EASA Part M.Subpart F, G, I.
All in all, an eminently workable system for GA. 50 hour done in a morning - no problem.
Scenario A - Today,
Owner flys, updates his logs & finds he now needs a 50 hour.
- Goes to local M3 who do the 50 hour. Fix something broken if needed, cos they have data to hand.
--Goes flying again.
Scenario A costs to the owner are
: a 50 hour + defects.
Scenario B - EASA Part M. September 2008 (– maybe?)
Owner Flys. Tells CAMO who update his logs. CAMO finds he needs a 50 hour.
- CAMO tells owner he needs a 50 hour.
--CAMO tells Maintenance Organisation (MO) owner needs a 50 hour.
---Owner tells MO he needs a 50 hour.
----Owner arranges with MO to do 50 hour.
-----Owner tells CAMO 50 hour will be done.
------CAMO provides MO with data to do 50 hour.
--------MO does 50 hour.
---------MO tells owner something broken
----------MO tells CAMO something broken
-----------Owner tells MO to fix something.
------------Owner tells CAMO something will be fixed.
-------------CAMO provides Data to fix something.
--------------MO tells owner something fixed.
---------------MO tells CAMO something fixed.
----------------CAMO tells owner something fixed.
-----------------MO tells CAMO plane ready
------------------MO tells Owner plane ready.
-------------------CAMO vets MO stuff.
--------------------MO tells owner to go flying.
---------------------CAMO tells owner to go flying.
Owner too poor / tired / exasperated / to go flying now. Gone sailing / kiting / something else instead.
Scenario B costs to the owner are
: a 50 hour check + defects
: MO maintenance contract involving provision of staff, facilities etc at a time that suits both parties.
: CAMO Contract, provision of qualified staff, approved data etc at a time that suits both parties, time spent auditing CAMO.
: CAMO time spent passing additional data to MO for defect rectification, on a prompt basis
: downtime while all this extra stuff is going on
: + I’m sure there’s more
Please explain how this makes flying safer and makes the hobby cost effective.
The owner remains responsible in both cases, so no change in responsibilities.
Then please also explain how this makes flying safer for aircraft to which EASA has no remit?
Sympathising wholeheartedly with A & C, I take issue with DFC and his rather rosy view of EASA.
DFC wrote
"If you simply want to continue to provide maintenance then there has not
been any significant increase in costs. If you want to provide extra services then there
will of course be extra costs involved in gaining the extra approvals".
---The above scenarios possibly demonstrate that no extra services are provided, at increased cost – the aeroplane flies, has its 50 hour, goes flying again. The same service is accomplished via yet another management level - the CAMO.
DFC wrote
"Did you just discover EASA part M etc last month. I seem to remember it being common knowledge (if not in final form) for almost a decade."
Well, you said it - not in final form.
Exactly what system should be set up when there is nothing to base the set up on?
Do we set up with a CAMO, or will we not need a CAMO??
Will the controlled environment remain as proposed or not be required for planes below 2000 kg??
MDM032 – not very helpful yet.
As you are in Euroland, you are probably unaware of the UKland's current state of not knowing whats going on at the moment. We find ourselves shortly having to be in compliance with something not finalised yet, and all done before by 28-9-08.
DFC wrote:
"So sit in your office and put up your prices.....remember that the cost of approval represents very few hours at UK engineer rates....what do you do with the income from all the other hours income? Don't complain when other maintenance organisations get your work."
Who is this bloke? Put up my prices - other maintenance organisations will get my work.
He clearly doesn’t live or work in the UK. The other Income now seems to pay Independent Auditors, time spent self auditing, redoing Maintenance programmes in whatever the latest fashion is, hunting for basic information on the CAA & EASA websites, reviewing the lasted Ads, SBs, MMs, IPC, Screwfix catalog, incorporating mandatory modifications in the UK which are seemingly not required elsewhere in the EU, removing these mods when the plane is sold back to the USA, getting LAEs converted from BCAR to Part 66 with types the CAA don’t seem to know about (eg metal planes made of wood), drafting repairs & mods for approval by someone in Euroland, progress chasing such things, ………………………and eating.
Forgot about actually doing some maintenance work to generate said income – cant believe I did that!
I know what to do – I’ll put up my price to £ 50/hr, then Mr Eastern European wont get a look-in at his £ 15/hr plus European grants and other stuff. Better still I’ll move to China, you can fly there and have your 50 hour at £5/hour. At that rate I wouldn’t dare complain if my work went elsewhere!
DFC wrote|:
"I can pay a UK engineer £60 per hour or I can pay a French one EUR60 for the same product i.e. EASA certified maintenance. That is a big difference when it comes to certain scheduled maintenance."
Earlier, you suggested putting up prices. Why recomend I put up my prices when I'm already more expensive? Is this part of a cunning plan?
Anyway, I'm off to Cuckoo-Land to get £60/hour working on PA28s - I need directions as my map shows (mostly) the real world. Could I borrow your copy please.
If I were to take a plane from the UK to France for maintenance, the saving between £60 and 60 euro in France might just be eaten away with transit fuel and en-route landing fees and hotel fees when stuck abroad due weather and time off work to do the trip or paying someone to do this for you or getting back when you cant fix something for a few days or weeks or months awaiting spares or EASA repair approval.
DFC wrote|:
"There is absolutely no reason for club training aircraft to be certified for public transport.A point hopefully EASA will pick up on."
Read the MDM032 update
(The 2 monthly update of the July one has just been issued by EASA this month - December)
Interesting comments about commercial activities contained therein!
Club training for free - yes please.
DFC wrote|:
"If the aircraft can not go to the maintenance organisation then the maintenance organisation can come to the aircraft."
Interesting thought. I was led to believe the idea was to remove the back of the car engineer from the system by having approved sites & facilities & staff.
How does that stand with MA402 and a PA28 in the middle of a cold, wet & windy airfield? (Would only happen in the UK only, of course)
DFC wrote about costs:
"I know one club in the South of the UK who lease hangar space to a local UK maintenance organisation that then charges thema fortune for crap maintenence. The club could take control of it's own maintenance and that of many local owners and do a far better job of it than at present."
That club probably don’t want to, or can’t afford to take on the cost of full time engineering staff, fund the approvals required and have no work. Crap weather= no flying+ staff to pay+bill to pay= financial disaster. (UK only, of course).
Is saying something about crap maintenance a wise thing to say in these litigious times?
DFC wrote about Duplicate Inspections:
"If the CAA thought that there was such a requirement then it would apply to among other fixed wing categories as microlights including the skyranger that ended up in a tragic accident some time back doe to misrigged controls."
The CAA oversees the BMAA. The BMAA does have such a requirement.
DFC wrote about Duplicate Inspections:
“But as an Engineer, you should know that without having to look it up should you not. If not then how can you say previously........”
Under EASA, just knowing something is totally unacceptable - you must always be in a position where you are able to refer to basic and detailed Information. (MA401).
" please explain the EASA duplicate inspection process and wht exactly is dangerous."
as explained by A&C, using a second licensed engineer is superior to using anyone deemed competent by a company who may, if they so choose, use the tea-boy for the task. I would agree use of the Teaboy for Duplicate Inspections is unacceptable and potentially dangerous.
DFC wrote about Engine lives:
“Of course, while the CAA may think otherwise, EASA does not think that if Lycoming or Continental say that the engine they designed, built and had certified is good for 2000 hours or 12 years whichever is first and then requires an overhaul..........then one can still call the engine a certified engine with 15 years since overhaul.
I would love to have an aviation authority like that.”
Well, we had that Aviation Authority until recently. Airworthiness Notice 35 / GR24 worked well until the calendar TBO RECOMMENDATION was too rigidly enforced, unlike in the relevant Service Bulletins which give some leeway. Under this system I have happily & confidently flown 3500/4000 hour Lycomings – I thought nicer than newer ones, and were much better looked after under the extension criteria.
Anyway, got to get redoing LAMS as LAMP for some of the planes, but not all of them, or shall I leave it as it might change to manufacturers schedules in January 2008 or September 2008??
Just got a LAMP addressed to the owner of an Annex II type?
Does anybody know what’s going on?? Perhaps its all just a giant EASA HF test just to see how well we can cope with being dangled by the b*******s??