Part M - Owners and Subpart G/F companies watch out

[EGBKFLYER]

Dear All

I was getting into the swing of Part M and even thinking it's not so bad - then this...:mad:

Subpart G and F organisations are approved by the CAA and have approval certificates which list the scope of the approval. In this case, it's an A2 organisation, which means the scope of approval lists which types we can work on.

Due to my crystal ball being a bit cloudy, I didn't foresee the need to have a particular French type on that list and now there's one that the owners want us to look after. No problem say I - will just have our approval certificate amended to include that type.

No problem say the CAA - that'll be £1380!!!!!!!!!!!!!:mad::eek::ugh:

Apparently every time you want another type/ group etc adding to the approval, that's the fee. No negotiation. If you're lucky, you can add 2 or three types at the same time for that fee but if it's just one you want, it's the same charge.

The CAA need do no more than ascertain you have the necessary resources to work on that type. In this case, it's another Lycoming-engine GA non-complex single, so how hard will that be?

So here we are - either pay up, make the owners pay up or turn the business away - just fantastic in this climate.

Take this as a warning - if you're an aircraft owner, make sure your maintenance company has your type on their approval certificate. If you're an organisation, put every type you think you might ever need on the application form, or face limiting the business you can do in the future.

Thanks a bunch EASA.:D:oh:

PS I've been back and forth with our surveyor (who has tried his best) and the CAA Approvals Dept. So far there is no option but to pay or turn the business away ultimately.

[smarthawke]

We're just completing our Subpart G and F approvals and have been warned about this. The situation already existed for JAR145 companies.

I've had to change my Subpart G CAME from 'Piper Single Engines' to individual models (not even 'PA28 Series') due to different engines (PA28-140, 180, 151, 161, 181, 201 etc etc)

We are still up against a very unlevel playing field with some companies already holding Subpart G approvals for 60+ aircraft types (and a type on one company's list is 'PA28 Series'...!). Bet they really hold up to date maintenance data for all those types that we're being told we now have to have if we want the type on our approval. I've been assured things will change at their next audit.

Still far too much individual CAA airworthiness surveyor interpretation of the rules coming into it.

[Lucy Lastic]

We've just been contacted by our MO to be told that the CAA are insisting that the maintenance manuals should be on site for our old aircraft. According to the leader of our group the CAA are insisting these manuals have to be in English, although the only versions available are in French or German.

We have contacted EASA and they say there is nothing in the regs to say that the manuals have to be there at all. All that is required is a tailored maintenance programme.

Looks like the old joke

EU Regulations

Drafted in Brussels
Read in Germany
Smiled at by the French
Laughed at by the Italians
and
Gold plated and vigourously enforced by the British :ugh:

[jxk]

Why is it that every time I see the acronym EASA I get a violent headache, depression and want to emigrate?

[Johnm]

Why is it that every time I see the acronym EASA I get a violent headache, depression and want to emigrate?

Because of this which is all too true and very definitely no joke:mad:

EU Regulations

Drafted in Brussels
Read in Germany
Smiled at by the French
Laughed at by the Italians
and
Gold plated and vigourously enforced by the British

[Lurking123]

Just wait until the really get going on FCL and Ops. :sad:

[jxk]

I have concluded that the CAA don't know anything (zero) about GA or light aircraft and are making a complete mess of the industry. Complain to your politician. What good would that be they don't even understand the economy let alone the aircraft world. :ugh:
My sympathies to all who are trying to get to grips with Part M.

[LH2]

Thanks a bunch EASA.

Do they set the fees? :confused:

[Malcom]

I was getting into the swing of Part M and even thinking it's not so bad -

That was your second mistake:ugh: Its all downhill from here - last EASA GA company out turn out the light at the end of the tunnel since there is absolutely no future in EASA GA.


No problem say the CAA - that'll be £1380!!!!!!!!!!!!!
You just know what happens next - Owner starts whinging at you because you try and recoup a little of that extra cost you've been lumbered with just so you can look after his plane - probably the only one of type as well.

Now, if the CAA had not jumped the gun and made 5/1/09 the deadline for part m, we could have had another year or two to get a system working that would be to everyones benefit owners/mo/caa. But no, they just had to leap in and f*** it up for everyone, including themselves!

I now need 3 new additional EASA/CAA approvals just to carry on as before, I cant see it being sustainable for very long.

EU Regulations:ugh:

Drafted in Brussels:confused:
Read in Germany:hmm:
Smiled at by the French:p
Laughed at by the Italians:)
and
Gold plated and vigourously enforced by the British :mad:

N reg - how tempting is that!

[Justiciar]

Is this not going to force more people the "N" registration route. The point has been made in the past the the maintenance costs advantage of the N reg is small. Now that maintenance organisations are going to be forced to pass the huge extra costs of Part M on to their customers the cost benefit must surely be increasing.

I am sure that IO540 could comment on this!

[IO540]

The problem is that maintenance organisations will spread any extra overhead costs over all their customers - G-reg and N-reg. That is what I have so far found.

Most owners have no option but to use a company, and they all do both G and N.

Only the very few fortunate enough to have a hangar in which they are allowed to do work will be able to get a freelance A&P/IA to do their maintenance. The bigger stuff cannot be done outdoors. I did a 50hr check the other day, wrapped up like an Eskimo, and froze my ***** off in -3C freezing fog :)

Also the treatment of foreign reg planes in years to come is not known. Some degree of local supervision is likely; this is fine (every decent owner maintains to the regs, and one cannot simply maintain an N-reg to EASA regs because that would probably breach its airworthiness, among other issues) but the big Q is how much somebody is going to charge for the "oversight" ;) How much does a Subpart F company charge?

[smarthawke]

'I did a 50hr check the other day, wrapped up like an Eskimo, and froze my ***** off in -3C freezing fog'

Ideal conditions to carry out a proper, thorough inspection of an aircraft. Still saved you some money....

[IO540]

Ideal conditions to carry out a proper, thorough inspection of an aircraft. Still saved you some money....

It indeed saved me a few hundred quid, even after giving a nice bundle to the A&P/IA who does it with me (a freelance engineer; another rarity under JAA/EASA) but the point is that while I don't mind much doing this, it is practical only for short jobs and most engineers won't work in these conditions (it's bad for the joints :) ).

There should be good business in renting out hangar space, for owners who need temporary space for maintenance.

[Malcom]

Going back to the first post, if APEX/Robin TC approvals are withdrawn/suspended, as may happen if no-one takes them up, and if you have just paid your £1380 to add it to your CAMO approval as an EASA type, will it cost another £1380 to remove it as a non-EASA type?

It is, after all a variation to the approval!
:ugh:

[IO540]

One day, somebody is going to hire a lawyer and sue the CAA for not following proper and reasonable procedures.

[robin]

One day, somebody is going to hire a lawyer and sue the CAA for not following proper and reasonable procedures.

Oh, pleeeaaassse!!!! :D

[WorkingHard]

Why dont all those affected and those who will be affected by crass CAA decisions (i.e. everone connected with aviation) start a fund to pay for such an action?

[EGBKFLYER]

Malcolm - I think that either the NZ CAA or EASA would have to take over the TCs if APEX/ Robin lost them - they couldn't just leave them homeless. It's effectively what's been done with the Beagle Pup at the mo. That said, who am I to comment - I believed the CAA would be reasonable about a business trying to expand in the currnt climate...:bored:

[Malcom]

EGKB,
I think the Beaglies have limited type support from DHSL, so thats how they qualify for their SAS TC.
If no-one takes up the Robin TCs,there would be no support for them at the end of the month, and that would mean Annex II status? From what I've read, Alpha cant/wont be interested, and if the CAA cant be a design authority surely the DGAC cant be either!

But, as you say - who are we to comment!
:ugh:

[robin]

No.. but as mentioned elsewhere, the problem with Robins is that so many are in commercial use.

If they need to be used for instruction, for example, and given the size of the fleet they are bound to find someone willing to take it on. Also, M Pellissier is bound to appeal against anyone trying to take his business away from him before the courts have made their decision.

This looks to be a case of brinkmanship which may not be decided for some weeks or even months....:ugh:

[NutLoose]

Funningly enough mine excepted that if i remember......... don't forget to ADD REIMS IF DOING CESSNA AS THEY DO NOT COUNT AS CESSNA, because they are built in France....... had that enquiry about a mod that was on a Reims 182 not being accepted on a US built one as a minor mod as it is a different make, but the same aircraft!.

Rumour control has LAMP being eventually ditched too

[Malcom]

No.. but as mentioned elsewhere, the problem with Robins is that so many are in commercial use.

Commercial as in AOC or as in just taking money for instruction? Thats yet another grey area of definition yet to be addressed - that will stir things nicely.

If its just taking the money for instruction, then a national C of A would not be a problem at the moment, if its under an AOC then the game could well be over.

[robin]

Quite -

It seems that EASA haven't really thought through the rules for this sort of thing, and they'll be making them up as they go along - just as they have done with Part M.

Of course, add to that our CAA rushing in with an early implementation of incomplete rules when they know full well they will be changed again........:{

[Malcom]

don't forget to ADD REIMS IF DOING CESSNA AS THEY DO NOT COUNT AS CESSNA, because they are built in France.......

All the reims cessnas (except 406) TCs were now covered by USA as state of design (CAP747 - your "one stop shop" that sends you here there and everywhere when deciding the applicable regulations & requirements).
I think you would only need to add (eg) Cessna 172/F172?

LAMP going? I hope so - whats the point of it when you have to use the manufacturers data anyway!


clear as mud!

[dg93]

Malcolm
I think that you will find that if the aircraft is on an AOC it is commercial.
Flying schools do not normally have their aircraft on an AOC therefore not Commercial.
As for the rules of Part M, I took and paid for training last year to write maintenance programmes and to be an Independent IRC signatory but they have changed the rules and I have wasted my money.
As to the Subpart F and G manuals I have been involved with 3 different CAA Local offices and yes they appear to be making it up as they go along.:mad:

[Malcom]

dg93
I think that you will find that if the aircraft is on an AOC it is commercial.
Flying schools do not normally have their aircraft on an AOC therefore not Commercial.

I think you will find that is what I was alluding to when I said Commercial as in AOC or as in just taking money for instruction?

:)

As for Part M............:ugh: