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Old 28th December 2007 | 22:40
  #88 (permalink)  
wigglyamp
 
Joined: Nov 2007
Posts: 408
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From: Too close to EASA
Part M

What DFC doesn't seem to have grasped is the new approvals an organisation must hold under Part M.

No one disputes that continued airworthiness is required. Most owners entrust their maintenance organisation (BCAR M-3 or EASA Part 145) to look after the paperwork review of SB's, AD's etc and accept that this is charged for as part of scheduled maintenance.

What changes with Part M for non-CAT aircraft is that the maintenance organisation has to hold a separate approval, at additional cost, to be able to review the maintenance documentation and raise the workpack. It is the cost of the additional approval and the cost of maintaining the approval that will be recovered from owners as additional fees, NOT additional aircraft paperwork.

To hold this approval as a CAMO, the new Part M sub-part G orginisation takes all the review responsibility away from the M3 or Part 145, including raising workpacks. The CAMO will require independant auditing, just like a maintenance organisation (after all, someone's got to check that they're doing the job correctly), it's own facilities, possibly additional staff (particularly for ARC renewals) and all these EXTRAS, beyond he M3 or 145, have a cost which can't be ignored, and will find their way into the bills of the aircraft owner.

Even if DFC sets himself up to maintain his own continued airworthiness as he's done in the past, he's going to have to apply to EASA for approval and pay the fees himself as well as getting himself audited!
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