Originally Posted by yakker
Had these good folk spoken to an organisation that has gone to the expense, time and cost of gaining Part M subparts I,F & G, and is already issuing ARCs, they would have had it all explained to them in plain English and prevented unnecessary time wasting and inconsistent speculation from sullying the pages of PPRuNe in this way!
Well let's hope you're not associated with one of those organisations because most of the important assertions in your post are total hogwash!
All a/c under 2730kg that fall into Annex 1 have to be with a CAMO (a subpart G organisation) and maintained by a subpart F organisation, which can be the same company.
Wrong. The maintenance management can be done by the owner (MA201) and the maintenance can be done by an independent, Part-66 licensed engineer (MA402) - i.e. the "uncontrolled environment". (In some circumstances some maintenance can be done by the pilot/owner and he can sign the CRS (MA803) - even in an "controlled environment").
If it is not it must go to a CAMO who, after a full inspection, can recommend the CAA issue an ARC The CAA will then go to the organisation's premises in their own time and carry out their own inspection and review of paperwork etc. at c.£160 per hour + vat.
Wrong. A sub part G organisation can carry out the airworthiness review on an aircraft that is in the uncontrolled environment, and in the UK that organisation can then issue the new ARC directly. i.e. print it off there and then, and hand it to the owner. (MA901(b) and CAA Aircom 2008 3.4)
Regarding the discussion about the proposed ELA changes involving sub 1000kg MTOW a/c :- ELAC 1 states that there could be a provision for a licensed engineer to be able to issue an ARC in the future, subject to the normal full annual inspection etc. However the CAA have no such procedure in place as yet and it is thought that it could be some while – due to the existing pressures on staff – before the necessary legislation can be drawn up.
Wrong. There is already a provision in the existing commission regulation that allows an independent, Part-66 licensed engineer, formally accepted by the NAA, to conduct the airworthiness review on ELA1 aircraft and recommend the renewal to the NAA. (MA901(e)). The UK CAA have as yet failed to put in place a procedure for accepting such engineers, but they are working on it now, and expect to have the procedure in place within "a couple of months".
G