It's not all bad this proposed Part M. It could result in a much needed shake up in some maintenance workshops.
But if you are the sort of pilot who takes his pride & joy to the trusted engineer for it's annual. Listens to the tale of problems and faults miraculously found and fixed, and you pay the huge bill without query. Then good luck to you and I hope you have not been ripped off too often.
I am an engineer, and this is the comment I have posted on EASAs comment response tool.
"I am particularly worried that UK engineers & maintenance organisations may try to continue to use the UK LAMS on EASA aircraft, in preference to an approved manufacturers maintenance programme."
"LAMS is appropriate for Annex ll aircraft but not for sophisticated modern types."
"Use of LAMS is similar to attempting to service a modern BMW car using the workshop manual of a Morris minor as reference. LAMS requires engineers to use their skill & experience to assess what work needs to be done. They are therefore free to do as much or as little work as they see fit. This leads to items being missed, or unnecessary work being done. It also tempts some engineers into extortion, presenting owners with massive bills for work that the owner has no means of verifying."
"In contrast, an approved manufacturers maintenance programme gives a type specific list of work to be done and the times to do it. No items are missed, and successful completion of the wok requires technical competance, not metaphysical intuition. A safe maintenance operation can be performed by the newest mechanic, or even a competant owner, and the owner is able to verify that the required work has been correctly done."
"Use of UK LAMS on EASA aircraft could be a flight safety hazard."