Part M - CAMO - etc

[S-Works]

Ok, so am sat here trying to get a grip on the EASA stuff.......

If an aircraft holds an EASA CofA and an ARC is it now supposed to be under a CAMO?

An aircraft that had a ARC in April 2008 and the allegedly non expiring CofA expires in April 2009 how do you get the ARC renewed?

[JUST-local]

If it is used for non public transport and under 2730 kgs, it does not need to be in the controlled environment of a camo.

It will however need to have its ARC renewed by a camo with part i (arc renenwal/ extension ability).

If it has been looked after by them for the last 12 months (in controlled environment) they can exend the arc for 12 months.

If it has not they must renew the arc.
All arc processes are similar amount of paperwork to the good old c of a renewal.

All clear as mud and a few changes occured back in December meaning we are not all grounded pending the CAA renewing our arc's!!

When the CAA get the paperwork going, I belive in a month or so the easa class under 1000KG simple aircraft (152's etc.) will be able to avoid camo's and have the work and arc renewed by a part 66 licence holder (with arc renewal ticket). This will be ok for two years then the third year will be done by a camo! sounds aufully like the three year c of a!

If it is a public transport aircraft (on aoc etc. not hire or reward/ flying school) or over 2730 KG or both! then you must be in controlled environment and be under a CAMO with contract etc.

This is only my interpritation of the rules which I have been reading for some time, they have been very slow to come out and the caa web site is not very clear for either owner/ operator or companies doing the work/ approvals for subpart f or g.

So if it is your Cessna 172? (seen in an old post), you take it to your part 145 or part F company who do the annual inspection (and may change lots of lifed items that have been on since new, seatbets etc!) If they are part g as well they will renew your arc as well or may get another company to do it or you could.
Class dismissed :rolleyes:

[bookworm]

If it is used for non public transport and under 2730 kgs, it does not need to be in the controlled environment of a camo.

Shouldn't this be "commercial air transportation"? Sounds pedantic, but EASA has a much narrower view of what constitutes "commercial air transportation" than what the CAA classes as "public transport" (which includes rental).

[JUST-local]

bookworm is correct.

They, EASA use the term CAT (commercial air transportation). Was late, again!

Simply operated under an air operators certificate.

[robin]

Typical of the CAA, making changes just after we have been persuaded to sign up to a contract with a CAMO which will cost us around £2500. :ugh:

[Justiciar]

under 1000KG simple aircraft

What does simple mean? Does this exclude VP/CS prop and retractable gear?

[JUST-local]

The new ELA (European light aircraft) 1 cat:-

A non complex mtom not above 1000kg
hot air balloons not exceeding 3400m3
gas balloons not exceeding 1050 m3
and it goes on about more and more airships etc.

Sure there is more details but I am unsure where they live. anyone?

Don't worry there will be another catogory covering things above 1000 kg for all the 172's, Warriors, bigger Robins etc.

All good but a bit late really :ugh:

[S-Works]

Thanks for the replies guys. So as my ARC has expired and my engineer is only Part 66 and the company that were doing the ARC stuff have called it a day I am out in the wilderness.

I have to either find an ARC company that will accept my existing engineer or move to another engineering company that will do the work and the ARC?

[peter272]

Hi Bose

I think it might be slighly worse than that.

If understand the rules if the ARC has expired you need to get an engineers and CAA approval to move it to where it can be inspected assuming you don't have facilities on site.

This costs.....

[S-Works]

Yep, the ferry permit side is sorted. It is more the way forward that I am looking at.

At the moment I am considering putting it back on the D reg or the N reg.

[Cows getting bigger]

Bose, have a chat with Brinkleys at Meppershall.

[S-Works]

I have decided to go N reg.

Sorting out a trust now and engineer to issue the CofA.

I fear that under EASA light GA (non permit) is going to be hunted to extinction. Even if I get a few more years out of it on the N Reg it will be worth it.

As a comparison, under EASA I am facing:

Prop Overhaul for a prop that has 700 hours on it from new.
Mag overhauls because they are over 500 hours
Vac pump replacement at 500 hours
Seat belts replacing as they are 10 years
Static lines replacing

None of those items has any problems at all, they all work perfectly on condition. So why do I need to spend nearly £7k to throw perfectly good kit away?

[SergeD]

7k is not soo much. Here http://www.pprune.org/private-flying/330423-caa-director-airspace-policy-170-000-bonus.html you wrote you would not work for as little as 170,000 GBP. those overhauls you have to do under manufacturer requirements anyway.

[S-Works]

7k is not soo much. Here http://www.pprune.org/private-flying...000-bonus.html you wrote you would not work for as little as 170,000 GBP. those overhauls you have to do under manufacturer requirements anyway.

Not exactly my field of expertise.......

Under FAA those overhauls become on condition items and overhauling a prop at 700hrs is a waste of time and money. Why should I pay out for nothing?

[Justiciar]

non complex

Which means ??

[giloc]

non complex
Which means ??

Complex-motor-powered aircraft is defined in EC 216/2008. In summary it means:

(i) an aeroplane: with a maximum certificated take-off mass exceeding 5,700kg or; certificated for a maximum passenger seating configuration of more than nineteen, or certificated for operation with a minimum crew of at least two pilots, or equipped with (a) turbojet engine (s) or more than one turboprop engine; or

(ii) a helicopter certificated: with a maximum certificated take-off mass exceeding 3,175kg or; for a maximum passenger seating configuration of more than nine or certificated for operation with a minimum crew of at least 2 pilots; or

(iii) a tilt rotor aircraft;

[Justiciar]

That's good, so non-complex still includes vp/ retractable - that makes a huge difference to the GA market

[jxk]

As a comparison, under EASA I am facing:

Prop Overhaul for a prop that has 700 hours on it from new.
Mag overhauls because they are over 500 hours
Vac pump replacement at 500 hours
Seat belts replacing as they are 10 years
Static lines replacingI believe even under N reg rules all of the above items are still required and it is a US manufacturers specification that demands that they be done. In effect EASA are just implementing what the US manufacturers edict in the first place. It is still within the scope of a part G organisation to extend the life on some of these items although it may not be sensible for them to do so. If your maintenance is based on the LAMP and is an acceptable method of compliance then in some incidences it can give you a little more latitude than working to the manufacturers schedule.
To go back on the N reg should/will require a complete investigation of all your previous maintenance and little things like non standard upholstery will require you to prove that it meets fireproof standards.
Of course if you find a UK based IA who is prepared to overlook some of the above it no different to a dodgy maintenance outfit in the UK.

It would seem to me that the only reason to go on the N reg would be to allow you to fly using an American IR; which would seem a little less daunting to obtain than the UK IR.

[jxk]

If you want to work out your ARC procedure you could try the CAA website below:

Renewals/EASA Transition - Touch It Once | Airworthiness | Safety Regulation (http://www.caa.co.uk/default.aspx?catid=720&pagetype=90&pageid=9362)

And good luck!

[SergeD]

bosex, is that 700 hours propeler overhaul a 6 year overhaul? Other ways, there is no need to do it.

[A and C]

Quote

Prop Overhaul for a prop that has 700 hours on it from new.
Mag overhauls because they are over 500 hours
Vac pump replacement at 500 hours
Seat belts replacing as they are 10 years
Static lines replacing

Interesting attitude!

As the owner of four aircraft I have found that Slick Mags require the 500 hour at just over 500 hours or the internal timing falls out of limits making for poor low speed running & starting, At about 600 hours the Vac pumps fails with no warning what so ever.

Just two issues that I would think the serious IFR pilot that you seem to be would give some consideration to.

As for the prop is that not the manufactuers limits ? not EASA.


As you may guess form other posts I am no friend of EASA however you seem to think that the FAA is unlikely to want you putting an aircraft on the American system just so you can cheapskate on maintenance.

[S-Works]

It is not about cheapskating, it is about having the option to run items on condition. Justify to me why seat belts NEED replacing at 10 years that the engineer deems to be serviceable. Justify to me why a prop with 700 hours from new NEEDS to be overhauled rather than inspected just because it is 6 years old?

I am all for ensuring quality of maintenance and ensuring safety, but we have to draw a line somewhere.

EASA is going to drive GA into extinction with this stuff. It therefore forces people to look elsewhere. The FAA seem to take a logical view which is to trust the engineers to decide if something should be run on condition.

A and C - Go, give me a reason why my static lines need replacing rather than inspecting and my engineer using his expertise to decide if they need anything doing with them? Same goes for the mags, they work perfectly, if they did not I would overhaul them. My last vac pump did 1500 hours and failed gradually so I replaced it.

I am not looking to cut corners, but at the same time I am not prepared to blindly just throw serviceable stuff away. Does that make me a cowboy?

[smarthawke]

But as others keep telling you, it isn't EASA making up the inspection/overhaul periods it is the aircraft manufacturer and it's all stated (and therefore required to be complied with) in the Maintenance Manual for the aircraft.

Doesn't matter where the aircraft is registered, the Maintenance Manual has to be complied with - if you don't want to replace the seatbelts every 10 years, sell the Cessna and buy a Piper.

McCauley and Hartzell mostly have 6 year overhaul periods on their CS props regardless of hours (how do you know what the internal condition of the hub is?) - McCauley have the same overhaul period on their fixed pitch props too. Sensenich FP props were 1000 hour overhaul period but extended it to 2000 hours.

Cessna stipulates in the MM a 500hr mag inspection (note 500hr service NOT overhaul) - Piper don't on say the PA28-161 - it just says 'replace or overhaul as required or at engine overhaul'.

So don't blame EASA or the CAA about the cost of maintaining your aircraft - have a go at the people who built the aircraft and its components.

[robin]

Smarthawke

You are wrong. It is EASA that have dumped the previous 'on condition' situation. The manufacturer's recommendations were just that, but EASA has taken that and made it a requirement.

Given that most light aircraft fly only a relatively few hours per year, this is an unwarranted impostion and additional cost.

What worries me is that my engine with 1000 hours against a 2000 hour 'life' may need an expensive maintenance because the 12 year calendar life - new from EASA - has appeared from nowhere.

A friend scapped a perfectly serviceable prop because it was scheduled for an overhaul, the cost was fractionally less than buying a new one. So rather than have the prop removed and checked and risk that it was out of tolerance, he went straight for a new prop.

We are not commercial outfits for whom these are legitimate business expenses. All this comes out of our taxed income and each new requirement (Mode S, Part M, PLB/ELT) just makes it less sustainable. :ugh:

[jxk]

Robin
I think part of the debate was that by moving to N reg it would obviate the need to comply some of what might seem to be nonsensical maintenance requirements. What was being pointed out was that N reg maintenance can be just as onerous.
Even under the old CAA M3 rules there were 100s of UK derived ADs which should have complied with - a lot of these disappeared when the move to EASA was implemented. I believe that SIDs (Supplemental Inspection Document) were being ignored by UK maintenance organisations. With regard to woobly props, under the old UK rules there was a Notice 75 every 3 years regardless of hours.
My advice would be to seek out a good maintenance organisation with Part G + I who should be able to help through what might seem a new and tortuous procedure.
HETLFT and flack jacket on!

[S-Works]

JXK has made the point I was trying to make. It is the new and stupid regulations that have been imposed that I am looking to move away from. The service manuals do dictate things like prop overhauls and seat belts, but the FAA allow them to run on condition and be changed when the engineers recommend it not just because they have reached some arbitrary figure.

I know the condition of my prop, it has a notice 75 inspection 100 hours ago, I would expect the engineers to inspect during the 100 hour and if they have an issue to recommend a solution. I do not see the benefit of dictating an overhaul without the need for it. The prop is lifed at 2400 hours, when I reach that then I expect to overhaul it or if it is damaged before then.

If a seatbelt has no damage and is in good condition then I why should I replace them? Why can't I refurb them rather than throwing them away?

Static lines, if they are inspected and deemed serviceable, why throw them away for the hell of it?

We are being hammered for our direct carbon emissions on the fuel, has anyone considered the carbon cost of producing all of these unneeded new parts and the fact that the old stuff ends up in land fill?

Safety always comes first and I will always maintain the aircraft to the highest standards. I will take the advice of my engineers and follow it, after all it is there signature that says the aircraft is airworthy.

[JUST-local]

Slick mags have a life limit which is the same a the tbo of the engine.

Slick recommend a 500 hour inspection so under EASA you must do this and I would also strongly suggest it is done anyway.
I can not imagine that FAA reg. aircraft with these mags miss such an important inspection.
You will usually find they need parts at 1000 hours or 1500 hours from new, the odd one needing somthing at 500 hours.

Lets be realastic a 500 mag inspection is around £100.00 + Vat + parts + removal and fitting/ timing.
It should take no longer than a couple of hours for the spannering! The parts however have gone silly at the moment with the $ being strong, mind you so has the price of a new mag.

Bendix mags are lifed at 4 years between overhaul! not inspection!!! Not sure about the hours without getting the book out, stick with the slicks....

[IO540]

I think there are some misguided views around.

Mags are about the weakest link on an engine. Overhauling them at 500hrs is a desirable thing. Just make sure it is not done by a cowboy.

Overhauling a prop at 6 years (which it sounds like this is) is perfectly reasonable too. Nobody knows the internal condition by looking at the outside of the hub. Anyway, based on previous postings (http://www.pprune.org/private-flying/354004-flying-hours-2008-a.html) by its owner here and elsewhere, that 6 year prop has done about 1800 hours, not 700 hours, so needs looking at. Again, make sure it is not done by a cowboy (like that well known firm which got shut down for forging a load of prop overhaul documents).

The static lines are probably a waste of time but they cannot cost that much... Changing the seat belts is definitely a waste of time if they look brand new, but the mountings need checking for corrosion (should be done annually).

The vac pump WILL go one day; probably before 1000hrs. Changing it at 500hrs is reasonable. That's about 50p/hour on the engine fund.

One can buy all these parts mail order from the USA, at good prices e.g. here (http://www.qualityaa.com/index.php) and here (http://www.aircraftaccessoriesofok.com/).

What is legally required is another matter. It is a bit complicated but I gather that only items listed in the Airworthiness section of the MM are mandatory; the rest are optional under Part 91. Overall, I have not found a significant saving in regular maintenance costs from being on the N-reg. The EASA moves do put costs up but the cost of doing the various small items is not that much. It is more irritation to take apart stuff for no good reason, than anything else, and this extra stuff results in the aircraft ending up in worse condition because of the monkey spanner people dismantling everything every year.

[smarthawke]

It is a fine line between what is actually legally required and what is recommended or interpreted as being required.

Case in point is the Slick 500hr inspection. On, for instance, the PA28-161 there is no call up for a 500hr inspection. Slick has a Service Bulletin to say that a 500hr inspection must be carried out but that is not mandatory as it is only a SB. LAMP leaves it to the discretion of the CRS signatory to determine what should be carried out to ensure the safe continued operation of the aircraft when it comes to continuing airworthiness stuff - like maufacturers SBs.

Normally, mags fail shortly after a 500hr inspection has been carried out....

PS If the prop on the aircraft in question actually had AWN75 carried out 100hrs ago, with the hours that it apprently flies annually, one would have thought the owner would have been better advised to bring the overhaul date forwards that few months....

[jxk]

bose_x
In theory a Part M - G organisation could make a decision as to whether eg seat-belts need replacing or even simpler whether an oil change is required however in these days of litigation would they or you take the risk of prosecution. You would be surprised how far the AAIB can go in establishing the provenance of parts even they are not related to the cause of an accident.

[IO540]

jxk

Normally, mags fail shortly after a 500hr inspection has been carried out....

If done by a cowboy, sure.....

You would be surprised how far the AAIB can go in establishing the provenance of parts even they are not related to the cause of an accident

Is the above real or hearsay? I think it is more hearsay because if many AAIB reports were anything to go by, many maintenance shops in the UK would have been shut down yet clearly this has not happened. Almost none (none?) have ever been shut down by the CAA, and the UK prop shop I mentioned got busted by the FAA, IIRC.

The reason why SBs are not generally mandatory is because when a manufacturer applies for a Type Certificate, he surrenders control of maintenance control to the certifying authority.

This is how e.g. the Lyco 12 year engine life is circumvented. The CAA and the FAA allow on-condition operation to say 2000hrs on public ops, and beyond 2000hrs on private ops. So Lycoming could stick a 12 month life on the engine but they would not be able to enforce it because they don't control it.

[jxk]

IO
Is the above real or hearsay? I think it is more hearsay because if many AAIB reports were anything to go by, many maintenance shops in the UK would have been shut down yet clearly this has not happened. Almost none (none?) have ever been shut down by the CAA, and the UK prop shop I mentioned got busted by the FAA, IIRC.From my experience it's real. Of course it's not the job of the AAIB to shut down maintenance organisations; it's that of the CAA. The CAA & AAIB are independent organisations but no doubt if the problem was significant there would some communication between them. I was just making the point in context of why or why not it may be acceptable to apply reason to allowing components to run on pass their shelf life etc..in the Continuing Airworthiness Environment.

[IO540]

Well, yes, the AAIB do voice opinions on maintenance. The recent fatal Sandown PA28 crash, with the well trashed engine, is one recent example. But the CAA does nothing about this, evidently, which makes the AAIB's views worth next to nothing.

Deciding what to change is often tricky. I (N-reg) could run a lot of stuff "on condition", and with a "suitably chosen" maintenance company could tacitly allow the ticking of a lot of boxes representing work done but not done. Unfortunately, planes are not like cars which can be fairly safely run into the ground without the owner giving a damn. The owner does have to get pro-active and has to understand which bits are important and which should therefore be done, even if not legally necessary.

And this applies equally on N-reg and G-reg, because the "box ticking" culture is widespread, and EASA will not change anything there.

A while ago, one American chap in the Socata user group wrote that he found a crack in his prop hub, and didn't like the cost of fixing it. It turned out his prop was 1985-original and never been looked at. I don't think 23 years on a prop is wise, but where does one draw the line? I average 150hrs/year which makes a £3k prop overhaul about £3/hr, which is hardly significant, along the engine fund of £10/hr. I got mine done at 6 years, not least because it was full of nicks (flying to airfields with sh*tty runways covered in stones) which had been individually dressed out.

As already stated by others, this thread is a bit of a puzzle because the owner in this case has claimed to be extremely rich and to fly a huge number of hours, yet the 700hrs probably does represent a 6 year prop overhaul - is there an earlier overhaul period? I though the 3 year one is gone and it is now as per the mfg, which is normally 6 years.

I have done two mag overhauls. One at 500hrs and one at ~ 700hrs when the engine was rebuilt for SB569A. Each one turned out fine, and the 2nd one was done in the USA (with the engine) and cost hardly anything which is why I had it done; to make sure the engine started off as a new known quantity. With a single shaft dual mag engine, this is definitely the weakest link in the engine...

[jxk]

Well, yes, the AAIB do voice opinions on maintenance. The recent fatal Sandown PA28 crash, with the well trashed engine, is one recent example. But the CAA does nothing about this, evidently, which makes the AAIB's views worth next to nothing.The AAIB Sandown report made reference to the well known Lycoming camshaft wear problem but I don't think they implied it was the cause of the accident. As you know the only test required on an engine is the differential compression test and although the cam might be worn in can only be detected by metal in the filters or by removing a cylinder for a visual inspection. I always felt that the 5 minute climb test embodied in the 3 year flight-test was the most useful part of the process and good for detecting poor performance, however this is no longer required under EASA rules (what about the FAA?). What I'm trying to say is that it would difficult to blame a maintenance organisation if compressions were good and there was no metal found in the filters.
Have you or do you ever carry out this 5 min climb test and compare the results with the POH performance figures??

[IO540]

The AAIB Sandown report made reference to the well known Lycoming camshaft wear problemThe well known Lycoming camshaft wear problem isn't going to make 40% of your cam lift disappear up the oil filter, without somebody noticing.

What I'm trying to say is that it would difficult to blame a maintenance organisation if compressions were good and there was no metal found in the filters.
Have you or do you ever carry out this 5 min climb test and compare the results with the POH performance figures??I partly agree in that the pilot should have spotted the fairly obvious shortfall on the book performance, on takeoff, at any time during the preceeding few years! My feeling is that a number of people dropped the ball on that one, over some years, including the final day.

I do the climb test every time I fly, making sure I get the right FPM. The 5 min climb is difficult as I would get done for busting CAS. Also, on takeoff, I check the MP, 2575rpm and the expected 23.6GPH flow rate. With instrumentation, one can see something isn't right.

[S-Works]

I think some people are missing the point here in the usual name of attempting to sling mud.

My issue is around spending on work that has not needed to be done under the old regime and now suddenly needs doing. Last year the prop was fine, this year it needs overhauling because the rules have changed not because the state of the prop has changed. Because of these rules I am going to have to have both of my props overhauled because they have reached an arbitrary life figure. So much for having a spare prop.

The same goes for the other stuff. If it NEEDED doing I would be happy to do so but to be forced into without a good reason grates with me.

I am not talking about trying to cut corners it is the principle of changing things for the sake of it. Rolling over and accepting it is going to force GA into extinction.

How much money I am or may not have or how many hours I or the aircraft may fly has nothing to do with it. It is the principle of the matter.

[A and C]

After 500 hours the only way to check the internals in a Slick Mag is to take it apart and look inside.

I cant see how without taking the mag apart how you can see if it needs servicing.

[S-Works]

After 500 hours the only way to check the internals in a Slick Mag is to take it apart and look inside.

I cant see how without taking the mag apart how you can see if it needs servicing.

There is a difference between an INSPECTION and a compulsory overhaul/replacement. I was told that they needed overhaul, however I now have the extracts from the Cessna service manual that show what is needed and they picture is becoming very different from what certain maintenance organizations are painting.

Not to mention the fact that the only investigation work that needs to be carried out by a new company is any work done since the last ARC, not the back to birth that some are claiming. As nothing has been done to my aircraft other than the 50 hours since the last ARC there is nothing to investigate. The seatbelts can also be run on condition along with a number of other items that I have been told have to be replaced. This answer from the CAA directly.

Following some excellent advice from an old friend I shall be staying G and not going into a controlled environment.

This is just an example of how the rules are not clear enough and a number of maintenance organizations are using the opportunity to rape us.

I shall probably end up getting both of my props overhauled as one is 700 hours and the other is 1900hrs but I will stagger it over a couple of years to keep some reserve on life.

[jxk]

bose_x

Without trying to be controversial; how do know for certain that the items you have listed are really satisfactory? The reason for instance, the prop is checked (3 or 6 years) is not only to check for bearing problems but to ensure that the seals remain in good shape. How can you ascertain this without stripping the hub down? As IO has pointed out with certain magnetos they are deemed to be good for only 4 years regardless of hours.Very often it's not the hours that are the limiting factor it's time in service where corrosion can set in and cause failures. Who would get the blame if your seatbelts failed in an accident? Not you but your maintenance person for not complying with the requirement.
There are more worrying things going on the aircraft world other than maintenance; what about fuel & oil supplies, airfields closing, lack of facilities and limited hours due rising costs.

[S-Works]

There are more worrying things going on the aircraft world other than maintenance; what about fuel & oil supplies, airfields closing, lack of facilities and limited hours due rising costs.

There is not a lot of point there being plenty of oil, airfields and facilities if no one can afford to get airborne to use them. Maintenance is an equal part of that equation. Doing stuff for safety is one thing, doing needless work is another.

If we do not trust our engineers to make the correct decisions on what needs replacing then why license them in the first place?

The system of engineers making sensible decisions on what is required has served us well for decades. The FAA as IO freqently points out serves the vast majority of world aviation and they have been firm supporters on reviewing based on the condition rather than arbitrary figures.

My aircraft have operated perfectly safely for many years by allowing the engineers to do the job they have trained and become experienced in, I have seen no evidence that there is a safety case to support a change.

I have seen proof that these new costs are forcing people out of aviation. I have a friend who is facing an 8 grand annual to replace stuff that the engineers not him, deem to be perfectly serviceable. Seat belts are just one example, £1500 to change a set of serviceable belts.

Who would get the blame if your seatbelts failed in an accident? Not you but your maintenance person for not complying with the requirement.

Tell me exactly how a serviceable set of seat belts are going to fail in an accident?

[smarthawke]

Re ARC subsequent issues, it comes down to how much a new CAMO trusts the previous CAMO. The buck, as usual, stops with the last signature. Personally, if an unfamiliar aircraft turned up on my doorstep for an ARC issue, no matter how many ARCs it has had before, I would ensure that ALL mandatory requeirements had been complied regardless of what another engineer said.

Now of course if all engineers were created equal then it wouldn't be a problem, but....

The CAA may state what the legal case is and what they require but they aren't going to have their licences pulled for someones elses failings.

As for the interpretation of allowing items to continue 'on condition' where the Maintenance Manual states otherwise, I know what my CAA surveyor would say to that.

[alphamikeecho]

I do have a concern about these!

Having purchased an aircraft which used to be looked after by a reputable maintenance company last year. The aircraft is nearly 30 years old, the seatbelts were the original ones despite the fact the manual says they are supposed to be lifed at 10 years. Fair enough you might say to run on condition. Except the pax seatbelt was attached to the airframe by a tiewrap, and when the belts were removed (to be replaced) the stitching fell apart.

Now maybe the owners had a say in not replacing them at the last check, but someone released that aircraft to service.

Luckily we didn't have to test the old belts in anger. Now we have fitted ones that aren't lifed.

ame

[robin]

Personally my issue is a company that has maintained the aircraft for over 10 years now finding faults.

What were we paying for over the past 10 years before Part M and are we entitled to cash-back.....

[IO540]

I would ensure that ALL mandatory requeirements had been complied regardless of what another engineer said.

Surely, maintenance has to be done on trust.

One company is entitled to assume the previous one did the job right.

Otherwise, you would end up paying for an Export CofA Annual every year, which is stupid.

[smarthawke]

I totally agree IO - if it were a perfect world. Unfortunately, it isn't a perfect world and as I said - he (or she) who signs last will be held responsible for the aircraft's airworthiness as a whole regardless of what has been done before. This means that, as far as you can, you ensure everything has actually been done that has said to be done.

The ultimate result of this is the threat of losing one's income due to someone else's error when the authorities come investigating. And I like my job, it saves me getting a real one....

[IO540]

who signs last will be held responsible for the aircraft's airworthiness as a whole regardless of what has been done beforeDo you have a reference for that? It is very much against natural justice and would never stand up in Court.

Take two scenarios I can think of, where I turn up at your firm for an Annual. Current TT is 800hrs; last Annual was done (different company) at 650hrs.

(1) My mags are at 800hrs, OH reqd at 500hrs, logbook entry exists to say it was done at 500hrs

(2) My mags are at 800hrs, OH reqd at 500hrs, no logbook entries on the subject

IMHO, in case (1) you are in the clear because you are 100% entitled to assume that the logbook entry is not a forgery. Otherwise, please provide a reference to the contrary, and actual case law. This cannot be legal because it would make you liable for the previous firm's document forgery.

In case (2), it is not so clear, is it? I'd like to see the legal guidance on this, if there is any. You are entitled to assume that last company did the job right, no? If not, that opens a huge can of worms because basically every plane going for an Annual with incomplete past records will need a full Export CofA. But I can see a directive to this effect standing up legally - despite being practically unworkable because of how much detail do you go into? This would be dealt with with professional liability insurance; accountants and solicitors have the same problem (conveyancing is one example where you can be sued for previous peoples' stuff).

I have had situation (2) on my plane (more accurately, some logbook entry did not make sense because it showed some work was done but the # of hours was not related to any actual SB or whatever) and I had it re-done immediately. But hey this is my own plane, I know where it's been, and I maintain it with money no object (especially the single shaft mags ;) ).

[smarthawke]

IO, I think you are perhaps taking my words too literally.

An ARC issue requires that all the past continuing airworthiness has been carried out etc etc and the aircraft is fine fettle. At the first ARC a company would go 'back to birth' - as far as one can. At the CAA Subpart G course I attended, the CAA agreed that it wouldn't always be possible to have all the log books, workpacks etc on hand to check this. In the case of GA machines there are rarely ADs etc carried out that can't be checked for compliance at a later date. At the next ARC, you only have to review work carried out/required to be carried out since the previous ARC.

If I hadn't seen an aircraft before and was issuing an ARC on it for the first time, I would want to satisfy myself that all ADs etc that were required to be carried out, had indeed been carried out. This may be accomplished by signatures in log books accompanied with Form 1s (for instance in the case of mag overhaul), signatures in the log book pink pages etc. No engineer is likely to accept the word of an owner that the mags had been overhauled without documented proof. It's easy enough to check with the company that overhauled the mags that the work had been carried out.

I'm not sure what the problem is with this anyway. How I choose to do my job doesn't affect the owner - we charge for a 'Star Annual' irrespective of the man hours and expense I put into the paperwork side and the amount of time I put into satisfying myself that all is well is up to me.

I'm not sure why the referral to the Export CofA is about - that too is only as good as the person carrying out the inspection just the came as any Annual or Star Annual.

We took on a Mooney for a 6 month/50hr check and there was more camshaft in the oil filter than in the rest of the engine. The aircraft had flown 1100 hours in 18 years, sitting around a lot outside, then flew a 100 hours in a year, Annual carried out and the aircraft sold. 6 months and 13 hours later it came to us for the check. It turned out that the new owner had bought the aircraft ( and flown the 13 flying hours) from a CAA licensed engineer who had rebuilt the aircraft following an EFATO (water in the fuel from sitting around outside, unflown) and a landing roll through a substantial wooden fence which (documented by photographic evidence) trashed both wings and bent one blade of the prop. The wings were rebuilt (no major problems apparent) but the engine hadn't been out for a shockload. The only documented evidence of engine work was the removal of 2 cylinders for a visual camshaft inspection. The previous owner claimed the new owner had abused the engine in its 13 hours of flying and had caused the canshaft failure. Subsequently, he did contribute to the engine overhaul costs...

My point? Not all engineers work to the same standards, that is a fact of all walks of life. What I do is ensure that, as far as is possible, aircraft leave us with everything correct - mechanical and paperwork-wise.

[flyingfemme]

I don't deal with the CAA so please forgive my ignorance........

Going "back to birth" is not really compatible with "as far as one can" - one or the other. There are many, older aircraft around that don't have all logs from new. It was often the case, with imports, that foreign logbooks were spirited off never to be seen again. How far does the discretion of the ARC issuer stretch?

Presumably the paperwork from the original ARC issuance becomes part of the paperwork history belonging to the aircraft (the owner paid for it after all) - so subsequent ARC processes can simply refer back to a list of SBs, ADs and modifications in an easy-to-check format?

[A and C]

I feel that some extream positions are being taken on this thread, a CAMO has to ensure as far as is practicable that all the maintenance tasks are compleated and time life items are all in date.

Some form of documentry evidence is required, If the last CAMO had put an entry in the log book that a Mag had a 500 hour check at XXXX hours then that is good enough for me and I would program the next Mag inspection at XXXX hours +500.

The problems come when the mainteance records are poor and incomplete, the fact is that you cant trust some owners to tell the truth when they think it might save them some money, I have had one owner lie to me to try to avoid having to pay for a major safety related AD on both the mags on his aircraft.

If i had taken the guy at his word and the aircraft was involved in a major accident what would have been the outcome for me?

Recent events indicate long and expensive court action with the dependents of the pilot/passengers seeking damages and that is likely to be the best outcome, if someone decides that this is criminal negilgence then a manslaugter charge would be made.

So for taking the owners word it is not unrealistic to say that I could be jailed and pennyless.

So that Bose-x is why I am very carefull about what I put my name to because if people like you die in a crash I expect your dependents to be very quick to court to seek compensation................... this is why Engineers are very keen to keep you alive despite your opinion that we are all money grabbing pirates.

[jxk]

A and C
Good answer. Also image that it was a 747 and the engineer just took a cursory glance around and said that looks OK. Would bose_x be happy with this situation? It looks as if bose has had some pretty sloppy people taking care of his maintenance in the past and now its catching up with him..

[S-Works]

It looks as if bose has had some pretty sloppy people taking care of his maintenance in the past and now its catching up with him..

My god, where have I made any complaint about the standard of my past maintenance? That is just a plain cheecky remark and not founded on anything that I have said in this thread.

My aircraft has spent it's whole life being maintained to the highest standard and I have no complaints what so ever about it.

I am referring to my experiences of having to find a Part M company as my existing company have not got Part M. I recounting the story of what I have been told by a number of part M companies, a lot of which seems to be less than factual.

Some of you really should read what has been said before opening your big gobs and making comment on half read stuff.

this is why Engineers are very keen to keep you alive despite your opinion that we are all money grabbing pirates.

I have never said this. In fact many times I have stood up for engineers in the past when others have accused them of being pirates.

If you read my very comments in this thread you will see that I want my engineers to be trusted to make the decisions that they are trained and experienced for, not having some bureaucrat doing some arse covering exercise and making stuff that was at engineers discretion in the past compulsory.

I have always left the decisions on what needs to be done to my engineers and as a result the aircraft has operated 100% perfectly for it's entire life in my possession. I can assure you that my maintenance records are 100% accurate, maintained by my previous engineers to the highest standards and I hope that my new engineers will continue in the same vein.

Sometimes some of you lot are cheeky judgemental bastards who only looking for a fight half read stuff. Quick to fire a response with half the facts.
:ugh::ugh::ugh::ugh:

[jxk]

bose-x
I quit you win.

[IO540]

Smarthawke

I think you are perhaps taking my words too literally.

If you don't write enough detail, that will sometimes happen :)

You are however talking about checking if an AD has been carried out. I was talking about more general stuff like mag OH at 500hrs which didn't get written up in the logbook at the previous Annual (done by a different company). The first must be recorded and if not you have to physically inspect and unless it has evidently been done you have to [re]-do it; the 2nd is a bit of a grey area - IMHO - and could be used as a money earning opportunity because there is not one plane flying whose logbooks are perfect. Not one plane landing at Heathrow right now has perfect logbooks. IF you can find the logbooks all the way back, which usually you can't.

[smarthawke]

Note to self, write in more detail...! Any work carried out on the aircraft (and its components) and parts fitted should be recorded in the aircraft logs and all paperwork kept on file - ADs, checks, anything.

But, you're absolutely correct that this isn't always the case - one reason why pre-purchase surveys include log book studying but with the proviso that people only write in them what they want others to see. The unscrupulous may not include the fact that they have fitted bogus parts, not shockload inspected the engine after a prop strike etc.

One of the facts of life is that the CAA surveyors concentrate more on the paperwork side of things than the actual physical state of the aircraft (although they do love checking placards during surveys!). A number of engineers have had their licences revoked or suspended and maintenance organisations had their approvals cancelled because of paperwork irregularities. Part-M brings even more paperwork, particularly during the organisation approval process and those that struggled to maintain their M3 approvals have little chance of surviving the path to Subpart F and G....

So as my colleagues have stated, we do what we feel we have to do (ask the CAA and they'll say non-commitally 'interpret the rules as you see fit') to keep the aircraft flying safely, our customers happy and the lawyers away from the door!

[A and C]

Quote

Sometimes some of you lot are cheeky judgemental bastards who only looking for a fight half read stuff. Quick to fire a response with half the facts.

The fact is that you seem to want to have your engineers risk financial ruin and may be jail by breaking the rules set down by the authoritys to save you a few quid on aircraft maintainence.

I can assure you that in the case of an accident the victims lawers would have a field day with anyone who was unlucky to have released an aircraft to service under the Bose-X maintenance schedule.

From a technical perspective I also find you judgment a little unlikely, 1500 hours from a Vac pump is getting on for three times the recomended life of all the carbon vane pumps built today, I can only put the longevity of this pump down to a miracle of biblical proprtions or an error in your techincal records.

Good practice on the part of your CAMO will save you from the latter error but I should not count on devine intervention as a basis for airworthiness.

[AC-DC]

Quote:
As a comparison, under EASA I am facing:

Prop Overhaul for a prop that has 700 hours on it from new.
Mag overhauls because they are over 500 hours
Vac pump replacement at 500 hours
Seat belts replacing as they are 10 years
Static lines replacing

I believe even under N reg rules all of the above items are still required and it is a US manufacturers specification that demands that they be done. In effect EASA are just implementing what the US manufacturers edict in the first place.

For non commercial these are recommendations only so you can fly your prop. for as long as you want.

[S-Works]

The fact is that you seem to want to have your engineers risk financial ruin and may be jail by breaking the rules set down by the authoritys to save you a few quid on aircraft maintainence.

No A and C, what I want is my engineers to be allowed to exercise the professional judgement that they have done for decades and like they are still allowed to do under other regimes. If you can provide me with a safety case that says the FAA are getting it wrong by allowing the engineers to exercise that experience then we can talk.

In the meantime were you one of the Part M companies that I talked to that gave me the truth as it suited them?

[A and C]

I doubt if we have talked to you about any maintenance services as we usualy work with aircraft of more exotic construction (however we do have a number of Cessna's on the books).

We would of course be pleased to offer you Part G, F services or both if you should require it.

[jxk]

bose_x

Just to show how helpful I can be check the following CAA website for those organisations with Part M subpart G:
Approved Organisations | Operations & Airworthiness | Safety Regulation (http://www.caa.co.uk/default.aspx?pageid=8381)

Regards

[S-Works]

Thanks JXK, but I had already been down that route and spoke to half a dozen companies as well as the CAA. It was not a lack of organisations, rather it was a lack of cohesive answers from some of them. Some in direct opposite to what the CAA were telling me.

On the bright side I have spoken to 3 organisations via these forums who have al told me the same story independently and that matches the CAA statement.

One of those will be doing the work for me. I will not being going into a 'controlled' environment though.

[yakker]

One would have expected that an AOPA committee member to have been thoroughly au fait with Part M.

When your Annex 1 a/c was last in for an annual in April 2008 it would have been issued with a 1 (not 3) Yr C of A, (or an Annual) to take it beyond 5.1.09 when Part M became mandatory.

Therefore, this April, if it gets through its inspection by a subpart F organisation it will be issued with a non expiring 3 yr ARC by the Subpart G organisation (CAMO) to which it is contracted. This will be renewed by the Subparts G & F organisations annually thereafter.

Issues of ARCs really only started after the beginning of 2009.

All a/c under 2730kg that fall into Annex 1 have to be with a CAMO (a subpart G organisation) and maintained by a subpart F organisation, which can be the same company. Most will be the same.

A/c in Annex 2 can still be maintained by an M3 maintenance company and will be issued with a 3 yr C of A with Annuals being issued at year 1 and year 2 following as in the past. A subpart F organisation can still maintain a/c in Annex 2 as well.

Any a/c in Annex 1 can now be used for Public Transport duties as long as it meets the requirements under EASA - which mainly relate to engine life. (JUST-local is incorrect in his post; as is Bookworm)

If an Annex 1 a/c is contracted with a CAMO then ARCs are issued as above. If it is not it must go to a CAMO who, after a full inspection, can recommend the CAA issue an ARC The CAA will then go to the organisation's premises in their own time and carry out their own inspection and review of paperwork etc. at c.£160 per hour + vat. This will be on top of the subpart F organisation and the engineer’s fees

Signing up an a/c with a CAMO will cost a one off fee of c.£450 (not £2500 as suggested by "robin") dependent upon the quality of previous record keeping and a/d incorporation etc.

If an a/c is put on the D register the same rules as here in the UK will apply. Both come under EASA.

If it is put on the N register this will have no effect on the cost involved in replacing or overhauling manufacturers lifed items, as in "bose-x's" case.

In addition there is a growing move afoot against the regular use of N registered a/c in EASA countries, which could mean that they may not be able to be used in future and will have to revert to an EASA state register.

If a prop needs to be overhauled on a time or hours basis, which one suspects is the case with “bose-x”, then the FAA will still require the work to be carried out if that is what the manufacturer or Type Certificate Holder says has to be done. “bose-x” will still have to pay to have the work carried out wherever his a/c is registered. The CAA are not always behind these requirements – it’s usually the manufacturer through experience of what is best practice.

Anyway anyone who earns a huge income and flies hundreds of hours a year would surely expect their aeroplane to be maintained properly and safely for around £40 per hour, which is considerably less (by at least 50%) than, say, a Porsche dealer will maintain their motor car, if that is what they drive.

Regarding the discussion about the proposed ELA changes involving sub 1000kg MTOW a/c :- ELAC 1 states that there could be a provision for a licensed engineer to be able to issue an ARC in the future, subject to the normal full annual inspection etc. However the CAA have no such procedure in place as yet and it is thought that it could be some while – due to the existing pressures on staff – before the necessary legislation can be drawn up.

Had these good folk spoken to an organisation that has gone to the expense, time and cost of gaining Part M subparts I,F & G, and is already issuing ARCs, they would have had it all explained to them in plain English and prevented unnecessary time wasting and inconsistent speculation from sullying the pages of PPRune in this way!

As you are at Spanhoe, why not do as 'grahama' recommended and try J & J Aircraft Services at Peterborough – Sibson.

[S-Works]

One would have expected that an AOPA committee member to have been thoroughly au fait with Part M.

Not my area so why would I. My expertise is IFR and FCL that is why I leave engineering to my engineers as a rule......

When your Annex 1 a/c was last in for an annual in April 2008 it would have been issued with a 1 (not 3) Yr C of A, (or an Annual) to take it beyond 5.1.09 when Part M became mandatory.

It was issued with a 2 year CofA actually and was issued with an ARC in 2008.

CofA / Permit: EASA Certificate of Airworthiness Validity Expiry: 06/04/2009
ARC Issue Date: 07/04/2008 ARC Reference: 051371/005/001

I am not sure why so many people seem to think that this about not maintaining the aircraft properly nor is it about what I may or may not earn or the type of car that I drive.

It is about the fact that highly skilled and trained engineers who have worked hard towards the licences they hold are being told that they are no longer trusted to apply safe judgement to what work is required. This is placing a further burden of expense on GA which in my opinion a number of engineering companies are taking advantage of. There is no need to enter into a controlled environment which severely restricts your choice of engineering and pretty much would allow the unscrupulous engineer to rape you as they see fit. It is also worth owners actually sitting down and looking at the maintenance manual for their specific aircraft and seeing what needs doing REALLY. I have had an interesting eye opener on that front this week.

As I pointed out earlier (but which I assume you ignored in order to have a pop at my income, car etc.) that I have found a Part M company.

I do not expect to cut corners on any aspect of the maintenance of my aircraft, I expect my engineers to be allowed to use their discretion and gve me correct guidance on the work that needs doing. I expect them to give me good advice rather than just advice that is easy for them.

Tell me Yakker, how many ways and at what cost is their to replace the seat belts in a Cessna? Which story are you going to give me?


If an Annex 1 a/c is contracted with a CAMO then ARCs are issued as above. If it is not it must go to a CAMO who, after a full inspection, can recommend the CAA issue an ARC The CAA will then go to the organisation's premises in their own time and carry out their own inspection and review of paperwork etc. at c.£160 per hour + vat. This will be on top of the subpart F organisation and the engineer’s fees

Really? This strikes me as another example of an engineering organisation using careful wording. Must and will are my highlights. Perhaps you would care to clarify that statement and provide evidence of the must and will.....

[robin]

Signing up an a/c with a CAMO will cost a one off fee of c.£450 (not £2500 as suggested by "robin") dependent upon the quality of previous record keeping and a/d incorporation etc.



Well, signing up under most CAMOs involves an Annual fee of around £600 to over £1000 (mine is £792+CAA fee) for a 3 year contract. Making it £2500 or so over the 3-year period. From correspondence with most others that seems to be a fairly standard amount and arrangement.

Not sure where the 'one-off' bit comes in.

There is supposed to be the 'limited' CAMO arrangement for sub-1000kg but we haven't found anyone who will offer this or tell us how we can achieve it.

[vee-tail-1]

Seems to me everyone is interepreting Part M according to their individual agendas.
But Part M is based on the long established French system, which I have happily used for ten years on my UK based French registered ATL.
I started out with a maintenance contract in the controlled environment. But the cost of annuals became too high for a retirement pension, and since I am an unlicensed engineer and licensed flt engineer, I started to do my own annuals. Then I took a subscription to GSAC/EASA for ADs, and APEX for SBs, and did those as well. Now I do most of the work on the aircraft, only using certain approved workshops for items that I do not have the competance to carry out. Eg: Mag O/Hs, NDT checks, major O/Hs on the engine, detailed inspection/repairs of wooden structures. My CRS has been accepted by the GSAC surveyors when renewing the three year C of A , and I have no reason to doubt that will be the case for issue of the first ARC. After all the ARC is mainly a check of the state of the paperwork, with little actual investigation of the physical condition of the aircraft. That is one of the reasons why I do my own maintenance, then I know it has been done properly, and exactly as laid down in my approved maintenance programme.
Yes for sure most pilots would rather not get their hands dirty, but EASA allows them to save sheds of money if they do some of the maintenance on their own aircraft .
Please don't allow certain engineers to tell you what you MUST do under Part M. EASA have set it up for 'creative interpretation' of the regulations, and that allows much more scope than some would like you to know. :cool:

[bookworm]

Any a/c in Annex 1 can now be used for Public Transport duties as long as it meets the requirements under EASA - which mainly relate to engine life. (JUST-local is incorrect in his post; as is Bookworm)

Can you expand on what you mean please yakker?

All I said was EASA has a much narrower view of what constitutes "commercial air transportation" than what the CAA classes as "public transport" (which includes rental).

Do you disagree?

[JUST-local]

Please tell me what was incorrect in my post? :confused:


JL.

[smarthawke]

Funnily enough, I heard from a friend that an owner of a Reims-Cessna FR172K had enquired of a Part M (F,G & I) organisation about them carrying out an ARC renewal and Star Annual the other week.

The owner said he was intending to fly the aircraft (ARC and Annual expired and sans ferry permit) to said place for the work to be carried out. Apparently the owner then took the aircraft elsewhere - not that the owner told them of his change of mind.

The maintenance organisation was spending time attempting to source the somewhat rare Maintenance Manuals for the aircraft (build year seemingly orphaned by both Reims and Cessna) and found out through some internet forum that the aircraft had gone elsewhere! They then called the manual hunt off but a bit rude not to let them know, I reckon.

[IO540]

Yes, something along these lines written in the other place.

Annual expiredNaughty, naughty... :=

Incidentally, don't ATP do the CDs for most planes? These CDs come up on Ebay from time to time ;)

[S-Works]

Blimey, I am glad our aircraft got moved before the CofA expired.

I would hate it if my engineering company breached a client confidence and blabbed about any discussions held with them on the internet.

I managed to get a copy of the manual for my aircraft from the internet and discovered lots of interesting things.

[smarthawke]

'I would hate it if my engineering company breached a client confidence and blabbed about any discussions held with them on the internet.'

I totally agree with you about the ethics of breaching client confidence. But if Client 'X' isn't a client by virtue of the fact he had never been a client of that company and that said person had taken his aircraft elsewhere prior to any discussion, that would appear to equal no breach of client confidence.

[giloc]

Had these good folk spoken to an organisation that has gone to the expense, time and cost of gaining Part M subparts I,F & G, and is already issuing ARCs, they would have had it all explained to them in plain English and prevented unnecessary time wasting and inconsistent speculation from sullying the pages of PPRuNe in this way!
Well let's hope you're not associated with one of those organisations because most of the important assertions in your post are total hogwash!

All a/c under 2730kg that fall into Annex 1 have to be with a CAMO (a subpart G organisation) and maintained by a subpart F organisation, which can be the same company.
Wrong. The maintenance management can be done by the owner (MA201) and the maintenance can be done by an independent, Part-66 licensed engineer (MA402) - i.e. the "uncontrolled environment". (In some circumstances some maintenance can be done by the pilot/owner and he can sign the CRS (MA803) - even in an "controlled environment").

If it is not it must go to a CAMO who, after a full inspection, can recommend the CAA issue an ARC The CAA will then go to the organisation's premises in their own time and carry out their own inspection and review of paperwork etc. at c.£160 per hour + vat.
Wrong. A sub part G organisation can carry out the airworthiness review on an aircraft that is in the uncontrolled environment, and in the UK that organisation can then issue the new ARC directly. i.e. print it off there and then, and hand it to the owner. (MA901(b) and CAA Aircom 2008 3.4)

Regarding the discussion about the proposed ELA changes involving sub 1000kg MTOW a/c :- ELAC 1 states that there could be a provision for a licensed engineer to be able to issue an ARC in the future, subject to the normal full annual inspection etc. However the CAA have no such procedure in place as yet and it is thought that it could be some while – due to the existing pressures on staff – before the necessary legislation can be drawn up.
Wrong. There is already a provision in the existing commission regulation that allows an independent, Part-66 licensed engineer, formally accepted by the NAA, to conduct the airworthiness review on ELA1 aircraft and recommend the renewal to the NAA. (MA901(e)). The UK CAA have as yet failed to put in place a procedure for accepting such engineers, but they are working on it now, and expect to have the procedure in place within "a couple of months".

G

[A and C]

Sounds to me like the type of customer that you can do without!

[robin]

Wrong. There is already a provision in the existing commission regulation that allows an independent, Part-66 licensed engineer, formally accepted by the NAA, to conduct the airworthiness review on ELA1 aircraft and recommend the renewal to the NAA. (MA901(e)). The UK CAA have as yet failed to put in place a procedure for accepting such engineers, but they are working on it now, and expect to have the procedure in place within "a couple of months".

Yes, great isn't it.

Fortunately this year's ARC renewal makes no difference in Controlled or Uncontrolled Environments as to cost. Like many I've been holding off to wait for clarity, but the Annual is due next month.

Thank you EASA and CAA....... :ugh:

[yakker]

Giloc, let me make it clear, I am not associated with any maintenance organisation. Rather than me trying to give a detailed response to all the questions I would suggest to any of the doubters that all can be verified by picking up the phone to any regional CAA office (easily found from the website) and speaking to a surveyor there.
They are keen to get the message across to private owners and will happily dispel any doubts. They are, however, not likely to get into discussion regarding commercial arrangements between maintenance companies and owners and it should be understood that surveyors are known to have differing interpretations of the rules. This is likely to be the case until the rules have been in play for at least 12 months. At least thats my take on it.

[IO540]

The staggering thing is that there are several people on here who seem to be maintenance people yet they cannot agree on the basics.

This sounds like Part M was designed for the French. You tick all the boxes, sign all the forms, and do what the hell you want. And the personal relationships between the owner and the CAMO are all-important.

This is great if you are a proactive owner who has got himself clued-up, and you have a trusted-relationship CAMO which will do what you actually want them to do and will generate "whatever paperwork" as a separate exercise. That is how a lot of maintenance is done, including most training fleets. I am happy with that.

What I find disturbing are some of the paperwork costs quoted. It cannot possibly cost that much to generate and complete forms. One can automate a lot of it anyway.

But owners who just take the plane to the firm, leaving a blank signed cheque on the seat, are going to get shafted, in most if not all cases. And, in some cases, the work done will be inadequate because even though most engineers think they know everything (because they have been doing it like this for 25 years) they actually don't know everything. So, in this scenario, nothing actually changes :)

[S-Works]

The staggering thing is that there are several people on here who seem to be maintenance people yet they cannot agree on the basics.

Welcome to my world.........

It seems rare that we agree these days IO but you are bang on.

I talked to a number of maintenance companies who all told my their interpretation of the rules. It was also frightening the figures being quoted for the paperwork exercise which was being seriously overstated by some companies. I had one company tell me that before they could do any work on the aircraft they would need to do 25 hours of paperwork at £42 per hour. Then the annual was on top. I also found that some trying to apply generic Cessna lifes to items rather than looking at my actual aircraft. As it turns out according to the actual service manual for my aircraft half of the stuff that I was told had to be replaced was not required.

The prop overhauls still peeve me but the other stuff is now not as bad as the first impression.

I don't really blame the maintenance companies, I think that some have been a little over zealous but the CAA have done such a crap job of implementing this that it was inevitable it would go wrong.

[A and C]

The trouble is that we have had to take on another person and set up a new company to do the part M subpart G paperwork.
I can see how the extra person might not be required by a fleet operator once the inital problems of part m have been overcome but the introducton of Part m had us flat out before Xmas with the CAA/EASA changing the rules by the day.

What Part M is showing up is that the quality of maintenance in the UK was to say the least very vairiable. Those who used the companys at the cheaper end of the market are now hurting ar things that should have been done years ago are now flagged up my a more formal audit system.

Some anomalys have been shown up by the different "recomended" lifes that manufactures put on accessorys, I could quote a number of these items but won't because it will just give the CAA more ideas!

The CAA has now also get it's head around gliding, this it is failing to do with gusto! Some of the policys in this area are so restrictive that I am going down the political route to get them sorted because the CAA seem to be getting rather intrenched.

On one hand they are insisting for powered aircraft that recomended life items in the maintenance manual are hard lifed at this recomendation and in the other hand they won't except the manufacturers mantenance schedule despite it being excepted by the EASA state of origin and part of the aircrafts (glider) type certificate.

[Justiciar]

things that should have been done years ago are now flagged up my a more formal audit system

If other engineers are of a like mind this would seem to reinforce the need for the stricter system now in force. I am no apologist for the CAA or EASA, but that seems to be the conclusion to be drawn from your comments. No doubt the CAA would say themselves that they are still getting to grips with a new system where the rules are open to differing interpretations, e.g. whether a "recommendation" = mandatory replacement, overhall or inspection. Will EASA be giving definitive guidance in some of these areas? If the CAA continue to misinterpret the EASA regulations (if that is what they are doing) then maybe AOPA or similar will take this issue through the High Court, though somehow I doubt it.

[IO540]

The only thing which a stricter system can universally change as far as the physical aircraft is concerned is the forced replacement of serially numbered parts - because the CAMO will have to be able to show the traceability documents for these.

Non-serially numbered parts could end up on a different aircraft to the one in whose maintenance records their documents end up :)

I still think the 6 year prop overhaul and the 500hr mag overhaul are a good idea...