OWNERS the LAMPS Replacement consultation has started [Archive]

vee-tail-1

13th Feb 2012, 22:39

For goodness sakes everyone have your say in the consultation.
This is my offering to the CAA:

Dear Sir/Madam

Oh my God! Why do you guys still hang onto Generic maintenance programmes?

First LAMS then LAMP now GMPT! Why oh why do you want to reinvent the wheel?!

EASA part M is based on modification of the old French system. That system from the start used TYPE SPECIFIC MANUFACTURERS MAINTENANCE PROGRAMMES. All French manufactured certified aircraft were (and still are) sold with such programmes. Those non French manufactured certified aircraft that did not have a manufacturers programme (Cessnas, Pipers, and many British aircraft) received an approved type specific, and equipment specific maintenance programme. This programme was developed jointly by the maintenance organisation and GSAC and approved for personal issue to the aircraft owner/operator. Consequently there exists a library of fully up to date type specific maintenance programmes for every certified EASA type light aircraft currently operating in the EU.
These programmes are mostly written in the French language which is one of the official EU languages. I have been maintaining my French Robin EASA aircraft using a French language type specific maintenance programme in accordance with EASA part M rules. The programme is very specific and tells me what to do, when to do it, and how to carry out the tasks. This ensures that any competent aircraft mechanic can achieve full and safe maintenance on any EASA aircraft … a huge increase in safety over the haphazard nature of ‘one size fits all’ generic programmes.
Instead of requiring owners/operators and maintenance organisations to reinvent the wheel by developing yet another maintenance programme …. Just obtain from the French authorities copies of all their existing approved type specific maintenance programmes and issue them to British owners. If the Brits can’t understand French then they can get an approved English translation, but in my experience technical French is not a problem.

What EASA aircraft owners/operators and maintenance organisations/CAMOs don’t need is yet another generic manifestation that will yet again become unfit for purpose. The type specific maintenance programmes for every EASA light aircraft already exist, are fully approved, and have been in use for many years. Why not use them?

wsmempson

14th Feb 2012, 08:19

I don't understand why the CAA would introduce this at almost the exact same moment that Part M, subpart G itself is under review. The likelihood is that by the time this is in place, it'll be time to tear the whole lot up and start again.

vee-tail-1

14th Feb 2012, 19:48

Whatever happens, for safety sake we should all be using the relevant type specific maintenance programmes for our aircraft.
Easy if you own French manufactured types such as Robin, Socata, etc.
You need to open a subscription to the documentation holders: CEAPR for Robin ... then order an English language (or French or German) copy of the Approved Maintenance Programme and the maintenance manual, plus if required, the flight manual, and parts manual.
You will receive a maintenance programme in the ATA 100 format. At the top of each page is a box for the owners name ... you must fill this in with the surname first (Bloggs Joe) on every page of the programme. At the front of the programme is an owner's 'declaration of responsibility for maintenance' under EASA part M rules which must be signed.
This programme is then sent off (in two copies) to the relevant National Aviation Authority (GSAC, CAA,) who check that it is for the aircraft registered in your name, and is the latest issue with all repetitive ADs incorporated. The NAA approves your personalised type specific (for your aircraft only) maintenance programme, keeps a copy and sends you the official version to be used by you or your contracted agents.
The process takes about a week in France, and costs a nominal fee of about ten Euros.
If you own a French aircraft, get hold of the correct maintenance programme, sign it and then become seriously assertive with the CAA and your CAMO and anyone else who thinks they can play fast & loose with the EASA part M rules.

A and C

15th Feb 2012, 05:57

The biggest issue that I can see with this change is that in will in effect make manufactures service bulletins mandatory and not advisory ( as is usually intended with non mandatory SB's).

The way this pans out all rather depends on the way it is implemented, if implemented in a pragmatic way in could be OK, but EASA being the blind, desk bound burocrats gravy train I would have little faith in a reasonable outcome in the short term.

My guess it is will result in a frenzy of removal of serviceable parts on calendar time limitations ( rather than using an on condition basis) with EASA finally relenting after a few years when it becomes clear that the industry is about to disappear and without it the employees of EASA will have no industry to oversee and will have legislated themselfs out of a job ( a bit like the part M overkill that they have been forced to review)

vee-tail-1

15th Feb 2012, 16:26

My guess it is will result in a frenzy of removal of serviceable parts on calendar time limitations
Sadly that fits with my experience and is a definite down side. It really galls to have to junk perfectly serviceable parts ... I did hear of a bit of creative paperwork where time expired but otherwise serviceable parts were swopped between identical aircraft. :E
However the old generic maintenance programmes allowed LAEs a lot of discretion, to do as much or as little work as they saw fit. One or two appear to have interpreted this as a way to extract money from owners by invoicing them for quite unnecessary work. If owners become very familiar with their type specific programmes (as EASA expect them to be) then it will be difficult for the odd shis**r to rip them off.

NutLoose

15th Feb 2012, 23:58

But the attached info states one of the reasons being to take some of the variance in standards out of it.......

Sorry, BUT you can write the best and most comprehensive maintainence programme in the world that ties the hands of those that work to a higher standard by introducing rules and regulations that make no sense, those that in the past never maintained those standards will STILL NOT do the work, the saying, you can lead a horse to water, but you cannot make it drink... Comes to mind.

An example of what I mean by no sense..

Cessna 152 seatbelts no life

Cessna 150 seatbelts 10 year life NO OVERHAUL

SAME BELTS and more or less same aircraft.

Say an owner has a 150 his aircraft is hangered, he only flies solo 20 hours a year, then every 10 years he will have to as now under lamps be forced to change an unused brand new right hand seat belt that has done 200 hrs.

Previously an engineer would inspect and proof test the belts, he would if required replace the buckles or get rewebbed etc...
That has been removed for no sense whatsoever ever.

Engine hoses, I.E Teflon, Cessna 10 year life, Socata same engines, on condition..
Even the MK 19 Spitfire with an engine that is working to a hell of a different performance and operating standards to a O-235 does not have the limits that Cessna lay down.
LAMS In its way recognised this and set a standardisation, those that came after are a shadow of the former... The CAA and EASA have lost the plot... Still.... legislate the light side of the business out of existance will effect the large side and eventually EASA will falter as well.

jxk

16th Feb 2012, 06:52

#11 Nutloose - I have to agree to everything you said: common-sense no longer comes into the equation. The current bunch of CAA surveyors seem to have no idea about the GA side of the industry. The licensed engineers with years of experience are being replaced by tick-box paperwork and accountable managers, quality insurance, schedules and the like - not very suitable for 2/3 man organisations. I was probably under the misapprehension that these kind of changes had to be cost justified; so where is the prove that these changes will improve quality or safety. I know that some owners feel in the past that the workmanship has not always up to standard but Part M does absolutely nothing to improve this.
This newly proposed individual maintenance schedule will do nothing more than the LAMP and the SB and AD research already accomplishes and just incur further expense for the owners because of the CAA involvement.

Peter Gristwood

16th Feb 2012, 10:04

I know that some owners feel in the past that the workmanship has not always up to standard but Part M does absolutely nothing to improve this.

Absolutely. It is a classic example of the use of quality assurance. EASA's paperwork trail is expensive and adds nothing to safety

It guarantees consistency so if the work is poor it will be consistently poor.

peterh337

16th Feb 2012, 11:22

those that in the past never maintained those standards will STILL NOT do the work

Exactly. The right boxes will be ticked though.

It guarantees consistency so if the work is poor it will be consistently poor.

Exactly, like the much bigger scam called ISO9000. Completely worthless nowadays.

But, this is the "European way".

giloc

16th Feb 2012, 12:19

Whatever happens, for safety sake we should all be using the relevant type specific maintenance programmes for our aircraft.

That is complete nonsense. You might prefer to use a type specific MP for any number of reasons, but there is not a shred of evidence to suggest that it is safer to do so.

jxk

17th Feb 2012, 16:38

Why aren't OWNERS consulted about these proposed changes, after all the CAA are supposed to be the authority that is responsible for representing their interest with regard to safety and COSTS. If, for instance, you think of the CAA with regard to air passengers, their role seems to be to protect them from airline bankruptcy etc.
I think owners should be canvassed for their opinion as ultimately it's their resopnsiblity to ensure that their aircraft is maintained to a suitable standard.
It would nice to think that the CAA were there to HELP not HINDER.

NutLoose

17th Feb 2012, 19:49

Get your comments in, it is a consultation until next month, the more comments they get may make a difference, that is why I mentioned it, it wasn't exactly publisiced much.

vee-tail-1

17th Feb 2012, 20:31

That is complete nonsense. You might prefer to use a type specific MP for any number of reasons, but there is not a shred of evidence to suggest that it is safer to do so.
Oh dear, I wonder just how safe a BMW might be if the garage used a Morris Minor maintenance manual to service it. :hmm:

How many "Gotchahs!" do you think are being missed by maintenance organisations using LAMP and working on an unfamiliar type? I can think of two safety critical tasks that are not addressed by LAMS, or LAMP, on my simple aircraft. The number on a modern complex type must be considerable.
Just because no one has yet died due to LAMP does not make it or any generic programmes safe or even fit for purpose.

NutLoose

17th Feb 2012, 21:20

LAMS and lamp were never intended to be a be all and end all maintenance programme, simply a basis to build upon.

peterh337

18th Feb 2012, 06:22

Silvaire1 above is right. The FAA system works.

Unfortunately here in Europe we have 2 issues.

First is the background of the people behind EASA. Eric Sivel comes from a certification background (a friend of mine has various ancient certificates on the wall, from aviation courses, with Sivel's signature on the bottom) and people from that background will always be out to generate documented processes. And once you embark on that, there is no end to it. Documentation will never be perfect, which makes it a great job to be in - so long as the layer of management above you is stupid enough to keep funding you. The "stupid enough" requirement is amply met in the EU ruling class (where nobody above the rank of Sivel and his cronies understands aviation) and it is usually met in business which is why ISO9000 is such a notorious "QA Dept empire building" scam which is nothing to do with quality.

The other is that crap maintenance is a feature of a significant % of accidents, and then it comes down to the debate of how much control the State should have over the individual's attitude to risk. In the USA the answer is "little". In Europe the answer is "lots".

And unfortunately the maintenance business plays into EASA's hands, by taking whatever schedule they have (LAMP, the manufacturers's full schedule, whatever), rubber stamping all the way down the page, but actually (in most cases) doing only some of it.

My aircraft has a very long mfg schedule which almost nobody follows - unless you ask for it, and then the price of the Annual doubles. And much of it is pointless. But a lot of it is essential, like dismantling bearings and greasing them... most maintenance shops just squirt some aerosol lube in there and the customer is happy because everything feels nice and smooth. He doesn't know the abrasive crap is still in there and years down the road he will get a huge bill for a new bearing, which in this ripoff game is usually a complete new airframe part because there is no CMM for replacing just the bush. I work this to my satisfaction by knowing what needs to be done and making sure it is done (I drop in during the Annual, and inspect everything before the inspection covers go back on) but most owners do not have that level of expertise so they get shafted with much expensive work when the chickens come home to roost in later years.

There will never be a good solution to this, because aircraft can be maintained to varying degrees and all of them work and are safe provided a small number of essential tasks are done (like magneto inspections or overhauls) and the work is done by somebody competent.

vee-tail-1

18th Feb 2012, 08:59

There will never be a good solution to this, because aircraft can be maintained to varying degrees and all of them work and are safe provided a small number of essential tasks are done (like magneto inspections or overhauls) and the work is done by somebody competent.

peter337 has accurately summed up the situation.

My take on it is:
Pilots/owners come in different categories:
Those who know their aircraft intimately, and until EASA part M came along did all the maintenance themselves. Many French owners of certified GA aircraft fit that category, and the French authorities neatly sidestepped part M by awarding restricted part 66 licences under 'grandfather rights' to competent owners.

At the other extreme are those owners (mainly wealthy Brits!) who almost never open a cowling or get their hands dirty. These guys couldn't give a toss as what maintenance programme their engineer uses so long as the aircraft is airworthy and available whenever they want to use it.

Somewhere in the middle are those (less wealthy?) owners who welcome the privilege of doing some maintenance on their own aircraft under appendix VIII. They also might welcome the ability to closely monitor the work done by whatever maintenance organisation they entrust to service their aircraft. LAMS / LAMP left them at the mercy of LAEs who could choose to do whatever work they deemed necessary. Now with type specific programmes the boot is on the owner’s foot ... the OWNER can specify what work he/she requires to be done and the programme allows that work to be checked by the owner.

However this presupposes that a significant number of competent Brits would wish to become more involved with the maintenance of their aircraft. Sadly there still seem to be a majority who take the 'horse from the stable' ride around the countryside and then return the horse to the stable without ever thinking to rub down or muck out the sweating animal. Guess as always in the UK it's a bit of a cultural & class thing. :hmm:

wigglyamp

18th Feb 2012, 09:28

I like that - the French issue restricted Part 66 maintenance licences to owners on 'grandfather rights'. There is no provision in Part 66 for issuing a 'restricted' licence! Are the DGAC insisting that owners prove the 5 years relevant experience and pass all of the Part 66 modular exams?

In the UK, extremely experienced engineers have to go through the whole exam route to get a licence even if they've previously held company approvals via CAA BCAR in the past. If they change jobs, grandfather rights go out of the window and they have to take Part 147 type courses on more complex types to regain approvals for which they probably have far more experience than the instructor or CAA examiner!

vee-tail-1

18th Feb 2012, 11:58

wigglyamp It was a one off situation ... you had to be a French citizen owning a French certified aircraft based in France. You had to have maintained the aircraft yourself for some years under the old French system, and provide proof of your technical competence and of the tasks you had carried out. There was a window of opportunity during the transition period sept 2009 / sept 2010 during which suitably qualified owners could apply for Grandfather Rights. If successful you received a part 66 licence restricted to your own aircraft, with which you could sign APRS (CRS) only for those tasks that you had been deemed competent. Those owners who were not successful had their DIY abilities reduced to the pathetic pilot/owner permitted tasks of part M appendix VIII. :*

A and C

18th Feb 2012, 12:07

Having gone over the document a number of times and dispite my prejudice when it comes to anything EASA I am starting to think that this might just be a good idea.

It will let the operator use the manufacturers maintenance program and in some cases reduce. The amount of work that has to be done.

For Cessna 152 owners 50 hour checks (apart from an oil change) will be a thing of the past as will six month checks. This will be replaced by the 100 hour or annual check. The maintenance company seem to be given some leeway when it comes to manufacturers SB's and calendar time limits.

All in all it is not a s bad as I had feared but some will no doubt us it as a way of generating income from the unwary aircraft owner.

peterh337

18th Feb 2012, 12:37

Does it mean the G-reg 150hr check is gone?

That would be a huge bonus for some syndicates.

jxk

18th Feb 2012, 13:54

Peter, you'll probably know the answer to this question: If on the N reg can you opt out as an owner, of having 'lifed' and SBs done (but not of course ADs)? It would be interesting to know whether under the LAMP replacement it is envisaged that when the new schedule is to be drawn up possibly between a Part G organisation and the owner, the owner could state that for instance they didn't want the seat belts renewed until x hours or until x year.

NutLoose

18th Feb 2012, 14:35

In a way yes Peter, talking 152 here, items you would do on a 150 hr cycle such as compressions under the Manufactures would now be every 100 hrs, the Us system always has been 50 and 100 hr cycles, the 100 also is the Annual, something's would makes sense, 152 seatbelts have no life so you could justify removing the replacement for them on a 150 which has the 10 year life, it also brings into play OEM which is a good thing, most belt manufactures do not put life's on them, so you would be able to justify on condition or overhaul against Cessnas replace.

A price being banded around however to get the schedule approved by the CAA is about £800 by the CAMO About £400, though that would be up to them and of course somewhere along the line you are going to need someone to sit down and write the schedule. If you have all the logbooks in your possession and they are comprehensively filled out it may be pretty simple to transfer..... HOWEVER, if you are missing any books or the recordings are scant then any missing records for SB's or AD's will require them all doing again.

A and C I thought it says you should consider adding items at 50 hr intervals where the manufacturer does not call them up.

At least this seems to be making some sense, though due to different radio fits and one engine fit, I will need to write over 14 different maintenance programmes for the ones I maintain..... Groan..

The problem with LAMPS was that it was trying to do both a 150hr cycle schedule and merge a US requirement that operated on a 100hr cycle, and that just didn't work......
By far the best we ever had was LAMS, it actually was a guideline and did not make you jump through loops but was a sensible approach, having given more onus on the engineer to make sound judgements on seat belt conditions etc and fixed pitch props etc on condition...... I could understand changing it all if they were dropping out of the sky like flies, but it just never happened.

peterh337

18th Feb 2012, 16:16

The only time the 100hr check is mandatory in the US is when you are carrying paying passengers, or training others in your plane.

AFAIK it is not mandated by the manufacturer.

Over there they do 50hr checks only, and then the Annual.

It is only schools (basically) that do the 100hr check.

The maintenance that is mandatory is what is in the Airworthiness section of the manual.

The more basic issue is that people are trying to legislate-out crap maintenance (or, on these forums, some people are arguing in that direction). This is IMPOSSIBLE. There is no way to stop some d1ck ticking all the boxes and rubber stamping all the way down the page but not actually doing the work. The only scenario where missing maintenance is traceable is on lifed items which carry a serial number. One has to live with this; it cannot be solved by legislation. It means that you have to be picky about where you take your fixed wing plane for servicing, and if it is a helicopter then you have to be 100x more careful :)

vee-tail-1

18th Feb 2012, 16:23

Nutloose Sometimes the way Brits think, and the way we not only routinely fit 'belt and braces' and in this case propose to reinvent the wheel, astonishes me.
There are 27 member states in the EU and all have light aircraft that need to be maintained. One state ... the UK ... has had a generic maintenance programme that is considered unfit for purpose. All the other states have NAA approved manufacturers type specific maintenance programmes for the same fleet of light aircraft as the UK. That is the same Cessna 150s, Piper Cherokee's, Lycoming engines, King avionics, etc, etc.
For goodness sakes there is no need for every CAMO / owner / CAA to go through the pointless exercise of developing a new maintenance programme for every light aircraft on the G register ... those programmes already exist for every combination of airframe/equipment. Go through the national registers and find an owner with the type & equipment required ... ask for a copy of that owner's maintenance programme (if in German, French, Serbo-Croat, Greek, etc, .. get it translated) then inform the CAA that you will be using this fully EASA approved programme in accordance with part M rules.
Or has all the UKs light aviation industry gone collectively insane, so as to willingly cough up large amounts of money for a completely unnecessary paper exercise.
Sometimes I despair of my fellow aviators. :ugh:

A and C

18th Feb 2012, 16:36

As a CAMO we see this as a chance to get the aircraft that we look after onto the maufacturers maintenance program with as little fuss as we can.

It is my intention to "populate" the new CAA document (using cut & paste) with the manufactuers data, the SB's will be the ones that I see as being relivent to the particular operation of that aircraft and will not be seen (by me) as being mandatory unless we as a company see it as a safety issue.

This is how I read the situation at the moment but I do expect to read the document about six more times before putting finger to keyboad on anything offical.

peterh337

18th Feb 2012, 16:45

there are NO hour-based checks for privately operated light aircraft. So no '50 hr check', only Annual Inspections per the FARs. Obviously, we maintain the aircraft properly between annuals, including oil changes.

Of course; agreed.

ADs have to be complied with also, at whatever interval is specified.

It's a good system, proven over decades, on a fleet which is bigger than all other aircraft in the world put together.

vee-tail-1

18th Feb 2012, 17:09

A and C I wish you luck in transiting from LAMP to Manufacturer's programmes, and let’s hope the CAA don't see it as an excuse to charge huge fees.
From my perspective, having used the GSAC approved Robin programme for some years, it all works well.
Owners of simple aircraft can be their own CAMOs, presenting their aircraft to the part G workshop with a request for maintenance as per the relevant section of the programme. The engineers and the owner are fully aware of what is laid down in the programme, so there can be no misunderstandings. Everyone knows what has to be done, when to do it, and how it should be done. The aeroplane gets properly serviced, no one gets over charged, and if any faults are found they can be rectified by agreement with all concerned.
It's still a bummer to have to scrap time expired but serviceable items however. :(

Having said all that ... if I lived in a large warm country with few cities and fewer people, and my own farm strip ... well guess who would abandon all that mass of regulations and paperwork and just fix & fly my aeroplane for the freedom and joy of it? :)

A and C

18th Feb 2012, 18:34

I think that the CAA would be very unwise to charge a lot of money, after all it is their maintainence program that has been found non-compliant under EASA rules.

I think thy would rather that this one went away quietly as they would look rather silly if the transport select committee started asking a lot of questions as to why the CAA was trying to get the industry to pay for its shortcomings.

robin

18th Feb 2012, 18:53

Why on earth would the Transport Select committee show any interest in GA. As far as I am aware all politicos swallow the line the CAA and all government bodies do - 'there is no price on safety'

I note that when it costs the government this is never used, except just after an accident (like Clapham) but when the costs are levied on rich idle playboys, like GA owners, they consider it is their duty.

NutLoose

18th Feb 2012, 19:37

Cost for the CAA to approve it is already out there...

OLD Charges

Approval of aircraft maintenance schedules or programmes
a) Subject to sub-paragraph 3.7 c), upon making an application for the approval of an aircraft maintenance schedule or programme different to the aircraft manufacturer's recommended schedule or programme, the applicant shall pay a charge of £711.
b) Subject to sub-paragraph 3.7 c), upon making an application for the approval of an amendment to the technical content of a maintenance schedule or programme, the applicant shall pay a charge of £569.
c) No charge shall be payable if the application made under sub-paragraphs 3.7 a) or b) is:
i) in respect of an aircraft with an MTWA of 5,700 kg or less or a single-engined helicopter; or
ii) supported by the type certificate holder; or
iii) supported by an organisation holding a BCAR A7-5 approval or concerning amendments made in accordance with Part-M M.A.302(e).

NEW charges as of April 2012

3.7 Approval of aircraft maintenance schedules or programmes
a) Subject to sub-paragraph 3.7 c), on making an application directly to the CAA for the approval of an aircraft maintenance schedule or programme different to the aircraft manufacturer's recommended schedule or programme, the applicant shall pay to the CAA a charge of £725.
b) Subject to sub-paragraph 3.7 c), on making an application directly to the CAA for the approval of an amendment to the technical content of a maintenance schedule or programme, the applicant shall pay to the CAA a charge of £580.
c) No charge shall be payable if the application made under sub-paragraphs 3.7 a) or b) is:
i)in respect of an aircraft with a maximum weight of 2,730 kg or greater and supported by the type certificate holder; or
ii) supported by an organisation holding a BCAR A7-5 approval or concerning amendments made in accordance with Part-M M.A.302(e).

Notice Ci has changed to allow charging at the rates mentioned above for aircraft under 2730kg. Where previously there was no charge.
Though it will not cost a CAMO, or appears it is not going to cost a CAMO to add the approval to their exposition to allow the CAMO to do it. How much they will charge for the service I do not know, as with A and C I too am still trying to figure out what we need to do to satisfy the changes.

maxred

18th Feb 2012, 20:48

It was precisely because of this that I went to N Reg. I was sick to the back teeth of being charged by maintenance companies under LAMPS, finding out half the work had never actually been carried out, then on complaining to the local CAA surveyor, guess what - it was all my fault as THE OWNER.

There were some snipers who said I was moving to N reg, to dodge maintenance and safety issues. Utter bollox.

I have never looked back, and I actually feel that my aeroplane is being managed more diligently than it has ever been under UK/CAA/LAMPS.

'If on the N reg can you opt out as an owner, of having 'lifed' and SBs done (but not of course ADs)?'

Not strictly accurate, you can under FAR91, operate lifed items 'on condition', i.e assuming non commercial activity, however, you will not be able to deviate from the manufacturers manual, and the IA/DAR, will recommend that the lifed items (on condition), become part of a structured replacement programme. Remember, it is in your own interest to maintain your aeroplane to the highest safety standards possible.

peterh337

18th Feb 2012, 20:55

There were some snipers who said I was moving to N reg, to dodge maintenance and safety issues. Utter bollox.

I have never looked back, and I actually feel that my aeroplane is being managed more diligently than it has ever been under UK/CAA/LAMPS.

I agree 100%.......

A and C

18th Feb 2012, 22:57

It depends on if you and others write to your MP's ...... If you do you get a chance at some reason........ if not you have lost before you start.

The Olympic airspace restrictions have been eased, that was not due to pure magic it was due to some of us writing to MP's and not rolling over with the first reply from the Minister for Transport.

The reason that AOPA in the USA is so powerfull is that their members back them and put presure on elected representatives.......the ball is in your court! then we see if you a forum wind bag or someone who gets things done.

For those of you who dont know it takes the same amount of time and effort to email you MP as it posting here.

NutLoose

15th Mar 2012, 12:41

YOU HAVE UNTIL TOMORROW TO GET YOUR LETTERS IN..... SO THOSE THAT WERE PLANNING TO GET IT DONE.

Apologies for shouting.

happybiker

31st Mar 2012, 15:03

The CAA has postponed the withdrawal of CAP 766 and CAP 767, LAMP. The reason for this is to wait for the outcome of the EASA Part M Task Force which was established last year to consider significant comments and items raised by stake holders. This is good news as there would be a considerable amount of work involved in preparing maintenance programmes to replace the LAMP and we do not wish to implement any changes that may be required more than once.

IN-2012/062: Postponement of the withdrawal of CAP 766 and CAP 767 | Publications | About the CAA (http://www.caa.co.uk/application.aspx?catid=33&pagetype=65&appid=11&mode=detail&id=4940)

A and C

1st Apr 2012, 09:02

Having seen how the new system was intended to work and writing the new maintenance program for my Cessna's based on the Cessna program of 100 hour check intervals that would save me a lot of time and money they now go and withdraw the idea.

I'm not sure if this will be good or bad in the long term but this year I will have to do a lot more faffing about doing things in two checks that could have been done at one big check if we are still using LAMP.

Duckeggblue

1st Apr 2012, 10:52

This is good news as there would be a considerable amount of work involved in preparing maintenance programmes to replace the LAMP and we do not wish to implement any changes that may be required more than once.

May or may not be good news - but many have already made significant efforts to prepare programmes to replace LAMP - because we thought we had to!!

Doh :*

robin

1st Apr 2012, 20:00

Perhaps a solicitor's letter to the CAA demanding compensation for jumping the gun......?

Aerials

2nd Apr 2012, 09:24

Postpone: to delay an event or arrange for it to take place at a later time.

Work done so far therefore will not be entirely wasted in my opinion, for what it's worth!

Duckeggblue

2nd Apr 2012, 11:17

Probably not wasted at all Aerials - in fact, I would be prepared to say that it was instructive to compare LAMP requirements with manufacturers requirements.
The " Doh http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/smilies/bah.gif" was more because there was a percieved urgency to understand the process, carry it out and get it approved - and this put other things on the back burner.

Now that EASA is talking of perhaps "unwinding the CAMO system" and retaining registered training facilities, will there be there will be another raft of paperwork to either generate or already generated that will not be required? Whilst this is not always a waste of effort, it is frustrating.....

In general,the message from the CAA seems to be to get your "offering" in early to avoid disappointment! The early bird, in many cases, is not rewarded with the worm because the CAA/EASA have taken it away at the last minute!!

jxk

3rd Apr 2012, 13:40

I expect this has been posted elsewhere on the forum but just in case it hasn't the below document from AOPA looks like at last there maybe some common-sense coming to the over bureaucratic Part M..

AOPA reports EASA Changes are in the air (http://www.aopa.co.uk/index.php?option=com_content&view=article&id=600:aopa-reports-easa-changes-are-in-the-air&catid=1:latest-news)

Applying Airliner type maintenance to 'puddle - jumpers' is ludicrous especially where typically the MOs are 2-3 man businesses: accountable managers, auditors, record clerks, storekeepers, educators etc..

A French-led team of experts has been tasked to begin planning a clean-sheet approach to GA regulation, and it has been urged by EASA’s Board of Management to “be broad in your thinking” – even to the extent of comparing GA regulation to that of boats and cars, and looking at American systems of regulation for possible guidance.Sweden supported the French proposal and said that continued airworthiness, Ops and FLC together represented a ‘total system approach’ which was not fully understood. Part M provided no better control than what went before, and there was a need to find a proper balance for GA.Hooray :-)