EASA part M what are you doing?

[A and C]

On 28 september 2008 all aircraft will have be contracted to an EASA part M maintenance company to keep your aircraft inside a "controled enviroment", If you are an owner what are you going to do? The three options are as follows.

1 Contract (for three years) the whole maintenance to one company that can do the EASA subpart G supervision and the maintenance.

2 Contract just the subpart G supervision to a company and then this would allow you to switch maintenance companys if you wished during the validity of the ARC if you are not happy with the maintenance company.

3 Do it at yourself at much greater cost by getting the CAA to issue the ARC annualy.

What ever option you take this needs action soon to avoid the unnessesary costs of getting trapped in option 3 by doing nothing.

CAA link below

www.caa.co.uk/default.aspx?catid=1461&pagetype=90&pageid=8336

[S-Works]

Why is option 3 more expensive? Other than the hundred quid for the paperwork annually it seems to me that option 3 actually works out cheaper?

If you don't think so please explain why?

[bookworm]

Doesn't EASA's Opinion 2/2008 (http://www.easa.europa.eu/ws_prod/g/rg_opinions_main.php) suggest an extension of at least a year to the transitional period?

[Malcom]

Option 3 is proposed to cost a measley revalidation fee of £50 per 500kg plus the additional investigatory charge at £122/hour.

This will be EVERY YEAR since you will be in the "uncontrolled environment"

How long did your last STAR inspection take? Remember that was done by someone who knows your plane!

Cheaper - I cant see it!


Anybody know of any CAMOs for GA types??

[Rod1]

“On 28 september 2008 all aircraft will have be contracted to an EASA part M maintenance company”.

Nope…

Option 4 Go LAA and avoid all the crap.

Option 5 Go FAA and avoid some of the crap

Rod1

[vee-tail-1]

Do most of the maintenance yourself under the supervision of the person issuing the ARC. Even if you have never fixed a car let alone an aeroplane take a maintenance course with the LAA. Yes I know, for many pilots getting their hands dirty would be a new experience, but that is what EASA allows you to do and it sure saves money :hmm:

[S-Works]

Option 3 is proposed to cost a measley revalidation fee of £50 per 500kg plus the additional investigatory charge at £122/hour.

This will be EVERY YEAR since you will be in the "uncontrolled environment"

How long did your last STAR inspection take? Remember that was done by someone who knows your plane!

Cheaper - I cant see it!


Anybody know of any CAMOs for GA types??

What investigatory charge?

My engineer tells me that apart from a yearly ARC there is no difference from. So £108 I think it is on top of the annual. My annuals and star annuals and not charged any different as the inspection is the same.

[IO540]

There is a 1 year delay and the creation of a sub-1000kg and sub-2000kg categories, with different requirements. I spoke to somebody today who has just come off some EASA course. But nobody really knows what will happen by the time it's all done.

Remember that was done by someone who knows your plane!

Most maintenance companies in the UK don't do a particularly good job, squirting WD40 everywhere. IMHO, the way to do maintenance which is good but at the minimum cost is to get very pro-active. Owners who just take the plane to some company and hope for the best will always get shafted, on quality, on cost, and usually both. And the certification regime merely enables crap work to be done legally - just like ISO9000 supports crap companies making crap products. This is what I like being on N-reg - there is a good choice of freelance maintenance engineers. The freelancers (or one man bands) will always be the best.

[Malcom]

This Investigatory charge:


http://www.caa.co.uk/application.aspx?catid=1513&pagetype=65&appid=27

""It has been proposed by EASA, through its CRD, that there shall be a requirement on a Competent Authority, at the request of an aircraft owner, to carry out Airworthiness Reviews itself in respect of non-commercial EASA aircraft of 2,730 kg MTOM and below and all EASA non-commercial balloons irrespective of weight. The current Airworthiness Scheme does not cater for the cost recovery of any Airworthiness Reviews in connection with Airworthiness Review Certificate reissues/extensions that may be undertaken by its staff. Therefore, this consultation proposes to remedy this situation""


The LAMS Annual and the STAR inspection have never been the same thing. Have a read CAP520, even though its out of date. Free STAR Inspection? Lucky person!

[jxk]

Doing it yourself means that you're not working in a 'controlled environment' any maintenance organisation worth it's salt wouldn't be prepared to except this as they have to sign-off all the work done up to the ARC submission. I also understand that if you do decide to go the DIY route it will require CAA surveyor input which will probably cost more than using a Part M maintenance organisation. Now the sad thing is that MOs are going to be landed with a lot more bureaucracy as well extra licensing costs and this ultimately means more costs to owners. It would seem that the UK CAA are as usual interpreting the new rules more stringently than our European counterparts.
I ask the question: what was wrong with the old M3 system?
I know some owners think that their existing MOs are not very good but do you really think they will be any better under EASA; same guys handling the spanners!
Re the LAA - this is fine if you don't want to fly over towns and cities or don't want to fly in IMC or at night and the annual permit renewal is not any cheaper than the annual ARC.

[Jodelman]

Re the LAA - this is fine if you don't want to fly over towns and cities

This really isn't relevant. When was the last time you heard of a CAA prosecution?

[A and C]

Rod 1

I was rather expecting that most people on this forum would be able to work out that the statment all aircraft was applicable to EASA aircraft only. After all the title of the thread was "EASA part M what are you doing?" Apparently I am wrong to assume that you are smart enough to work that out for your self.

Vee-tail-1

EASA part M requires a subpart G company to supervise the paperwork and an approved maintenance company to do the maintenance, this can be a company that holds both approvals. A subpart G company may well not have a licenced engineer and so the company issuing the ARC may well not have the authority to issue the CRS for the work done on your aircraft.

IO540

It would be nice if the CAA would communicate these things to the companys that have applied for EASA part M approval, I have not been told a thing about this by the CAA.

jxk

M3 maintenance was not perfect but on the whole it was a good system, the only problem with it is that it would not keep enough eurocrat snouts in the feed bucket. (annex 2 aircraft will stay on M3 for the time being).

So back to the question, have any of you put in place a contract for your EASA part M maintenance and have you decided on option 1 or 2 ? as option 3 is not a cost effective option at all.

[vee-tail-1]

Still the penny has not dropped for many people. EASA has changed the rules of the game. Sure you can continue as before and be ripped off by unscrupulous maintenance organisations. & the CAA will goldplate EASA rules to ensure they collect fees for work which EASA never intended.
But part M contains a comprehensive list of tasks that an owner can do on his aircraft. That same owner can take his aircraft to a specialist maintenance organisation and TELL THEM to do the jobs for which he is not competent.
He is then free to take his aircraft to any part m sub part G&I org and request an ARC. If they start to hum & hah he can tell them to get lost and find another usually independent engineer to do the job. Also he could go to any qualified engineer in any EU member state where the costs are much less. PLEASE stop treating engineers and maintenance orgs like gods and start to see that they are there to do what YOU want, not what they think they can get away with. I know cos I am an engineer!
A & C Don't know if you read French but since part M is based on the current French system that would be a good way to understand what is proposed. Go to www.gsac.fr Click on telechargements, then on documents, scroll down to MGM Manual for airworthiness maintenance organisations. This manual gives everything you need to know as to how part M should work in practice. Like I say its a whole new ball game for us in UK...better get used to it, and not try to hang on to the old ways that sometimes amounted to extortion.

[A and C]

vee-tail-1 you are so so wrong!

To have a part G company issue an ARC you have to stay within the "controled enviroment" of that Part G company. Yes you can change the company that maintains the aircraft but not the part G company that supervises that maintenance.

Once you step outside the "controled enviroment" the CAA fees will cost you dear.

As to the list of things that you can do these have to be approved by your maintenance company and they have to check that you are able to do these tasks, in effect they will have to issue with a "simple & limmited" approval as part of that maintenance company to carry out these tasks.

[vee-tail-1]

A and C
EASA gives the owner authority to issue a CRS for work done according to the list of tasks in part M. For the tasks which the owner has requested be done by a specialist organisation, they had better issue a CRS or they don't get paid! So the sub part G organisation has no need for an engineer to issue a CRS and can get on with checking the paperwork prior to issuing an ARC.

What you are saying is probably what the CAA wishes to impose on us as its "goldplated" version of part M. Are you working for the CAA?

But this is against both the letter and the spirit of what EASA intends, and is certainly not the part M that the French propose in their very helpful GSAC manual.

[vee-tail-1]

The main cultural difference brought in by part M is type specific maintenance programs. These are specific to the aircraft type and its mod state. They say what has to be done and when to do it, no interpretation needed. Any competent mechanic (or owner) can achieve full maintenance, and it is easy for the work to be checked. It looked as if LAMS would be ditched, but the CAA managed to keep it by re-branding it as LAMP and getting it into part M as an alternative to the type specific programs. So once again providing scope for "creative maintenance" in some UK organisations.

[Malcom]

OK -so we face cultural change. This ball started roling years ago - when will it stop?
9-08 or 9-09 or when? The uncertainty is what is the problem. We need to know facts - not proposals for a Part M system which is in place!

If you take your car to a MOT Tester and tell him everything is done and "pukker" what will he do? Unless you wrap your **** in a £50 note he will go the extra-picky mile just for the benefit of your wallet.

The ARC is more than a paperwork exercise. Have a look at MA710. Your G&I company will not act any differently to the MOT man. If they have cause to hum and ha, they also hum and ha to the NAA - (MA710h). It is not in their best interest to do otherwise, and not in yours as the owner. They are not there for your benefit - they are there for the NAA's.

And never, never TELL him what to do, always ask him nicely (via a wriiten works order of course) or that extra-picky mile will seem never-ending!

[jxk]

As has been stated the CAA are/will be the 'competent' authority in the UK and have been interpreting the proposed EASA rules with gold plating. From my knowledge of how the French currently do their maintenance I can't believe that they will accept the kind of rules that the CAA are trying implement in the UK.
And as for owners doing their own maintenance this may be true but how many would want to and how many would you feel happy to see do the work?
Ultimately a MO will have to sign-off the ARC to say that the work done, modifications, fitted equipment, ADs and etc are satisfactory. Would you be happy to let any Tom, Dick and Harry do work on your aeroplane and sign for it?
If you work for a M3 organisation you must know that even as things stand there is an awful lot of research and paperwork to do when it comes to applying for an ARC or CofA (appendix 2). I don't see that the proposed parts F & G do anything more than what's being done today except they involve a lot more red tape and expense for the MOs.

[S-Works]

Well my engineers interpretation of the rules is the same as Veetail and I don't see any change in my cost of operation as a result of it. If I did I would just head to France and get the work done there.

With all respect to the fine engineers out there, perhaps it is time they starting working to quality and price and not gold plating regs to secure business.

[A and C]

I am still trying to find out if owners intend stay inside the "controled enviroment by taking a contract with a subpart G company to supervise the mantenance of the aircraft and then "shop around" for the maintenance to be done by any company that might be avalable at the time.

OR

Contract both the supervision and the maintenance to one company and do this for three years to stay inside the "controled enviroment".

So far I see a lot of misunderstanding of the system as the CAA intend to apply it in the UK and not a lot of companys yet approved to do any work.

The last time I checked only nine supervision/maintenance approvals under part M had been issued and this with the implimentation date five months away.

[A and C]

You must have a very nice engineer if he is not going to charge you any extra for all the work that he is going to have to put in to get the required Part M approvals. He will certantly be cutting in to his proffit if this is the line that he is taking. I have to ask if your engineer has got his part M approvals yet?

Please remember the maintenance industry did not ask for or want this European system, it has been forced on us by Brussels but the choice is stark, put up the prices to cover the extra paperwork/approval costs or run the risk of going out of business.

I notice that no one has been able to answer the question that started this thread! perhaps it is because there is so little understanding of what is going to happen.

[Malcom]

A & C

I believe we had this conversation at Xmas - good to see nothing has changed, apart from the posibility of a years grace, and no firm progress with the NPA, but it is still very much head in sand throughout GA.



Malcom

[vee-tail-1]

I guess there's only a small number of pilots who have the competence & confidence to do much of the maintenance work on their aircraft. Also since they would need to work from a type specific maintenance program, this would restrict them to the mainly French aircraft whose manufacturers already provide such programs. Some people should never be let loose with a spanner, and the CAA are probably horrified at the thought of DIY aircraft maintenance.

However the CAA are out of order if they interpret EASA rules to prevent competent owners working in the un-controlled environment. Under my interpretation of part M owners have a choice between the NAA and any CAMO to renew their ARC once a year. In the controlled environment the ARC is renewed every three years, but you have to take out a contract with the CAMO to do the work...no DIY.

[IO540]

I guess there's only a small number of pilots who have the competence & confidence to do much of the maintenance work on their aircraft.

The 50hr checks are easy for anybody who is mechanically competent. It's probably true that most owners can't do it but the system should not prevent it.

Also since they would need to work from a type specific maintenance program, this would restrict them to the mainly French aircraft whose manufacturers already provide such programs.

Do Socata offer this? I haven't seen this.

Some people should never be let loose with a spanner,

most of whom already work at EASA145 certified companies :)

and the CAA are probably horrified at the thought of DIY aircraft maintenance.

I don't see why, looking at some of the cowboys who they already certify.

The best maintenance my plane gets is when I do the 50hr checks, working with an A&P/IA colleague. It's the only time it gets proper lubrication, with bearings packed with fresh grease instead of a squirt of WD40.

[DFC]

Bose-X is correct in his assessment.

Some maintenance providers are having to get their act together and are having to put some work in to bring their operation up to a minimum acceptable European level.

I simply hope that owners are not as foolish as A and C plus many other maintenance providers would like them to be.

Every manufacturer produces a maintenance program. If you contact your manufacturer they will provide the relevant guidance and documentation.

There is nothing wrong with you drawing up your own program and having it approved.

In the absence of the above 2 then you can simply use the CAA's generic light aircraft maintenance programme with the relevant type specific issues added.

So once again - Nothing much is going to change other than a few bits of paperwork. Many people knew that a long time ago and nothing has changed. It is not a case of head in the sand but a case of having it sorted and not believing those that are trying to cash in on those that do not know better.

Regards,

DFC

[Malcom]

Most maintenance manuals contain an inspection program already, but these dont often contain everything needed to make a suitable maintenance program. LAMP is pretty well ready to go with a component list & AD compliance list. The TB10 manual contains one for normal use and a progressive program too.

In the Controlled environment you can still do your own stuff, provided the CAMO authorises you, assesses your competence, etc.

By all means do your own maintenance - all for it, but your ARC revalidation cost is now a complete unknown. At £122/hour proposed, CAMOs will be in a position to undercut the CAA at £120/hour.

Malcom

[IO540]

The TB10 manual contains one for normal use and a progressive program too.

That's news to me. I enquired about progressive maintenance options for the TB20 and none existed, N-reg or G-reg. This is true for nearly all GA aircraft, anthough progressive maintenance (avoiding Annuals and all other calendar-time-fixed checks) is common on big stuff. PG for GA would be brilliant because the process could be spread over a sequence of 50hr checks, instead of the Annual check being confined to ... the Annual, and this could be used to avoid the dependency on a specific company.

[Malcom]

IO540 - you seem to imply being tied to a MO to be in the Controlled Environment.
You are not going to be tied to any Maintenance Organisation, any Part 145 or Subpart F MO can be used. You are only tied to a CAMO to retain the Controlled environment status.

TB10 inspection program is in the Maintenance Manual section 5. Most recent types have this as a part of their certification process.

Nearly all GA have these inspection programmes in their Maint. manuals.

[jxk]

Regarding owners doing their own 50hr checks. I would like to see how owners check the AD status and sign that they have been complied with the requirements without the necessary access to the information. From my experience those who sign for a 50hr don't work to LAMS/LAMP schedule and often make it a paperwork exercise only. Most just do an oil change and think that's it! I know that some people posting here are competent engineers and do a good job but this isn't always the case. It would also seem that a few here have had a bad experience with their MO and seem bitter about it. I don't believe the introduction of Part M will remedy this!
It would seem that no one on this forum has has really any experience of how Part M will work but I stand to be corrected.

[A and C]

You can indeed do some of the work on your aircraft but the question is who is going to renew the ARC?

In your case you seem to think that it is just a matter of putting the paperwork to the CAA but the £122/hour to check the paperwork and the day out from the local CAA office to conduct the aircraft survey are going to sting you so hard that you will be in no doubt who the fool in this conversation is.

The strange thing is that as much as I am opposed to the part M thing DFC thinks that the rest of the maintenance industry and myself are trying to rip-off the aircraft owner by fooling them into some sort of bondage, the truth of the matter is that I would like to see aircraft owners get the best from the system however most of you seem to have not given these important issues much time and this is likely to cost you a lot if you take no action.

We are on page two of this thread now and no one has attempted to answer the question that I first asked, I am begining to think that no one knows what this subpart G is all about.

If you own an aircraft you MUST get the with the program on this or you will fall outside the "controled enviroment" and into the hands of the CAA at £122/hour. please don't take the advice of the likes of DFC on these forums but go talk to the a few enginering companys and the CAA and get the true story.

[Piper.Classique]

Ho hum
Got an annex two a/c
Don't want to go LAA, it is a glider tug. So the CAA is now pushing us to go LAA, and that will mean if we accept; that it isn't a glider tug any more:mad:

[IO540]

I don't know anybody who does owner maintenance totally alone. Normally it is done as an "owner assist" and obviously you need a friendly engineer to do it with.

The information isn't hard to get. One normally has the last Annual worksheets and return to service schedules of ADs etc complied with and together with mfg data one can work out which ADs need to be done. On the TB20 there is very little in between annuals; nothing I recall recently.

And the manuals ... one can buy "used" ATP CDs on Ebay :) This also has the wiring diagrams and the IPC, which is very handy. In fact socata.org has the official up to date TB maint manual online, which is even better.

I think owner maintenance has its place - in between Annuals which are rarely doable by the owner for the usual airfield political reasons: cannot work in the hangar, cannot do a lot of work anywhere because it upsets based maint firms, the gossip circuit, etc. But a Sunday morning is perfect for a 50hr check in which everything is properly greased, not the WD40 squirt job which the "proper" MO is doing. When I was on G-reg I used to pay £600 for 50hr checks (JAR145 MO) and no way was that good value.

[DFC]

I would like to see how owners check the AD status and sign that they have been complied with the requirements without the necessary access to the information.


There has always been a requirement for owners to ensure that ADs etc are complied with. They are also required to ensure that any revisions to the maintenance manuals are incorporated.

Far too many owners have simply assumed that the maintenance organisation they ask to complete their maintenance did all that......but the responsibility lies on the owner.

That is why owners must ensure that the manufacturer or in the case of the manufacturer no longer being round the responsible authority have their correct address.

Nothing has changed in this regard either.

-------

A and C,

I have not offered any advice. I have simply stated my position and my opinion on the matter.

Cessna has a progressive maintenance programme that you can get from them and you can have it approved.

IO540,

You need to speak with the manufacturer, they and you can agree on a progressive program. When you have the agreed program in place simply start using it.

In your case you are better placed if you can approach them directly and perhaps with a non-UK address. Don't bother trying it via the UK distributor and hence the non-UK address to avoid stepping on their toes.

Regards,

DFC

[ACX]

I would think that there would be huge differences in the costs between an aircraft in a controlled environment and those that are not.

People seem to be forgetting that in the un-controlled environment, to get the CAA to come out and renew the ARC, you first need a sub-part G to make a recommendation to them to renew the ARC, thus you will need to pay the sub-part G to do a full review and then the CAA costs on top. This is verses just paying the sub-part G an annual fee to do the job anyway.

With regards to owner maintenance, I have no problem with this and know many competent owners who do this and in some cases know more about their aircraft than I do, but I do have to agree that most forget about AD’s and as such, may have just done a very nice 50hr check, but have forgotten about the AD that is due every 50hrs or actually have done it; but an owner can not sign for an AD and thus could find himself flying illegally. Remember that most older GA aircraft have 50hr reoccurring AD’s, whether it be the old magneto switch check or just putting the additive into the oil. They all count as AD's.

ACX

[gasax]

It is surprising just how little many owners seem to know about their responsibilities.

As DFC has pointed out it is all the owners responsibility. The CAA may have licensed the engineers and the company they work for but that is almost irrelevant, the owner is responsible for the content and quality of the maintenace of their aircraft - and amazingly there is case law to back it up. So to a large extent the CAMO stuff is not terribly relevant. It will remain the owners responsibility.

So if you get 'stiffed' by a fairly typical CAA licensed engineering company - it is your fault.... Wonderful situation. Given the present level of competance of UK aero engineering cocmpanies I congratualte myself on choosing a permit aircraft.....

If you have a decent company stay with them, if not it is the usual shop around...

[IO540]

As DFC has pointed out it is all the owners responsibilityThat statement may be legally true but is surely meaningless, as the vast majority of owners barely know what an "AD" stands for. Most owners just drop the plane off at their dealer and collect it some time later, not asking any questions.

TBH this is a difficult area because if you (the owner) get pro-active with a MO which has been doing it a certain way for many years, they are going to get cheesed off and may get aggressive. One is immediately into the usual airfield political issues and unfortunately one cannot consider how Mart M etc is going to work without considering these.

For example, I am sure the majority of owners don't use a based MO for their maintenance - they fly away somewhere. Then if there is a dispute re the work, they don't end up doing you know what on your doorstep. One must not fall out with the MO on the airfield - one day you will need their release to service (even if their work is crap - irrelevant) so you can fly somewhere where required work can be done. If the based MO is crap then the only way to not fall out with them is to rarely if ever use them! And that is what you just have to do.

This is why I am unhappy about regs which appear like they tie the owner to a specific MO. In this business so many people have the owner over a barrel already.

[Malcom]

IO540 """This is why I am unhappy about regs which appear like they tie the owner to a specific MO. In this business so many people have the owner over a barrel already."""


I say again:

""IO540 - you seem to imply being tied to a MO to be in the Controlled Environment.
You are not going to be tied to any Maintenance Organisation, any Part 145 or Subpart F MO can be used. You are only tied to a CAMO to retain the Controlled environment status.""

Your CAMO need not be your MO.

As for usng "used" CDs, be very careful - you must use current maintenance data or you invalidate the C of A and insurance, etc.

[IO540]

Your CAMO need not be your MO

How would that work politically - if say the CAMO is on your airfield, and perhaps owns your hangar or even the entire airfield, but the MO you actually use is elsewhere.

[Malcom]

Your choice of CAMO and MO is exactly that - yours. You need to weigh up any politics in your assessment, or move?

The CAMO could concievably be a man in a bedroom somwhere. He is only managing the aircraft - not working on it. He would visit the plane at the MO to do his surveys.

The three of you - owner MO and CAMO will be contracted to each other so any politics will have been dispensed with at the outset.

If you had a combined CAMO/MO on your field, why go elsewhere anyway? But. that is your choice

[IO540]

The CAMO could concievably be a man in a bedroom somwhere. He is only managing the aircraft - not working on it. He would visit the plane at the MO to do his surveys.

The three of you - owner MO and CAMO will be contracted to each other so any politics will have been dispensed with at the outset.

I think that the man I spoke to the other day (just come off the EASA course) was training for just this. He doesn't do actual work, just certification paperwork.

This sounds interesting.

If you had a combined CAMO/MO on your field, why go elsewhere anyway? But. that is your choice

The usual reason for not using a local company is a) to get a decent job done or b) to keep one's own doorstep clean if there is a dispute over the work. As I wrote before, the local outfit must be available for AOG work; if you burn your bridges with them, you are stuffed and are into the realm of travelling engineers which ISTM are pretty rare for G-reg.

[Johnm]

I'm signing up with a fairly large but reputable outfit. They are just doing my annual and after they'd taken the aircraft to pieces the engineer walked me round every little part and discussed the action plan in copious detail, this discussion was orchestrated by the senior management of the company.

He showed me all the dodgy elements and was certainly thorough but in no sense attempting to over-engineer the maintenance of a 40 year old aeroplane.

In discussion we also agreed to overhaul the engine and I shall be seeking advice on run in and engine management from experts here and elsewhere in due course;)

The overhaul shop are also happy for me to go and look at their work and I probably will next week

I have no doubt that the final bill will be an eye watering 5 figure sum but I shall have an aeroplane I thoroughly understand in good nick and I'll then try and keep it that way through regular maintenance.

I will get the EASA C of A via CAA and the rest of the paperwork. I can and will do some of the maintenance myself going forward, but there are practical issues. I have a good set of tools and I'm mechanically competent but I don't have a hangar and maintenance in the middle of a field is not ideal!

[giloc]

People seem to be forgetting that in the un-controlled environment, to get the CAA to come out and renew the ARC, you first need a sub-part G to make a recommendation to them to renew the ARC, thus you will need to pay the sub-part G to do a full review and then the CAA costs on top. This is verses just paying the sub-part G an annual fee to do the job anyway.

I don't think that's correct. For aeroplanes < 2730Kg, if a CAMO has recommended that the CAA renews or reissues the ARC, then the fee to the CAA is £25 per 500Kg MTOW. The CAMO has already done the Airworthiness Review, so you don't pay the CAA their £122/hour to do it.

[robin]

You should remember, though, that the CAA has priced its part of the process actively to discourage owners using the CAA.

They (and EASA) want our a/c to be in the controlled environment and will be making life in the 'uncontrolled environment' expensive and inconvenient

[Malcom]

Confusion reigns again! It is either the CAA or the CAMO who recommend the ARC revalidation. If you're in the uncontrolled environment you can choose between finding a CAMO who will take you on for the occaison, or go direct to the CAA

If the CAA does the ARC, £25/500kg plus £122/hour is proposed.

If a CAMO does the ARC £25/500kg plus whatever their charge is.

[giloc]

It is either the CAA or the CAMO who recommend the ARC revalidation.

There is now a third option for ELA1 aircraft (includes aeroplanes < 1000Kg). For these aircraft, the airworthiness review may be performed by appropriately qualified independent certifying staff for two consecutive years. In this case, the airworthiness review must be performed by a CAMO or by the CAA once every three years. See M.A.901(g)

[robin]

The ELA1 line is still only a proposal, isn't it? At least until they get round topassing the necessary legislation

[IO540]

Can anybody say what is the latest proposal for 1000-2000kg?

[vee-tail-1]

Part M is based on the present French system for EASA aircraft: The owner signs a "Declaration of Maintenance" acknowledging full responsibility for maintenance of the aircraft. Includes full understanding of the maintenance program, repetitive and one off ADs, service letters, etc. Owners are expected to have subscriptions with manufacturers for Service letters, and to keep updated on ADs via the GSAC website and/or EASA website which will automatically send all new ADs to subscribing owners.
The type specific maintenance program is obtained in my case from Robin/Apex and it has to be "personalised" for the state of equipment, engine type, etc and then submitted to GSAC for approval. The approved program has my name and signature printed on each page and becomes legally binding on me. I am entitled to carry out all work in the program myself, or contract some or all of it to a maintenance organisation/engineer. No matter who does the work I am responsible for it and will be held liable if the MO screws up.
This is the cultural difference I mentioned earlier. If you have been in the habit of giving your aircraft to the MO and "letting them get on with it" you are putting yourself at risk. For if by using LAMS or LAMP the MO misses something and there is an incident, YOU the owner are responsible. You should have supervised the MO and ensured they were doing the work correctly using the appropriate documentation etc. Up till now UK MOs have used LAMS/LAMP with all that entails. There was no need for manufactures particularly French ones to provide an English language type specific program. I had to translate my Robin program into English for my own use, but the approved version is in French. It may be that UK owners can submit programs to the CAA for approval in the original French, pointing out that French is one of the official EU languages! Whatever happens don't try to maintain your aircraft using LAMS/LAMP if you are not an experienced engineer. for you will surely miss something vital. Type specific makes it easy to achieve proper maintenance. ELA 1 may well be similar with perhaps a lighter touch.

[IO540]

For if by using LAMS or LAMP the MO misses something and there is an incident, YOU the owner are responsible

I wonder how that squares up with that other weird concept: the law? Surely, in cases of negligence... Also one cannot expect the owner to remove all the inspection covers etc after the firm has done the Annual.

I wonder how this is supposed to work in practice.

Whatever happens don't try to maintain your aircraft using LAMS/LAMP if you are not an experienced engineer. for you will surely miss something vital. Type specific makes it easy to achieve proper maintenance.

LAMS is a ripe area for all kinds of practices, ranging from minimal (but legal) maintenance, all to way to outright cowboy practices.

For example I have a TB20, for which the Socata maintenance manual specifies a huge long list of stuff to be done. I am sure nobody in the UK does that whole list. It would take "too long". Most UK MOs do the inspections listed (they are quick) and the lubrication is done with an aerosol can instead of dismantling/re-greasing (bearings with grease nipples are done with a grease gun, but many don't have nipples). This is OK if you don't fly in the rain too much, or keep the plane outdoors... but it complies with LAMS.

Now, on the N-reg, I do all the real lube on the pilot maintenance; the 50hr checks. The Annual is just a legal requirement on which little is done beyond the inspections.

[robin]

If you have been in the habit of giving your aircraft to the MO and "letting them get on with it" you are putting yourself at risk. For if by using LAMS or LAMP the MO misses something and there is an incident, YOU the owner are responsible. You should have supervised the MO and ensured they were doing the work correctly using the appropriate documentation etc.

And that is what worries me. As a reasonable pilot but next to useless maintainer of mechanical equipment, I shouldn't be trusted with a screw-driver. It is ludicrous to expect me to supervise my highly-experienced and trusted MO.

In fact, in English law, there is likely to be a test of 'reasonable-ness', but that would take a few cases to end up in court to establish it, and that could take shedloads of money and time.

Owners are expected to have subscriptions with manufacturers for Service letters, and to keep updated on ADs via the GSAC website and/or EASA website which will automatically send all new ADs to subscribing owners.


Really - this is the first I have heard about this

[vee-tail-1]

Look up:-
http://ad.easa.europa.eu [EASA Airworthiness Directives Tool] Very useful just enter your aircraft type in the search box and all relevant ADs are displayed.

www.gsac.fr (http://www.gsac.fr) click on "telechargements" and on "Consignes de navigabilite" also includes the guides to implementation of part M, and much other useful stuff. All documents, forms, the Declaration of Maintenance, responsaibilities of owners, responsibilities of maintenance orgs, etc, available on this easy to use website.
If you have a piece of equipment which might be subject to AD action, enter the manufacturers name in the Resp for navigabilite section and the ADs will come up. EG: enter "MT Propeller", or "Becker radio", "Lycoming", etc.

http://www.apex-aircraft.com/
(http://www.apex-aircraft.com/support/support/-nav.php)
Click on support, and support-navigation for list of ADs, SLs, SBs, etc.
Being a commercial outfit, they will charge you money for details of the SBs, SLs, and type specific maintenance programmes which are part of the French language manuals.

[ProfChrisReed]

vee-tail-1 wrote:

Look up:-
http://ad.easa.europa.eu (http://ad.easa.europa.eu/) [EASA Airworthiness Directives Tool] Very useful just enter your aircraft type in the search box and all relevant ADs are displayed.

Unfortunately not so. I tried this for my glider (Schempp-Hirth Open Cirrus, first manufactured 1967) and the site said no ADs. I know this is not true!

Looking at the search boxes, the earliest ADs you can search for seem to be from 2003. If, as with my aircraft model, there have been no reported problems in recent years, then the site returns no matches.

I suppose if you know all ADs to date have been complied with this might be OK, but as someone pointed out previously there are recurrent ADs which, if older than mid-2003, this site won't show.

The User Guide section specifically states that the site is to inform users about new or amended ADs, so it might be worth registering to get these automatically via email. For older ADs you need a different source (the BGA site for gliders, for example).

[diso]

A and C and all,

You are wrong with your initial post, only aircraft of over 2730kG MTOM and aircraft operated as CAT have to be managed by a CAMO by Sept 2008.

Details of the proposals can be found in this document

http://www.easa.europa.eu/ws_prod/r/doc/opinions/Translations/02_2008/Opinion%2002-2008%20v6%20for%20publication.pdf

Read page 12 paragraph 42 to to 45.


The first thing to remember is that EASA will be providing an extension to the existing system for at least one year to allow the changes they propose to make to Part M to come into effect. So don't panic unless your aeroplane is over 2730 Kg MTOM or you operate as CAT.

Under the new proposals, as I understand it, your continuing maintenance will depend on a number of things,

1 are you an owner/operator.
2 are your operations classed as CAT
3 the MTOM of the aircraft
4 aircraft is non complex or complex

The proposals are, that if your aeroplane is non complex and under 1000 kg MTOM (EA1) and you are an owner/operator, you will not have to enlist the services of a CAMO, therefore you will not have to operate in a controlled environment. Your maintenance engineer (as I read it any licensed engineer and not necessarily belonging to a subpart F organisation) can look after your aircraft with much of the work being undertaken by the pilot/owner if he wishes to or wants to undergo some training or is deemed to be competent enough. The licensed engineer should be able to renew the ARC twice with the third being done by recommendation to a CAMO or National Authority by the licensed engineer (very similar to the old CAA system with star annual every third year).

It must be assumed that if the MTOM is in the next band ie 1000 - 2000 kg (EA2) or is a complex aircraft you will fall under the CAMO umberellea, the same goes for aircraft between 2000 Kg and the upper limit of 2730 Kg MTOM



I too own an Annex II aircraft on a CofA and therefore will take no part in all this EASA stuff, but I have been following the maintenance side of things as I work with a licensed engineer who is a one man band and not tied to an organisation.

Piper Classique

As I understand it they will relax the rules on aircraft used as glider tugs so the practise can continue with the LAA if necessary, but I'm interested to know what information you have regarding Annex II aircraft and their continued airworthiness. I have contacted somebody in the LAA regarding this and it would appear that there will be approx 350 aircraft left on Annex II with a legitimate CofA. There is no information coming from the CAA about what organisations will be allowed to look after them. The only thing I have learned is that M3 organisations will continue to be licensed as such at no extra cost when they apply for EASA Subpart F approval from the CAA. I too hope that Annex II aircraft all end up on LAA PtoF but, unless de Havilland Support go under and cease to support all the aircraft they hold the Type Approval Certificates for, I doubt that this will happen. Please PM me for further.

[S-Works]

I have just had my first ARC done and it was no different from any other year. My engineer does not seem worried so at the moment I am relaxed about the situation. If it changes then I will review it. No part in getting worked up over it!!

[giloc]

The ELA1 line is still only a proposal, isn't it? At least until they get round topassing the necessary legislation

It is already included in EASA's Opinion 02/2008.

I have just had my first ARC done and it was no different from any other year.

In the UK, the processes for issuing the initial non-expiring C of A and the ARC are essentially unchanged from existing national arrangements. The new requirements will apply from 28 Sep 08 (or 09 depending on what the CAA decide on the transitional arrangements.)

[Malcom]

Diso,

Proposals aren't the law. Opinions aren't the law. You have to go with the law as it stands.
> Part M as it stands will be the law as of 28-9-08.

All EASA types will have to be managed to be in the Controlled Environment unless these proposals to amend Part M do become law.

What if the proposals to change dont go through? What if they change yet again some more?

It was said by the CAA some time ago there would not be any extensions to that date, but now look!


Bose-x

Youv'e just had a "Transitional" C of A and ARC Issue, issued the same way as a M3 recommendation. It is the next one that you should think about.

[diso]

Malcom

I accept what you say, but the eurocrats change the law based upon recommendations made by governing bodies such as EASA. I doubt that these recommendations or opinions will be objected to do you? So I think you can be pretty sure that the transitional provisions will be implimented.

If our dear old CAA said that there would not be any extensions to 28/09/08 it was probably based on information fed to them by EASA. EASA make the rules not the CAA.

I agree that Bose-x has just had a transitional CofA or ARC, and his next one will almost certainly be transitional as well but after that ?????

[giloc]

Proposals aren't the law. Opinions aren't the law. You have to go with the law as it stands. Part M as it stands will be the law as of 28-9-08.

An EASA Opinion is essentially a draft of legislation sent to the European Commission. The Commission, or the Council of Ministers, or the European Parliament could reject it, but at this stage that seems unlikely, so I'd say it's wise to plan for it being 'the law'.

[robin]

I agree that it is quite likely to become law, but the guys at the Belgrano only follow the actual law in place at the time.

Think of how many times governments promise to change the law and then fail to do so.

In this case, the work is still on-going until the law is actually changed

[giloc]

The point is that aircraft owners, maintenance organisations, competent authorities, etc, need to plan for the changes that Part-M will bring. After an extensive process of consultation and refinement involving several NPAs, consultations, and CRDs it's clear that such planning should be based on the latest draft amendments to Commission Regulations 1702/2003 and 2042/2003 that have now emerged from that process.

[Malcom]

No one can plan ahead with any degree of confidence in the proposed system until it becomes law.
How many planned for the original Part M for 9-08, only to find out they have wasted a lot of time and effort because they may not need it for another year yet, or to find many owners may not necessarily need a CAMO anyway?.

[giloc]

How many planned for the original Part M for 9-08, only to find out they have wasted a lot of time and effort
Well, according to EASA, as far as MOs and CAMOs are concerned, very few.

Nevertheless, there's no doubt that Part-M for non-commercial use has been a moving target over the last couple of years. However, the latest changes have come out of a widely publicised consultation process to which very many 'stakeholders' have contributed. As far as I'm aware no more consultations on the relevant Commission Regulations are planned.

or to find many owners may not necessarily need a CAMO anyway?.
The only significant change in this regard has been for ELA1 aircraft used in non-commercial operations. Owners of these aircraft may need a CAMO only every third year instead of once a year. But it is an additional choice for owners - if they have a convenient CAMO that they like they could use it for every airworthiness review.

I expect that for many owners their existing maintenance organisation will move things over to the new regime for them pretty seamlessly. But for those who want to understand their choices and make an informed decision about how they should proceed, ignoring the NPAs until 28/9/08 or even 28/9/09 is pointless.