Sub-part G CAMO

[camlobe]

Can't seem to get a straight answer to these questions:

'How many sub-5700Kg Part 145 organisations are Sub-part G approved?'

'How many sub-5700Kg Part 145 organisations have applied for Sub-part G?'

So, who out there has applied for or has Sub-part G approval.

The main reason for asking is, I don't know anyone who has, and all those I have spoke to have said they are not going to bother due to cost, both of application and administration, plus the added grief for no perceived benifit, even to safety.

I look forward to the comments from my peers.

camlobe

[om15]

Camlobe,
We have around 50 to 60 aircraft on the books, about half are N or VP registered, the rest are G private or JAR OPS, 3 types below 5,700 kg and 6 types above, all twin jet.
The initial reaction was not to apply, due to cost and the distraction from the core business of maintenance, this was reinforced by the increasing numbers of aircraft applying for registration with the IOM, which of course does not have the costly sub part G requirements.

However there hae been a couple of developments, we have been firmly advised by the CAA that they intend to make the renewal of ARCs by the area office so difficult and costly that it can't be an option, secondly the Private customers have indicated that if we wish to keep their custom we must offer a complete package of maintenance and subpart g support.

Next step is the assessment of the task and staffing requirements, any body a suggestion of the number required to support say 20-25 small jet twin aircraft?

I think that the costs will drive the smaller MROs out of business, the IOM will expand the register very rapidly, and the G reg Operators will have to fund another tier of audits, none of which will enhance safety in any way at all.

Best regards,
om15

[themoonsaballoon]

OM15, I agree with your comments regarding IOM, the staffing requiremnts for a subpart G will not be based largely on the number of Jets (20-30) but more the different types as similar types will be far less onerous to research and control.
All AOC operators are subpart G approved, not many PART145's are yet but if they want to retain a Technical services and planning function for ARC recomendations and control Aircraft within the famous 'controlled environment' then they need to crack on,
Below 5700KG subpart F etc will struggle the costs are huge, BJ at the IOM can not open his post quickly enough!
TMAB

[camlobe]

Thanks for your response guys. It helps me appreciate the situation elsewhere. Many thanks.

camlobe

[matkat]

Part M sub-part G is only for commercial aviation so the simple answer to your question is none.

[wigglyamp]

From 28 September next year, all non-puiblic transport aircraft (e.g. my private PA28) except annex 2 aircraft, come under Sub-part G and need a CAMO.

[mono]

Matkat,

So you think there are no commercial operations below 5700kgs huh??

Hmmmmmmmmm.

Methinks you should think again.

[Paradism]

There is discussion about a Part 145 Maintenance Organisation holding a Part M Subpart G approval. My understanding is that the Part M Subpart G approval is vested in an operator's AOC and and whilst some of the continuing airworthiness tasks may be subcontracted to another organisation, they remain the responsibility of the operator. There certainly are organisations that hold an AOC, a Part 145 MOA and also have Part M Subpart G approval.

One of the essentials is that the operator has a Continuing Airworthiness Manager ("CAM") who must be acceptable to the authority. Depending upon the size of the operation, a CAM may be directly employed by the operator or subcontracted, but according to Part M Subpart G, should not be employed by a subcontracted maintenance organisation but may do so with the approval of the authority. Good, in'it.

[Blacksheep]

The objective of Part M Subpart G is for the operator (the AOC holder in the case of a commercial operator) to exercise independent oversight of the maintenance organization. The person or persons responsible for the oversight functions cannot be employed by the contracted maintenance organization. Continuing airworthiness functions such as record keeping, planning, technical services etc. can be included in the maintenance contract, but the operator/owner is responsible for airworthiness.

It would appear that a whole new breed of specialist companies is about to arrive on the scene.

[slycamel]

could not agree with you more.

[themoonsaballoon]

I stand by my posting that those that can walk (SIC) onto another reg can and will do so!
TMAB

[ericferret]

I wonder what private owners of older aircraft such as the Cessna 150 are going to get for their money.

No new AD's on your aircraft this year sir, that will be £300 please!!!!!!!!!!!!!!!!!

Oh and your c of a has run out so we need £90 for EASA plus our costs so you aircraft can be ferried!!!!!!!!!!!

[Yoth]

Hi everyone,
I'm glad to see that the GA community is starting to wake up to Part M and continuing airworthiness in general.
I am the Continuing Airworthiness Manager for a new stand alone Part M Subpart G organisation. We are in the process of gaining Part M Subpart G approval with our local CAA office with Subpart I (ARC certification) coming later.
Having gone through the pain of compiling the CAMO/CAME and adding a private owner of a Cessna 172 as a test customer, there is a huge amount of work in establishing aircraft onto an approved database, with quite a few gaps in documentation required by Part M which the owner cannot supply, such as damage/repair reports and form 1's for rotable components.
I can see a reasonable amount of compromise being struck between owners and the CAA over Part M, otherwise there will be a lot of privately owned aircraft for sale next year with the associated reduction in income stream for the CAA.
I look forward to your responses.

[robin]

Sounds about right

We have just responded to the ESA consultation which would imply there is scope for change, but the new arrangements are already in place.

Where I am most of the LAEs are not able to continue carrying out the work they have been doing satisfactorily for years. Instead we are being forced back into the hands of an organisation notorious for overcharging and poor workmanship

[venetian]

I would like to point out that the CAMO managing the aircraft is the only way to stay in the controlled environment and to get the ARC through the CAMO itself.
The ARC will then last 1 year + 2x 1 year, provided the aircraft remains under the same CAMO.
No airworthiness review is necessary in the 2nd and 3rd year.

This seems to be a good advantage. Morevore there is no more need to apply to CAA for CofA renewal

[camlobe]

Thank you everyone for your replies. All much appreciated.

Just wondering, any Part 145's sub 5700Kg presently holding a SubPart G approval?

camlobe

[ericferret]

So what is it going to cost for say a Cessna 150 to be looked after by a part G over a 3 year period?

[146fixer]

Yoth I've sent you a PM

[Yoth]

I have replied.