Easa = ???
I have been watching this thread for some time with great interest.
At a professional level, it pleases me to see that fellow Engineers are up to speed with the impending requirements as proposed.
At a personal level, it disheartens me as an owner/pilot to see how painful it will become to retain my aircraft on the G reg.
I am in the fortunate(?) position to have my own Part 145. However, this won't prevent the needless expenditure EASA are enforcing through the UK CAA. Nor will it ease the increase in totally wasteful paperwork. Neither of these two issues will make my own aircraft any safer. Continual in-depth inspections by experienced Engineers, both licenced and unlicenced, are the only way to catch something minor before it becomes more dramatic.
Unfortunately, the experienced guys are going to be busy dealing with more non-aircraft paper-shuffling tasks. Work the rest out for yourself. Hence the continual comment about this burden of paperwork not contributing positively in any way to aviation safety.
When I cornered my CAA surveyor earlier this year, I got him to give me the 'horses mouth' view regarding SubPart G CAMO's and ARC's. Sure enough, the CAA want three licenced guys doing what I have been doing for years. 'Who pays' says I. 'The customer will have to' says the CAA. I note that the CAA website makes no mention of this.
Although the CAA are carrying out the initial ARC issues, my surveyor stated that, with regard to the CAA carrying out ARC renewals, the Authority would make the situation financially untenable for the customer. This would assist forcing owners to stick with their present maintenance organisation so they remained in a 'controlled enviornment' even if the owner wasn't entirely comfortable with that organisation.
Therefore, moving from one organisation to another will be prohibitivly expensive, even if it is for the owners piece of mind, or worse still, to ensure the owner receives the quality of maintenance they rightly deserve. This expense is because the CAA will have to renew the ARC as the aircraft won't have been within a controlled enviornment for the previous twelve months. This is also the scenario if the owners present maintenance organisation call it a day.
It was also hinted that some retiring CAA surveyors were considering setting themselves up as CAMO's.
Add this latest grief to the same old line from the CAA 'we can't take anything away from you' which we Engineers know through experience, is codswallop. Remember when we had the ability to certify pressurised and unpressurised aircraft above 5700 Kg on your licence; issue Fitness for Flight to everything covered by your licence. This was only a couple of years ago.
Withen this short passage of time, the experienced Licenced Aircraft Maintenance Engineer is being fadded out to be replaced by an administrator with the new title Aircraft Maintenance Licence holder. Don't believe me? Ask your Engineer to show you his CAA and EASA licences. The old BCAR licence is an Aircraft Maintenance Engineers Licence. The new Part 66 licence is an Aircraft Maintenance Licence. We are slowly losing our identity, having our responsibilities redefined, and having our authorised capabilities reduced. Has any of this increased safety? I have my own views.
Acting as responsibly as possible, I have endevoured to keep my customers abreast of impending changes, attempting to be impartial without painting a black picture or overstating any issues. None of my customers have found fault with my explanations. They have, however, voiced considerable dismay with the CAA and EASA.
The two most common questions asked directly to me over the last year have not been 'how much to upgrade my avionics' or 'how much to replace my engine'. Instead, they have been 'how do I put my aircraft on the 'N' reg', or, 'I am going the PFA (LAA) route, what can I sell my aircraft for?'. There is also the growing realisation that G reg aircraft values may well dip in the near future as the market becomes potentially flooded with unwanted, overly-expensive to maintain aircraft.
As an A&P and PFA (LAA) inspector, it looks like I am going to be busy this coming year. And the best part? Very limited, if any, EASA input and paperwork. Might even be worth my while not renewing my Part 145 Approval. Hmm.
I posted a question on Pprune earlier. How many sub-5700Kg Part 145's have SubPart G CAMO approval. Have a look yourself to see what response I got.
There is a letter in the latest GA buyer from the Chief Engineer of Coulson Aviation Services (apologies for spelling). I suggest you all read it. It is another Engineer telling the GA community the reality of EASA. And it refers to the real and further decline in maintenance organisation numbers.
Over the next year, there are rumoured to be a number of established maintenance organisations who are going to call it a day and not renew their Approvals (not pay the CAA any more money). Having spoken to a number of the individuals involved, I know this to be substantiated and not just rumour.
The reasons given are consistant, and these are not my words:
Far too much paperwork for no perceived benifit in safety. Too much cost for insufficient return. Dissatisfaction with service from the Authority. Erosion of the professional licenced Engineers status. Small-minded EASA muscle-flexing against the FAA e.g. preventing the fitment of FAA PMA Approved parts in some instances; non-acceptance of American repaired or overhauled parts even with FAA Form 8130's attached.
DFC
It is commendable that you have taken an in-depth interest in your aircraft maintenance in the past. Long may your example continue. Unfortunately, if you don't gain CAMO approval yourself, you might find yourself frustrated when it comes to maintaining your oversight, as your CAMO will have the last word, not yourself. And you will have the pleasure and privelage of paying him/her to remind you of this, no matter what your view on this issue is. Welcome to the real world of EASA.
For all.
And remember, once the FAA have issued the C of A for an 'N' reg aircraft used for private use or training, they have no further involvement provided the aircraft is properly maintained. No FAA renewal fees. No organisation approval fees as your aircraft can be maintained by an A&P, and the modifications and Annual certified by an IA, thereby making maintenance cost effective and safe. Sensible FAA IR making flying safer. No wonder EASA wants to kick out the 'N' reg aircraft.
Enough for now, but remember, it is the eyes and experience of the licenced and unlicenced Engineers that spot and repair the defects and problems with your aircraft, not the attached six inch pile of paperwork.
P.S.
I have an unlicenced guy here who carries out the second part of the Independent Inspection...and he makes the tea.
Now, before you get on your high horses, he happens to have ten years experience within a 145 enviornment, and he has been properly briefed and Approved in accordance with Part M, and I trust him more than some of the Licenced idiots I have come across over the years.
camlobe