Winter and spring 2015 editions of 'Tech Log' magazine
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Winter and spring 2015 editions of 'Tech Log' magazine
Dear Fellow and Lady Engineers
In 2014, I wrote an educational paper intended to explain to the layman (i.e. someone with no prior knowledge of EASA continuing airworthiness aviation regulation) the basics of EASA regulations concerning Part-M, Part-145, Part-66 and Part-147. This occurred shortly after carrying out a Part-66 training standards survey on Pprune which so many Pprune engineers responded to (thanks!).
This paper, in an abridged version, was published in two parts in the winter and spring 2015 editions of ‘Tech Log’, the quarterly magazine of the Association of Licensed Aircraft Engineers. It is the product of a particular experience I had working with an operator when it became apparent that the majority of individuals working in that operator’s Continuing Airworthiness Management Organisation together with some individuals in its Part-145 organisation did not understand the difference between Part-M and Part-145 and were generally confused about regulations. Most of the individuals were not aircraft maintenance engineers, but admin staff and engineers other than maintenance. Being confused about EASA regulations is quite understandable, and this helped to clarify the confusion in a straight forward manner.
The above is part of a larger research project I am developing and working on as I have a particular interest in engineering training and how to communicate complex concepts (such as law) in a simple manner so that EVERYONE can understand, not just a select few. This activity forms part of the requirements I have set myself to achieve professional engineering chartership. The aim is to publish on-line a number of papers, articles and study aids, completely free of charge, to help the maintenance engineer or the would-be maintenance engineering student. My target for this is approximately 2 years’ time as I work on this project outside my working week job at the Ministry of Defence and on top of raising a family.
If you know of a particular area of the 1321/2014 regulations (was 2042/2003) which seems to always create conflicts between the engineers and management, or which seems to create confusions and misunderstandings, I would be really interested to hear what the query/confusion is so that I may attempt to create a document which would clarify the matter and communicate it in a simple manner. Please keep in mind that I do this in my own time outside working hours and that it may take some time to come back to you: but I will always reply to emails. Moreover, rest assured that your name will never be used and you will remain anonymous. I will only use the actual regulation clarification which resulted from your query.
For a copy of the unabridged paper, which has a comprehensive glossary at the end, or if you would like me to look into clarification of particular confusing regulations, please email me at [email protected] and I will send you an electronic copy.
Any feedback on this educational paper would be greatly appreciated.
Disclaimer: The above represents my personal views and activities and not those of the UK Ministry of Defence who happens to also be my employer. The above work is my work as a professional engineer.
In 2014, I wrote an educational paper intended to explain to the layman (i.e. someone with no prior knowledge of EASA continuing airworthiness aviation regulation) the basics of EASA regulations concerning Part-M, Part-145, Part-66 and Part-147. This occurred shortly after carrying out a Part-66 training standards survey on Pprune which so many Pprune engineers responded to (thanks!).
This paper, in an abridged version, was published in two parts in the winter and spring 2015 editions of ‘Tech Log’, the quarterly magazine of the Association of Licensed Aircraft Engineers. It is the product of a particular experience I had working with an operator when it became apparent that the majority of individuals working in that operator’s Continuing Airworthiness Management Organisation together with some individuals in its Part-145 organisation did not understand the difference between Part-M and Part-145 and were generally confused about regulations. Most of the individuals were not aircraft maintenance engineers, but admin staff and engineers other than maintenance. Being confused about EASA regulations is quite understandable, and this helped to clarify the confusion in a straight forward manner.
The above is part of a larger research project I am developing and working on as I have a particular interest in engineering training and how to communicate complex concepts (such as law) in a simple manner so that EVERYONE can understand, not just a select few. This activity forms part of the requirements I have set myself to achieve professional engineering chartership. The aim is to publish on-line a number of papers, articles and study aids, completely free of charge, to help the maintenance engineer or the would-be maintenance engineering student. My target for this is approximately 2 years’ time as I work on this project outside my working week job at the Ministry of Defence and on top of raising a family.
If you know of a particular area of the 1321/2014 regulations (was 2042/2003) which seems to always create conflicts between the engineers and management, or which seems to create confusions and misunderstandings, I would be really interested to hear what the query/confusion is so that I may attempt to create a document which would clarify the matter and communicate it in a simple manner. Please keep in mind that I do this in my own time outside working hours and that it may take some time to come back to you: but I will always reply to emails. Moreover, rest assured that your name will never be used and you will remain anonymous. I will only use the actual regulation clarification which resulted from your query.
For a copy of the unabridged paper, which has a comprehensive glossary at the end, or if you would like me to look into clarification of particular confusing regulations, please email me at [email protected] and I will send you an electronic copy.
Any feedback on this educational paper would be greatly appreciated.
Disclaimer: The above represents my personal views and activities and not those of the UK Ministry of Defence who happens to also be my employer. The above work is my work as a professional engineer.
In a previous position, in 2009, I needed to write a training presentation for about 50 technical staff who did not fully understand the new MAOS regulations, the technical relationships within the new suite of regulations (including DAOS), the limtations and boundaries of those organisations and also the implications of non-compliance from a Part M organisation.
To my surprise my presentation was really well received and in order to maintain the same new level of understanding (in a 'revolving door' environment) I simplified it further into a similar motor car analogy but using a fleet of Buses to keep a focus on who does what and why. I also included myself (then as Quality Manager) in the company Induction Process in which I gave the presentation to the new boys and also gave them the 'Bus Company Analogy' for further bedtime reading.
Although I didnt publish my version of the motorcar analogy, I think it was widely circulated within the international company and I believe someone in a 'higher' office also took to trying to improve it. I am not sure of the outcome of that improvement.
To my surprise my presentation was really well received and in order to maintain the same new level of understanding (in a 'revolving door' environment) I simplified it further into a similar motor car analogy but using a fleet of Buses to keep a focus on who does what and why. I also included myself (then as Quality Manager) in the company Induction Process in which I gave the presentation to the new boys and also gave them the 'Bus Company Analogy' for further bedtime reading.
Although I didnt publish my version of the motorcar analogy, I think it was widely circulated within the international company and I believe someone in a 'higher' office also took to trying to improve it. I am not sure of the outcome of that improvement.
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Hi Rigga
Thanks for that. It was whilst working in Part-M quality management for an operator that I came across the problem and wrote up the paper. I own a bog-standard silver Ford Focus (so many of them on the road). I like the idea of a bus fleet.
The quality manager I was working with used the car analogy too and was spending so much time trying to explain it to people.
I then worked at the Military Aviation Authority and since military regulations are very different from EASA, it was well received there too.
I have no doubt this car analogy has existed for some time, but I never thought of the bus fleet! I can imagine you had a lot of success with your teachings!! And yes, I think clear and understandable EASA/CAA regulation basics ought to be part of all staff inductions in this industry.
Thanks for that. It was whilst working in Part-M quality management for an operator that I came across the problem and wrote up the paper. I own a bog-standard silver Ford Focus (so many of them on the road). I like the idea of a bus fleet.
The quality manager I was working with used the car analogy too and was spending so much time trying to explain it to people.
I then worked at the Military Aviation Authority and since military regulations are very different from EASA, it was well received there too.
I have no doubt this car analogy has existed for some time, but I never thought of the bus fleet! I can imagine you had a lot of success with your teachings!! And yes, I think clear and understandable EASA/CAA regulation basics ought to be part of all staff inductions in this industry.
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I have read the article and found it good. I do however think the bus fleet analogy would work better.
My view is that all these types of articles and discussions help keep us focussed as things become ever more blurred.
My view is that all these types of articles and discussions help keep us focussed as things become ever more blurred.
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Hi BCAR Section L
I agree with keeping focused as things get more blurred, which is why I have been doing things like the above in my own time to try to help particularly those newer people in this industry (like myself) who are faced with an avalanche of data spread out all over the place!
It seems to me that those who have been in this business for many decades have had the chance to follow the whole development from pre-EASA to now. That can be a real bonus!
I agree with keeping focused as things get more blurred, which is why I have been doing things like the above in my own time to try to help particularly those newer people in this industry (like myself) who are faced with an avalanche of data spread out all over the place!
It seems to me that those who have been in this business for many decades have had the chance to follow the whole development from pre-EASA to now. That can be a real bonus!
I suppose the point of these articles is to explain the regulations in English (British) and not English (Euro-Legal).
As for us older guys? It can be true to some extent that we knew what has changed from CAA CAP360 to JAR-145 to EASA Part 145 and moving to the introduction of EASA Part M - which moved responsibility for the condition of an aircraft from the maintainers to the owners. (Do you know why Part M is Part 'M' and not a number?)
The trouble was that those on the shop floor were not actually involved in any tangible change of responsibility - their jobs didn't actually change much more than the certifying paperwork.
But in military maintenance and military manufacturing companies, they were used to being 'in charge' of their versions of airworthiness. MAOS stripped maintainers of that responsibility and gave it to the fleet operators and their Heads of Sheds rather than the fleet maintainers. I actually suggested that the Duty Holder post was moved from Group Captain to Air Ranks because the Groupies were only budget holders and not budget owners.
By the same means, DAOS split design services away from MAOS technical services (done by the same people until I did my presentation).
Even in civvy street many LAEs still cannot grasp that they are not the owners of the aircrafts overall status.
The main difference for the Bus fleet is that the driver is not the owner and there may be a management board to make maintenance policies and decisions.
As for us older guys? It can be true to some extent that we knew what has changed from CAA CAP360 to JAR-145 to EASA Part 145 and moving to the introduction of EASA Part M - which moved responsibility for the condition of an aircraft from the maintainers to the owners. (Do you know why Part M is Part 'M' and not a number?)
The trouble was that those on the shop floor were not actually involved in any tangible change of responsibility - their jobs didn't actually change much more than the certifying paperwork.
But in military maintenance and military manufacturing companies, they were used to being 'in charge' of their versions of airworthiness. MAOS stripped maintainers of that responsibility and gave it to the fleet operators and their Heads of Sheds rather than the fleet maintainers. I actually suggested that the Duty Holder post was moved from Group Captain to Air Ranks because the Groupies were only budget holders and not budget owners.
By the same means, DAOS split design services away from MAOS technical services (done by the same people until I did my presentation).
Even in civvy street many LAEs still cannot grasp that they are not the owners of the aircrafts overall status.
The main difference for the Bus fleet is that the driver is not the owner and there may be a management board to make maintenance policies and decisions.
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HI Rigga
So I was right in saying that you older guys really do have a wealth of data having seen the evolution. You personally seem to be very familiar with the military system too. For new entrants, it is easy enough to get accustomed to the current ways, but sometimes it is really useful to understand the background history. Although I work in Defence, I am only accustomed with the civilian way and only just now getting to grips with the military way (after a stint at the MAA).
I would be delighted if you would enlighten me as to why it is Part-M and not a number. I have looked around many times and asked many times but I could never get an answer. I also looked around many times and asked about 66, 147 and 145 (which I know were JARs before, but why the number) and again no answer, the only thing I eventually came up with through my own digging around was that these numbers seem to match the equivalent US 14 Code of Federal Regulations (14 CFR) numbers and for the sake of harmonisation with the US, were adopted with the JARs.
I would be grateful for your input.
So I was right in saying that you older guys really do have a wealth of data having seen the evolution. You personally seem to be very familiar with the military system too. For new entrants, it is easy enough to get accustomed to the current ways, but sometimes it is really useful to understand the background history. Although I work in Defence, I am only accustomed with the civilian way and only just now getting to grips with the military way (after a stint at the MAA).
I would be delighted if you would enlighten me as to why it is Part-M and not a number. I have looked around many times and asked many times but I could never get an answer. I also looked around many times and asked about 66, 147 and 145 (which I know were JARs before, but why the number) and again no answer, the only thing I eventually came up with through my own digging around was that these numbers seem to match the equivalent US 14 Code of Federal Regulations (14 CFR) numbers and for the sake of harmonisation with the US, were adopted with the JARs.
I would be grateful for your input.
Hi guys,
My apologies, I didn’t realise you were waiting!
You're right about the origin of the numbers.
The whole idea of the transition to a single Euro-Regulation was to align the (then) 17 different NAA systems into one and eliminate all those different National Type Certificates, each with their own separate requirements, across Europe making it cheaper for makers like Boeing and Airbus, etc to get their aircraft certified in one go. It was also seen as wise to align with, and if possible to improve on, the US 14 CFR system. However, even now the CAA sometimes dusts off "CAA Specs" or "AARs" to catch unsuspecting QAMs out.
So, in 1997/8, the UK transformed from CAP 360 to the new JAA regulations: JAR-OPS (-1 Aeroplanes and -3 Helicopters) and JAR-145.
CAP360 had two parts; first was the management of aircraft operations and the second was the maintenance agreement in which the responsibility for airworthiness rested with the maintenance organisation.
This agreement was carried through to JARs - but in JAR-OPS there was a 'sub-part M' in which part of CAP360 Pt2 (the management of the AMP) was contained although this remained a maintenance responsibility under the OPS regulation until the introduction of EASA Part M (now separated from JAR-OPS Subpart M) as issued in IR(EC)2042/2003 - 5 years after the intro of JAR-145 and JAR-66 Licences (who remembers them?)
Cos I'm an old git who doesn’t throw anything away, I still have copies of the CAA presentations on the changes and how to manage them, and the minimum we needed to do to remain legal over that transition.
The EASA regs aren’t perfect, but the (UK) civil translation of the words is totally different to the MoDs original (Def-Stan 05-130) MAOS/DAOS translation when reading the same words. I believe MoD tried to press the new regulations into their current practices rather then try to change their extant practices to accommodate the regulations. Even the guys who wrote the Def-Stan’s (ex-mil Consultants) couldn’t understand what MoD was doing to them!
I had a four year struggle trying to get MoD to see the light (mildly successful in areas that didn't matter) but gleefully left when I was offerend a proper job back in civvy street. Recently, I spoke to someone having exactly the same 'understanding' issues that I had three years ago!
FYI: State Aircraft (police aircraft) are still being held to CAP360 - even though it has not been amended since 1997 and was formally withdrawn in 1999!
CAA - Really on the Ball!
My apologies, I didn’t realise you were waiting!
You're right about the origin of the numbers.
The whole idea of the transition to a single Euro-Regulation was to align the (then) 17 different NAA systems into one and eliminate all those different National Type Certificates, each with their own separate requirements, across Europe making it cheaper for makers like Boeing and Airbus, etc to get their aircraft certified in one go. It was also seen as wise to align with, and if possible to improve on, the US 14 CFR system. However, even now the CAA sometimes dusts off "CAA Specs" or "AARs" to catch unsuspecting QAMs out.
So, in 1997/8, the UK transformed from CAP 360 to the new JAA regulations: JAR-OPS (-1 Aeroplanes and -3 Helicopters) and JAR-145.
CAP360 had two parts; first was the management of aircraft operations and the second was the maintenance agreement in which the responsibility for airworthiness rested with the maintenance organisation.
This agreement was carried through to JARs - but in JAR-OPS there was a 'sub-part M' in which part of CAP360 Pt2 (the management of the AMP) was contained although this remained a maintenance responsibility under the OPS regulation until the introduction of EASA Part M (now separated from JAR-OPS Subpart M) as issued in IR(EC)2042/2003 - 5 years after the intro of JAR-145 and JAR-66 Licences (who remembers them?)
Cos I'm an old git who doesn’t throw anything away, I still have copies of the CAA presentations on the changes and how to manage them, and the minimum we needed to do to remain legal over that transition.
The EASA regs aren’t perfect, but the (UK) civil translation of the words is totally different to the MoDs original (Def-Stan 05-130) MAOS/DAOS translation when reading the same words. I believe MoD tried to press the new regulations into their current practices rather then try to change their extant practices to accommodate the regulations. Even the guys who wrote the Def-Stan’s (ex-mil Consultants) couldn’t understand what MoD was doing to them!
I had a four year struggle trying to get MoD to see the light (mildly successful in areas that didn't matter) but gleefully left when I was offerend a proper job back in civvy street. Recently, I spoke to someone having exactly the same 'understanding' issues that I had three years ago!
FYI: State Aircraft (police aircraft) are still being held to CAP360 - even though it has not been amended since 1997 and was formally withdrawn in 1999!
CAA - Really on the Ball!
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Hi Rigga
Thank you so much for the explanation! so I take it the M is for maintenance basically.
I looked for CAP 360 on on the web as I thought I would read it to enlighten myself with all that you explained (being accustomed mainly with EASA regs) but could not find Part 1, only Part 2. Would you happen to have an electronic copy of Part 1?
Anyway, your info is great and will allow me to delve into this a little more and understand the specific history leading up to EASA Part-145/M in relation to UK.
I have more work to do with the military side of things as although recently working for MoD and despite a several months at the MAA, I haven't got around to all the details of military regs: I started at the MAA and because I understood EASA 2042/2003 (now 1321/2014) regs well, I was put straight onto EASA/European Military Airworthiness Requirements (EMAR) project and never got to see much of the mil regs. But that is life, I'll catch up shortly.
Once again, brilliant! Thank you.
Thank you so much for the explanation! so I take it the M is for maintenance basically.
I looked for CAP 360 on on the web as I thought I would read it to enlighten myself with all that you explained (being accustomed mainly with EASA regs) but could not find Part 1, only Part 2. Would you happen to have an electronic copy of Part 1?
Anyway, your info is great and will allow me to delve into this a little more and understand the specific history leading up to EASA Part-145/M in relation to UK.
I have more work to do with the military side of things as although recently working for MoD and despite a several months at the MAA, I haven't got around to all the details of military regs: I started at the MAA and because I understood EASA 2042/2003 (now 1321/2014) regs well, I was put straight onto EASA/European Military Airworthiness Requirements (EMAR) project and never got to see much of the mil regs. But that is life, I'll catch up shortly.
Once again, brilliant! Thank you.
No, M is for maintenance management. (Formerly known as the MMOE). 145 is for maintenance (MOE).
My CAP360 search was probably as enlightening as yours - but I'm amazed that part 2 is still available!
I suspect that "BCAR Section L" is more than a mere LWTR and may know more of this history than both of us!
My favourite trick to get out of using CAP360 (for police ops) was to ask the CAA for a copy...and when they could not supply one reject their insistance for complying with it!
I seem to remember that Part 1 was quite thin compared to CAP789...I'll see if I still have a copy of it. Dont hold your breath...
By the way; I think the EMA is going the right way (well, it was when I was watching them!) I left Marham as the MAA took hold and started to mess about with the MAP and Mil Regs - reverting (in my opinion) to their 'traditional' systems of work.
FYI, I was in military aviation for 24 years until 1999, but I was also working many weekends with my CAA LWTR for 10 years before I left. I've been in QA and AW positions for small and large operators since 1999.
My CAP360 search was probably as enlightening as yours - but I'm amazed that part 2 is still available!
I suspect that "BCAR Section L" is more than a mere LWTR and may know more of this history than both of us!
My favourite trick to get out of using CAP360 (for police ops) was to ask the CAA for a copy...and when they could not supply one reject their insistance for complying with it!
I seem to remember that Part 1 was quite thin compared to CAP789...I'll see if I still have a copy of it. Dont hold your breath...
By the way; I think the EMA is going the right way (well, it was when I was watching them!) I left Marham as the MAA took hold and started to mess about with the MAP and Mil Regs - reverting (in my opinion) to their 'traditional' systems of work.
FYI, I was in military aviation for 24 years until 1999, but I was also working many weekends with my CAA LWTR for 10 years before I left. I've been in QA and AW positions for small and large operators since 1999.
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Hi Rigga
Thank you!
Firstly, I concur about Mr BCAR Section L being more than meets the eye.
Then next, M for maintenance management, I got it, thank you.
The European Military Aviation Requirements are an interesting area of development and the Military Aviation Authority is involved in this project. For an update of what is happening, the February 2015 issue of the AeroSpace magazine of the Royal Aeronautical Society featured an article entitled "Harmonising Airworthiness" as written by Air Vice-Marshall Martin Clark, Director Technical MAA. (I sat a few desks from him for a few months and he's a really nice chap actually, engineer of course.) If you are interested in this area, it is worth reading.
Lastly, since this discussion has turned out really interesting, I feel that for the benefit of foreign viewers and also new or would-be engineers (and anyone else for that matter), I would like to ensure all the acronyms which have been used so far in this thread are clarified. I notice you use a lot of acronyms and one of my biggest bugbear when I was new to MoD was the endless amount of acronyms used for everything and not even defined!! I imagine with so many years in the military you know what I mean.
This is the same with the aviation industry etc. so many acronyms and very often, it is a challenge to find out what they mean. I think it behooves the speaker/author to take care to define the words he uses or make sure they are clear so that the audience receives the message and understands it. I would prefer that viewers of this thread come away with having learned something or refreshed their mind, but not leave with confusions over the content of the posts just because of acronyms, particularly for students (I always keep young engineering students in mind).
Skybrary website has good definitions for most of these acronyms.
So here it is (by all means correct those which are wrong).
AARs - Additional Airworthiness Requirements
MAOs - Maintenance Approved Organisation Scheme (UK military)
DAOS - Design Approved Organisation Scheme (UK military)
CAP - Civil Aviation Publication (publications from the UK Civil Aviation Authority)
JARs - Joint Aviation Requirement(s), a precursor to EASA regs
EASA - European Aviation Safety Agency
LAE - Licensed aircraft engineer
MAA - Military Aviation Authority (UK)
NAA - National Aviation Authority (the aviation authority of a particular country)
14 CFR - 14 Code of Federal Regulations (US aerospace/aviation law based on their own legal numbering system)
JAA - Joint Aviation Authorities
IR(EC)2042/2003 - Implementing Rule (European Commission) 2042/2003 Note: this has now been replaced by IR(EC) 1321/2014.
MoD - Ministry of Defence (UK)
Def-Stan - UK Defence Standards (include standards for military aircraft design etc.)
FYI - For your info
CAA - Civil Aviation Authority
EMA(R) - European Military Airworthiness (Requirements) Note: See website of the European Defence Agency for full details.
MMOE - Maintenance Management Organisation Exposition
MOE - Maintenance Organisation Exposition
BCAR Section L - British Civil Airworthiness Requirements Section L, licensing requirements for UK maintenance engineers before the introduction of JAR-66 and then EASA Part-66 licenses. However this license is still in use for certain types of aircraft such as historic aircraft (see further posts below on this and thanks to input from Rigga and Nutloose)
LWTR - License Without Type Rating
Thank you!
Firstly, I concur about Mr BCAR Section L being more than meets the eye.
Then next, M for maintenance management, I got it, thank you.
The European Military Aviation Requirements are an interesting area of development and the Military Aviation Authority is involved in this project. For an update of what is happening, the February 2015 issue of the AeroSpace magazine of the Royal Aeronautical Society featured an article entitled "Harmonising Airworthiness" as written by Air Vice-Marshall Martin Clark, Director Technical MAA. (I sat a few desks from him for a few months and he's a really nice chap actually, engineer of course.) If you are interested in this area, it is worth reading.
Lastly, since this discussion has turned out really interesting, I feel that for the benefit of foreign viewers and also new or would-be engineers (and anyone else for that matter), I would like to ensure all the acronyms which have been used so far in this thread are clarified. I notice you use a lot of acronyms and one of my biggest bugbear when I was new to MoD was the endless amount of acronyms used for everything and not even defined!! I imagine with so many years in the military you know what I mean.
This is the same with the aviation industry etc. so many acronyms and very often, it is a challenge to find out what they mean. I think it behooves the speaker/author to take care to define the words he uses or make sure they are clear so that the audience receives the message and understands it. I would prefer that viewers of this thread come away with having learned something or refreshed their mind, but not leave with confusions over the content of the posts just because of acronyms, particularly for students (I always keep young engineering students in mind).
Skybrary website has good definitions for most of these acronyms.
So here it is (by all means correct those which are wrong).
AARs - Additional Airworthiness Requirements
MAOs - Maintenance Approved Organisation Scheme (UK military)
DAOS - Design Approved Organisation Scheme (UK military)
CAP - Civil Aviation Publication (publications from the UK Civil Aviation Authority)
JARs - Joint Aviation Requirement(s), a precursor to EASA regs
EASA - European Aviation Safety Agency
LAE - Licensed aircraft engineer
MAA - Military Aviation Authority (UK)
NAA - National Aviation Authority (the aviation authority of a particular country)
14 CFR - 14 Code of Federal Regulations (US aerospace/aviation law based on their own legal numbering system)
JAA - Joint Aviation Authorities
IR(EC)2042/2003 - Implementing Rule (European Commission) 2042/2003 Note: this has now been replaced by IR(EC) 1321/2014.
MoD - Ministry of Defence (UK)
Def-Stan - UK Defence Standards (include standards for military aircraft design etc.)
FYI - For your info
CAA - Civil Aviation Authority
EMA(R) - European Military Airworthiness (Requirements) Note: See website of the European Defence Agency for full details.
MMOE - Maintenance Management Organisation Exposition
MOE - Maintenance Organisation Exposition
BCAR Section L - British Civil Airworthiness Requirements Section L, licensing requirements for UK maintenance engineers before the introduction of JAR-66 and then EASA Part-66 licenses. However this license is still in use for certain types of aircraft such as historic aircraft (see further posts below on this and thanks to input from Rigga and Nutloose)
LWTR - License Without Type Rating
Last edited by capitaine flam; 4th Jun 2015 at 12:34.
Capitaine Flam:
"BCAR Section L - British Civil Airworthiness Requirements Section L, licensing requirements for UK maintenance engineers before the introduction of JAR-66 and then EASA Part-66 licenses."
...BCAR Sect L are actually still in use for some aircraft.
"BCAR Section L - British Civil Airworthiness Requirements Section L, licensing requirements for UK maintenance engineers before the introduction of JAR-66 and then EASA Part-66 licenses."
...BCAR Sect L are actually still in use for some aircraft.
Last edited by Rigga; 3rd Jun 2015 at 22:38.
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Hi Rigga
Oh thank you. I think I see where I have gone wrong. BCAR Section L licenses would still be in use for some non-EASA aircraft flown under the jurisdiction of CAP 393 "The Air Navigation Order"?
I have looked up CAP 393 again (which has just been heavily amended again as of April 2015) and it seems to confirm this.
According to this order all EASA aircraft must be maintained under EASA rules, and the only licensing I know for this is Part-66.
Let me know if that's what you meant or if I am missing something here.
The following link to CAA website defines what is an EASA and non-EASA aircraft for viewers who may have a query on this. https://www.caa.co.uk/default.aspx?catid=2691
Oh thank you. I think I see where I have gone wrong. BCAR Section L licenses would still be in use for some non-EASA aircraft flown under the jurisdiction of CAP 393 "The Air Navigation Order"?
I have looked up CAP 393 again (which has just been heavily amended again as of April 2015) and it seems to confirm this.
According to this order all EASA aircraft must be maintained under EASA rules, and the only licensing I know for this is Part-66.
Let me know if that's what you meant or if I am missing something here.
The following link to CAA website defines what is an EASA and non-EASA aircraft for viewers who may have a query on this. https://www.caa.co.uk/default.aspx?catid=2691
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...BCAR Sect L are actually still in use for some aircraft.
http://www.haa-uk.aero/engineering-detail.php?eng-id=8
I still hold my BCAR Section L licence alongside my EASA Licences, you do not pay for the Section L Licence these days if you hold the EASA ones.
The problem is as there are no Section L courses anymore, as Engineers retire they are going to be in the position of having no one left to maintain the Annex 2 fleets.
I believe part of the HAA's (Historic Aircraft Association) (if it ever gets going properly) problem is that ex Military stuff appears to be going down the route that it will require a Section L Licence to be held, except the CAA no longer produce them, the "get around" I heard they were working on ( The CAA) was to have them do the EASA Licence, then isssue a " quasi grandfathered" section L licence..
Fine in principal, but if you have a company that say only operates several Spitfires and their Engineers study for the EASA Licence, you then get the catch 22 situation that they have nothing in their hangar ( IE EASA recognised types ) to put down experience on to allow the issue of the said licence.
Personally I thought Annex 2 was a mistake, It should have either all gone under EASA or not at all, I went from a simple to understand and clearly laid out licence, that relied on weight limits etc to the farce that is EASA, where groups and aircraft types change at the drop of a hat and you constantly have to check the web to see if you can certify XYZ.
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Last edited by NutLoose; 4th Jun 2015 at 16:04.
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Hi NutLoose
Thanks for this clarification. It's very useful. Now I get the picture. The Annex 2 being the second annex to Basic Regulation 216/2008 which describes what kind of aircraft do not fall under the Basic Regulation, such as historic aircraft.
I can see how one would have to check on the EASA list of all aircraft which it considers fit in that Annex 2 category and I do thinks your views on the impending problems are rather valid.
Thanks for this clarification. It's very useful. Now I get the picture. The Annex 2 being the second annex to Basic Regulation 216/2008 which describes what kind of aircraft do not fall under the Basic Regulation, such as historic aircraft.
I can see how one would have to check on the EASA list of all aircraft which it considers fit in that Annex 2 category and I do thinks your views on the impending problems are rather valid.
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It wasn't an easy transition, Originally the likes of the DC-4 DC-6 and DC-3 moved over to the EASA licence, hence well known operators in the UK would have had to move over to a Part 145 approval and their Engineers to part 66 Licences.
About a year or so later Easa decided they would be better suited under the Original Section L licence, so it all reverted back. I could imagine a lot of companies in the UK would have ended up out of pocket over that one.
That also brings up the fact that what is printed on your licence is worthless, until my EASA Licence was renewed several years later it still carried the DC-4 DC-6 and DC-3 and other types that were no longer covered by it on my licence coverage page!
About a year or so later Easa decided they would be better suited under the Original Section L licence, so it all reverted back. I could imagine a lot of companies in the UK would have ended up out of pocket over that one.
That also brings up the fact that what is printed on your licence is worthless, until my EASA Licence was renewed several years later it still carried the DC-4 DC-6 and DC-3 and other types that were no longer covered by it on my licence coverage page!
