Flight under A conditions

[Fuji Abound]

Chirp picks up this topic.

Some of us with distance maintenance organisations will recall the good old days when an engineer could sign an aircraft as fit to fly for maintenance if it was time expired.

No more.

The CAA now charge £80, paperwork must be completed and there is the inevitable delay. I understand the changes have come with the introduction of EASA.

The point I believe is well made that this is putting increased pressure on pilots to "get the plane there" in possibly unsuitable weather or lose time getting it there early.

Moreover, there is the potential for yet another cost, a disincentive for operators to chose the "best" maintenance organisation and I would guess (but I cannot prove) no evidence that the system was not working perfectly well before.

My engineer tells me (perhaps tongue in cheek) that if you try and ‘phone EASA you will find no contact details on their web site and nor for that matter has he yet been able to track down their number using any other means. When EASA takes over the A conditions paperwork presumably you have also got no mechanism of finding where it has got to!

[A and C]

I have filed a CHIRP about this removal of the "A conditions" certificates of fittness for flight, in by view the lack of the CoFF is putting pressure on the strictly VFR sector.

There are sometimes blocks of two weeks in the winter when VFR flight of the older and less well equiped aircraft would be marganal if not imposable.
I think that the £80 charge and the administrve delay put undue pressure on pilots and owners to move aircraft in weather conditions that They would not normaly fly in.

I have writen to my MEP but all I get back from all the authoritys is that the A conditons did not meet international standards and we are now (in effect) ruled from Brussels and no one can change that.

Unfortunatly EASA cant or wont see that the lack of a usable A conditions system is a flight safety risk and an errosion of the safety standards that the CAA has upheld very well over the years, it is my opinion that EASA don't understand aviation other that in the airlines and this is not an issue for the IFR sector.

The bottom line is that one or two of us have to die trying to move aircraft under this artificial time pressue before what is called the European air SAFETY agency will take note.

[IO540]

A lot of people fly "away" to get their maintenance done, and I don't blame them for a moment!

Actually - short of having an ILS at the place you are going to - bad weather affects IFR ops almost as much.

And if your home field doesn't have an ILS then you can't get back after the work has been done..... I have cancelled many trips into Europe because of the lack of a usable IAP back home.

[DFC]

The annual can be done up to 60 something days in advance of the due date and the new annual will run from the original date for another year.

If your annual runs out 31 December 2006 then it can be done any time in November or December and the next one will be due 31 December 2007!

You could fly the aircraft over in the late October and have the paprwork signed 1st week of November.

That can be done this year, next year and every year. You will always get the aircraft over to maintenance late October and the annual will always be due 31 Deember.

Not very difficult is it?

This is the same as pilots who have a 3 month window to get their SEP rating signed and then moan that they need a test because it is 1 day over.

:mad:

Regards,

DFC

[david viewing]

If your annual runs out 31 December 2006 then it can be done any time in November or December and the next one will be due 31 December 2007!

Is that true if it's a *annual?

[DFC]

Yes.

You have a 2 month window. If you can not get the weather in that period then the money you saved by not flying will pay for the cert required. :)

Regards,

DFC

[Fuji Abound]

DFC

With respect, your dismissive post shows a complete lacking of understanding of actually owning and operating a light aircraft privately. I assume you don’t?

As but one example, to reduce costs often efforts will be made to contain the maintenance cycles to coincide the 150 check with the annual with 50 hour checks required to slot in accordingly. In consequence it is only as simple as you suggest if hours can be discarded and flying commitments can be cancelled, the scheduling of engineers can be bent to your will and the availability of parts can be guaranteed.

The A rules have been around for as long as I can remember and then some before. I am not aware of any evidence that they failed to operate without problem and nor can I see any justification to change a system that has stood us in all good sted. Finally I can see no justification for imposing a charge or involving the regulatory authority in an entirely paperwork exercise when it is quite apparent they already are unable to keep up with the paperwork.

What do you think they are going to achieve by “stamping” the engineers application?

As is so often the case it seems to me regulation for regulations sake without any justification of why the system needs changing. Even the responder in CHIRP seems unable to give any logical justification for the change or for the imposition of yet another charge when none was made previously.

I tell you what lets add £80 to the TV license - why - we thought it would be a good idea!! Don’t expect anything more for it and don’t expect any justification for the change.

[A and C]

I could not have put that better myself.

I can only think that DFC's veiw of the situation is tinted by the smoked glass windows of the EASA HQ in Germany.

[DFC]

DFC
With respect, your dismissive post shows a complete lacking of understanding of actually owning and operating a light aircraft privately. I assume you don’t?


Assume makes an Ass out of you in front of Me. :D

I do as it happens.

As for having to curtail one's flying? It needs an annual each year. Flying is going to be curtailed one way or another while the annual is done. You could like me arrange for the annual to be done in January while you go on holiday. Do I have to explain again that if your annual falls due 27 February, you have all of January and February to get it done without loosing any Annual validity (you could park it up after the New Years Day fly-in!) and without having the aircraft away for more time than it needs to be and without having to pay £80

You say the engineers have to be at one's beck and call - Tosh.

Book the aircraft in for Monday in week x, If the weather is too poor to get it across, it has to wait until the next day or next week or whenever the weather improves. No matter if you have the sense to book it in at an appropriate time relative to the available window or not (and pay the £80 fee) it makes no difference, the weather is too bad and the engineer will have to wait for your aircraft (they will usually have other work to keep them going).

As for waiting for spares - if they affect the airworthiness then the aircraft is just as grounded inside or outside the window available to complete the annual.

Should you really want to look after your aircraft and avoid long downtime periods, you should look at progressive maintenance schedules which can be EASA approved.

There is some merit in being able to time the annual to co-inside with a 150 hour check and with more than a 2 month window, there is the oportunity provided you fly enough. Otherwise it is not worth worrying about.

If you want to try and run to the last day of the annual to save money then simply factor in the possible -£80 in the possible saving.

Dismissive? Perhaps so. I think that there is nothing wrong with EASA tightening the rules on who can issue A conditions.

Regards,

DFC

[A and C]

What safety evidence do you have to be of the opinion that tightening of the "A" conditions regulations is warrented ?

In twenty years I have not seen the system abused by any engineers and only once by an aircraft owner (who the CAA took action aganst after a report from the engineer who issued the certificate)

There are countless reasons why an aircraft may not reach the place of maintenance in time the weather and overrun at the maintenance shop are two that the owner can't control.

When issuing this certificate now the engineer still has to take full technical responsability, the CAA are unlikely to look at the aircraft all they do is shuffle the paper and charge £80.

If I could see any inprovement in safety standards I would have no objection to the changes, but all I see is a reduction in safety standards because of the pressure that the change puts on owners.

The stark reality is that we now have to pay more for no advantage and a posable reduction in safety standards the CAA regulation system has produced one of the safest GA systems in the world, are we now going to chuck this all away under the influence of some of the worst GA regulators for the sake of european integration?

[flyingfemme]

(you could park it up after the New Years Day fly-in!) and without having the aircraft away for more time than it needs to be and without having to pay £80
Parking is not always available at another field. A maintenance unit may not be able to store customers aircraft indefinitely. Such storage may also be expensive, if available, and certainly on top of regular parking arrangments.

As for waiting for spares - if they affect the airworthiness then the aircraft is just as grounded
See the parking/storage thing.....you can't expect a business to burden itself with other people's aircraft when it isn't practical. Get the parts, then move the job in and do the work.
And what about unplanned maintenance?
The system ain't broke.....no need to fix it. And as for "international standards"; the FAA have a similar thing that also seems to work fine.

[S-Works]

<Assume makes an Ass out of you in front of Me. >

Actually it makes an Ass out of U and ME......

Another example of DFC twisting things to his own end........:rolleyes:

[QDMQDMQDM]

Chill out everyone. This person, DFC, is a wind-up merchant.

[OVC002]

I do as it happens.


Dismissive? Perhaps so. I think that there is nothing wrong with EASA tightening the rules on who can issue A conditions.
DFC


You own an aircraft, and think there is nothing wrong with a change that adds nothing but delay and cost, and will, if anything, make things less safe. :hmm:

Of course you do. :rolleyes:

On the same basis you would think there would be nothing wrong with the CAA having to approve every paperwork entry made by a maintenance engineer.

We could even have a little menu from them.

Oil change £80
50 Hour check £80
Minor repair £80
Etc

IMHO only an employee of EASA or the EU or the CAA could genuinely hold such a view. Even then most would admit it was out of pure self interest, and not in the interest of safety.

[Fuji Abound]

The wind ups are entertaining :D , but if that is what they are they can also be useful.

Well thought out criticism should stand up to any scrutiny.

However, on this occasion I don’t believe DFC has proved his case.

The fact is good rules and regulations should be introduced these days to address a problem, and even then the impact of the regulation on existing user should be considered - that is why the CAA is obliged to perform a regulatory impact assessment.

In this instance there is:

no evidence that the existing arrangements are unsafe or are not operating satisfactorily,

no evidence the existing arrangements are being abused in any way,

no evidence that an additional cost burden should be imposed, because the CAA do not appear to be providing any service for the fee charged.

On these grounds allowing a change in the regulations should be resisted by us all.

As seems to be increasingly the case no justification is given by the regulator for the change, no regulatory impact assessment appears to have been carried out and so one can only assume EASA is unaccountable to the people effected by this regulation.

[DFC]

I honestly can't see the problem!

I would agree that the CAA are charging far too much for a piece of paper.

However, I can not see how with a two month window to get the aircraft to the maintenance organisation, many pilots would have to hand over £80 because the weather was not good enough to get the weather to fly.

Given 62 days, even a U/S aircraft could have parts ordered, repair made, bad weather waited out, flown to maintenence organisation, annual inspection completed and still have the date on the new annual 12 months on from the old one.

--------------

flyingfemme,

Parking is not always available at another field. A maintenance unit may not be able to store customers aircraft indefinitely. Such storage may also be expensive, if available, and certainly on top of regular parking arrangments.

Have I missed something here?

If I book my aircraft into a maintenance organisation for work to start on the first working say of January, would it not be reasonable for me to leave the aircraft outside their door that day or the evening before?

Would it not be reasonable to expect that if the weatehr was unsuitable that I could fly it over the next day or the day after or whenever the weather became suitable?

If the aircraft needs a spare part is it not reasonable to expect a U/S aircraft to be retained at the maintenence organisation while awaiting spares?

Would the above not also apply if I was silly ehough to leave myself having to pay £80 to the CAA on top of the other costs?

And what about unplanned maintenance?

If the aircraft is unairworthy it will have to be fixed where it is or trailored. If it is not U/S then it will be safe to fly.

----------

I think it is quite right that the CAA should charge. If it was not so then the costs would have to be recouped probably via the C of A revalidation charge or similar. I do not want my C of A charges to increase simply because some people can't get an aircraft from A to B within the same country in a 2 month window.

£80 may be a bit on the high side however.

Regards,

DFC

[Say again s l o w l y]

This is a badly thought out of legislation, with no basis in reality.

It is in much the same vein as the ruling that light a/c with engines over 12 years can no longer be operated for PT use.

Unnecessary and totally without basis.

There is no justification for this change, no matter if you can have it done early.
Why, if a pilot is happy to fly it, or an engineer happy to sign it off do we need any more paperwork?

Good legislation should be about common sense, this just creates extra headaches for no good reason.

Doing a check early can be a pain for a myriad of operational reasons and no thought has been given to the end users. i.e us lot.

It is not as simple as just doing a check early, sometimes you need a machine until the last day, add this to the fact that most people have been caught unawares by this and have only realised it when they are presented with a bill of £80 for s*d all, then they are bound to get annoyed.

Another rubbish piece of thinking from our regulators, who quite frankly seem to have about as much nous as your average gold fish and communicate their bright ideas with about as much clarity.

[A and C]

DFC can only be living in a perfect flying world were the weather is always good, pilots don't have to work,engieerig companys have unlimmited parking spaces and maintenance always happens to plan!............... I just wish I could find a way into his parallel uiniverse, things would be so much better.

Meanwhile back on planet earth I have found a way around the "A" conditions CoFF but I am not going to tell you what it is because if I do the CAA beancounters will close the loophole.

I would like to make it clear that EASA have forced this change on the CAA and the CAA are only charging for the time that they have to spend doing the EASA paperwork, Engineers can still issue "A" conditions CoFF on Non-EASA aircraft.

EASA as yet has no "little aircraft" experience and the rules are framed for large aircraft but having writen to my MEP he has been assured that this is being adressed by the EASA management. I do know that the PFA is putting a lot of pressure on EASA and the PFA are quite hopefull that things for GA are going to improve.

I think the bottom line is that without lobbying by a focused GA sector we won't get what we wan't so please join the PFA,BGA or AOPA and dip into your pockets a little or the "A" conditions issue will be just the tip of the iceburg.

[DFC]

It is in much the same vein as the ruling that light a/c with engines over 12 years can no longer be operated for PT use.
Unnecessary and totally without basis.


Perhaps one could say that the CAA were wrong to permit aircraft to operate with engines that according to the manufacturer were u/s.


The reason why this change affects so many is the insistance by the CAA that many aircraft which in reality are not involved in public transport (passenger) or (cargo) have public transport C of As.

Other European countries permit flight training including schools to use private C of As and groups can have private C of As.

I have said this many times before - the CAA have some very draconian laws and some very loose operations with often the two being interrelated. The CAA does it's best to avoid the enevitable EASA take-over by retaining it's draconian laws while removing every loose operation that EASA points out as being regarded as unsafe by the rest of Europe.

------

A and C,

I am only too aware that maintenence does not go to plan. If a maintenance organisation can not take my aircraft for it's annual at some stage during the 2 months prior to the annual expiry, then I would go elsewhere.

As you know having a stable relationship with a reputable maintenance organisation is one of the most important things in operating an aircraft.

If the weather is to bad to fly for 2 whole months then I will have saved the £80 in fuel costs. I do not know of any reputable mainternence oprganisation that will take a booking for maintenance and not have space to park the aircraft.

If you don't like the LAMS then feel free to get your progressive maintenence sscdhedule approved. Piper Cessna and many other manufacturers have progressive maintenance schedules. In that case the annual can be signed off without the aircraft being out of action for weeks. It also costs less in the long run.

Regards,

DFC

[Fuji Abound]

The annual is in December. The owner has flown around 150 hours a year for a long time. In that way only one “major” service is required. The annual is the 150 hour check. Of course the owner knows he could bring the annual forward by two months but he can now only fly 150 hours in the next fourteen months before the next 150 check is due, or the annual has to come forward again.

A typical scenario and one which in theory works until the juggling with the hours around the time of the annual / 150 check and the engineers commitments unexpectedly results in a missed deadline and a far greater expense, or the annual ends up taking two months because an engine overhaul is required or parts aren’t available.

I think that is the real life scenario being referred to.

Of course in the real world people don’t all fly Pipers and Cessnas and parts aren’t just sitting on the shelf. There is fortunately a huge variety of types still flying. Unless you have experience of some of the problems keeping them operating I doubt you are in a position to comment constructively.

As I have said before changes need to be justified.

I don’t and wont excuse the CAA or EASA making any change unless they can justify their reason for doing so.

.. .. .. And I know it is a problem because my engineer raised precisely this issue with me. It is causing him a huge headache, and he also tells me his local CAA office is fed up with other engineers complaining about the change. That tells me one thing - the changes are ill thought out, have not been properly “advertised” and have been introduced with complete disregard to the parties involved!

I will not support such a system.

[Mandator]

Reading through this thread we seem to be talking about some deliberate change in the rules which now requires a bit of paper which costs £80 if you are unfortunate enough to get caught with an expired annual or CofA (and in future the ARC?). I speak from experience of getting an aircraft in for maintenance at 7.00 pm last night, a full five hours before its CofA expired at midnight! In my view, no new rule has been deliberately made to cause this to happen. The problem is that the old BCARs allowed the use of A Conditions but the new EASA regime does not have such a thing as A Conditions. When the EASA rules were consulted in 2003, over a miniscule period of about 28 days if I recall correctly, nobody spotted that they did not allow the Euro equivalent of A Conditions. Nobody from our representative organisations, maintenance organisations, licenced engineers or individual aircraft owners and operators spotted that this facility would go so no-one kicked up a fuss during the consultation. As a result, we now have a problem for EASA aircraft whilst non-EASA aircraft, of course, can still use A Conditions. Having lost the opportunity to get the founding legislation right, I fear it will will be the devil's own job to get any changes made. I think we are going to have to live with this one.
Similarly, we are going to have to live with the engine overhaul life thingy. Again, I don't think that EASA has just invented a twelve year rule out of spite, it is just saying you MUST comply with the engine manufacturer's recommendations. Therefore, because the big two put a twelve-year calendar time limit on engine overhaul in addition to the operating hour limitation then that is what you have to comply with. Note that there is certain flexibility allowed by Generic Requirment 24 in CAP 747 but even so it is no longer economic to have overhauled engines lying around for several years as spares 'just in case'.
There is also a big problem with Euroland's definition of commercial operation. As I understand it, the European Parliament definition included in the founding legislation means that if money changes hands it must be commercial. Hence, flying training, even on microlights, is defined as commercial and the aircraft must be certificated and maintained accordingly. I was at an EASA working group a couple of weeks ago and the EASA staff stated that this problem has been recognised but it could take up to two years to get any required change through the European Parliament legislative process.

[IO540]

The Q to always ask in these situations is this:

The FAA oversees approximately 90% of all the GA in the known universe, and they don't have 12 year+ planes plummetting out of the sky everywhere.

Why not?

What is it that the intellectually and morally superior Europeans know??