manage the paperwork. Indeed if your aircraft is not a very simple type, don't even think of going the uncontrolled route, it's not worth the hassle. But for some aircraft it is possible for a competant owner to carry out 50 hour and Annual checks using the detailed instructions (what to do and when to do it) in the type specific maintenance programme. Always keeping an eye on the pilot/owner task list in Appendix VIII Like I said, it's not for everyone, and you still have to get a LAE to sign up the ADs, and deal with items of servicing beyond your level of competance. Above all don't just sit back and moan about part M, it gives possibilities for perfectly legal creative interpretation of the regulations.Could you (or somebody) elaborate on this, and if possible document it on a website?

I fly a TB20 (currently N-reg) which is French, and wonder if your "type specific maintenance" bit applies to that. I do my own 50hr checks (with an A&P/IA but that's irrelevant as all the work done is within FAA pilot privileges) and the maintenance manual contains a long list of items to do. The TB20 has very few ADs to check in between Annuals.

Could I do my own Annuals too?

Managing the paperwork is no rocket science. The problem I see is a political one: some work does have to be done by a company with tools (e.g. landing gear work, needs jacks) and airfield political considerations dictate that one needs to keep in with a company to get them to do this sort of stuff.

Pilot maintenance saves a lot of money, for those able and so inclined. Under G-reg I used to pay £500+VAT for the 50hr checks, so that is £1000-1500/year, and the Annual costs £2500 but takes only about 1 man-week to do.

[vee-tail-1]

IO540 You are so right, the problem with interpretation of part M is political. LAEs have studied long & hard to get their licences, and are going to be well fed up if lots of owners go DIY. Their attitude will understandably be "either I do the lot or none at all, take it or leave it!"
There is a middle way in my opinion, but it's going to need a lot of trust to get it to happen.
As regards your TB20, you are probably familiar with the EADS SOCATA website www.socata.eads.net (http://www.socata.eads.net) this gives a list of maintenance manuals under the GA section. The manuals are published in French & English, and the French ones will have a GSAC approved type-specific maintenance programme. I doubt that the English version will have that programme, because until part M came along there was no need. US registered aircraft used FAA procedures, and UK used LAMS (now rebranded as LAMP) Both LAMS & LAMP are generic programmes, which require an engineer to interpret using his skills and experience to do as much or as little work as seems necessary. The type-specific programmes however need no interpretation, since they say what has to be done and when to do it. So a competant mechanic can achieve full & safe servicing, which is the key to pilot/owner maintenance. You could obtain the French maintenance manual for your TB20, and submit the French type-specific maintenance programme to the CAA for approval if you wanted to put your aircraft on the G register. French is an official EU language so the CAA should accept it. You might get someone to do an English translation for a small sum & a few beers, but only the French language version would be legal. But your aircraft is considerably more sophisticated than my simple ATL, so there will be a number of servicing procedures in the annual check which do not fall under the appendix VIII list of pilot/owner permitted maintenance. My guess is unless you enjoy very good relations with your local engineers, they are likely to tell you to get lost if you ask them to do those tasks only and not the whole annual.
As regards ARC renewal when not in a controlled environment. EASA CRD to NPA 2007-08 brought in the owners choice of having the review done by the NAA, or by any CAMO with part I privileges.
The French GSAC published a useful guide to implementation of part M on their website at the end of 2007, but it has been withdrawn, probably because already out of date due constant moving of goalposts!

[IO540]

Very interesting stuff, Vee-Tail.

Socata only recently opened up their maintenance manuals. One can find them now online on the user group socata.org but these are English ones. I cannot see anything on the EADS website though. Until recently, Socata published these only through the $1000/year ATP subscription. I also have one of the ATP CDs, with the whole lot there. What form should this look like, to comply?

Anyway.........

Given the vast majority of GA is under 2700kg and used only privately, I wonder if this will result in organisations setting up specifically to cater for the DIY market?

What about individual LAEs? Can a "LAE" work out of the back of a van? For a typical GA plane you need very few tools. Some special tools for e.g. the Lyco vac pump bolts (crow's feet spanners) and an owner could buy any others easily. Jacks for gear checks, etc. The freelance LAE could also maintain the documentation.

Most owners who hangar are in any case banned from maintenance inside their hangar, so unless the hangar is owned by their maintenance company (not politically advisable because they have you over a barrel) they are free to go anywhere. My 50hr checks are done outdoors for this reason.

The cost savings would be very big and I am sure somebody will see the opportunity - unless freelance operators get excluded using some other means.

[EGBKFLYER]

Certainly an interesting option - will be very interested how many people try going along this route. One tiny point - NPA 07-2008 is not law yet (though it has been at the final stage before that since about May).

Re Mickey Kaye - I think Flying club aircraft are not classed in the Commercial Air Transport section. If they were, they would have to be maintained by a Part 145 organisation. I think you could therefore do your own maintenance, with all the caveats/ limitations, so long as you owned the aircraft in question. Anyone agree?

[Yankee]

With ref, to owner pilot maintenance, does the owner have to have an ICAO PPL licence or can a UK NPPL only licence holder do it. Have asked a local, soon to be Part M, organisation and it left them scratching their heads.

[vee-tail-1]

IO540 The EADS website is a bit of a maze. From the main page click on General Aviation, then Support, then Online Publications, then Online docs, then in Tech Publications Status click on TB, the page that finally appears gives a list of Flying manuals with a list of other manuals at the bottom. Click on ME-MM (Manual d'entretien-Maintenance manual) which should come up with a list of the current French - English maintenance manuals.

[IO540]

Vee Tail - one gets as far as here (http://www.socata.eads.net/1024/en/General%20Aviation/support/Online%20Documentation/Online%20Documentation.html) and there is no further link, other than the mysocata.com one which needs a login. I've tried in both Firefox and IE7.

[vee-tail-1]

Yankee The only reference I can find to your question is:
M.A.803 Pilot-owner authorisation. Which is part of the NPA 2007-08 which is about to become law:

(a) The pilot-owner is the person who owns or jointly owns the aircraft being maintained and holds a valid pilot license issued or validated by a Member State for the aircraft type or class rating.

2. Pilot owner maintenance shall be performed by:
(i) the pilot owner.
(ii) in the case of joint ownership, the pilot owners designated by the registered owners of the aircraft being maintained or
(iii) where the joint owner is a limited liability company or a legal entity, by a pilot who is a member of, and designated by, that company or legal entity.

(d) The certificate of release to service must be entered in the logbooks and contain basic details of the maintenance carried out, the maintenance data used, the date such maintenance was completed and the identity and pilot licence number of the pilot-owner issuing such a certificate.

So not only will a pilot-owner be able to do some of the servicing, but he/she can issue a CRS.

[vee-tail-1]

IO540 Click on Access our TBM online documents at click here
Then on the page that comes up, under Tech publications status you will see TBM700 TBM850 TB RALLYE
Click on TB and you should see the list of Flight manuals and option to click on ME-MM for maintenance manuals.
Hope it works on your PC as it's ok on mine.

[IO540]

Doesn't work here. That TB link just loads an Excel spreadsheet, listing the manuals in various languages, by part numbers. Are you saying you can download the maintenance manual itself?

[vee-tail-1]

Sorry for the misunderstanding, no, only SBs & SLs are free to download. The list is of maintenance manuals which are available to buy, presumably by subscription to EADS / SOCATA.

[Yankee]

Yes, but the AMC for MA803 states.

1. The pilot–owner should hold a valid pilot license issued or validated by a member state for the aircraft type being maintained.

Now my understanding of that is as the NPPL is issued by the CAA then it should be OK, but the potential CAMO I spoke with is not sure that is how EASA will see it.

A very nice site for getting to grips with part M which is much clearer than the EASA or CAA web site can be found at easyEASA home page, english, EASA part-M regulations in an easier to read format (http://www.easyeasa.net) there is a version there incorporating the proposed NPA 2007-8 changes.

[IO540]

OK, Vee-tail, so I thought. The MM is free via socata.org but only in English. It appears that Socata sell the MM otherwise, and I guess they also still sell it via ATP. Very pricey stuff, especially if you are legally obliged to have a current copy, despite the aircraft having left production years previously.

Having said that, I know that much maintenance is done by firms who don't have current MM subscriptions. At the ATP prices, it isn't worth their while.

[EGBKFLYER]

Beware not having up to date MM subscriptions - our surveyor pulled us up for it... And you're right, it is expensive to maintain all those manuals.

[IO540]

Is there a law saying that a maintenance organisation must have its own MM subscription, and must not refer to somebody else's?

I know about the ATP copyright statement but that is a separate issue. Also not everybody uses ATP.

[Yankee]

Whilst talking about MM's if any Grumman AA5 owner wants to know the latest version it's revision 5 dated March 1, 2004. Most if not all out there are revision 4, June 1 1983. If you need a copy send me a PM.

[IO540]

It's similar to Socata. The main MM is c. 1988 unless you have the GT in which case it is 2001. The latest pages I have seen are c. 2005 but they don't contain anything relevant. Production ceased 2002. The requirement for the $1000/year ATP subscription, just to get an exactly identical CD every month, therefore seems silly. And the SBs and ADs can be found separately, at no charge.

As I mentioned. socata.org carries the MM free anyway but the principle applies equally to other, long obsolete, types.

[EGBKFLYER]

There is no law stating the MM must belong to the maintenance organisation, only that up to date data must be accessible and used - M.A. 401

[vee-tail-1]

Regarding MM and Maintenance schedules. In the present French system only the type-specific maintenance programme (which is usually part of the MM) is approved and up-dated by GSAC. The rest of the MM is there for guidance, but is up-dated by the manufacturer not the GSAC (NAA)
I find the most effective way of servicing is with a copy of the parts manual (lots of pictures) and the schedule/programme to hand.
But I guess in the real World where insurers use any excuse not to pay out, an out of date MM might not be good.

[vee-tail-1]

Having opened a pandoras box by suggesting DIY pilot/owner maintenance, the nightmare of someone totally non-tech trying to service an aeroplane comes up. :eek:
EASA has not yet properly defined pilot/owner maintenance competance, and that surely needs to be sorted soon. My thoughts are that someone with an engineering qualification, or with proven technical skills would be suitable. Perhaps the LAA maintenance courses would be one way to aquire the skills. As a minimum, the ability to change the brake pads/shoes on a car, and remove/replace an alternator, plus the ability to rewire an electricplug ?? Any thoughts?

[IO540]

IMHO, most maintenance is really easy, and some is pretty hard because it needs special tools or knowledge/techniques.

So I would not remove the prop (a 2 man job anyway) or do anything on the retractable gear.

However, it's perhaps true that the biggest cost savings come not from doing pretty coarse machinery maintenance (like changing the vacuum pump, skinning your fingers in the process) but from doing avionics or electrical work. This work is traditionally very expensive and generally a big hassle, because avionics shops most of all hate doing small jobs, like replacing a single instrument, and don't even return calls if remotely busy unless you are a big regular spender. Also there are not many of them around, especially if you are looking for one with some level of competence.

The savings which can be had from DIY avionics/electrical work are massive. I've just had a vacuum driven AI pack up (a complicated one with a flight director and analog outputs for pitch/roll). This costs an eye watering $11k (mail order from the USA) but would be billed at something like £8k if bought in the UK. I ordered an exchange refurb one (basically rebuilt to new standard) for $3k, popped it in, got it signed off, and off I go. Otherwise I would have had to hassle a load of avionics shops to see if one can do it, fly there (VFR only of course), and spend a whole day on this job. And not many are keen on installing customer issued kit.

Most avionics shops seem really busy doing £10k refits these days.

Whereas any maintenance firm can change a vacuum pump, or brake pads.

[EGBKFLYER]

IO - none of the jobs you mention would be allowed under the Pilot/ Owner Maintenance list (Appendix VIII in Part M). The possible exception is the avionics box replacement but even that is doubtful:

From Appendix VIII:
30. Removing and replacing self-contained, front instrument panel-mounted navigation and communication devices that employ tray-mounted connectors that connect the unit when the unit is installed into the instrument panel,(excluding automatic flight control systems, transponders, and microwave frequency distance measuring equipment (DME)). The approved unit must be designed to be readily and repeatedly removed and replaced, not require specialist test equipment and pertinent instructions must be provided. Prior to the unit's intended use, an operational check must be performed.

To do anything like you mention would mean having a very friendly relationship with a licenced engineer who would be supervising the work being done directly. If the aircraft is in a controlled environment, the Subpart G organisation managing the aircraft would also have to approve of the work being done by you under the engineer's supervision.

Can't see that being a realistic option for most people and the list of Appendix VIII tasks is really pretty clear.

Vee-tail: You're right about competence not being defined. That's left up to the CAMO to decide at the mo. I have a Masters degree in Engineering and reasonable automotive skills but I wouldn't try even simple jobs on a simple aircraft right now - too much of a minefield without some training input from a professional. I think competence needs to be practically assessed case by case by a LAE.

[vee-tail-1]

Finding a licensed engineer with the appropriate avionics certification privileges is like finding hens teeth! We have a guy who turns up occasionally with loads of test equipment to certify a new installation. He is treated like a god, and like god never answers the telephone!

[vee-tail-1]

As regards competance. It does seem to be a catch 22 situation for many people. If maintenance becomes much more expensive some will give up flying and the engineers will have lost customers & income. But if LAEs take pilots under their wings as "apprentices" and allow them to become competant in some permitted tasks, then surely everyone can win.
It maybe that EASA will formally propose a syllabus for a practical pilots maintenance course, conducted at tech college and with an EU diploma award. They can hardly give pilots DIY privileges without ensuring those same pilots are capable of using them.

[EGBKFLYER]

Such a scheme would be great to see but I fear it will never happen... As you mentioned previously, existing LAA courses may be an equally useful route. t's early days yet - I think we'll see clearer by Jan 2010 when everyone has had an ARC renvewal under the Full weight of EASA rules and approvals.

[IO540]

To do anything like you mention would mean having a very friendly relationship with a licenced engineer

Indeed, and I have that in a few key areas - however most of the work is pretty easy. Most of the "circular" instruments are just four screws and the connector in the back; a monkey can change them. Compared to some of the authorised pilot maintenance items, this job is a piece of cake and very safe.

A few years ago, when I was on G, I looked into what is involved in becoming a LAME. I wonder how hard it is today. The financial benefits are pretty substantial.

[robin]

Such a scheme would be great to see but I fear it will never happen... As you mentioned previously, existing LAA courses may be an equally useful route. t's early days yet - I think we'll see clearer by Jan 2010 when everyone has had an ARC renvewal under the Full weight of EASA rules and approvals.

I'd like to be able to do some of the more basic tasks myself, and have a couple of group members who are reasonable at this sort of thing. They don't have a 'ticket' as such, but have some years of experience in mechanical matters.

The idea that we'd have to do a college course to gain accreditation for work we are already doing (and tasks we'd like to do) is tricky as these seem ony to be for professionals.

I'm hoping for the LAA route but so far this is under-resourced and not covering the subjects we'd want to do. But its early days yet.