EASA money pit

[A and C]

Having been head down in unproductive paperwork for the new EASA part M maintenance approval I had rather missed the new scale of charges from the CAA.

According Maurice Colson in the latest Loop the maintenance approvals will form 2008 cost £1552pa for the M3 approval and £3482.50pa for the EASA part M subparts F&G.

All this extra money to pay for the aprovals just allow us to to do what we are doing now!

The cost for the approvals in 2004 was £654pa.

That is a price hike of £4380pa over four years............. That is why maintenance prices will have to rise and not a penny of it wll end up in the hands of the engineering company's.

[DFC]

That is why maintenance prices will have to rise and not a penny of it wll end up in the hands of the engineering company's.

Not True.

If you simply want to continue to provide maintenance then there has not been any significant increase in costs.

If you want to provide extra services then there will of course be extra costs involved in gaining the extra approvals.

If you are correct in describing the paperwork catch-up exercise you have to do as unproductive, please explain how productive you organisation will be without having completed the catch-up exercise?

You could also explain just what paperwork you are so far behind with?

Did you just discover EASA part M etc last month. I seem to remember it being common knowledge (if not in final form) for almost a decade.

This is like the CAA - Oh ICAO have decided to change R/T for climb clearances. Shock Horror. We have not have time to assess the impact and we can not change our procedures until we have an assessment and consultation..............Was your man at the ICAO meeting asleep? Did they have memory loss after the meeting? Did they simply claim the expenses and go shopping in Montreal instead?

You are correct to say that not everyone is in the same boat and it is not a level playing field............most have recognised what work if any was needed years ago and are sitting happy. Unfortunately, Jonny'd dog ate their homework and they have to stay behind to catch up.

So sit in your office and put up your prices.....remember that the cost of approval represents very few hours at UK engineer rates....what do you do with the income from all the other hours income? Don't complain when other maintenance organisations get your work.

Regards,

DFC

[IO540]

My guess is what will happen is that a lot of maintenance facilities will do the work and get a chap from another firm (which has paid for the approvals) to come in and sign the papers.

The people who actually do aviation maintenance are in many cases kinds who can barely pick up the right end of a screwdriver. This is JAR/EASA 145 I am talking about, too.

[A and C]

Just how thick are you? or is it you are on some anti-mantenance company agenda?

All the extra approvals are needed JUST TO DO THE WORK THAT AN M3 COMPANY IS DOING AT THE MOMENT! not anything extra.

Why should the maintenance companys have to take the hit just so EASA and the CAA can employ more people to push paper that had very little to do with safety.

The fact is it will encourage the low end of the business to cut corners.

we have been on this project for about 18 months and the reason for all the paperwork it that EASA keeps moving the goalposts, just a few weeks or so back they published LAMP to replace LAMS...................yet another paperwork re-hash to pander to EASA if you are an aircraft owner you will get a CAA LTO on the subject soon.

[Fuji Abound]

Moreoever these costs are an issue of economy of scale.

Like any regulatory costs they may be better absorbed by larger concerns.

However, some of the best engineers do not fall into that category. There life long work has been in this business - they are as good as any, and better than most when in comes to working on some of the ageing and traditional GA fleet.

I know Maurice well and he most certainly falls into that category.

If he, or any others like him, were unable to continue in business because of these signficant increases it would be a very sad day.

Maurice has devote a great deal of his time to this matter and he is to be congratulated for doing so in my view.

[DFC]

I have more sense than to believe your excuse for putting up your prices.

I also have more sense than to restrict my maintenance to just UK based organisations when better value is available elsewhere.

I remember the UK training organisations moaning about how much their prices would have to rise because of JAR-FCL. One particular Balckbushe operator was very up front in saying that JAR-FCL was going to cause price rises in his organisation............which went under in shady circumstances shortly after.

I know that there is noting new in EASA Part M that has not beein known about for a long long time.

There is the class of engineer who listens and learns and prepares for the future then there are those at the back who are constantly playing catch-up.

This is that I use top of the class Maintenance because in the long run it costs less and do not listen to the old..........ah if you get maintenance done in xyz EASA country we won't touch your aircraft back in the UK.

Isn't eradicating that attitude what EASA was all about?

I can pay a UK engineer £60 per hour or I can pay a French one EUR60 for the same product i.e. EASA certified maintenance. That is a big difference when it comes to certain scheduled maintenance.

Regards,

DFC

PS Must remember to moan to my employer about the bookwork I have to do every 6 months just to keep up to speed as a professional pilot. Not very productive being in the classroom is it?

[Fuji Abound]

DFC

Please help me, I dont understand your point.

How can light aircraft maintenance for the average owner operator or even small flying school be a level playing field?

Most people are far too busy to have the time not so much to get the aircraft to some far flung maintenance organisation but more to the point to get back. I doubt that many owners take their aricraft far from their local field, if they even do that.

A days loss of income may represent 20% or so of the total cost of an annual, so going further afield will often end up costing more.

Moreover there can be all sorts of other hassels associated with doing so not least including the weather hampering plans to move aircraft around, particularly if there is no let down at the maintenance organisation base and having to use other MOs if there are minor snags between checks to name but two.

How do you square the circle?

[Chuck Ellsworth]

How do you square the circle?

Fold the paper work into a perfect square and then shove it up a bureaucrats ass? :E

[DFC]

If the aircraft can not go to the maintenance organisation then the maintenance organisation can come to the aircraft.

Worth trying some figures regarding maintenance. Try looking at the cost of an Eastern Europe EASA qualified engineer based at your school but working for you and your local owners in terms of supervision and day-to day rectification with further support drawn in from the home country EASA approved based maintenance organisation for larger maintenance tasks.

Remember that a 50hr in a PA28 is not rocket science.....that is why a PPL can do it if operation is private.

Now compare the charge for a UK maintenance organisation to provide the same level of cover.

Of course, with EASA taking over, we will eventually end this rather silly situation where group owned aircraft and club aircraft and aircraft used for training are public transport.

There is absolutely no reason for club trainng aircraft to be certified for public transport. A point hopefully EASA will pick up on.

I am not anti-engineer, I am anti leading people down the garden path.

Regards,

DFC

[Fuji Abound]

If the aircraft can not go to the maintenance organisation then the maintenance organisation can come to the aircraft.

DFC

So help me out a bit further please?

I dont understand how the maintenace organisation can come to the aircraft?

Are you suggesting some sort of travelling workshop?

Setting up new maintenance companies with labour from outside the UK may seem like an idea - but I dont beleive it is. It is very easy to under estimate the cost of setting up the operation. The pay back period would be considerable. Then there is the minor matter of finding premises - which are in short supply. Of course even if th einitial underlying labour costs are a little less you can guess how quickly they will rise as the engineers realise what they need to earn to live in the UK!

[PH-UKU]

DFC wrote ...
If the aircraft can not go to the maintenance organisation then the maintenance organisation can come to the aircraft.


Aye, that'll really keep the costs down. OK for you being able to nip over to France but those of us 3-4 hrs north ain't got much option.

There is absolutely no reason for club trainng aircraft to be certified for public transport. A point hopefully EASA will pick up on.


I agree, but don't see EASA changing this soon. Bit of a pisser for me and hundreds of others who are now forced to re-engine aircraft for 'public transport' (ie. flying club) ops. All because CAA re-interpreted the engine TBO rules and insist 12years/2000hrs means whichever comes first. At the stroke of a pen some faceless bureacrat has written off 800hrs of remaining engine life and just cost me £20k. :mad:

Of course, with EASA taking over, we will eventually end this rather silly situation where group owned aircraft and club aircraft and aircraft used for training are public transport.


Your faith is touching. I heard that the CAA claimed their re-interpretation of the engine TBO rules was forced on them by EASA. Easy to blame someone else ... ?

"rather silly" is a slight understatement when you view the costs involved. Perhaps someone can explain how things are safer as a result ? I guess I've now just got £20k less to spend on other stuff like Mode S transponders, fuel, landing fees etc..etc..

[A and C]

So it is now clear some Eastern European turns up in and the maintenance gets done, it must be very interesting to see how he gets the hangar and it's equipment in the back of the van.

The fact is back of the van maintenance is not sustanable if you are looking for quality, a few years back I had cause to look over an aircraft that had had a 150 hour check done in a field from the back of a van, the bloke took half a day to do the check and there was no evidence of some safety critical landing gear work having been done (because the guy did not have the jacks in his van). If that work is not done the gear will fail to free fall in the event of a Hydraulic failure.

What price is "back of a van" maintenance then?

50 hour check Yes as DFC says a PPL can do this but what he can't do is any inspections that are the subject of an Airworthiness Directive, most AD's are 100 hour items so a PPL will have to get a LAME in to do these items on the second 50 hour check in the cycle.

CAA costs & the small business most of the small maintenance outfits are probably looking after about 40 aircraft so the new CAA charges will come to £109 pa per aircraft or about £1.50p extra per flying hour for the average private owner in extra CAA fees. DFC please note this is fact not leading you down the garden path you just have to do the sums.

What I am tyring to make clear to DFC is EASA Part M only brings lots more paperwork and CAA charges, you don't get is any extra "hands on" maintainence and in the area of duplicate inspections of flying controls and other critical systems the EASA system is a real errosion of safety standards.

DFC we all know that paperwork is required and I have no problem with this but what I don't like is extra paperwork that has no benifit to the industry or the customers.

Now I am going to take a stab in the dark and guess that DFC professionaly fly's long haul for Big Airways and spends too much time in the cruise thinking of ways to save a penny or two.............. but on this I could quite well be wrong.

[IO540]

Now I am going to take a stab in the dark and guess that DFC professionaly fly's long haul for Big Airways and spends too much time in the cruise thinking of ways to save a penny or two.............. but on this I could quite well be wrong.

It would be well wrong, indeed. I don't think he flies anything these days, although he probably used to at some time. He certainly doesn't fly IFR today.

There are a few people (3 or 4) on here who stir up a lot of hot air. My approach is to ignore them unless they state something which could lead somebody to waste time/money.

Pprune is quite a good forum, with some real expertise over a broad area, but only provided one avoids taking the baits that pop up with much regularity.

[A and C]

Just to add to the debate under EASA part M PPL's will no longer be able to do a 50 hour check without approval from the part M company that they have the aircraft maintenance contract with.

So DFC you will have to stop doing those 50 hour checks untill an engineer is checks you out and is happy that you are up to the job!

[DFC]

I know one club in the South of the UK who lease hangar space to a local UK maintenance organisation that then charges thema fortune for crap maintenence. The club could take control of it's own maintenance and that of many local owners and do a far better job of it than at present. Of course employing people from a country with a highly skilled and well established aircraft design and production industry always makes sense.....but that does not describe the UK anymore unfortunately.
They (the club) are in prime position to think on a wider basis.
A and C,
When I come from there always has been the requirement that a pilot was trained by a qualified on type maintenance engineer in how to do the 50 hour check, had the appropriate manuals and that the maintenance engineer was available for advice or assistance if required. EASA changes nothing there.
To do otherwise would permit the PPL who does not know a spanner from a wrench to do a 50hour check and thus render a serviceable aircraft an unairworthy piece of future aluminium rain.
The engine overhaul periods are applied by the manufacturer. The CAA was permitting "uncertified" engines to be used in "certified" aircraft. EASA was quite right to question that practice.
Of course, while the CAA may think otherwise, EASA does not think that if Lycoming or Continental say that the engine they designed, built and had certified is good for 2000 hours or 12 years whichever is first and then requires an overhaul..........then one can still call the engine a certified engine with 15 years since overhaul.
I would love to have an aviation authority like that. Hi, I would like to certify this aero engine. I can show that a TBO of 2000 hours is appropriate.........CAA response - Yes great we will accept that and give it a TBO of 8000 hours.
in the area of duplicate inspections of flying controls and other critical systems the EASA system is a real errosion of safety standards
Perhaps you would like to explain that one.
Regards,
DFC

[Fuji Abound]

I know one club in the South of the UK who lease hangar space to a local UK maintenance organisation that then charges thema fortune for crap maintenence. The club could take control of it's own maintenance and that of many local owners and do a far better job of it than at present. Of course employing people from a country with a highly skilled and well established aircraft design and production industry always makes sense.....but that does not describe the UK anymore unfortunately.

A club with a reasonable number of aircraft is a different matter.

Aircraft out of service cost money - and the best time to do some of the work is after hours.

However, the capital cost of setting up such an organisation is significant.

Schools find it almost impossible to make money anyway, unless they are involved in commercial training - and there are very few of them.

I dont suppose you will find many going into this business without some history these days, or if they do, they dont last long, which says something about the industry.

Now what would make senses is a structured system of continous maintenace - but that would be far too simple.

[Mandator]

Gents - I think there are some misunderstandings around. At a briefing on Part M approx three months ago at Stansted Regional Office, the CAA stated that discounts were applicable to maintenance organisations needing multiple approvals. They cited the case of an organisation needing Part M Subpart F and G+I plus M3. They said that the highest price approval would be at the full rate, with second and subsequent approvals being charged at only 25% of the rate.

In this case the fees would be:

Subpart G+I - full price
Subpart F - 25%
M3 - 25%

As ever, the CAA is its own worst enemy. Why wo'nt it put an article in the mags or put up a spokesman for interview, so that everyone can get the gen? The info is probably tucked away in the middle of their website somewhere, but how can you find out?

[A and C]

DFC as you no doubt know after maintainance of a critical aircraft system (usualy a flying or engine control system) this has to have to have two independant inspections.

Under the CAA system this has to be two licenced engineers or some one with a CAA approval (very unusual)

The EASA system requires the second inspection but the person doing the second inspection can be nominated by the maintenance company, they dont have to be a licenced engineer or CAA approved.
I see this as a loop hole that the bottom end of the market will use to get the tea boy to do safety critical inspections.

[DFC]

Yes I am aware of the requirements for a duplicate inspection. However, there is no link to licensing. After all, UK major airlines have operated safely for years with very few licensed engineers among the many people who inspect and maintain their aircraft. Company approval worked well under the CAA and could work just as well under EASA.

You forget that the UK CAA ignores the requirement for duplicate inspection in respect of many aircraft on the register.

To say that an unqualified and unknown person can sign off a duplicate inspection is not quite true now is it.......please let everyone know the real requirements for the person (not a licensed engineer) who performs the inspection to confirm that the first person has not reversed the controls or similar.

Regards,

DFC

[englishal]

There are a few people (3 or 4) on here who stir up a lot of hot air. My approach is to ignore them unless they state something which could lead somebody to waste time/money.
Yes, good idea. Also worth noting that SOME of these people don't actually fly very much at all, and have not used their ratings for some years apart from the odd reval test - they just love to stir. I've had many a banter with EXPERTS only to find out they haven't flown for years - and they are still experts!!!!

I guess because they don't fly they love to read rule books and other documents.

Makes me chuckle to myself when I find this out ;)

[ericferret]

Did company approval work well under the CAA?

Examples.

1)Engineer X fails the UK engineers licence, his employer a major UK operator then gives him full company approval without any form of examination or retraining.

2) Same company then gives full approvals to other engineers without licenses (again with no examination) and advises them not to sit the licence exam as it might cause problems.

Can you imagine the outcry if this had been pilots and not engineers.

The CAA then changed the system so that a basic licence was a requirement to hold company approval. So in effect holders of approvals were still licensed engineers.

[A and C]

DFC one more time you show how little you know of the system !

Yes it is quite correct that that all the airlines in the UK do the certification of maintenance via an approval system, that is because they would not issue a type rating for an aircraft under BCAR 8-13.

However it was a requirement to have an engineers licence (without type rating) befor you could go on the approved course to get CRS approval.
To give some sort of idea the course for the Airbus A320 airframe & engine lasted nine weeks. Without this you could not certify a duplicate inspection.
In all the UK airlines that I have worked for (five in all) I have never seen anyone who was not a licenced engineer carry out a duplicate inspection except in componant workshop and that comes under a different approval system.

As to light aircraft I can only think of a few places that non-licenced staff can certify a CRS and they have major overhaul approval for very limmited tasks.

At NO time in this business (30 years) have I seen the CAA "ignore" the requirement for a duplicate inspection on flying controls Etc.

[DFC]

Yes but a 3rd year apprentice can get a Basic Licence. i.e. They have the licence before completing the apprentiship!

I don't think that there was ever a case of;

a major UK operator then gives him full company approval without any form of examination

Yes there were people with company approval who failed the licence. However, there was an approved training system in place from apprentiship through to shop floor in order to get the approval.

OK you could argue that if one had company approval on the B737 then obtaining a basic licence and adding a B737 type should be easy.....but for some, 10 to 15 years after apprentiship, it took quite a bit of work to pass the theory element of the Basic Exam.

None of Us can remember the finer points that we learned and passed tests in at 19 or 20 years of age.

----------

A and C,

I'll ask again. Please give us all the details of the proposed EASA duplicate inspection scheme that you find such a problem with.

As for aircraft under CAA with no duplicate inspection - how about those that one can remove the wings from for road transportation. No requirement for duplicate inspection (very hard at times to find another person in a field in the middle of nowhere).

If the CAA thought that there was such a requirement then it would apply to among other fixed wing categories as microlights including the skyranger that ended up in a tragic accident some time back doe to misrigged controls.

Not all aircraft are required by the CAA to have a duplicate inspection. You should know that.

Again - please explain the EASA duplicate inspection process and wht exactly is dangerous.

Regards,

DFC

[A and C]

I will have to go deep into the books for the EASA duplicate inspection details and I don't have then here now as you won't be happy untill you get this chapter and verse.

Aircraft that are intended to be de-rigged have never required a duplicate inspection after rigging but these systems are built to be "idiot proof" (unlike this forum!). However even a de-riggable aircraft has to have duplicate inspections on the flying controls if they are disconected in any way apart from that in the POH.

You are showing how out of date you are with the maintenance system as you are correct that you could get an engineers type rating on the B737-200 but it was the last big jet airliner that the CAA would issue a type rating on.
From the mid seventys the CAA would only allow large jet transports to be maintained under a BCAR 8-13 approval so as I said above it reqired an engineers licence (without type) and a company approval to certify the CRS.

So even if an engineer had a type rating on a B737-200 by the 80's he could not certify a CRS without a company approval for the type.

Microlights are not part of the EASA system and so should not be included in this thread.

[DFC]

Microlights are not part of the EASA system and so should not be included in this thread

They are CAA approved aircraft operated under the CAA oversight and do not need duplicate inspections.

I am not saying that is safe but the CAA does permit aircraft to fly without duplicate inspections. In one case (the Skyranger I mentioned) misrigging resulted in a fatal accident.

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

I will have to go deep into the books for the EASA duplicate inspection details and I don't have then here now as you won't be happy untill you get this chapter and verse.

But as an Engineer, you should know that without having to look it up should you not. If not then how can you say previously........

What I am tyring to make clear to DFC is EASA Part M only brings lots more paperwork and CAA charges, you don't get is any extra "hands on" maintainence and in the area of duplicate inspections of flying controls and other critical systems the EASA system is a real errosion of safety standards.

(My highlighting)

........When here you say that you do not know what the EASA requirement is.

Clearly a case of EASA bashing or simply trying to make excuses to those pilot that either don't know better or fail to question such claims.

Regards,

DFC

[A and C]

IF you are so sad that you can commit to memory all the EASA part M chapter and paragraph numbers so be it, As I said you won't be happy unless you have chapter & verse.

I am paid to have a broad understanding of the leagal side of maintainence and a much deeper understanding of the technical side but most important I have the nouse to know when to commit something to memory and when to go look for something in the manuals!

I for instance would not rigg a flying control system without the aircraft manual in front of me, dispite the fact that I might have done the job a number of times before, Its a safety thing!

So now you go tell the world that I can't can do my job without the books to tell me how to do it!!

[A and C]

You will find the full details in EASA part M M.A.402. (acording to CAA publications).......... I have not had time to check it myself as I have to spend all day changing the LAMS paperwork to LAMP.................. another unproductive day!!

And before you tell me I am behind the drag curve the implimentation date is 28 September 2008.

[DFC]

A and C,

OK I can see it clearly now.

You said;

and in the area of duplicate inspections of flying controls and other critical systems the EASA system is a real errosion of safety standards

Which can only be said if one has actually read or otherwise has knowledge of the requirements for duplicate inspections.

However, you now say;

I have not had time to check it myself

Which says that you have not seen and do not have knowledge of the requirements.

Thus you can not say that the requirements which you don't know are unsafe now can you?

Regards,

DFC

[A and C]

I have not actualy checked the LOCATON of the duplicate inspection requirements today.

I can assure you that I would not comment on the subject if I did not have some knowlage of the subject, the duplicate inspection or Independant inspection as EASA call it was initaly raised a t CAA part M meeting.

DFC so far all you have done deliberatly misinterpret all that I have writen and push your own out of date and misleading view of engineering practices and the cost of doing business. It is not posable to have a reasonable exchange with you because you are to busy trying to score points and push your own slanted agenda.

I suspect that you were one of the "old guard" of pilots who looked down on engineers as a lower form of life and resents having to pay to have your aircraft maintaned by "lowlife" who in your opinion are clearly ripping you off.

Well I have news for you, flying a jet airliner is not reason for you to be considered a skygod or the font of all aviation wisdom and you have clearly demonstrated this to a number of the people in this forum.

Oh............by the way flying a jet airliner can't be that hard............ a number of us engineer lowlife do it as a hobby to relax from "real" work!!

[ericferret]

Well DFC the subject of engineers holding approvals who had failed the licence was the subject of a crewroom conversation only a couple of days ago. A number of us remember it well and could name names if necessary

Approvals were dished out on the basis that X was a good egg. There were no formal examinations of any kind.

This was why the CAA changed the system to make it a requirement to hold a basic licence.

You appear to have a British Airways hat on with talk of apprenticeships. None of the engineers in question had been trained by the operator they were all "imports".

[ericferret]

On the subject of current company type approvals.

All that is now required under the current system for an engineer to be able to certify on type is, Basic licence, pass the type course, 2 weeks OJT and the company approval is a paper exercise.

[DFC]

Thanks for the insults A and C. Pleae note that I refrain from acting in kind and since you do not know me, you do not know how wrong you are top say;

"I suspect that you were one of the "old guard" of pilots who looked down on engineers as a lower form of life"

However, you are the one who said that the EASA proposals for duplicate inspections were dangerous but you do not know what they are.

Don't make claims that you can't back up simply to try and excuse inflated pricing or simple EASA bashing because it gets you no where.

Regards,

DFC

[A and C]

Clearly you don't read anything I said that you would require chapter and verse to shut you up and that I did not have that to hand at that moment NOT that I did not know what the EASA regulations are.

The basics of it is that a company can approve anyone that it thinks is fit to do a duplicate or (in EASA speak) independant inspection.

At the moment it is very unusual to find anyone who is not a licenced engineer who has duplicate inspection approval.

A duplicate inspection is a very hard thing to do not so much from a techincal point of veiw but from a human factors stance, the person comes to the inspection knowing that a licenced engineer has already inspected the job and is more likely to start with tha assumtion that all is correct.

If the person with the duplicate inspection approval is a non-licenced junior member of staff and the job has been done by the Chief engineer it is likely that he will feel uneasy about expressing doubts about the job, this is a lot less lightly to happen if a licenced engineer is doing the duplicate inspection as his status in the company will be a lot higher as well as having a lot more experience in engineering.

There is some psyco-babble to discribe this but I cant put my finger on the term right now................... Oh no ! DFC is about to demand that I go on a CRM refresher course!

[DFC]

OK A and C, since you don't know the requirements, let me explain them to you. They are very simple.

The first independent inspection is completed by a person qualified to complete the task and also qualified to certify the work. This person certifies the work.

The second independent inspection is completed by a competent person who does not need to hold certification privileges since they are not signing the maintenance release.

However, the mainrenance organisation has to have procedures to show that the person performing the second inspection has been trained and has gained experience.

It is not acceptable for the person signing the release (the first inspection) to show the person making the second inspection how to perform the inspection at the time it is completed.

Now to me, there is nothing new there. The second inspection must be completed by a previously trained and competent person who is familiar with the system.

Is that dangerous. If the answer is yes then the system currently used in the UK is dangerous and has been for many years.

Not much is changing. No excuse for a moan or a hike in prices for competent organisations that keep abreast of developments.

Regards,

DFC

[Malcom]

EASA Part M.Subpart F, G, I.
All in all, an eminently workable system for GA. 50 hour done in a morning - no problem.
Scenario A - Today,
Owner flys, updates his logs & finds he now needs a 50 hour.
- Goes to local M3 who do the 50 hour. Fix something broken if needed, cos they have data to hand.
--Goes flying again.
Scenario A costs to the owner are
: a 50 hour + defects.
Scenario B - EASA Part M. September 2008 (– maybe?)
Owner Flys. Tells CAMO who update his logs. CAMO finds he needs a 50 hour.
- CAMO tells owner he needs a 50 hour.
--CAMO tells Maintenance Organisation (MO) owner needs a 50 hour.
---Owner tells MO he needs a 50 hour.
----Owner arranges with MO to do 50 hour.
-----Owner tells CAMO 50 hour will be done.
------CAMO provides MO with data to do 50 hour.
--------MO does 50 hour.
---------MO tells owner something broken
----------MO tells CAMO something broken
-----------Owner tells MO to fix something.
------------Owner tells CAMO something will be fixed.
-------------CAMO provides Data to fix something.
--------------MO tells owner something fixed.
---------------MO tells CAMO something fixed.
----------------CAMO tells owner something fixed.
-----------------MO tells CAMO plane ready
------------------MO tells Owner plane ready.
-------------------CAMO vets MO stuff.
--------------------MO tells owner to go flying.
---------------------CAMO tells owner to go flying.
Owner too poor / tired / exasperated / to go flying now. Gone sailing / kiting / something else instead.
Scenario B costs to the owner are
: a 50 hour check + defects
: MO maintenance contract involving provision of staff, facilities etc at a time that suits both parties.
: CAMO Contract, provision of qualified staff, approved data etc at a time that suits both parties, time spent auditing CAMO.
: CAMO time spent passing additional data to MO for defect rectification, on a prompt basis
: downtime while all this extra stuff is going on
: + I’m sure there’s more
Please explain how this makes flying safer and makes the hobby cost effective.
The owner remains responsible in both cases, so no change in responsibilities.
Then please also explain how this makes flying safer for aircraft to which EASA has no remit?
Sympathising wholeheartedly with A & C, I take issue with DFC and his rather rosy view of EASA.
DFC wrote
"If you simply want to continue to provide maintenance then there has not
been any significant increase in costs. If you want to provide extra services then there
will of course be extra costs involved in gaining the extra approvals".
---The above scenarios possibly demonstrate that no extra services are provided, at increased cost – the aeroplane flies, has its 50 hour, goes flying again. The same service is accomplished via yet another management level - the CAMO.
DFC wrote
"Did you just discover EASA part M etc last month. I seem to remember it being common knowledge (if not in final form) for almost a decade."
Well, you said it - not in final form.
Exactly what system should be set up when there is nothing to base the set up on?
Do we set up with a CAMO, or will we not need a CAMO??
Will the controlled environment remain as proposed or not be required for planes below 2000 kg??
MDM032 – not very helpful yet.
As you are in Euroland, you are probably unaware of the UKland's current state of not knowing whats going on at the moment. We find ourselves shortly having to be in compliance with something not finalised yet, and all done before by 28-9-08.
DFC wrote:
"So sit in your office and put up your prices.....remember that the cost of approval represents very few hours at UK engineer rates....what do you do with the income from all the other hours income? Don't complain when other maintenance organisations get your work."
Who is this bloke? Put up my prices - other maintenance organisations will get my work.
He clearly doesn’t live or work in the UK. The other Income now seems to pay Independent Auditors, time spent self auditing, redoing Maintenance programmes in whatever the latest fashion is, hunting for basic information on the CAA & EASA websites, reviewing the lasted Ads, SBs, MMs, IPC, Screwfix catalog, incorporating mandatory modifications in the UK which are seemingly not required elsewhere in the EU, removing these mods when the plane is sold back to the USA, getting LAEs converted from BCAR to Part 66 with types the CAA don’t seem to know about (eg metal planes made of wood), drafting repairs & mods for approval by someone in Euroland, progress chasing such things, ………………………and eating.
Forgot about actually doing some maintenance work to generate said income – cant believe I did that!
I know what to do – I’ll put up my price to £ 50/hr, then Mr Eastern European wont get a look-in at his £ 15/hr plus European grants and other stuff. Better still I’ll move to China, you can fly there and have your 50 hour at £5/hour. At that rate I wouldn’t dare complain if my work went elsewhere!
DFC wrote|:
"I can pay a UK engineer £60 per hour or I can pay a French one EUR60 for the same product i.e. EASA certified maintenance. That is a big difference when it comes to certain scheduled maintenance."
Earlier, you suggested putting up prices. Why recomend I put up my prices when I'm already more expensive? Is this part of a cunning plan?
Anyway, I'm off to Cuckoo-Land to get £60/hour working on PA28s - I need directions as my map shows (mostly) the real world. Could I borrow your copy please.
If I were to take a plane from the UK to France for maintenance, the saving between £60 and 60 euro in France might just be eaten away with transit fuel and en-route landing fees and hotel fees when stuck abroad due weather and time off work to do the trip or paying someone to do this for you or getting back when you cant fix something for a few days or weeks or months awaiting spares or EASA repair approval.
DFC wrote|:
"There is absolutely no reason for club training aircraft to be certified for public transport.A point hopefully EASA will pick up on."
Read the MDM032 update
(The 2 monthly update of the July one has just been issued by EASA this month - December)
Interesting comments about commercial activities contained therein!
Club training for free - yes please.
DFC wrote|:
"If the aircraft can not go to the maintenance organisation then the maintenance organisation can come to the aircraft."
Interesting thought. I was led to believe the idea was to remove the back of the car engineer from the system by having approved sites & facilities & staff.
How does that stand with MA402 and a PA28 in the middle of a cold, wet & windy airfield? (Would only happen in the UK only, of course)
DFC wrote about costs:
"I know one club in the South of the UK who lease hangar space to a local UK maintenance organisation that then charges thema fortune for crap maintenence. The club could take control of it's own maintenance and that of many local owners and do a far better job of it than at present."
That club probably don’t want to, or can’t afford to take on the cost of full time engineering staff, fund the approvals required and have no work. Crap weather= no flying+ staff to pay+bill to pay= financial disaster. (UK only, of course).
Is saying something about crap maintenance a wise thing to say in these litigious times?
DFC wrote about Duplicate Inspections:
"If the CAA thought that there was such a requirement then it would apply to among other fixed wing categories as microlights including the skyranger that ended up in a tragic accident some time back doe to misrigged controls."
The CAA oversees the BMAA. The BMAA does have such a requirement.
DFC wrote about Duplicate Inspections:
“But as an Engineer, you should know that without having to look it up should you not. If not then how can you say previously........”
Under EASA, just knowing something is totally unacceptable - you must always be in a position where you are able to refer to basic and detailed Information. (MA401).
" please explain the EASA duplicate inspection process and wht exactly is dangerous."
as explained by A&C, using a second licensed engineer is superior to using anyone deemed competent by a company who may, if they so choose, use the tea-boy for the task. I would agree use of the Teaboy for Duplicate Inspections is unacceptable and potentially dangerous.
DFC wrote about Engine lives:
“Of course, while the CAA may think otherwise, EASA does not think that if Lycoming or Continental say that the engine they designed, built and had certified is good for 2000 hours or 12 years whichever is first and then requires an overhaul..........then one can still call the engine a certified engine with 15 years since overhaul.
I would love to have an aviation authority like that.”
Well, we had that Aviation Authority until recently. Airworthiness Notice 35 / GR24 worked well until the calendar TBO RECOMMENDATION was too rigidly enforced, unlike in the relevant Service Bulletins which give some leeway. Under this system I have happily & confidently flown 3500/4000 hour Lycomings – I thought nicer than newer ones, and were much better looked after under the extension criteria.
Anyway, got to get redoing LAMS as LAMP for some of the planes, but not all of them, or shall I leave it as it might change to manufacturers schedules in January 2008 or September 2008??
Just got a LAMP addressed to the owner of an Annex II type?
Does anybody know what’s going on?? Perhaps its all just a giant EASA HF test just to see how well we can cope with being dangled by the b*******s??

[A and C]

DFC You seem to have avoided the issue one more time and are just showing how out of date you are with the CAA system. unfortunatly I can't write it in large multi-coloured wax crayon but I will try to make it clear.

Under the CAA system almost all duplicate inspections are done by licenced eneineers. EASA reqires the maintenance company to use a competent person

This is a change as under the CAA system a duplicate inspection is a CRS item.

[SIZE="2"]The CAA did go down that road for a short time but the systen was being abused so stopped it in the mid 70's[/SIZE

EASA is about to repeat a thirty year old mistake and you clearly are to blinded by your own out of date view to see that this is an errosion of standards

[A and C]

Thank you for that post it clearly sums up the situation and hopfully will put that DFC half wit back in his box.

I rather lost all respect fo the guy's point of view and the tunnel vision has decended following a day on front of the computor writing the individual "customised" LAMP workpacks that the CAA are demanding for each aircraft we look after............... another day of unprodutive pen pushing!

[DFC]

A and C,

You just do not get it.

If a person is competent, then that is it.

There are quite a few licensed engineers that I would not call competent.
I like the way you are inventing work for yourself.

Perhaps it is the CAA's fault for asking you to produce things that toy should have had all along.

---------

Malcolm,

You need to read the requirements again. Even those CAT operators who operate several fleets do not have to go through all that.

The BMAA does not require duplicate inspections. It does recomend them in certain cases.

If I want to I can take the wing off a microlight and dismantle the wing, put it on a trailer, travel to a field in the middle of nowhere reassemble the wing and put the wing back on the aircraft then go flying. I can do that solo with no contact with any other person and the permit to fly remains valid.

Regards,

DFC

[A and C]

DFC I am constantly amazed the dispite at least two people who are directly involved in trying to make this EASA part M fiasco work you insist that you know better.

I can't understand why you keep banging on abou microlights these low energy powerd kites have nothing to do with the EASA part M system.

The bottom line is the EASA part M is going to cost a lot of money to introduce and at best will do nothing to improve safety.

The result is that I expect by September 2008 a number of engineering busnesses with shut cutting the supply of maintenance, aircraft owners will find it harder to find maintenance and the price will increase purly because of the laws of supply and demand.

The only people to loose out will be the owners of aircraft who will have to pay up or stop flying.

But to look on the bright side at lease those of us who survive the dark days to come will be able to charge more for the services that we provide and recover some of the time and money spent introducing EASA part M.

DFC I look forward to one the day when EASA part M hits you very hard in the cheque book, only then will it dawn on you that Malcom and myself were right all along.

[Fuji Abound]

I have been following this debate with interest.

DFC

Without mention of micro lights can you explain in concise terms what advantages in either safety or cost part M will bring?

A and C

What ever happened to the regulatory impact assessment with regard to these changes?

[Malcom]

DFC -
I'm sorry, but you are still missing the point being made.

A EASA Duplicate inspection Authorisation is not issued by a Competent Authority, but by a company. There are many pressures to get things done quickly, cheaply and with a minimum of fuss - this could potentially lead to the potentially less scrupulous operator potentially issuing an authorisation to a potentially unsuitable person.

Using a type rated Licensed Engineer, there is potentially a greater degree of confidence.
Granted some not potentially as good as others. Just as there are potentially poor licensed engineers there are potentially poor companies too, even perhaps some working for those companies.

Since only detailed information will suffice, if you take the trouble to read the BMAA Airworthiness Guide issue 7 page 21 available on the internet, you will find detailed guidance on the use of Duplicate Inspections. I would consider removing wings and things a change to primary strucutre, but I must doff my hat to you and your superioity in not needing to worry about such trivia, but this is digressing away from Part M again.

As for the CAMO, the requirements do not say how things are done, but what must be done, and by whom.
Owner owns plane,pays for everything & takes responsibility, MO Maintains plane as instructed by owner & CAMO, & CAMO controls and manages records, maintenance program maintenance data, & mandatory requirements for the plane.

I have presented the logical extreme extension to the scheme as currently presented. As I have perhaps misinterpreted the Regulations, please would you be kind enough to offer your maintenance scenario for say a PA28, covering contracts, provision and sharing of data / spares / liason etc & the authorisation of non scheduled maintenance between an owner and a seperate MO and a seperate CAMO, and remain in a controled environment?

It could well save me a great deal of aggravation for which I would be eternally grateful.



Fuji - take a peek at the EASA site, MDM032 update. Doesn't say a lot though.


Best regards
Malcom

[ericferret]

On the cost issue this might be of interest 3 years ago charges purely for paperwork and related costs for a 3 year c of a £375.

Under the new scheme for a one year c of a £450.

[DFC]

Fuji,

It will not have any effect on my maintenance. As owner, I am responsible for ensuring the continued airworthiness of the aircraft. That will not change. I will manage the maintenance to meet the private requirements and will contract the maintenance organisation to carry out the required maintenance.

This is the private pilot forum and we are talking about private aircraft on private level C of A's / maintenance reviews.

We already have the LAMS which the CAA (the appropriate authority) will approve or you can use the Cessna Care programme (or similar) if you like and have that approved.

As owner, I get all the service bulletins and letters as well as the AD's which you can check on the FAA and EASA and NAA websites also.

If my aircraft needs a 100 hour check, I will book it in and have it done. No big change there.

If my aircraft was on an AOC or otherwise commercial flying (note according to EASA club flying, group flying and flight training are not public transport) and there is no limit on the number of members in a group.

----------

A and C,

One of the reasons why you have so much paperwork to do is because you have to tell how you intend for example to establish and ensure the competence of all personnel involved in each area.

You should be aware that the authority will no longer check that a licensed engineer has recent experience before renewing their licence. It is up to the organisation providing the maintenance to ensure that the certifying staff have the appropriate experience and are current.

The authority will perform spot checks but even for the licernsed certifying staff, it is up to the organisation and not the authority to confirm that everything is done as it should.

You try telling a NAA (or me as a customer) in your manual that you will use the tea boy for a duplicate inspection and you a) will not get approval and b) will not get any business from me.

OK so people can write one thing in a manual and do something else in practice. That has been going on in the UK for years with unlicensed people doing maintenance that is later signed for by a licensed engineer. The amount of checking being up to how risk adverse the engineer is.

---------

Malcolm,

The only time the BMAA require a duplicate inspection is when doing a mod.

To have it any other way, one could not unfurl the wing, rig and attach it to the trike, fit the training bars and then depart on a paid for trial lesson from the farmer's field behind the customer's house.

Regards,

DFC

[ericferret]

As a matter of fact the CAA won't approve LAMS they will approve LAMP (LIGHT AIRCRAFT MAINTENCE PROGRAM) replacing LAMS. Pity they have told hardly anybody about it.

Its supposed to be detailed in a Letter to operators, but as they haven't distributed it properly. Hardly anyone knows whats going on.

As to the famous NAA websites the GSAC (French) site has been out for over a week.
As I was attempting to renew the C of A on a French aircraft at the time it wasn't a lot of good. Mind you I had some hand written notes taken previously so I used those.

[A and C]

Sorry I mis understood you ! I had not realsed that you are a EASA part M approved CAMO.

As this is the case you can oversee the maintenance work and tell the company working on your aircraft what work is required.

Have you got this EASA approval just for your aircraft or do you sub-contract to other aircraft owners as well?

I ask because the work required for you to get the approval is rather expensive just to keep just one aircraft inside the controled enviroment.

[DFC]

Why do I need approval to be responsible for the maintenence of my sub 2730Kg private aircraft?

Why do I need approval to enter into a contract with an appropriate maintenance organisation (no requirement to be Part 145) to have the maintenance that I ask it to do completed?

EASA is very clear it is the owner's/ operator's responsibility.......even if they wish to farm out the tasks so why let some idiot get you in poo by missing something that causes your C of A to be invalid.

Regards,

DFC

[Malcom]

DFC, hopefully correcting some inexactitudes, assuming you have an EASA type aircraft:
As Owner you are allowed to manage your own maintenance, if you consider yourself suitably capable of doing so. That is a matter for you, your conscience and the Board of Enquiry in the event. You dont need approval to be responsible for maintenance of your plane - you ARE responsible, regardless of who does what.
You need an awful lot more data than just ADs & SBs to do it though. You cannot manage maintenance if you dont have a current maintenance manual to tell you what & how & when & why to do stuff? What about the IPC, SIDs, SRM?? What about data for the engine & propeller & the equipment fitted & the mods installed? How do you technically asses the data and incorporate it into your maintenance program? A working knowledge of the relevent regulations? In so avoiding the CAMO you are outside the infamous Controlled Environment.
But, by managing yourself, you still cannot avoid using a CAMO, and each year you will need a FULL Airworthiness Review performed byone of them.
(unless you deal directly with the NAA, who have said up front that they will be v. expensive so as to to drive this function to industry)
As an occaisional CAMO user, you will find yourself way down a CAMOs list of priorities. Those with contracts will get prioity, AND will only need their Airworthiness Review once in every 3 years. Either way, the owner will pay more for whats already being done.
You dont need approval to enter into a maintenance contract, you either do - or dont. The choice is yours entirely, but maintenance outside of approved shops again places you outside the controlled environment.
LAMS will not be acceptable for EASA types. You will need LAMP, or your own pre-approved program.
(A & C - Heads-up from the two glass towers - LAMP to be ammended shortly so dont go too mad!!!!!!!!!!!!!!)
Flying Groups used to be limited to 20 people. I must admit I do not know if this is still the case in EASAland .
Public Transport is an ANO definition. It does not have any meaning in EASA terminology, Commercial Air Transport (CAT) is what you meant. However, currently you still abide by ANO Public Transport requiremments if needs be.
MDM 032 update says money changing hands is a commercial activity. How long before paid for Flight training is seen as such and then deemed to be CAT?
So , you could do circuits & local flying non-CAT (Curiously A to A flights are not deemed CAT) but your XC A to B flight will be CAT.
CAT requires Part 145 Maintenance, thus Flying schools will need CAT status and Part 145 maintenance to provide a full learning experience..
Even I would not tell the Authority the teaboy does duplicate inspections. But, an unscruplous company could, potentially, assess a certain Mr T. Boy as
competent to perform the task, and attest to that with a load of old tosh in his authorisation file. Again, a Licence would attest to some knowledge for the file.
The BMAA say Duplicate Inspections should be made on all changes to primary structure or powerplant (including regular maintenance).
If as you suggested earlier you were removing wings surely then this is a change to primary structure?.
If as you are now suggesting the plane is designed to be easily de-rigged & re-rigged then no duplicate would be nesessary, but I would say inadvisable - the RF5 accident at North Weald a very tragic case in point. (Yes i know a RF5 is not a microlight and probably a non EASA type, but the principle is the same)
Best Regards
Malcom

[DFC]

I will just simply repeat what I have said at the start - it will not make any difference to me.

The responsibilities of the private owner with regard to maintenance have not changed. The only ones who will suddenly find that they can't cope with for example having to get a maintenance manual and/or maintenance programme are those who have not been meeting their responsibilities all along.

Similarly the engineering organisations who struggle are those who were in the same boat.

Perhaps you simply need to either wait until the UK gets it's act together or go abroad and find out how the rest of Europe is proceeding with this no real change other than in the rule book.

The best thing to do is to come back in 3 years and I expect that just like Y2K and other great money spinners for those that were willing to take the money from the fools that did not know better, those who do know better will simply say....no change here.

Regards,

DFC

[A and C]

Malcom thanks for the tip about LAMP but i had to move quickly as I have two aircraft on annual just after new year.


As for DFC well all I can say is Head, Sand, In !!

[DFC]

Not at all. Perhaps the opposite even.

My aircraft will not suddenly become unairworthy when it's C of A becomes non-expiring and it is fully under EASA.

If I was able to ensure the continued airworthiness for the past (can't remember but a lot) years what in terms of information available etc has changed to make it harder for me to complete what is my responsibility, has been my responsibility and will in the future (regardless if I pay someone else or not) continue to be my responsibility.

These days, obtaining information is far easier than in the past and pre-internet times.

Perhaps owner's in the UK did not fulfill their responsibilities in the past and simply expected (relied on) the maintenance organisation to do everything.

However, for the owner that can check the required info and make a contract with a maintenance organisation there is no need to pay either that organisation or a third organisation to do it for them.

[DFC]

The latest GASIL has some info on this.

When asked "Should we pay for continued airworthiness management?", the CAA says "it is usually done better when done professionally. So even the CAA says that there will still be businesses out there who will not do it properly and who is responsible when they don't do it right............the owner.

I must check on this point from Malcolm that the CAA will set it's prices at such alevel as to force certain optional requirements on private owners. I am sure that EASA would have something to say about the UK using such a method to limit certain parts of the Law.

Regards,

DFC

[Malcom]

DFC

When you've had your non-expiring EASA C of A for 12 months, please explain how you will have it revalidated - without there being any difference to you.

You are quite certain you operate an EASA type, aren't you??

Best Regards

Malcom


A+C Did you realise the ARC was optional, as alluded to by DFC?

[ericferret]

I find myself in the same position as DFC in many ways.

I maintain my own documentation, I have all the relevant manuals and I am a type rated licensed engineer.

Why should I have to pay someone to do something I have done for the last 14 years without any major problems?

I have yet to see anyone issue a scale of charges for my aircraft and I am waiting to see just what this paper chase is going to cost in reality.

The effort required to maintain it's paperwork with an aircraft only flying 100 hours a year is minimal. There are currently only 9 airframe AD's and only one is repetitive for my aircraft.

I don't mind paying if I am going to get some value for my money.

If this gets really expensive I will apply for the approval myself and contact every owner of the type in the country and do it for cost. It clearly makes more sense to do it on a type basis than have one organisation holding maintenance data for 30 types and charging accordingly!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!

How is this wonderfull Part M working in practice.

Well one organisation I know of, is as we speak changing an engine because the Part M failed to tell them that it was timex and they have had another aircraft grounded for over a week because the Part M failed to complete the C of A paperwork in time.

Good job its in house otherwise the legal eagles would be making a killing already!!!!!!!!!!

[Malcom]

DFC

"""I must check on this point from Malcolm that the CAA will set it's prices at such alevel as to force certain optional requirements on private owners. """

That is not what I said. Please re-read,

"But, by managing yourself, you still cannot avoid using a CAMO, and each year you will need a FULL Airworthiness Review performed byone of them.
(unless you deal directly with the NAA, who have said up front that they will be v. expensive so as to to drive this function to industry)"

Best Regards
Malcom

[ericferret]

I have heard from a source not related to this forum that the CAA's intention is to make it prohibitively expensive to use the alternative route.

Given that the CAA has little in the way of direct type expertise these days, I can't imagine they would inspect any aircraft themselves. They would probably subcontract the work to a CAMO!!!!!!!!!!!!!!!!!!!!!!!!

[DFC]

Why should I have to pay someone to do something I have done for the last 14 years without any major problems?

You don't despite what some organisations would have you believe.

The problem is that there is nothing new for someone like you but those seeking to make some money from the confusion would have you believe that you need to be superhuman to keep the paperwork and maintenance up to date so that there are no issues when the annual is done and the ARC completed.

I like your idea for the single type approval. To manage the maintenance for others you would not need much more than what you already have.

However, on the engine out of time and the late paperwork, nothing new there either. Happens to lots of people under the old system also.

Like I said, just like the JAR-FCL, I will in 3 years time look back and say - this has not affected my operation at all despite all the hipe. Perhaps even like JAR-FCL it will make it cheaper for training organisations to operate and more profitable also than under the old system.

Regards,

DFC

[ericferret]

I wish I had your confidence DFC.

You are right about the eng change/c of a mistakes happening previously. However this is specifically what Part M is designed to avoid so there is little improvement although huge amounts of money have been expended.

The cost of maintaining technical libraries can be huge. Single type or single manufacturer would be far more sensible. Costs would be reduced to a minimum.

The worst case scenario would be a maintenance organisation with its own Part G looking after multiple types and trying to recover it's costs.

I seem to remeber that the technical documentation for the Arriel engine alone ran to several thousand pound. So unless the owner can provide the books this cost has to recovered.

I feel that eventually this system will settle down, however I believe I already see them moving the goal posts yet again.!!!!!!!!!!!!!!!!!!

[A and C]

DFC and I agree on something at last !

Why should he pay someone to do what he has been doing for the last 14 years?

The answer is becuse you are going to be forced down the EASA road of having your aircraft maintained in a "controled enviroment" simply becuse the charges for going down the other route will be too high.

DFC the big question for you is how much money you are going to put into the EASA money pit? Do you get the CAA in each year and retain your independant position and pay the CAA's fees or do you get a part M to cover the work and get an ARC?

I can see that what I have been saying about this whole part M system is slowly dawning apon you, it is a pointless excersise in paperwork that add's nothing to flight safety and will increase costs to the aircraft owner. It can't be any other way the maintenance companys have to cover the cost of the extra paperwork or they will go out of business.

You of course can do the paperwork yourself but what of the CAA fees?

The bottom line is that you as an aircraft owner are between a rock and a hard place and it is not of the maintenance companys doing.

[ericferret]

One long standing G.A engineer has told me that he expects to see an increaced number of aircraft for sale. It will be a result of increaced costs and people just not wanting the hassle.

Our aircraft has been grounded for the last 2 months largely due to missing paperwork.
That is the c of a paperwork dissapeared twice.

Who was to blame CAA, Post Office, Engineering, who knows.

I know we have an expensive piece of aluminium that cant be flown.
I can put up with the cost, I can put up with the hassle, but both?

[G-KEST]

Having ploughed my way though this thread I am even more convinced that Part M is a potential disaster for General Aviation in terms of certificated light aircraft not in Annex II.

Malcom's intial post was a real breath of fresh air that brought the whole Part M house of cards bureaucracy into perspective on a grotty Christmas Eve here at home with a lousy cold.

As far as I know we still await the CRD on the responses made to Part M last autumn. The grapevine seemed to indicate a huge weight of informed opinion that the watering down of Part 145 has proved an utter waste of time and totally inappropriate for general aviation type maintenance. Furthermore that any implementation date should be deferred way beyond September 2008.

Thank the Lord our aircraft is operated on the basis of a PFA administered permit to fly with all the huge benefits in cost that implies in terms of continued maintenance.

Cheers,

Reaper 69
:mad::ugh::mad:

[TheOddOne]

a grotty Christmas Eve here at home with a lousy cold.



Sorry to hear that mate. Get well soon, see you at the AGM in Jan?

I got a letter from the CAA yesterday about our a/c and the change to LAMP. I'm considering moving the date of the Annual from next July (silly time of year for an Annual) to this Feb coming and get the pain out of the way.

Cheers,

TheOddOne

[DFC]

Perhaps I am missing something here but;

The owner has been responsible until not for ensuring that the paperwork was up to date, the mods and AD's, service letters and so forth were incorporated as required and that the required maintenance was completed when it was due not to mention that lifed components were changed at the end of their life, not after.

Many countries were very clear in this respect and required owners to be registered with the manufacturer for updates and to have or have the required access to the required manuals which had to be up to date etc.

When it came to the C of A renewal, the maintenance organisation and the owner completed the required paperwork exercise that renewing the C of A mostly was and hey presto the C of A was renewed.

Do we now have lots of owners who did not do the required paperwork, did not have the required information and simply blindly relied on others in the aviation world to look after them?

Do we also then have maintenance organisations who factored a certain amount of paperwork time into the C of A renewal costs who are now saying that they will now charge extra for the same paperwork exercie?

This EASA law is for Harmonisation if in order to harmonise with the standard you need to do lots of extra work then ask yourself why could this be if you were at the required standard?

I hope plenty of UK owners sell their aircraft. I would offer 50% of the value because it is becoming clear that there are lots of owners who did not maintain their paperwork etc to the required standard and if they are selling to avoid the cost, I am going to factor that into any offer.

Like I said, wait 3 to 5 years and see what difference there really is. Like JAR-FCL the answer will be none for bad but few for good.

Regards,

DFC

[robin]

DFC
Pardon my ignorance on this, but I think you are missing one of the key elements of the change.
We already keep the logbooks, arrange for maintenance to be done as and when and have an LAE signing off our 50 hour checks. Our annuals are donne by a reputable company a little away from our home base, where there is no maintenance facility.
As far as I am aware, the CAMO is the only organisation able to raise the paperwork to recommend the issue of the CofA and extend an ARC - you cannot do this yourself, unless you register, at some cost, with EASA.
You have 2 choices from next year - unless you operate a Permit or Annexe II aircraft. You can take the 'Controlled' route where you sign up with a CAMO and agree with them the limits of your maintenance freedom, or the 'Uncontrolled' route, where you pick and choose.
The CAA have already set the pricing regime to discourage the 'Uncontrolled Option' by making it considerably more expensive.
The problem we are already seeing is that perfectly acceptable maintenance organisations are shutting up shop. This reduces choice and puts us into the hands of cartels. In my area, 2 of the most popular organisations are closing their doors, and we will have to try to register with a very unpopular and overly-expensive EASA approved organisation instead - if, in fact they want to take us on, which is questionable.
As most of my friends left that facility because of their pricing and poor customer service, the thought of being forced back into their hands by EASA is one we find hard to bear.
As I said earlier, although not licenced engineers, we have, under supervision, doen much of our own work, but the plan, as stands will make life a lot more tricky after our next annual.

[Malcom]

Glad to see that the penny has started to drop, hopefully it will land before 28 September 2008!


Happy Xmas

Malcom

[DFC]

The CAA have already set the pricing regime to discourage the 'Uncontrolled Option' by making it considerably more expensive.

and then you think that;

being forced back into their hands by EASA is one we find hard to bear.

Is it not your own local CAA that is forcing certain options on those that do not know better.

Maintenance organisations that were up to scratch would have no problem with the new scheme but those old ones who either can't be bothered or are simply not capable of meting the basic international standards shut up shop. If that clears out a few cowboys then good.

One simply is left wondersing how can such supposed "capable" organisations have such trobble catching up with the rest of the world.

Now back to the paperwork. If your maintenance company completed the Annual and required paperwork exercise to renew your C of A previously and say that cost was X including work, parts, expendibles and paperwork then provided that they are capable of getting the required approvals then they can continue to complete your Annual and C of A paperwork.......then what has changed to justify an increase in costs......unless they were not doing it properly before!

Remember also that some European countries had annual C of A's for PT flights and 2 yearly for private.

Would you prefer to stick with the old system and have a C of A every year?..........would that be cheaper?

Regards,

DFC

[A and C]

From your comments it would seem that you take the stance that the UK aircraft maintenance industry is providing poor service and is not keeping up with the new EASA requirements.

Quote:-
This EASA law is for Harmonisation if in order to harmonise with the standard you need to do lots of extra work then ask yourself why could this be if you were at the required standard?

The fact is that UK GA as a whole is the safest in europe and the number of accidents due to maintenance errors is almost nill.

The evidence is that UK based mantenance companys on the whole do a good job, yes there are one or two places that should not be in business but this is the same in any industry.

The problems with EASA part M are the extra paperwork that is required to do the job and the extra expence of the approvals required to do the work. The amount of maintenance "hands on" work on your aircraft won't change under EASA. What will change is the amount of paperwork that is required and the CAA charges for doing this paperwork.

You seem to think that this harmonisation is the UK stepping into line with Europe. It is not. It is an entirely new system for all Europe but as we know the Europeans are very good at sidestepping regulations that they don't like and most of the European states aviation authourity's are not required to recover costs from the industry.

So wile the CAA is diligently enforcing Part M on the UK and charging the "going rate" for it I fully expect the French to be ignoring the regulations and getting the services of the NAA paid for by the state.

Level european playing field? .......................I think not!

[A and C]

As we were both posting messages at the same time perhaps I can give you an example of the extra paperwork that EASA is creating.

Under the UK system if you had lets say a DME fitted to your aircraft the avionic company would raise the MOD paperwork, send it to the CAA and they would decide if it was a Major or Minor modification.

In the case of a DME it would be a Minor MOD the charge would be in the order of £50, the DME would be fitted and that would be the end of it.
Each year the DME would be checked at the Annual check under the LAMS system.

The modification application now has to go to EASA and they then usualy send it to the CAA for implimentation, they then work in much the same way as before but with another layer of paperwork.

Now under EASA the aviomic company has to produce a document called Instructions for continued airworthiness This document runns to about seven pages for a simple DME instalation.

All this document tells you is what any avionic engineer should know and what is already mandated in LAMS or LAMP.

It is a pointless excercise but it writing this for each individual piece of extra equipment in an aircraft adds to the cost to the owner.

[IO540]

For what GASIL is worth (not a lot usually), there is a mention on page 6/7 on Part M etc

http://www.caa.co.uk/docs/33/srg_gad_gasil4of2007.pdf

[DFC]

A and C,

Much of your complaint seems to be with the CAA. So why don't you title the thred CAA money pit...........because as you say, they are the ones charging the large sums of money and making a profit.

The instructions for continued airworthiness has been arround for decades. If you never came across it before then it says alot about the UK system.

Cessna when they used cessna branded radios decades ago inlcuded the info in the maintenance manuals as a matter of course.

If you wanted to put in a King set then you had to not only modify the flight manual but of course also the maintenance information etc etc.

Aircraft move round a bit and your aircraft with the new DME could be in Italy next week. No LAMS/P there and if you have not produced the required info for the DME then there is a hole in the maintenance information.

Once again I say...........nothing new there.

Regards,

DFC

[A and C]

Yes you are correct information for continued airworthiness has always been avalable and it was expected that if any referance was required the engineer would just consult the manufactures manuals.

What is new is that for each aircraft the (in this case avionic) installer has to write for each individual aircraft and bit of kit installed a set of instructions to tell the engineers to look in the manufactures manuals.

If a maintenance company can't work out that they need a King manual to maintain and check a King DME they should not be in business. meanwile owners like you are going to have to pay to have this unnessesary paperwork produced.

As you say there is not a lot new in aircraft maintenance.................... Except the reams of paperwork that are required by EASA.

[DFC]

The paperwork is necessary, and always has been necessary.

Like I said Cessna were doing ti back in the 50's. Don't know of your experience reaches back that far but you can still find the manuals.

It is more than simply the box maintenance. It is also about the instalation maintenance/ rectification............and as you know it can be different on every aircraft.

I would not touch an aircraft with a box of tricks fitted without all the required paperwork.

Now I can see why you say that many UK aircraft have lots of missing paperwork and why aircraft elsewhere do not have the same problem.

Again I say...........nothing new for me in all this. If engineering organisations are going to charge more for doing what they were doing (or should have been doing) all along then I can rightly claim that they are profiteering from the confusion surrounding the issue and in many cases, addid to that confusion probably for their own benifit.

The thred should be entitled CAA Money Pit.

Then you could indeed have a debate.

Regards,

DFC

[A and C]

I have just checked the maintenance manuals from three manufactures Piper, Robin and Cessna all have no more detail that contained in LAMS/LAMP.

The reqirement in each of these manuals is to check at intervals the avionic equipment to IAW the avionic manufactures requirments.

So why all of a sudden do we for each radio in each aircraft have to publish a 7 page document to tell us what to do in detail when it is contained in other manuals and referance to this data is contained in the manufactures maintenance program & LAMP/ LAMS?

DFC I don't think that you have yet seen a C.A.I. document and are in for a big shock at the next C of A renewal!

[camlobe]

I have been watching this thread for some time with great interest.

At a professional level, it pleases me to see that fellow Engineers are up to speed with the impending requirements as proposed.

At a personal level, it disheartens me as an owner/pilot to see how painful it will become to retain my aircraft on the G reg.

I am in the fortunate(?) position to have my own Part 145. However, this won't prevent the needless expenditure EASA are enforcing through the UK CAA. Nor will it ease the increase in totally wasteful paperwork. Neither of these two issues will make my own aircraft any safer. Continual in-depth inspections by experienced Engineers, both licenced and unlicenced, are the only way to catch something minor before it becomes more dramatic.

Unfortunately, the experienced guys are going to be busy dealing with more non-aircraft paper-shuffling tasks. Work the rest out for yourself. Hence the continual comment about this burden of paperwork not contributing positively in any way to aviation safety.

When I cornered my CAA surveyor earlier this year, I got him to give me the 'horses mouth' view regarding SubPart G CAMO's and ARC's. Sure enough, the CAA want three licenced guys doing what I have been doing for years. 'Who pays' says I. 'The customer will have to' says the CAA. I note that the CAA website makes no mention of this.

Although the CAA are carrying out the initial ARC issues, my surveyor stated that, with regard to the CAA carrying out ARC renewals, the Authority would make the situation financially untenable for the customer. This would assist forcing owners to stick with their present maintenance organisation so they remained in a 'controlled enviornment' even if the owner wasn't entirely comfortable with that organisation.
Therefore, moving from one organisation to another will be prohibitivly expensive, even if it is for the owners piece of mind, or worse still, to ensure the owner receives the quality of maintenance they rightly deserve. This expense is because the CAA will have to renew the ARC as the aircraft won't have been within a controlled enviornment for the previous twelve months. This is also the scenario if the owners present maintenance organisation call it a day.
It was also hinted that some retiring CAA surveyors were considering setting themselves up as CAMO's.

Add this latest grief to the same old line from the CAA 'we can't take anything away from you' which we Engineers know through experience, is codswallop. Remember when we had the ability to certify pressurised and unpressurised aircraft above 5700 Kg on your licence; issue Fitness for Flight to everything covered by your licence. This was only a couple of years ago.
Withen this short passage of time, the experienced Licenced Aircraft Maintenance Engineer is being fadded out to be replaced by an administrator with the new title Aircraft Maintenance Licence holder. Don't believe me? Ask your Engineer to show you his CAA and EASA licences. The old BCAR licence is an Aircraft Maintenance Engineers Licence. The new Part 66 licence is an Aircraft Maintenance Licence. We are slowly losing our identity, having our responsibilities redefined, and having our authorised capabilities reduced. Has any of this increased safety? I have my own views.

Acting as responsibly as possible, I have endevoured to keep my customers abreast of impending changes, attempting to be impartial without painting a black picture or overstating any issues. None of my customers have found fault with my explanations. They have, however, voiced considerable dismay with the CAA and EASA.

The two most common questions asked directly to me over the last year have not been 'how much to upgrade my avionics' or 'how much to replace my engine'. Instead, they have been 'how do I put my aircraft on the 'N' reg', or, 'I am going the PFA (LAA) route, what can I sell my aircraft for?'. There is also the growing realisation that G reg aircraft values may well dip in the near future as the market becomes potentially flooded with unwanted, overly-expensive to maintain aircraft.

As an A&P and PFA (LAA) inspector, it looks like I am going to be busy this coming year. And the best part? Very limited, if any, EASA input and paperwork. Might even be worth my while not renewing my Part 145 Approval. Hmm.

I posted a question on Pprune earlier. How many sub-5700Kg Part 145's have SubPart G CAMO approval. Have a look yourself to see what response I got.

There is a letter in the latest GA buyer from the Chief Engineer of Coulson Aviation Services (apologies for spelling). I suggest you all read it. It is another Engineer telling the GA community the reality of EASA. And it refers to the real and further decline in maintenance organisation numbers.

Over the next year, there are rumoured to be a number of established maintenance organisations who are going to call it a day and not renew their Approvals (not pay the CAA any more money). Having spoken to a number of the individuals involved, I know this to be substantiated and not just rumour.
The reasons given are consistant, and these are not my words:
Far too much paperwork for no perceived benifit in safety. Too much cost for insufficient return. Dissatisfaction with service from the Authority. Erosion of the professional licenced Engineers status. Small-minded EASA muscle-flexing against the FAA e.g. preventing the fitment of FAA PMA Approved parts in some instances; non-acceptance of American repaired or overhauled parts even with FAA Form 8130's attached.

DFC
It is commendable that you have taken an in-depth interest in your aircraft maintenance in the past. Long may your example continue. Unfortunately, if you don't gain CAMO approval yourself, you might find yourself frustrated when it comes to maintaining your oversight, as your CAMO will have the last word, not yourself. And you will have the pleasure and privelage of paying him/her to remind you of this, no matter what your view on this issue is. Welcome to the real world of EASA.

For all.
And remember, once the FAA have issued the C of A for an 'N' reg aircraft used for private use or training, they have no further involvement provided the aircraft is properly maintained. No FAA renewal fees. No organisation approval fees as your aircraft can be maintained by an A&P, and the modifications and Annual certified by an IA, thereby making maintenance cost effective and safe. Sensible FAA IR making flying safer. No wonder EASA wants to kick out the 'N' reg aircraft.

Enough for now, but remember, it is the eyes and experience of the licenced and unlicenced Engineers that spot and repair the defects and problems with your aircraft, not the attached six inch pile of paperwork.


P.S.
I have an unlicenced guy here who carries out the second part of the Independent Inspection...and he makes the tea.

Now, before you get on your high horses, he happens to have ten years experience within a 145 enviornment, and he has been properly briefed and Approved in accordance with Part M, and I trust him more than some of the Licenced idiots I have come across over the years.


camlobe

[Johnm]

I think I'll just maintain my aircraft myself and forget all the paperwork. I can maintain a Morris Minor and my aircraft is probably less complicated

[IO540]

Gentlemen, can I make a suggestion?

Find a nice cynical way to deal with this crap.

I have a business in electronics (30 years now) and we have been bombarded with all kinds of crap. BS5750, CE, ISO9000, ROHS, you name it.

A lot of it is sponsored not by Wonderful Europe but by fellow businessmen - people who make a living out of selling "consultancy" time, at anything up to £1000/day if EMC lab time is involved.

The electronics trade press carries constant righteous crap articles (written by journos who were failed engineers) about how such and such stupid reg will be enforced with strict penalties and how this is right and proper.

Many of their advertisers are electronics component distributors who nowadays are cardboard box shifters who add exactly zero value and just waste a couple of hours of your time while their stupid know-nothing sales rep takes you to lunch. Years ago, one company (Macro) employed mostly pretty women, so that was at least good fun (they knew nothing too but a good looking woman gets away with that every time), and obviously they were immensely successful, but eventually they had to stop the practice after some equal rights body set them up with bogus interview candidates. Anyway, these stupid distis are always desperately looking for ways to make the good old commodity-level components (which are cheap and plentiful) obsolete and forcing users to comply with new "standards" is always a good gravy train.

In the early 1990s a lot of people made loads of £ selling self adhesive "CE" stickers which would get stuck on everything.

Similarly, you get an "ROHS" (lead-free) rubber stamp which goes onto every carton. The Chinese print them onto everything as standard, even if it contains tampons.

Every time a new reg comes out, there is a mad panic as all the quality managers (invariably socially disfunctional little men who probably plane spot as their hobby) send out a load of forms for the company's suppliers to fill in, with questions like "do you have a system for segregating defective product" (yeah, Sir, actually, we deliberately mix up the crap with the good and send it all out of the door together :ugh:). The other day I had one such QM on the phone, British Rail no less, pointing out that the EN number in one of my data sheets became obsolete about 10 years ago and can I please re-issue another certificate referring to the new number. I told him politely to take his EN # and put it somewhere warm and dark; his business wasn't big enough to cover my time ordering the ISO documents and reading them.

Then we get export documents, 6 copies, with special wording certifying that the goods are made in the UK etc. The reality is that the box we send out could contain Chinese tampons and nobody will notice or care. The world is full of warehouses full of filing cabinets where this stuff is filed by endless streams of socially disfunctional little men.

Now we have ROHS, mandating lead-free solder and components and obsoleting vast swathes of equipment and designs, exposing soldered parts to much higher temperatures, and resulting in "non compliant" component stocks which have to go in the skip. Lots of people (Brits!) rubbing their hands. The more sensible firms just carry on and ignore it, or pretend to use one of the exemptions like "control and monitoring equipment".

Anyway....

What has happened in electronics is that you print up a form for everything, and sign it and rubber stamp it. It doesn't matter if it isn't really applicable; if it looks good, nobody cares.

For frequently repeated text you get a rubber stamp made. Very cheap.

Every label has "CE" on it. The regulars know it stands for "Chinese Export" and nobody cares.

If you want ISO9000, you get a consultant in for a few k, generate a load of forms, a Quality Manual (which nobody reads and which can be full of crap), and you generate a streamlined system under which you can continue making the same old product, the same way, and the paperwork is done efficiently. Everybody knows this now, which is why ISO9000 means nothing at all.

It's possible that people who work in aircraft maintenance are not as IT savvy or as literate as electronics engineers and thus find paperwork hard (certainly my barely legible maintenance records are a poor indictment of the UK education system) but if you get organised you can do it.

The 7 pages somebody mentioned are almost certainly pretty regular stuff and one could do some kind of standard form which you just duplicate / cross out bits and sign/stamp at the bottom.

Nobody is going to read it anyway; the vast majority of maintenance records get lost when the company goes bust years later. Only the most diligent owners ask for copies and they are welcome to the wads of paper.

I know a firm which does a fair number of TCAS installations; they have the paperwork for FAA and EASA all copied up and they just send it all off with the fees; minimal work really.

Rubber stamps are cheap and you can get a whole load made for standard wordings. Or use a PC, standard texts etc.

It's a cynical approach but when the regulatory authority is anally retentive what do they expect? You play their game, no less and absolutely no more.

[Fuji Abound]

IO and Camlobe

Both your post made me chuckle. You tell it as it is.

It reminded me the last time I needed to get a new fuel pump.

No one had one in the UK, so I went direct to the manufacturer in the States.

How much is the pump? I asked

40 bucks, he said.

With the paperwork? I asked

Ah no, he said, with the paperwork that will be 180 bucks.

So what this difference? said I

We fit one to the Cheverolet, the other to your aircraft.

No, no what is the difference in the pumps, said I, you must test them to a higher standard?

Oh no, said he, same pump, same production line, no difference, except the paperwork that is.

Of course I had the one with the paperwork, because my engineer insisted.

:confused:

[IO540]

One point not lost on the more imaginative is that with any part which doesn't carry a serial number (and most small parts don't) you can use the paperwork which came with the previous one ;)

This enables you to purchase e.g. spark plugs from the USA. People like Aircraft Spruce try to con foreign customers (Brits, generally) out of $60 per item for an 8130-3 - a total ripoff. A lot of companies can't even supply an 8130-3. A lot can but only because they have an in-house inspector which can sign the piece of paper.

It's the same as the JAR145 scam - a JAR145 company can issue a JAR1 form for anything; they just need to look at it and fill in the form. I was quoted £800 extra for a certain engine part with a JAR1 form; the part is merely weight selected for dynamic balancing i.e. is not even touched, and the US company which does this charges about $100. $100 to £800 - not a bad margin and I suppose this kind of ripoff is what is needed to fund the JAR company approval. Another JAR145 company converted a $9000 prop (with an 8130-3 from Hartzell) to a £11500 prop (with a JAR-1 form from the JAR145 company).

Ultimately, this ripoff culture is all that safety regulation has achieved. To get the safety benefits (i.e. avoid counterfeit parts made of duff materials etc) all you need is a certificate of conformity!!! And they generally come free, in the form of a delivery note etc from the manufacturer...

You've got to laugh, because everybody up the supply chain has already fallen over backwards laughing at YOU.

[DFC]

IO540,

It's not as simple as that. The supplier will have a record of selling you an automotive part.

The only way to do as you say is to not record the fact that the pump is u/s and make no paperwork entries. Usually stands out a bit that the shiny new part must have been recently fitted...........check logbooks - no record, check credit card - automotive part ordered from US. Best paying in greenbacks when flouting the law. :)

-----------

Camlobe,

You simply make my position crystal clear - it is the CAA and not EASA that is causing much of the problems and uncertainty.

If the CAA is going to make the situation financially untenable for the customer then it is breaching the law and operating outside it's authority.

EASA should slap down these people ASAP and let everyone get on with what EASA intended and not how the CAA are trying to muck it up.

The problem with the title "engineer" is that people who simply pick up a screwdriver call themselves engineers these days in the UK.

---------

This whole thing reminds me of the UK family who paid thousands to replace their plumbing because the plumber told them their imperial pipework was not compatible with metric and only metric sizes are available these days.

You have to laugh and people who are stupid enough to believe such stories.

How many stupid owners are there who will either unnecessarly pay through the nose or unnecessarly give up?

Regards,

DFC

[ericferret]

Try this one for size the details have been changed slightly to protect the innocent.

Pilot comes "in sorry boys but I've overtorqued the aircraft, my fault incorrect engine handling".

Engineers start to replace some very expensive hardware.

Part M gets involved and produces a process for returning the aircraft to service.

Part of this process is a check of the engine management system.

Engineers work through the process to humour the Part M, they know the cause of the problem ( he is sitting in the crewroom).


Bottom line is if no faults found replace the Fuel Control Unit, mega expensive. A test bed run will cost a few thousand with the recertification.

Engineers refuse to change the unit as they know that the cause was the "stick to seat interface".

The Part M insisted the unit was changed. Th engineers were forced to change it under protest.

Can't you just wait till that happens to you!!!!!!!!!!!!!!!!!!!!!!1

[DFC]

I take it that by "Part M" you are referring toPart Manufacturer?

Can't see anywhere in European Law instructions for specific engine maintenance and repair. Lots of it in the Manufacturer's Maintenance, Overhaul and Repair manuals.

Good story.

Regards,

DFC

[A and C]

Four pages on now and just about all the posts exceping yours are of the opinion that the introduction of EASA part M maintenance will drive up the cost of opperating an aircraft on the Uk register (not PFA or annex 2).

Are you finaly ready to admit that I might just be right about the costs of introduction of EASA part M?

[robin]

>>>I take it that by "Part M" you are referring toPart Manufacturer?

Can't see anywhere in European Law instructions for specific engine maintenance and repair. Lots of it in the Manufacturer's Maintenance, Overhaul and Repair manuals.<<<<

DFC

I don't know if you have seen any of the presentations made about the new regime, but you do seem not to have heard any of the 'horses mouth' stuff we have attended.

The new regime for continued airworthiness is designed to harmonise across EU, but with the local NAAs like the CAA acting as its representative. It is also responsible for sending back to EASA its 'cut' of the costs.

I have just spoken to my own maintenance organisation about next year, and although they have but in their application for approval, they still haven't heard back whether or not they have it. Yet since September they have been trying to get a straight answer from CAA and/or EASA as to what to do.

Some aircraft they have carried out a CofA on are to be moved to Annexe II or to a PFA permit very shortly, thus causing the owners undue expense.

As to my earlier point about being forced into the arms of a cartel, this has already happened to one friend. His maintenance organisation, which has been doing good work for him for years is no longer able to continue to operate to the new policy. He tried to register with the only approved outfit in the area, but they have turned him down - they have enough work with the aircraft based on their site to want to bother with anyone else.

If there is one thing that the UK does have, it is the requirement for an impact assessment of any proposed regulation. EASA does not require this, so when half the GA fleet stops operating because of this regulation there will undoubtedly be a gallic shrug from the French, who do it their own way, and from the CAA who will blame EASA.

[DFC]

Are you finaly ready to admit that I might just be right about the costs of introduction of EASA part M?

No.

I don't see any extra cost in my future maintenance bill as a result of EASA.

I said the same about JAR-FCL and am happy to say I was correct. IN fact JAR-FCL has worked out better than I even expected.

I do see lots of "it's going to cost you to go from imperial to metric pipes" stories being told round the UK.

Like I said - Lets look at this again in 3 years.

-----------

Robin,

The problem is that no one in their right mind is going to be influenced by people on a rumour network who for the most part simply are anti- anything that comes out of Europe - even if it is the CAA that aree causing the problem.

Don't see many Irish, French, Dutch, Belgian, German, Spanish and so on people complaining.

Could be that some are going from annual C of A renewals to a far simpler and cheaper system.

The whole thing about change is to ensure that you win as a result.

Compare the UK aircraft engineering population to Europe - a very small part.

Welcome to democracy.

Regards,

DFC

[robin]

>>>The whole thing about change is to ensure that you win as a result.<<<

Hmmm

Perhaps we ought to have a little wager on the side on this. I've not seen any legislation introduced by the CAA or EASA which has given me any 'wins'. Quite the reverse

[skydriller]

I don't see any extra cost in my future maintenance bill as a result of EASA.
I said the same about JAR-FCL and am happy to say I was correct. IN fact JAR-FCL has worked out better than I even expected.


I cant say I know much about the up coming EASA Maintenance changes, but I take issue with your statement that the JAR system doesnt cost more than the old CAA one.

Old CAA PPL issued once when you pass skills test, valid for life.
JAR PPL needs to be "renewed" every five years at a cost of £70 a shot.

That is an additional cost in anyones book....all be it minor in the grand scheme of flying costs.

Back to the issue at hand, if the new system requires additional paperwork for regulation, it is an unfortunate fact of business life that an increase in regulatory paperwork usually entails an increase in cost, which is passed on to the customer...

Regards, SD..

[DFC]

Robin,

Perhaps we should! :)

---------

skydriller,

If you had a "for life" PPL then you still have it. No change there.

If like other Europeans you had to renew your PPL every 2 years then only having to do it every 5 years is a great cost saving.

It may not be win/win but it is no change / win.

Add to that the validity of the licence in any JAA state, that is a great saving in admin / hassle / costs.

A law increasing the cost of a bus ride in Newcastle from GBP1.00 to GBP 2.00 while reducing the cost of national train journeys from GBP20.00 to GBP10.00 will have people who never look beyond Newcastle up in arms. Those that uses the system to it's fullest extent will benifit and be glad of the changes......................especially if they live in London!! ;)

Regards,

DFC

[DFC]

Skydriller,

Forgot to say that when I was referring to costs under JAR-FCL, I was referring to the costs involved in operating training organisations and obtaining approvals required.

Having the ability to provide training services across a number of states without separate approvals and different requirements from a single base instantly increased the available market. Many have tapped into this increased market, some simply came back from expensive private flights to Australia and laid off instructors without paying for work done........blaming JAR.

Where is Tony these days?

Regards,

DFC

[wigglyamp]

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!

[A and C]

I have been saying much the same thing for the last three pages but I am sorry to say that all of us must be totaly wrong, after all DFC says that dispite the increased cost of approvals, more paperwork and more company audits costs will not increase.

It is just left to DFC to make it crystal clear how his economic system that has a company's outgoings increse and income stay unchanged with the proffit staying unchanged works, perhaps he would like to enlighten us. I am sure that my accountant would be very interested as if he could get a grip on DFC's economic insight he would make a fortune and so would I.

So come on DFC tell us what you know!

[DFC]

Companies that fail to grasp oportunities and exploit them go down the pan eventually no matter what they charge.

Please explain how going from having a Full C of A renewal every year along with the Annual inspection to having the Annual and a bit of paperwork completed is any different.

Noting is changing.

You may have to play catch-up and your customers may have to suffer the cost of your having to do so but I will see no change in continued airworthiness costs - 2008 is already sorted and it is 2009 that we must plan for.

Regards,

DFC

[wigglyamp]

Suggest you read the EASA scale of charges for 2007/2008 on the EASA website. The initial application fee for a CAMO in accordance with Part M subpart G is Eu 24000, and renewal is 18000. This is the new fee above and beyond the current Part 145 approval or BCAR M3 approval that companies must pay in order to carry out the paperwork for ARC renewal that they currently do as part of scheduled maintenance. If your CAMO can, from September 2008, do this without any additional cost, I suggest you publish their details so all of us can go to them for the ARC - as well as a Part 66 engineer, I also own a PA28, and can't justify the Eu 24000 fee to continue managing my own paperwork!

[AC-DC]

If you had a "for life" PPL then you still have it. No change there.

If like other Europeans you had to renew your PPL every 2 years then only having to do it every 5 years is a great cost saving.

It may not be win/win but it is no change / win.


DFC
Please excuse my stupidity.
I have a CAA PPL for life, all I have to do is a flight with an instructor once every 2 years, sign the logbook and I am done,no fees to the CAA or EASA. According to the new proposals I will have a new EASA PPL for life but this time I will have to pay X Pounds every 5 years to the CAA or EASA. So please explain to me, Is it a win/win situation or a lose/lose situation?

Maybe you europeans were in a worse situation than us in the UK, I don't know, you might gain as a result of the changes but we are going to lose big time. I am not urprised that you can't see it but we can.

[robin]

Not forgetting the loss of certain UK ratings that don't fit in with the French (sorry, EASA) view of the world, like the IMC

[DFC]

Suggest you read the EASA scale of charges for 2007/2008 on the EASA website. The initial application fee for a CAMO in accordance with Part M subpart G is Eu 24000, and renewal is 18000. This is the new fee above and beyond the current Part 145 approval or BCAR M3 approval that companies must pay in order to carry out the paperwork for ARC renewal that they currently do as part of scheduled maintenance

Why would I refer to that unless I was based outside the EU or I wanted design or type certificate approval.

If I was in the UK, I would look for the charges here;

http://www.caa.co.uk/docs/33/ORS5~218.pdf

[/I]5.1.1 Initial application charges
In respect of an application to the CAA for the approval or authorisation of a person or
organisation, for the purposes of Part-21 (Subparts F or G) or Part-145 or Part-M
(Subparts F or G), for the investigations required by the CAA, the applicant shall pay on
application:
a) in the case of an approval or authorisation Part-21 Subpart G, or in respect of the
A1 or B1 ratings of Part-145, a charge of £8,640;
b) in the case of an approval in Groups A2, A3, A4, B2, B3, C or D ratings of Part-145,
a charge of £2,160;
c) in the case of an authorisation in Part-21 Subpart F, a charge of £1,070;
d) in the case of an approval in Part-M Subpart G1 for aircraft > 5,700 kg, a charge of
£4,320 and for aircraft up to 5,700 kg, a charge of £2,160. However, where the
applicant already holds a CAA maintenance approval or a BCAR Group E3 design
approval, then a charge of £1,070 will be applied regardless of aircraft weight;
e) in the case of an approval in Part-M Subpart F, a charge of £2,160. However,
where the applicant already holds a CAA maintenance approval then a charge of
£1,070 will be applied;
f) in the case of any other approval, a charge of £2,160.
Provided that for the purposes of sub-paragraphs a) to f) above where the cost of the
investigations exceeds the charge specified, the applicant shall pay a charge of such
amount as may be decided by the CAA having regard to the expense incurred by it in
making the investigations, see paragraph 6.4, but not exceeding £106,000 for any year,
or part of the year, during which the investigations are carried out.
5.1.2 Variation charges
In respect of an application to the CAA for the variation of an approval of a person or
organisation for the purposes of Part-21 (Subpart F or G), Part-145 or Part-M (Subpart F
or G), for the investigations required by the CAA, the applicant shall pay:
a) in the case of a Part-21 Subpart G, Part 145 or Part M (Subpart F or Subpart G), a
charge of £1,070; or
b) in the case of a Part-21 Subpart F, a charge of £535; or
(This Note is not part of the Scheme)
1. If applied for, and without extra charge, the grant of a Part-M Subpart G approval may include a Subpart
I privilege that would permit the applicant to issue Airworthiness Review Certificates.[/I]

There is more if you look at the whole document.

The UK CAA is expensive but not such a drastic expense that some would believe.

---------------
AC-DC,

Us (you and me) Europeans simply have to accept that living in the past is no good.

-----------

Robin,

I think that you will have to include every other country on earth along with the French. ICAO do not recognise it and no UK pilot has ever obtained permission to make use of it outside the UK, CI and IOM.

Regards,

DFC

[tmmorris]

Us (you and me) Europeans simply have to accept that living in the past is no good.

Sorry, I've kept out of this so far, but that is the most asinine remark I've ever seen on PPRuNe. You are saying that we must accept change, even bad change, to avoid 'living in the past'? You cannot be serious..?

Hitler, Stalin - hey, even Saddam Hussein - represented 'change' in their own milieu. I think we probably agree that it was bad change.

Tim

[A and C]

A lot of text but you are still avoiding the outgings vs income issue but at the same time publishing data that shows an increase in charges for regulation.

Is it not time to admit that you are soon going to have to pay a CAMO to do the technical paperwork that you up untill now have been doing yourself or pick up an even larger bill to do this yourself.

[wigglyamp]

Whislt the CAA curently have the discretion to vary charges, the new charges laid down in the current EASA scheme effective from June 2007 will prevent the UK CAA from offering reduced fees in the future. If you look at Ch IV, Article 14 para 1 (d) of the EASA fee structue, you'll see that in future, the surveillance fees given in Part 3 para 2 (the EU 18000) will apply. Whilst these can be reduced by the multiplier based on turnover, they are nevertheless a significant additional charge not previously required and hence industry will need to recover them from customers or see margins diminish. In addition, the note on the signature page makes clear that the regulation is legally binding in ALL member states - so no get-out, and not applicable ONLY TO PEOPLE OUTSIDE THE EU!

[Malcom]

Just back for a short break, only to find things going from bad to worse. I did see a glimmer of hope for DFC, its just gone out!


""""This EASA law is for Harmonisation if in order to harmonise with the standard you need to do lots of extra work then ask yourself why could this be if you were at the required standard?"""""

If you need to do work to harmonise with a standard, surely this means you were at a different standard to start with, hence the extra work to harmonise with the new standard?



"""""Much of your complaint seems to be with the CAA. So why don't you title the thred CAA money pit...........because as you say, they are the ones charging the large sums of money and making a profit.""""

European harmonisation guff?? Our CAA is required to make a profit, whilst other NAAs are state funded. Level playing field - right?

The CAA act for EASA & do what they are told. When they know, then we find out!



""""""Now back to the paperwork. If your maintenance company completed the Annual and required paperwork exercise to renew your C of A previously and say that cost was X including work, parts, expendibles and paperwork then provided that they are capable of getting the required approvals then they can continue to complete your Annual and C of A paperwork.......then what has changed to justify an increase in costs......unless they were not doing it properly before!"""""

As previously described ad-nauseum, a new approval is required to issue / revalidate your non expiring C of A. THE NEW APPROVAL COSTS MONEY.



""""Again I say...........nothing new for me in all this. If engineering organisations are going to charge more for doing what they were doing (or should have been doing) all along then I can rightly claim that they are profiteering from the confusion surrounding the issue and in many cases, addid to that confusion probably for their own benifit.""""

As previously described ad-nauseum, a new approval is required to issue / revalidate your non expiring C of A. THE NEW APPROVAL COSTS MONEY.




"""""Can't see anywhere in European Law instructions for specific engine maintenance and repair. Lots of it in the Manufacturer's Maintenance, Overhaul and Repair manuals."""""

European Law specifically requires you to use that data, therefore it is part of EU law.



Time to put-up or shut-up DFC, give us the benefit of your insight & business ideals, tell us how you will have your non expiring C of A Issued and revalidated at no additional cost.

Best wishes to all for 2008
Malcom

[DFC]

tmmorris,

If the change is bad for you but good for 2 other people then the change is overall good.

However, you are missing the point I am making - there will not be any change in this. There will not be any major hike is fees for small private operators who know what the system is and make appropriate arrangements.

Do a google search on what other aviation authorities have to say, look at the various power point presentations that are on line from EASA and others, look at the EASA requirements yourself along with the scheme of charges.

Have a good look at what maintenance organisations in other countries are saying in their adverts.

A and C was pointing out that in their opinion the option of having the CAA complete the required ARC was going to be so expensive that no one would be able to afford it and everyone would be forced to use the industry controlled and managed maintenance option. However, what A and C has forgotten (or has not yet learned) is that every fourth certificate has to be completed by the CAA. So if they set the prices very high then all the UK people will have to pay them every fourth time. Thus there is no way of avoiding the CAA fee.

Under EASA you can get your club C172 maintained by a member of your club (subject to conditions), certified by a JAR-66 engineer and the NAA will look after the private C of A /ARC.........just not on the G register yet. Now tell me that is more expensive than going to your local M3 organisation and having to maintain a public transport C of A on your club aircraft.

People simply have not done enough research on this and if they have not made appropriate provision will get fleeced by those that use the favourite UK line - say metric does not fit imperial.

------

Wigglyamp,

You need to do more reading!

I will come back to this in 3 years and then the answers will be clear.

Regards,

DFC

[A and C]

As DFC says some maintenance tasks can be carried out by the owners & pilots however they will require to be trained & checked to do these tasks by the maintenance company that they are contracted to.

In effect they will be issued with a task limmited company approval by the maintenance company.

This brings us back to the cost to the maintenance company to get the Part M approvals. The next cost is that to check the owner/pilot can perform the task safely.

So for DFC to get the approval to do what he can now do under LAMS he will have to get checked out by the maintenance company that he will have to be contracted to and have to pay the cost of administering the check out and approval.

Now do we think that if DFC gets the CAA to do the ARC each year they are going to give him a limmited task approval for free ?

[robin]

Forgive me (again)

My understanding of the situation is that the CAA will issue the first ARC with the non-expiring EASA C of A.

After that, if you sign-up with a CAMO in a controlled environment and agree with them the limits of the maintenance, then the costs are reduced. You 'may' also have the ARC extended for up to 2 years, so we have the current situation of Star-Annual-Annual-Star.

In the 'Uncontrolled Environment' where the owner has no agreement with a CAMO, he is not able to raise the work pack and each time he approaches an MO he effectively funds a Star Annual. The costs in this option are significantly higher than in the Controlled case.

Worse, because it becomes prohibitively expensive to change CAMO, they have you by the short and curlies. They can also remove any or all of your rights to carry out pilot maintenance, if they so wish.

This will lead to owners carrying out their own maintenance or getting someone else to help out, and not recording it, in the hope or expectation that no-one will notice.

One of the great joys of looking at EASA legislation is the way that it encourages owners to find ways around the legislation, rather than complying with it. Hardly something that was planned.

Now, this may be different in Euroland, but we are being driven down the preferred CAA view.

[A and C]

I think that you more or less understand the plot (more than we can say for DFC!).

It would be my stance to encourage some owner maintenance for those who have the correct attitude, at least this way people will be "up front" about what they are doing and not try to hide things from me.

The good thing about owner maintenance is that it teaches the owner a lot about his aircraft and he soon finds out that good maintenance is not easy, this understanding helps to balance the rubbish spouted by flying club bar flies who think that any one can maintain aircraft.

[DFC]

we are being driven down the preferred CAA view

So why is this thread not titled "CAA money pit"?

Will A and C ever notice that light aircraft mainenance can be completed by a JAR-66 licensed engineer. No contact with a maintenance complay required at all. How much does being able to permanetly steer clear of over priced maintenance organisations who seem to be using this to push their inflated prices further upward.

The requirements for owner maintenance and in the club environment for maintenance by a club member simply require the person to be suitable to the authority. Noting about having some maintenance organisation approve them.

Is that another line you are going to spin to your customers in order to further increase you income?

My final words on the matter are - Owners please check out carefully before you spend unnecessary money with those who seek to exploit your lack of knowledge.

Regards,

DFC

[Malcom]

DFC
I so very happy for you in that you are OK with an ARC renewal every year by the CAA, or a CAMO.

I am not.

True, a MO does not need to approve you to work on your plane, but just who is suitable to the authority?
- LAE ? Fine as long as nothing is found wrong.
Worn out seat rail on a C152. 8 screws out, replace rail, 8 screws back in and the job
is done. LAE cannot certify this job.
- Owner? Fine as long as you limit your club plane to 50 hours a year, and nothing goes wrong.

Part M. I would recommend you have a read & inwardly digest.

The problem with having ones head in the sand is that others can only see the bit sticking out.

Best Regards
Malcom

[robin]

DFC

>>>The requirements for owner maintenance and in the club environment for maintenance by a club member simply require the person to be suitable to the authority. Noting about having some maintenance organisation approve them.<<<

I'll dig out the chapter and verse on this, but as I read it the CAMO will permit or otherwise any pilot or other maintenance.

You have to inform the CAMO within 30 days of any maintenance carried out and they may require to inspect the work. If they find it not to their taste, they have the authority to limit any pilot maintenance still further. They can also prevent an LAE from doing work on your aircraft if they have grounds for believing it to be below (their) standard.

Under agreements with CAMOs, which we are being 'encouraged' to take out, we have the responsibility for continued airworthiness, but are firmly in the hands of our CAMOs.

[Malcom]

Robin,
You dont HAVE to use a CAMO for managing maintenance - it just reads a bit easier at the moment.

DFC has pointed out an owner can do this if he deems himself competent. As I've said before that is a matter for the owners technical competency, his wallet, his technical library, his conscience, & the Board of Enquiry in the event.

This puts you outside the "controlled environment", and then you will only need the CAMO with ARC revalidation privileges (or otherwise go to the CAA) to carry out the Airworthiness review each year - effectively a C of A renewal every year.

If you do use a CAMO to manage maintenance, then you are in the controlled environment, they can approve certain tasks an owner can do. The plus here is that then you can have two CAMO issued extensions to your Airworthiness Review, so a bit similar to the current M3 renewal process, just paying for yet another approval and its upkeep to do the same as at present.

Best Regards
Malcom

[camlobe]

DFC wrote

"Will A and C ever notice that light aircraft mainenance can be completed by a JAR-66 licensed engineer. No contact with a maintenance complay required at all."

If I understand what you appear to be saying, and please correct me if I have failed to, you are suggesting that a JAR 66 Aircraft Maintenance Licence holder can complete and certify ALL maintenance on your 'G' registered aircraft?

You also appear to suggest that you will not require the services of a maintenance company (I am guessing you are referring to what is correctly termed an Approved Maintenance Organisation, be it M3, E4-M5, or Part 145) by contact or contract for any aspect of maintenance on your 'G' registered aircraft.


Hahahahahahahahahahaha

Oh, sorry. Please excuse me, one and all.

You see, up untill now, I was actually convinced that DFC was genuine. I even believed that he may have been a committed aircraft owner or active flying club member who took a deep interest in his aircraft maintenance, as well as being shrewd. I thought it was most commendable of him to stand up to the industry here and try and make his point.

Then I read his post containing the above quote. It was at this point that I realised, we have been had.

As those of us actually involved in aviation know, the CAA require all Annual Inspections (including CAA ex-mil Permit types) and C of A renewals to be carried out within the premisis and confines of an Approved Organisation. EASA similar.

So, either:

a) DFC has never been an aircraft owner, [Milt or wannabee]

or

b) DFC has only owned microlights or PFA/LAA Permit types, [Milt or wannabee]

or

c) DFC has only recently purchased an aircraft, and has believed everything the salesman said,

or

[B]d) DFC has an AML (JAR 66 licence) and does all his own work, [suffers from foot-in-mouth disease and doesn't understand the limitations of his licence]

(or, e) hypothetically, perhaps a certain amount of readies pass between two people once every year in exchange for a quiet signature or two. However, if this has previously taken place, following the high-profile "won't cost me any more" statements in this well viewed thread, the signatory will most probably disappear into thin air to prevent capture and loss of licence, nee income). [golden goose shooter]

I learnded Englische when I was a children. Notwithstanding this fault of mine, looking at the grammer and spelling contained in DFC's posts, and considering the 'precise' content of some of his quotes, I wonder if DFC is really a two-year-college-special freshly-churned-out-but-nil-experienced B1 or B2 who falls into d) above. a) may also apply.


camlobe

[ericferret]

Well the current LAMS, (I wont go into LAMPS as I dont understand it fully yet) says in section 5 page ""certification of maintenance-non commercial air transport""
Defined as aircraft operated without an AOC.

Annual inspection may be certified by the holder of a UK AMEL or Jar 66 licence.

Star inspection must be completed under the supervision of an approved organisation.
The wording was changed a number of years ago to remove the statement that it had to be carried out at the premises of an approved organisation. I reckon the change was made about 7-8 years ago.

Camlobe
You must know something I don't.
Being a sad git I just do what the approved maintenace schedule tells me to do!!!!!!!!!!

[DFC]

This is not great but it gives you a compact idea.

www.easa.europa.eu/doc/Events/Part%20M%20presentation.ppt

Note that EASA said that it would be OK to continue using LAMS. What a pity the CAA representatives are usually sleeping off their hangovers at the back of the room when such things are mentioned.

Or is it simply work creation to bring in the LAMP?

People like camlobe would like to have owners thinking that they have to have maintenance done at expensive maintenance facilities.

Just more of the mis-information that is being spread.

Only fools will be paying more for their maintenance on their private light aircraft as a result of EASA.

Regards,

DFC

[Malcom]

That link opened a Part M presentation dated 1 December 2006 - isn't that a bit over a year old and out of date by now ?? If that is current gospel, then .................................(stuff).

Up to date is what you need to be reading, not old hat EASA "oops - they dont seem to like that very much - we had better think again - see if they like this instead then" back-pedalling.


Best Regards
Malcom

[ericferret]

According to LAMPS, certification is made in accordance with Part M MA 801 and MA 803 for non AOC aircraft.

803 is pilot maintenance, I'll leave that.

801. This is for aircraft not released by Part 145 organisations.

Basically it says that post maintenance a release to service can be issued by

1 Appropriate certifying staff from a subpart F approved maint org.

2 (Except for Appendix 7 tasks) By certifying staff in compliance with Part 66, i.e licensed engineers. Appendix 7 corresponds more or less to the old AWN Notice 3 tasks requiring special techniques e.g welding, bonding, major structural work.

3 I.A.W MA 803 i.e pilot maint.
So it seems to me that a licensed engineer can sign for an annual or any other work within the scope of his licence providing an AOC is not in force.

Malcolm you say that a liceensed engineer cannot change a seat rail that is screwed down.
I think you are in error. Appendix 7 covers seat rails but not those that are screwed down.

[Malcom]

Re-read appendix 7 - mis-read that, thanks for the correction.

Regards
Malcom

[A and C]

Guys I am having increasing problems getting into the regulations part of the EASA website...................are any of you having problems ?

[ericferret]

Yes, but I believe that this is being caused by low steam pressure in my computer system combined with easterly winds!!!!!!!!


Just gave it a go, got to the Part M pdf in about a minute, which is pretty good by my usual efforts.

[ericferret]

What is to stop an owner going to a different CAMO at each ARC if he so choses.

Once the initial ARC is issued by the CAA only work carried out between that point and the next renewal needs to be reviewed.

For many private owners this will be minimal, probably a calendar 50 and an annual.

Providing the log books, maint schedule and associated documentation are in good order, the only requirement would be an AD search and an aircraft survey.

The cost of this in a competitive environment should not be excessive.

It has been suggested that the CAMO needs to generate a workpackage before a maintenance check can be carried out. If the schedule and associated documents are in order this need not be the case. The person certifying the check for a simple aircraft can easily extract this information and carry out the required work as they do now.

I believe that any regulation that forced an owner to stay with a particular CAMO due to the excessive costs in changing CAMO's, would be viewed as anti-competitive and therefore in breach of European law.

[robin]

Eric

There is nothing to stop you changing CAMOs each year. In fact that would be the situation if you went into the 'uncontrolled environment'. But the problem that would result from this is that each ARC would effectively be a Star Annual.

The CAA have already stated that they would prefer us to have a long-term arrangement with our MOs and so by staying the in the 'controlled environment' we have the current situation of Star-annual-annual-Star annuals, which should cost a lot less.

[ericferret]

At the moment I can't envisage how the whole process will work and what it will cost.

It is just that if you are not in the controlled environment it has been suggested that the CAA would renew the ARC at enormous cost.

I am suggesting that you could go to a CAMO on a one off basis at £?????
This must be possible otherwise what happens if a CAMO closes it's doors for any reason. You would have to start from scratch then.

I think that once the paperwork is at the required standard which it should be for the initial issue of the ARC by the CAA then the year to year maintenance of it should not be a difficult or costly matter ( for a simple aircraft).

Basically I am looking for the loopholes and pitfalls in the system. They will be there as anyone who has looked at the EASA legislation so far will be forced to concede. Those drafting it are not very bright!!!!!!!!!!!!!!! Nice but dim!!!!!!!!!!

[robin]

I'm baffled.

You do not go to a CAMO on a one off basis. That would be ludicrous under the scheme as planned.

What would happen is that the new CAMO would have to go through your documentation in great detail, raise the paperwork for the issue of an ARC , suck in their breath and say 'did you realise that your last MO didn't do this, that and the other, so we'll have to do it all over again....' They'd even question your own record keeping, as they have a responsibilty to EASA (as well as having to fund their aprovals)

On the other hand, you could sign up with a CAMO who would do the work, keep the records and for up to 2 years you don't have the effort or cost of a full Star Annual - the CAA and EASA really want this to happen, so have loaded the costs accordingly.

Now if you have shedloads of money or are unhappy with your MOs, then you can 'be a tart' and move between organisations. Otherwise we are being 'encouraged' to stay with an organisation that knows our a/c.

Problems come when our chosen MO decides not to carry on, or when we buy an a/c from another area of the country. That will really hurt

[ericferret]

My point exactly. I can see no reason why the new CAMO should have to go through the old paperwork in great detail?.

That will have been done previously. All that is required is to review the paperwork since the issue of the last ARC. Probably a 50/Annual and AD's. This should be a minimal cost.

This is how C of A's have been carried out previously. You only review the paperwork since the last C of A. Why the need to reinvent the wheel?

This system should work in many ways in the same way as the old system except for the fact that the paperwork (CAMO) and maintenance organisations may not be one and the same.

The fact that the CAA want owners to strike up a long term relationship with the CAMO/Maint org is nothing new they have been banging that drum for 30 years.

A long term relationship beneficial to both parties is a good thing. However what people are afraid of is being trapped in an unsatisfactory relationship and being unable to move.

This CAMO system was designed for commercial air transport operations with an AOC in force. Even EASA are looking at modifying it almost before it is operational. It is clearly a sledge hammer to crack a nut.