Confused about ARC CofA EASA etc

[jxc]

I am totally lost to try and figure out what are ARC Easa and CofA etc are
I know CofA is an annual for the plane but when looking at planes to buy they all ahve different things
is there a simple way of explaining this to me or a website explaining it all ?

Cheers

[A and C]

The EASA C of A is a document that is issued for the life of the aircraft

The ARC is issued for one year and then renewed annualy provided that all the maintenance requirments have been carried out.

The C of A has nothing to do with the annual check what so ever.

THe ARC is normaly renewed at the annual check but it is not unusual to find ARC renewal out of phase with the annual check.

I hope that is clear enough!

[jxk]

You also have to determine whether the aircraft you're looking at is an annexe 2 (orphan) type or not. If it is annexe 2, it requires a CofA once every 3 years (known originally as a 'star' annual with fees to the CAA) and an annual carried out by a suitable M3 organisation . If it is included in the list of types recognised by EASA then it has to have an ARC issued for a year and this has to be carried out by an organisation with Part M approval. Simples! But surely a case for Nick Clegg to look at if he's trying to determine ways of saving bureaucratic costs.

[Cows getting bigger]

What's the point of a CofA if you need a current ARC? Seems like an additional bit of paper to me.

[peter272]

Hmm - you've not been keeping up have you?

Have a look through the threads on Part M and enjoy the pain and suffering we've had over the past 2-3 years.

Once upon a time the CofA was renewed at annual. Effectively the ARC becomes what was the CofA - at additional cost.

The non-expiring CofA is a different animal as it is now just a registration issue.

[A and C]

Thank you peter you beat me to it by ablot 30 sec

[Cows getting bigger]

I think that was my point. Certificate of Airworthiness. That seems to imply, err, airworthiness. The reality, as you say, is that this is a registration document.

So, back to my (rhetorical) question, what's the point?

[jxc]

I need therapy now thanks guys !

[A and C]

The C of A is more of a statment that the aircraft has a type certificate that complys with the mandatory requirments of EASA.

It is the ARC that ensures that all the work has been done (at the time of issue) to make the aircraft airworthy.

[David Roberts]

Let me try and explain.
Firstly, the EU basic regulation (218/2008) and the related 'Part 21' for airworthiness of aircraft, supported by rules drafted by EASA and approved by the Commission and the political process, embrace prima facie all aircraft registered in EU Member States. The exceptions to this scope are in Annex II to 218/2008 and cover aircraft such as microlights (< 450kgs MTOM), historic aircraft (pre-1955 design / pre-1975 production), home-built aircraft, ex-military aircraft, hang-gliders etc. Annex II aircraft remain under the airworthiness jurisdiction of each respective Member State and their own rules.

Thus in the UK, an Annex II aircraft will still have a UK CAA C of A which requires renewal every 3 years, together with associated maintenance and compliance with ADs (Airworthiness Directives) etc. In the case of certain categories of aircraft this process may look different, as with Permit to Fly aircraft (non-C of A) but the essential principles are the same.

For aircraft subject to EU regulation, again the system looks different but the fundamental principles are the same. An aircraft requires a C of A - thus it is a 'certified aircraft' compliant with the original airworthiness requirements including the relevant design code and production process etc. The first difference is that unlike the old (but still current for Annex II aircraft) UK system the C of A is not an expiring document - it is for the life of the aircraft. But, the validity of the C of A is subject to periodically meeting the other requirements, the main one of which is an annual review of the aircraft's continued airworthiness state over time. This review is documented in a process leading to the issue of an ARC - an (annual) Airworthiness Review Certifcate. The process that underpins this requires an assurance that all relevant ADs etc have been complied with (during the last year), that any mandatory modifications carried out since the last ARC have been implemented in accordance with offical data etc and that the aircraft's maintenance has been carried out according to the legal requirements, which usually means the manufacturer's maintenance manual. This maintenance programme is quite separate from the ARC process itself and is often on a different timing to the due date of the ARC, though it is convenient to try and align the dates.

Within the EU / EASA laid-down processes there is now a clear separation of functions between those who can issue an ARC and those who can conduct the maintenance and release the aircraft to service. This is not the case with the old CAA system (which still applies to Annex II aircraft). The former is a 'sub part G' organisation known as a CAMO - Continuing Airworthiness Management Organisation, whilst the latter is a sub part F organisation.

Depending on the aircraft category / class some of the maintenance can be performed by the owner / operator (see Annex VIII of Part M) whilst more complex maintenance has to be done by qualified experts / engineers etc. Within Part M (= Maintenance) there is the option to go for a 'controlled environment' whereby one contracts the work to an approved organisation, or the 'uncontrolled environment' whereby the owner can 'shop around' more freqeuently. That's a whole new discussion, but hopefully the above means that you are a little wiser!

[bern444]

Well, that's the bureaucrats mortgages paid for another few years, and those of a few lawyers too, probably. Whew! Thank goodness for that!

[robin]

Thanks David

Perhaps you can let us know how we in the UK fare as compared with those in Europe.

Given that we went VERY early in the process, my feeling is that everyone else waited to see how the legislation panned out and used the exemption to 2011/2012.

Speaking personally I am aghast at the way Permit to fly aircraft almost identical to mine are now permitted overflight and foreign travel - one benefit of the CofA. Add to that we see complex aircraft such as the RV10 with glass cockpitand looking for IFR and night flight.

These aircraft have an Annual cost 1/10th of the price of my ancient and very simple CofA aircraft.

When my aircraft lost a prop a while back, I had to pay 40% more for the replacement compared with an equivalent (identical) Permit aircraft - just for the Form 1

The LAA make clear the benefits of Permit ownership and how much Permit aircraft can now do. In an ideal world I would own such a type, but instead I have a much-loved aircraft that is bankrupting me and that is almost unsaleable.

Why is it that there there is such a mismatch between advanced Permit aircraft who aren't on Part M rules and ancient types (sometimes identical types) who are being screwed by massive cost.

And who is standing us for us to get some fairness into the system? The LAA can't, the CAA won't and AOPA aren't interested.

[Justiciar]

Why is it that there there is such a mismatch between advanced Permit aircraft who aren't on Part M rules and ancient types (sometimes identical types) who are being screwed by massive cost.

The system has grown up by evolution rather than design. The C of A regime derives from ICAO conventions and standards designed for civil air transport. When ICAO was formed flying was more problematic and machinery less well built and reliable. For that reason every bit of a certified aircraft had (and has) to have a paper trail which shows it is to an standard. The fact that often the uncertified component is the certified one without the paper trail is just one of the absurdities.

The evolution of light aircraft from a regulatory perspective is complex, but for various reasons the high level of regulation in the certified market with the associated high cost of modification or development of a certified design has resulted in a GA fleet which is several decades technologically behind the motor car industry.

On the other hand, permit aircraft which were once all home built from plans have evolved hugely and benefited from the general development in materials, design, electronics, precision engineering etc. Light touch regulation in most countries that have a permit system means that such aircraft can benefit from all the advances we all benefit from in every other sphere. General increased reliability of things mechanical and electronic means that we now have permit aircraft every bit as reliable as their certified brethren (witness the recent lifting of restrictions on permit aircraft overflying built up areas). The irony is that not only are C of A aircraft no safer but they are often noisier (the cost of modifications to silencers being too great to justify it) and less environmentally friendly, generally burning more fuel and leaded avgas as opposed to mogas or jet A1.

The relatively few innovators in the field of mainstream certified aircraft - largely Cirrus and Diamond - speaks for itself. Piper have seen the light with their tie up to market the Sportcruiser.

I would say that the market for second hand certified aircraft is largely dead and likely to remain so unless their is a significant reduction in EASA maintenance requirements, which seems unlikely. Even then many aircraft, the high performance ones, are a dead end because of the disappearance of avgas over the next five to ten years and the expensive conversion work they will require to run on any substitute fuel that may appear.

You only have to look at the recurrent adverts in the flying magazines for some aircraft which have been for sale for literally years. Private single ownership is an option for very few who have specific requirements. The market for group purchase is not great either. Eventually no doubt the second hand market will sink to a level to make it attractive, but it has some way to go before that point is reached. Owners will have to reconcile themselves to taking a big hit on their pride and joy in order to sell!

[IO540]

These aircraft have an Annual cost 1/10th of the price of my ancient and very simple CofA aircraft.

Robin - I don't think that 10:1 could possibly be real unless there is something fishy going on.

My TB20 is 8 years old. Unscheduled maintenance has been pretty minimal to date (barely 4 digits total) unless I count the Lyco crank business. Now let's say it went on a Permit. What would I save?

I would save the £200 for the A&P/IA signoff. Plus a few hundred quid. But there is about 40 man-hours, mostly inspections, and these would still need to be done, and that comes to about £2000. Plus VAT

So what could I do about that 2k? If I was an A&P I could do it myself, and if I was mates with an IA I could get it signed off for a beer.

So I spend a week or so on my back, getting dirty and oily.

In fact I could do a "customer assist" job where I work for a week together with an A&P mate of mine. The catch? One needs a hangar in which one is allowed to work, and these are damn scarce in GA.

Once one starts examining closely the often claimed massive savings on LAA types, it usually comes down to

- the owner is the type who likes to get his hands dirty, and places a zero value on his time (there's two grand already, eh?, need I go on?)

- the owner is an engineer who is able to do the work (and if he messes up, something comes off in the air; not an entirely unusual event in the LAA scene......)

- the owner has access to a hangar or other building where he can work, because the crowd where he revolves is more "chummy" so he has a big pool of contacts

- the aircraft is simpler so there is less to do....

- ADs can be disregarded (e.g. the Lyco 1997-2002 crank recall can be disregarded if you are on LAA or the US Experimental; different people will have different views on that one, shall we say... and since I fly over water and mountains, you can guess what mine would be)

- in the "chummy" LAA world you pay cash whenever possible, which saves the VAT In the ICAO world you try the same thing but one can't normally do it with companies..... but you have to go to a company for the Annual because.... you are not allowed to work in your hangar (not because you need their expertise)

There are real savings like not having to use certified parts, but the financial effect of these depends on the airframe condition and history. But (see my Form 1 comment below) the biggest factor is how smart one is in buying parts. If you have a Piper and go to the Piper dealer for everything including spark plugs, you get what you asked for.

So yes there are savings by going non-ICAO but 10:1 ? No way for like-for-like aircraft and complexity. Any such claim is pulling your leg.

Smart ICAO owners get it to a fine art. They log airborne time carefully, not "hobbs" time which costs another 20% or so. They develop valuable contacts who have the right bits of paper allowing them to sign stuff, and they build trust so they can do the work themselves and a friend signs it off. And they learn about engine management which saves them 20-30% on the fuel.

Of course there are people who do zero maintenance for years, and forge their records. You can do that on a CofA plane (and some have) but it is a lot easier to do on a homebuilt.

When my aircraft lost a prop a while back, I had to pay 40% more for the replacement compared with an equivalent (identical) Permit aircraft - just for the Form 1

You don't need a Form 1 for any privately operated G-reg. The FAA 8130-3 or even any other evidence of traceability is fine, so you can buy bits from the USA by mail order. EASA Form 1 (which many shops dishonestly try to tell you you need) is for AOC aircraft only. Anybody says otherwise - ask for legal references. Form 1 is a giant margin-scam; a ripoff; I paid £11k for a prop with a F1 which listed in the USA at $9k with an 8130-4 (Export CofA) which is what is needed for Class 1 parts (engines and props). There is a recent reg change which appears that an 8130-3 is fine for Class 1 parts too. The prop came from the USA and "passed through" a JAR145 company which just printed off the F1 and made the 4 digits for the cost of the laser printer toner. That was an insurance job and I knew little about planes back then anyway, but even I knew that £1=$1.60 back then so somebody (Socata and Air Touring Ltd mostly) were seriously minting it

[robin]

I hear what you say but the last annual/ARC renewal was over £3k for me. Compare that with Rod1's celebrated £300 Permit renewal..... My ex-CAMO did not allow me to 'assist' in the Annual so no scope for savings there

Similarly, the prop that came to replace the broken one was the 'certified' one, £461 more than the identical 'uncertified' one to include the notorious Form 1.

I questioned that, but was told that the uncertified one was only for Permit aircraft - nothing about a privately-operated exemption

[A and C]

At the end of the day you only get what you pay for, Rod is kidding himself if he thinks that the £300 permit was anything other than a "one off", he is ether not telling the whole truth about the other maintenance that he has done over the year or is flying a deathtrap (I suspect the former!)

[AdamFrisch]

If I might predict the future, this is what I think will happen: certification will become easier and the LSA/Microlight and certified and experimental classes will converge at some point.

Background: The US LSA classification has been rather easy to get and a great success. The FAA is now looking into moving away from the manufacturers self certification and testing, towards a solution where FAA will test it for the manufacturers, at a cost (why they haven't done this already is beyond logic). This provides standardization and results in economics of scale, as each manufacturer is now spared all the ancillary stuff in connection with the process. There is also a greater movement that wants to see that happen for normally certified aircraft FAR part 23. So it is a reasonable bet that this will happen one day.

If this happens, you will probably see a quicker and cheaper certification process across the board and the EASA has got no choice but to follow suite (they always copy FAA). So hopefully that prop that you have to pay twice for just because it has some ancient type certificate attached, will become a bit cheaper as most aircraft will have a type certificate.

The real restraint these days is not technology, but the fact that it's near impossible to get STC's and sensible technological advances without paying a fortune. We could all be flying Diesel engines in our aircraft if it weren't for ancient certification processes.

[IO540]

It is easy to get an Annual done for £300.

(1) Do the work yourself and value your time at zero value

(2) Do not use any significant parts

(3) Pay a mate of yours £300 to sign it off



Actually I know a bloke who used to get his piston twin annuals done for £300. He was a CAA LAME and did them himself, including the signoff. Oil (cheap oil) costs about £80 for a twin, two oil filters at £12 each... what else? All the rest is LABOUR

That's why all these claims are thoroughly disingenuous.

A repair on my lawn mower, done by the shop, costs me £300.

[vee-tail-1]

R.I.P. cheap flying on a certified aircraft thanks to EASA.

1) Own a simple certified light aircraft.
2) Base it at an airfield that allows maintenance in the hangars.
3) Keep it on the French register and sign for your own maintenance.
4) Be on friendly terms with local M3 engineers so as to hire their tools.
5) Fly it to France every three years to renew the C of A.
6) Have extensive engineering experience so you know what needs doing.

Not any more:

Now I have to pay a CAMO to check the paperwork, and issue an ARC.
Now I have to pay a part F organisation to oversign my work, or insist on doing it themselves.
Now the only DIY allowed is the pathetic list in appendix VIII. I can't touch anything 'safety critical' like flying controls, engine overhaul, instrumentation, etc. It pi****S me off and the only options are to sell or go illigit.

[IO540]

The tools should not cost anything much. I carry practically the whole toolkit to do the Annual, change the vac pump, starter motor, etc, in one toolbox.

AIUI a "part F" can be one individual. If you get friendly with one of those, that might be helpful

Avionics (if you understand the stuff) you can do yourself; nobody could ever find out if it is a straight replacement because the serial numbers are never checked, so I wouldn't worry about that. And there are loads of freelance avionics blokes around who will do an avionics test for you for a small fee.

Engine overhauls I wouldn't do unless I was damn good and did it for a living.