Part M for Mess-up
Hopefully my earlier post was considered informative and accurate in its content. There is the usual situation of individual interpretation by surveyors that will add further 'fun and games', as well as further potential movement of goalposts.
jxk, regarding your posts, I tried to ascertain what the costs would be for combined Part 145 and Sub Part G and I at renewal time next April. This was of particular interest to me as, like all other Part 145's, my approval renewal fee in April 2008 was somewhat higher than I was expecting. Foolishly, I expected an increase of inflation plus 6% (what we all have been told will be the standard CAA pricing updates to maintain their self-funding capability), giving around 10% max. Boy oh boy, did I get it wrong. The way I do maths, £2100 to £2786 is just under 30%.
I have been told by CAA Policy dept that the fees will be going up approximately 3% compared to the 2008 rates. And that the fee increases are decided 18 months in advance. Well, if they are decided 18 months in advance, the industry could be informed 18 months in advance, assisting in financial planning. He didn't tell me what the combined approval fee would be though. Also, I haven't been told how much extra the CAA will want in order to add another type or types to the Sub Part G approval. I am guessing that each and every addition will be classed as a 'variation' and they arn't cheap to obtain. Have a look at the CAA ORS series scheme of charges. So, more money to be found by the organisation and billed again to the customer.
Gives you a warm feeling to know EASA are only concerned with your safety, not their pension plan.
EGBKFLYER, my apologies for my omission.
smarthawke, I would be very interested to hear what your surveyor comes back with.
IO540, re the wording, I am at home at the moment and not near the EASA Part M Sub Part G, Sub Part I or Part 145. However, the content of the EASA documents do state such. I will try and locate the specific paragraphs when back in the office. As a quick breakdown, For the certifying engineer in the Part 145, he doesn't have to be an experienced engineer. The printed words are clear. A graduate with an 'appropriate' degree and a few months in an 'aviation enviornment' can gain and hold hold a Part 66 'C' licence allowing base maintenance certification. Tech records departments, battery servicing bays and seat maintenance bays are all classed as an 'aviation enviornment'. The reality is you could have a graduate with absolutely no live aircraft experience certifying aircraft as fit to fly following deep and heavy maintenance. Now doesn't that make you feel good next time you take your family away on an airliner?
The EASA M.A documents for Sub Part G and I do state the positions held will be either a licenced person or a graduate.
Malcolm, I totally agree, it is a serious Human Factors issue. Unfortunately, I don't see the situation improving for small organisations.
robin, please let us know what replies you get.
David Roberts, like yourself, I have tried to be a conformist. Like yourself, I am running out of patience, even to the point of considering dropping my Part 145, complete with its unjustifiable costs, and concentrating on 'N'reg.
camlobe