GA Engineering - Part M Regulatory Impact Assessment
I don't profess to understand this but it is a copy of a letter sent by a well respected person in GA, particularly vintage, engineering [and published here with his permission] to the CAA's Head of Maintenance and Policy. Those of you that understand what it is about may wish to make your own representation.
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It has just been drawn to my attention that a document is in circulation in the form of a Questionnaire from a qango organisation titling itself "Air Eurosafe", purporting to be carrying out a "Regulatory Impact Assessment" concerning the implementation of Part M. This document is, I understand, directed at owners, operators and organisations and seeks views on the impact of Part M on existing M3 organisations.
I am an owner and an operator, yet I have never been contacted by any department of the CAA for my views on this matter. Furthermore, from a quick canvass of colleagues and many others who own, operate and maintain aircraft, neither has anyone else.
I am advised that the deadline for replies is 7th December. This is wholly inadequate for this fundamental change, especially in view of the likely catastrophic effect on General Aviation of the change to Part M.
Part M will impose virtually all the burdens of Part 145 on the already parlous state of the GA M3 maintenance industry, both economically and in terms of time-wasting, at a time when there is a chronic dearth of skilled manpower and a great many existing proprietors are retiring or otherwise giving up and leaving in droves, rather than face the avalanche of bureaucracy facing the industry for no gain in continued airworthiness. For the same reason enterprise, management and recruitment into the industry is virtually nil because the rewards, neither financial nor "job satisfaction", faced with the new requirements, are not worth the trouble and responsibilities of setting up.
Furthermore, the "theft" from personally licensed engineers of their ability to exercise their skills and the privileges of their qualifications independently, as journeyman engineers - a fundamental right, hard won and exercised by skilled craftsmen for centuries - has caused great bitterness and many will leave the industry.
This matter is so important that you MUST NOT conclude this Assessment prematurely without fully consulting EVERY owner, operator and organisation IN PERSON, as is the stated aim of the Assessment.
Meanwhile, please will you let me have a copy of the relevant documents in order to make my own comments.
Yours faithfully,
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