C.A.M.O.

[pilotfa90]

Sorry if this one has already been done to death, but I'm researching the charges made by maintenance organisations for ongoing charges under the C.A.M.O. scheme. As usual, there seem to be wild differences between them.

By the way, I understand that the value of Permit aircraft has increased significantly since the start of the scheme, as owners finally get fed up with the costs involved in running aircraft that require a C of A.

[Rod1]

“By the way, I understand that the value of Permit aircraft has increased significantly since the start of the scheme, as owners finally get fed up with the costs involved in running aircraft that require a C of A.”

I think it is more a case that C of A aircraft have lost value. The exchange rate has also had an impact on second hand value, with some LAA aircraft being snapped up at “silly money” as the Euro value was more than the perceived £ value so European owners came over to the UK to acquire aircraft.

Rod1

[A and C]

EASA part M should put your annual maintenance bill up by about £700 if it is being done properly.

This charge it made because of the costs involved with employing one more person (at a small company) to do all the extra paperwork.

[robin]

That's true, but £700 of unnecessary bureacracy which was being done already.

[Shunter]

Really don't understand why people get so upset with the CAMO crap. Just go uncontrolled... the whole thing has barely made a difference to us. Sure, we pick up some slightly elevated costs c/o the additional red tape, but it's nowhere near £700.

[englishal]

EASA part M should put your annual maintenance bill up by about £700 if it is being done properly.
Which is about 38% for us....

[pilotfa90]

Thanks Guys, keep it coming! I've spoken to 7 different local organisations. The most expensive is 700 quid a year. Some charge a one off figure for the survey, and then nothing. Some have raised their hourly charge by a few pounds to cover it.

It seems that the smaller the organisation, then the more expensive it is. I run a business which has nothing to do with aircraft ( thank God ) and I'd love to have a system which locked customers into me, I can't imagine them wanting to pay me for it though!

[JUST-local]

pilotfa90

You still have more homework to do if you think you are locked in to one maintenance organisation!

The only aircraft (fixed wing) which need to be kept in a controlled environment (locked in as you called it) are above 2730 KG MTOM and those used for commercial air transport such as aircraft operated on an air operators certificate.

So your choice if you are not above 2730 or CAT.

1. Non-controlled evironment which means a full airworthiness review (15b) each year, as there are now pleanty of companies doing this this can be done from £300.00. but like anything I'm sure there will be cheaper!

2. The controlled environment means a full review (15b) then the tasks/ maintenance is controlled (hopefully!) for the next 12 months, due to the controlled status off the aircraft this is extended again after 12 months (15a) the same again after another twelve months. At year three a full review is carried out again, simples!
As stated on here previously, charges vary greatly and some do monthly some annual and some do both!

The views on lifed items and service bulletins also vary greatly between companies, engineers and CAA regional offices!

We all want safe reliable aircraft but none of us want to throw away perfectly good aircraft parts!

[pilotfa90]

O.K. J.L., I know that I'm not strictly locked into one organisation; but if I decide to go the controlled route then it's a new survey each time I change which is far from ideal. I want to establish a good working relationship with one organisation, but the one that I'm currently with wants to charge me £700 per. year, which is £700 more than the guys down the road who seem to provide an equally good service.

[dirkdj]

In the maintenance manual of my aircraft there is an Overhaul and Replacement list.
Our CAA now says under Part M this list is compulsory and needs to be followed to the letter.
Most of these items were 'on condition' under the national maintenance regime, now changed to EASA Part M.
One owner on the field was quoted 40000€ to carry out all these items, he owns a 40 year old Bonanza.

The page 1 of the schedule reads (capitals as in the original text) :

" All overhaul and replacement times designated herein are but guidelines, NOT MANDATORY REQUIREMENTS. Climatic conditions, maintenance practices, and other factors may either extend or decrease these times. In the final analysis, adjustments in the overhaul and replacement periods should be determined by inspection findings and servicing experience."

if we have to follow the manual to the letter, how much is this worth? I would like to know how these TBO times are interpreted by various national authorities? This is for non-commercial private category SEP aircraft. Under the national regime we had declared most of these items 'on condition'.

I am speaking about landing gear motors, flap motors, landing gearbox, flap actuators, fuel selector valve, fuel boost pump etc. To me, on condition means fix it when it needs to be fixed, be it at 20 hours or 2000 hours.

[robin]

The CAA over a number of years made it clear that the pricing policy was to make the 'controlled environment' cheaper than 'controlled'.

By staying 'controlled' the annual revisit of airworthiness would be minised, so it was equivalent to the old Star - Annual - Annual - Star.

But what actually happened was that there is no benefit. The annual charge equates to the annual review, but by then many of us had signed to to a 3/4-year contract.

Worse, the CAMOs have different views of what they are doing. Ours have told us what we need to do (go to one of their subsidiaries) and when - no discussion. I've had 2 licenced engineers contradict our CAMO's view, but they won't listen, and I can't find another CAMO to take us on. So I'm stuffed. I either do what they say and get the ARC renewed, or I have a worthless pile of metal.

There was supposed to have been a change in rules post-July 2009 which means that sub-1000kg aircraft can have their ARC renewed by suitably qualified engineers. There are very few, as the CAA has made it impossible. The secret is to go Permit, as I wish I'd done

[giloc]

There was supposed to have been a change in rules post-July 2009 which means that sub-1000kg aircraft can have their ARC renewed by suitably qualified engineers.There are very few, as the CAA has made it impossible.

There are few, but it certainly isn't impossible to get the approval. I know of two independent engineers - one south, one east - who have the approval and are making recommendations for ARC issue. PM me if you want details.

[IO540]

What keeps a lot of maintenance firms in business is the fact that there are very few hangars available in which you could put your plane and get a freelance engineer to work on it.

Most hangars are owned by somebody who either runs a maintenance business, or is a mate of somebody who does, and they make sure you don't do any work indoors.

I have been doing my own 50hr checks, occassionally with a freelance A&P/IA when some extra work needs doing, but we have to pick a reasonably non-horrid weather day, and in the winter this means hats, gloves, thermals, the works. It's easier to schedule it with an N-reg because the 50hr check doesn't have to be done on any precise timing, but nobody is going to do an Annual that way because one normally does Annuals during the winter and working outdoors for a week is simply not on; anyway one cannot put a plane on jacks when it's windy, etc.

It's an occassionally depressing manifestation of the ancient rule that property owners rule the roost.

[englishal]

I am comfused by this whole CAMO lark...

Our aeroplane is currently maintained on an EASA CofA by a maintenance organisation. We haven't signed any contract or any other stuff. They do the annuals and 50 hr checks.

This time we opted to do the annual in place of a 50hr to move the annual into the winter months, a) because we're going to try and sell and selling with a new annual makes sense, and b) they are giving us a good deal on the work.

But they did mention something about CAMO fee being due in 6 months time...what is all that about and what is it likely to cost?

Tell you what, I can't wait to be shot of the G reg and onto the N reg where everything is so much simpler and the amount saved in CAA fees will probably pay for the annual each year......

IO you can always borrow our hangar for your checks...we have a nice space heater available too and it is big enough for at least 2 aeroplanes;)

[robin]

I'm thinking of moving to another CAMO.

Can anyone tell me who owns the documentation the CAMO holds about our aircraft. The maintenace programme and records of SBs and ADs that form our pack. Given that we've paid for it, can we have it when we transfer? Or does it belong to the CAMO?

[Rod1]

“Most hangars are owned by somebody who either runs a maintenance business, or is a mate of somebody who does,”

Interesting comment. My strip has 5 hangars and no maintenance business. The surrounding area has a number of similar situations, with just two licensed airfields with maintenance business. Numerically, the Strip hangarage must outnumber the licensed airfields hangarage by 4 to 1 or more. Why not do a deal with a local farm strip to do your maintenance in the dry?

Rod1

[A and C]

Most of the comments above seem to be about the cost of the CAMO and how to avoid the extra costs that result from EASA part M and the replys seem to indicate that the Maintenance companys are making a lot of money from this.

The problem is that the industry has been forced to invest quite a bit of time and effort in implimenting EASA part M so whatever happens to part M the maintenance industry will have to recover that money.

Some of us in the industry had been telling the CAA & EASA that part M was unworkable on cost grounds and was of no safety benifit with some of the EASA practices being downright stupid. The level of oversight required for a two seat light aircraft is more approprate for a corperate jet.

The result has been that the burden of regulation is has encouraged owners to take as they see it the common sense approach to maintenance by fitting parts that have no paperwork trail themselfs and not recording this work in the logbooks when in the past they would have called an LAE to do the job and he would have made sure that the parts fitted had a release note and the job was properly recorded in the aircraft log books.


So far I cant see one thing that EASA has done within GA to improve safety and all the efforts that they make are so pooly implimented as to have the reverse effect from what was intended.

[robin]

Nicely put A & C

I wish we could do as you say. Our replacement prop cost over £500 more than an identical one fitted to a permit a/c thanks to the dreaded Form 1, and it was the CAMO who insisted on changing it.

I've written to the Office of Fair Trading as the current legislation means that our CAMO can insist that we have to have work done (and where) or they won't sign off the ARC. They can refuse to accept any second or third opinion as they say that it is they who are responsible for our continued airworthiness.

Yes the CAMOs faced ludicrous charges from the CAA, but it is a restricted market and costs have gone up for all of us. As I am a hobby flyer I can't justify the cost of Part M and will be selling my beloved baby before the next annual.

Thanks EASA and s*d off CAA....:{

[A and C]

I have sympathy for your you but your CAMO also has the probelm that if is fails to meet the requirments of part M and the authoritys pick this up they will get the approval pulled and instantly have no business.

The trouble with your Propeller is not a Part M issue even under the BCAR system the prop would have needed a Form 1 or FAA 8130.

In a recent audit we have rasied some issues with the CAA and made it clear that we suspect (but cant prove) that the part M system is resulting in "underground maintenence" being carried out.

We are also have contacted the CAA CSO about a number of issues arising from the requirments for a Form 1 when parts are removed from one aircraft and fitted to another if full tracability is not an issue, we are also working on the full scope of GR24.

On a personal note we do a lot of Robin work and if yours is wooden we might be able to help you.

[a4fly]

robin, You have a P.M. !

[IO540]

Our replacement prop cost over £500 more than an identical one fitted to a permit a/c thanks to the dreaded Form 1

You can import a prop from the USA, with an FAA 8130-3. It is good enough for a G-reg, non-AOC ops.

Anyway, most props will come over with an 8130-4 - an Export CofA. Good enough for anything.

I once paid £11k for a prop with a JAA Form 1, which listed at $9k with an 8130-3.

[hatzflyer]

" I think it is more a case of C of A aircraft have lost value "

I have a Cessna 150, early model, sound, needs an annual. First £6k buys it.
Pm me if interested.

( can't be doing with all this camo crap )

[robin]

Anyway, most props will come over with an 8130-4 - an Export CofA. Good enough for anything.

I once paid £11k for a prop with a JAA Form 1, which listed at $9k with an 8130-3.

Quite - I still fail to see why the piece of paper for an identical item can add so much to the cost -in our case over 35%

[S-Works]

The problem with the whole CAMO/Part M rigmarole is that a good number of maintanance organisations have used the opportunity to lift their customers skirts to pay for the record keeping that they should have been doing in the first place. They have also taken the opportunity to charge for it at engineering rates and not admin rates.

I blame the engineers to a large extent for their greed in seizing an opportunity to extract large sums of money and blame it on someone else.

But I think it will start to come home to roost. Shooting the goose that laid the golden egg was not a very smart move.

[IO540]

I still fail to see why the piece of paper for an identical item can add so much to the cost -in our case over 35%

Lack of access to information :) :)

In GA, often the most appropriate saying is: in the land of the blind, the one eyed man is the king.

The other thing, of course, is that if you bought that $9k prop, the maintenance company is not going to make the margin supplying it (say £2k on a £11k supply) so their only income will be the installation labour at £50/hr or whatever.

One can make similar huge savings on avionics by importing from the USA - of the order of 40%, after allowing for VAT and shipping. But no major avionics shop will install the item, so this practice is limited to hands-on owners who work with a one-man installer who is probably happier not supplying the hardware as doing so would push him above the mandatory VAT threshold.

The downside is that there is no meaningful warranty on US imports, in that you cannot practically sue anybody. You can return the item... OTOH any warranty implementation in the UK tends to involve a flight to the installer's airfield, which (especially with hotels) is going to cost way more than whipping out the item and sending it back to the USA by DHL...

[A and C]

You have missed your calling in life with your talent for speaking with authority on a subject that you clearly know nothing about you should be writing for the Daily Mail.

The costs of setting up and maintaning the Part M approval are high, it is not just an admin job as you seem to think and the terms of the approval are clear on who should do and oversee the work, it is not something that can be done by someone that you picked up last week at the job centre.

We are required by the regulations to have another member of staff to carry out the EASA part M subpart G, this is why we have to charge the customer more, we are not ripping any one off, just covering the costs of doing the work that the law demands. The fact that in my opinion is total overkill is another matter, I cant do anything apart from make my views known to the CAA when I get the chance.

As always your comments on these forums are "good copy" but on this subject you are abusing your right to be wide of the mark.

[S-Works]

Spoken like a true engineer!!!

The back room cost of you running your business should not be the burden of the customer. The cost of you keeping the records for you to operate within the regulation should not be the burden of the customer.

Notwithstanding my previous comment. There may be justification in the minds of some engineers in recovering those costs from there customers directly initially. However to keep coming back is inexcusable.

Care to explain how owners doing there own CAMO work outside of the controlled environment are managing if it is such a highly skilled task?

I don't have an issue with an engineer making an element of cost recovery. What I do have is an issue with them raping there customers. I had a friend who was charged 50hours of 'engineering' work to have his books checked for part M by the same engineering company that had being doing the work for 7 years. Makes me wonder what they hell they were doing for the previous 7 years?

[robin]

Certainly each time I've spoken to CAA staff about it (actually its usually me pinning them in a corner and crying on their shoulder or shouting loudly at them), they express astonishment at the amount charged.

"Nothing to do with us", they say. "It shouldn't add any more work as the paperwork was being done already, it's just being done by a different part of the organisation".

So all in all, a fairly typical legislative screw-up with known, but unconsidered consequences.

We all told them what would happen but they ignored us. Then they brought in (late) the ELA1 exemption.

The French I note are setting up a grand-fathering right to continue a form of pilot maintenance with a licence for you to continue to maintain your own aircraft, if you have shown the ability to have done so previously.

[pilotfa90]

Coming from a business point of view, I can see why an organisation might want to make an initial charge for a survey. but why do they need to keep on charging £700 ish. year in, year out. How much more work is the organisation doing than it was doing before? Even at £50 per.hour that's a lot of work for someone to keep the records straight. For an organisation who look after several aircraft of the same type, surely that's a money printing exercise?

I'm with bose-x on the assertion that I shouldn't be responsible for the back room costs of running their organisation. Imagine sending an invoice to a customer for £700 per.year for you as a supplier to keep up with Health And Safety legislation? If they need to put up their hourly rate to remain profitable, so be it. If I'm wrong then why is their wild variation in what is being charged?

[A and C]

I think that you guys are kidding yourselfs the customer always pays for the costs of a business......... that is just how it is, the differance is with part M the costs are clear and not hidden in the labour rate.

As to the extra costs for part M shall we start with the costs of re-jigging the worksheets, a weeks worth of time attending to extra CAA inspections (we also have to do the BCAR stuff as well) CAA charges, writing the new exposision etc etc etc.

All this takes time that should be used fixing customers aircraft......... and that is what brings the money in. If I do less "real work" & more paper pushing the costs have to be recoverd from a smaller customer base.

If took business advice from Bose-X and did not pass on the rising costs that I have then eventualy I would go out of business.

So the costs of part M are going to be passed on some how and some companys tweek the labour hours and some are honest about the costs of part M, If you think that you are getting Part M for only £300 then you are kidding yourself.

[IO540]

A&C - can the extra Part M paperwork be automated, using some suitable "IT" solution?

[robin]

From my own perspective I'd already estimated the cost, based, as A & C has said, on the cost of employing new staff divided by the number of aircraft on their books.

The villains in this piece are EASA and the CAA in introducing the additional burden for no good reason.

It leads to some silly elements

Prior to Part M, I held and maintained the logbooks, my tech log had a countdown of hours to the 50 hour check and the annual.

Now I'm supposed to leave the books with the CAMO and to email them monthly the flight hours so they can update the logbooks and remind me the 50 hours are due. I tell them when I am going to do it, under pilot maintenance, so they send me worksheets. I send them back and get by return a release to service certificate.

In the past it was recorded once in the logbooks, but now we are funding the Royal Mail. I can't blame the CAMO but rather the way the CAA insist in their QA procedures.

Part M was designed along the assumption that we operate as airlines and have easy access to our maintenance organisations. A lot of us don't.

And if they ever get round (as they have said they want to do) to requiring the microlight and Permit fleet to operate under Part M rules, they'll have a riot on their hands.

[IO540]

Hang on, surely, having the MO writing up your flight hours in your logbooks (which are your property) from your emails, is somebody taking the p1ss...

Unless your plane has an AD whose applicability falls in between 50hr periods, what hours you fly between the 50hr checks is not the MO's business at all.

IMHO, of course :)

I am so glad to be N-reg. Write up all the logbooks myself, do the 50hr checks myself (with an A&P/IA who drives down) with some extras added, and for every Annual I can freely choose who does it. One of the best things is that if somebody doesn't do a job right I never need to use them again. Aviation maintenance is full of barrels, with aircraft owners bent over them.

[S-Works]

I hold my logbooks. I complete them after the flight and when I get to 50hrs I let my CAMO know. They then let me know what is due and if anything fall between 50hr checks. A straight 50hr check I do myself. Anything that needs a lifed item replacing I take to them.

I do not pay any of the exorbitant charges being discussed here. My CAMO are honest and admit that there is little extra in the way of Part M that they should not be doing anyway.

There is no requirement for the CAMO to hold your log books.

Like I said, a lot of engineers have taken the opportunity to write there own interpretations of the rules and price accordingly. The cynical like myself would say that many are exploiting the situation.......

A&C you and I never going to agree on this, however don't think that I am stupid enough not to know the rules or have a lack of business knowledge to allow you to insult me into having the wool pulled over my eyes.

[robin]

There is no requirement for the CAMO to hold your log books.

When we were talking to a number of potential CAMOs some took the line that if they were to be taking the responsibility for continued airworthiness, retaining the logbooks was part of the deal.

Again, it all comes down to the way the rules were interpreted.

[S-Works]

Again, it all comes down to the way the rules were interpreted.

And that was exactly the point I was making......
;)

[Rod1]

robin

“And if they ever get round (as they have said they want to do) to requiring the microlight and Permit fleet to operate under Part M rules, they'll have a riot on their hands.”

Reference please!

Rod1

[Shunter]

Robin. Sorry to say this, but you've been well and truly suckered.

Most of what you are complaining about is unnecessary. The maintenance firm we use, whilst fully approved, take a fairly cynical view of the whole CAMO bollocks and certainly in our case have chosen to completely ignore it, tick the extra boxes and carry on as normal.

The increased outlay is insignificant, given the overall cost of maintaining an aeroplane.

[robin]

“And if they ever get round (as they have said they want to do) to requiring the microlight and Permit fleet to operate under Part M rules, they'll have a riot on their hands.”

Reference please!

IIRC you were at the same meeting at Turweston where this was raised as an eventual aim.

There is ample paperwork to demonstrate that Annexe II is only a short-term measure. Gliders now fall under Part M, microlights were specifically mentioned and the LAA were discussing the possibility of becoming an approved organisation.

I've lost track of where things have gone since, though

[IO540]

chosen to completely ignore it, tick the extra boxes and carry on as normal.

Hang on, you can't do that. I mean, it has never been done before... I mean, it's not like the great majority of GA maintenance wasn't done that way as a default, was it??? :)

:ok::ok:

[A and C]

Bose-XQute...........
A&C you and I never going to agree on this, however don't think that I am stupid enough not to know the rules or have a lack of business knowledge to allow you to insult me into having the wool pulled over my eyes.

As ususal you seem to think that the light aircraft engineering busness is getting rich at your expence (and that of all aircraft owners), I don't see the owners of these businesses riding around in big cars and playing the tables at Le Touquet. The guys on the hangar floor are only making £15-18/hour with the businesses charging £45-50/hour for labour. By the time you take out rent, heating, CAA fees, manual subscriptions and all the other nif-naff & trivia you are not left with a lot of proffit, I only wish that I made 10% of what Bose-X thinks I make out of this game.

I don't need to pull to wool over your eyes you do that yourself with your "rip off UK" attitude that is no doubt fuelled by the wisdom aquired from reading the Daily Mail. The fact is most CAMO's are not making much money at all, for that you need to look at the likes of the CAA to who cost is no object as they have the CAMO's over a barrel.

IO540
WE have an IT guy on the case but it is only of limited help as the info has to be drawn from a number of sorces all with different sysyems.

[yakker]

Bose with your business acumen and your in depth knowledge of aircraft maintenance, why don't you set up a maintenance company at Deenethorpe? We would all bring our aircraft to you given the low costs you can give compared to others, it would be a little gold mine.

[A and C]

What a wonderfull idea, I am sure the lessons that Bose-X could teach us with his insight and wisdom would be iluminating.

[IO540]

WE have an IT guy on the case but it is only of limited help as the info has to be drawn from a number of sorces all with different sysyems.

I hate to sound cynical ;) but in my business (electronics) all regs are approached with massive cynicism, and complied with accordingly.

When BS5750, later ISO9000, became trendy, 99% of firms hired a consultant (sometimes in-house) with a brief to generate the forms and the rubber stamps, but nobody changed the end product (which, as things are, was often crap). Now, one gets "ISO9000 compliance" questionnaires all the time, with crap questions like "do you segregate defective product" (no, Sir, actually we mix it up with the working stuff and send it ALL out :ugh: ).

Then we got ROHS. A load of bollox. Every carton coming from China has ROHS stamped on it. Job done.

Now we have the bollox REACH directive. More bollox. Nobody can actually verify all the substances used in every component (every resistor, etc). So you rubber stamp all the forms with NO all the way down and send them off, and the customer's REACH compliance officer (a £40k post, no doubt) is happy. He couldn't care less.

So............. I am sure it is not beyond the wit of man to work out something to, shall we say, "streamline" Part M?

Especially in aviation maintenance, where "streamlining" not only the paperwork but the actual job is a pretty common activity ;)

[Aviator1512]

It is clear that this issue has caused at lot of confusion and expense.
It is true that the cost and change to the industry has been considerable, and unfortunately these extra costs do have to be passed on to the customer, either by a general increase in costs, or as a specific charge for the service.

However, it appears CAMOs have a very varied way of charging, and indeed how they conduct their busines, and I feel that a lot of scare-mongering has gone on.

The Part M system is nothing significantly new. Aircraft have to be maintained, to an approved schedule (sorry programme!), and their paperwork has to be kept current for the CofA to be valid. Nothing new here.
The 'controlled environment' and having an aircraft 'managed' is only new by allowing an organisation to be specifically approved for this purpose, where as before the owner/operator was completely responsible for the continued airworthiness of their aircraft. The actual task of this 'management' is not all that difficult, but for a CAMO to do it there has to be a contract in place between that CAMO and the aircraft owner/operator and much time has to be spent by the CAMO in keeping logs up to date, informaing owners when/what maintenance is due - lots of time pushing around paperwork.
Owners have a choice. You can have someone (a CAMO) manage your aircraft, in which case you have to pay, or you can do the task yourself, in which case the aircraft falls into an 'uncontrolled environment'.

For an aircraft kept in an 'uncontrolled environment' the ARC has to be renewed at year following an Airworthiness Review. The ARC cannot be extended (as it can be if the aircraft is fully compliant within a controlled environment, however the ARC can only be extended twice, so each third year requires the full Airworthiness Review').

The Airworthiness Review is not a particularly great task, but does require the CAMO to survey the aircraft, and fully review all the paperwork for the aircraft, including the Flight Manual, docs, TCDS, recent maintenance records etc. The full Airworthiness Directive compliance has to be established, as well as the status of life limited components, modifications, repairs and maintenance. However, again, nothing is new here - this has always been required for an Annual (was all in the old LAMS schedule), and had to be confirmed to the CAA for the old COfA renewal (Star Annual). So if a company has known an aircraft for a period of time they should already have this information properly recorded, otherwise they haven't done it right in years gone by.
For an aircraft new to a CAMO, it doesn't take all that long to establish it's compliance (provided the owner provides the relevant logs/docs), but it's often found that work has to be done to make it complaint (from replacing missing placards, sorting out missed ADs to replacing out-of-life parts etc) albeit these issues should have been resolved under the old system, unless an issue had arisen between maintenance inspections.

For most private use aircraft, I firmly believe, that the 'uncontrolled environment' is the most cost effective way forward. Yes you have to do the AR every year, but the cost of this (especially if done at the same time as a annual when the aircraft is already opened for inspection) is less than the cost of the management service. Typically management costs between £500-1000pa, whereas the Airworthiness Review and ARC renewal is being charged at a few hundred pounds - do the math! (The fees payable to CAA for the ARC validity is the same regardless of how the aircraft is managed).

If anyone has a specific quiery then you can PM me. And yes I am a Licenced Engineer and ARC signatory working for a Part M approved company (F&G, and M3 for you non-EASA bods), currently overseeing around 125 EASA aircraft.

[robin]

A and C

A perfect summary.

And one that shows that the CAA were more than a little economical with the truth when describing it to us at the outside.

I wrote down a quote at one CAA presentation on Part M

"The pricing has been made to discourage use of the "Uncontrolled environment".

At the original presentations the fact that the ARC renewal was cost-free led us to believe there were no associated costs in the intervening 2 years.

Any chance of GA having a crack at the CAA as a class action???

[S-Works]

Yakker, A&C, thats what I love about PPrune, as soon as someone tells a few home truths you have to resort to personal insults!! Try coming back with a robust argument that justifies why some maintenance organisations can charge very little extra in order to cover Part M and others are making eye watering charges.

When type your responses try and do it with a little logic rather than resorting to low brow insult.

[A and C]

The simple fact is that some CAMO's hide the cost within the labour rate, others are up front about the cost.

My guess is that under BCAR all the paperwork costs were hidden in the Labour rate as you would be dealing with one company.

As subpart G requires a seperate corperate identity (with all the costs of another company) the subpart F & G will require seperate billing, The subpart F & G are seperate approvals that are audited ( and paid for) seperatly and so you get an invoice from both companys.

The fact of the matter is that the subpart F bill should be a little smaller however as most of the parts for aircraft are sorced in US$ (or Euro for Robin) I would guess that the bills have gone up due to the weekness of the GB£.

The only true indicator of a ripp off is if th Subpart F labour hours have not fallen a little.

Bose X I hope that this is logical enough for you however I would like to see you try to run a CAMO, I am sure that you would soon change your tune.

[S-Works]

The company I work for is a Part 145 and CAMO for our fleet.

Thankyou for your non insulting reply though.

[vee-tail-1]

Just to add my experiences as a kind of 'joker' amongst UK based aircraft owners.
Part M is nearly the same as the French system which I have used for 10 years on my French registered aircraft. Under that system a 3 yearly CDN airworthiness review took a mornings work and cost around 200 Euros. Now under EASA part M the same airworthiness review is called an ARC in English and a CEN in French. The review can be done on any EASA aircraft by any CAMO (with the required approvals) in any member state. So far the reaction of UK CAMOs to my request for an airworthiness review on my EASA aircraft has been comical. First they are aghast that I expect them to look at the documentation only as far back as the last review. Second that I do not require any maintenance and have myself carried out and released the last three annuals under French rules. Thirdly since I know exactly how much work is involved and how long it should take, I expect and insist on the bill not exceeding £300. After 28th Sept 2010 I will no longer be able to release my own annuals, but by that time a number of French CAMOs will be up and operating offering ARC/CEN renewals at a fraction of the current rip off UK fees.

[Aviator1512]

A and C
You're not quite correct in stating that the Subpart F (or 145) and G have to be seperate companies, in fact most approved compaines have both approvals. There has to be some independancy within the organisation - the person who makes the airworthiness review recommendation should not have active involvement in the continued airworthiness management of that aircraft. However this only applied to aircraft being 'managed' within a controlled environment. The ARC signatory can be same person as the certifying engineer for whatever work has happened at the ARC renewal.

Vee-tail
You are techincally correct that the review period is only supposed to be looking at the time since the last ARC renewal, however a CAMO has to be certain of the facts, and most are not prepared to risk overlooking someone else's mistake. Albeit for a simple aircraft establishing the status of the aircraft does not take long, and as I previously stated there is nothing massively new about part-m

[IO540]

After 28th Sept 2010 I will no longer be able to release my own annuals, but by that time a number of French CAMOs will be up and operating offering ARC/CEN renewals at a fraction of the current rip off UK fees.

Presumably these firms will be able to do G-reg planes also?

however a CAMO has to be certain of the facts, and most are not prepared to risk overlooking someone else's mistake

So what has changed since the previous regime, under which an Annual was always done on trust? One has to do work on trust, otherwise you would take the whole plane apart at every Annual, checking every part for having been illegally changed in between Annuals.

[vee-tail-1]

<< however a CAMO has to be certain of the facts, and most are not prepared to risk overlooking someone else's mistake >>
What mistake? In the case of French registered aircraft, the NAA made the rules, approved the maintenance programme, issued the ADs, approved the mods, and carried out all airworthiness reviews on the aircraft since it was constructed.
For a UK CAMO to suggest that a back to birth inspection is needed in case 'someone made a mistake' is just pure extortion.
Same deal for G reg aircraft, where the CAA did the inspections before issuing a new C of A. No it seems to me that some engineers are using the new part M as a money making enterprise.

[A and C]

Vee-tail-1

I would think that those CAMO's who have taken the "back to birth" stance with ARC renewals have most likely done so because of badly kept log books and tech records. These are usualy found asscociated with aircraft that have had a lot of different maintenance companys looking after them over the years. This is normaly as result of owners playing the field in search of what they think is a better deal.

I cant see any CAMO going "back to birth" with a good set of books avalable for inspection.

We have been looking after an aircraft that was on another European register, this has been a problem in the fact that some of the paperwork looked very suspect to the CAA, This resulted in a lot of delay while the CAA checked that the documentation met the national requiements of the state of origin, The delay has cost us time and the owners money but all was (eventualy) found to be in order. Some might have said that the delay and extra cost was down to us as the CAMO by being too fussy but we presented the paperwork to the CAA and they delayed things while investigations took place, in the end the CAA excepted the paperwork as first presened to them.

I would not have recomended buying this aircraft had I been asked, not because it was a bad aircraft but because the paper trail was unusual (not wrong in any way) and likely to result in delays to issue the ARC when it was put on the UK register.

Well so much for a united European aviation industry under EASA!

[vee-tail-1]

A and C
Excuse my frustration at the way part M has been interpreted here. As I understand it, EASA intended 'harmonisation' of maintenance throughout the EU, but it seems there is way to go before that happens.

[A and C]

The problem is a political one, all the national aviation authoritys are trying to avoid the fact that they are soon to just be an EASA local office.

Some are gold plating EASA regulations, some are trying to hold on to national regulations, some are just being obstructive and the French just do what the French want to do.

All resent the power going to EASA and All are in fear of jobs disapearing to EASA.

So while this lot have a bun fight over who gets the power we have a mis-regulated industry that has to pay for the bun fight.

Vee-tail I agree with you!

[IO540]

I still don't see a difference in actual prosecution risk between

1) a MO not spotting an illegal mod done before on a part M Annual
2) a MO not spotting an illegal mod done at any previous time

Either way, when they sign off the Annual they are signing a (highly technically) bogus release to service. But some 90% of planes are technically illegal to fly, anyway. If the CAA busted "technically bogus" releases to service, every single MO in GA would be gone tomorrow.

Like the old management accounting proverb "cash is king, everything else is conjecture", in this case "prosecution risk is the bottom line, and everything else is just paperwork".

Obviously, if a plane comes with obviously crap paperwork then one cannot sign it off, but if it comes with history which looks "OK" but just happens to come via a number of different companies, their signatures must be taken on trust. That's how maintenance/certification works. Otherwise, it is ripping off the customer.

[pmh1234]

Our shop has been doing all maintanance on out 172sp for several years.
They keep a log and tell us what needs to be done at every service. A 100 hours service we have been able to do in a long day with the help of one of the aircraft owners. Usually app. 10-12 hours have been invoiced where the major parts of the hours where used on paperwork.
With part M can we expect a lot of change? The shop is offering a fixed rate CAMO service. Paying the fixed rate must be substituting all the paperwork hours, making the service bill far less???

[A and C]

While you are quite correct that subpart F & G don't require different companys however the subparts have to maintain a "distance".

When this Part M first anounced and the CAA held a number of "roadshows" the direction was very much on the lines of two companies.

We decided to go along the two companies route (after the first roadshow) so that we could offer subpart G services to companies that might not want the subart G stuff and wanted to just get on with the subpart F business.

One of the expences of Part M was the ever moving goalposts, for example just as I had got all the stuff for the controled enviroment for my C152's they withdraw the requirment........... more useless work!

I see one of the problems for the maintenance business is the new system has resulted in a bit more transparency in charging as with the maintenance split between two companies the customer gets two bills and can see what he is paying for.

The CAA charges and audits these as two approvals and so one insted of two days so my time is given to this rather than paying work, this all adds up to more paperwork and cost.

Some above are very quick to charge the maintenance business with overcharging but cant see the level of investment in time and effort required to meet these new regulations, I only wish we could charge the same hourly rate as the CAA charge for engineering investigations, then we would be making the sort of money that Bose -x thinks we are!

[S-Works]

then we would be making the sort of money that Bose -x thinks we are!

I have no idea how your particular business model works and you have not stated your fees to my knowledge so was making no assumptions about how much money you make.

I merely pointed out that I know what the rules are as I work for an organisation that holds Part 145 and CAMO. I still maintain that there are no justifications for the figures that people are quoting on here and that many engineers are using Part M as a reason to 'lift the skirts' of customers by charging for work that should already have been done if they were anywhere near competent as engineers.

The excuse for charging an owner whose maintenance they have been doing nearly a decade for a back to birth inspection of the books - £3000 for the paperwork, is indefensible. Sadly this is not an isolated case.

[A and C]

OK Bose-X

Show us the hard evidence of these ripp off charges.

[S-Works]

Please explain what you mean in terms of hard evidence?

The post earlier in this thread of £700 a year or a scanned copy of my friends bill for £3k for his Cessna? Or the quotes I received when looking for a CAMO originally?

Or the countless posts on here quoting fees and people asking if they are reasonable?

Or do you think this is all anecdotal and really everyone is being charged a *fair fee and just making up stuff to complain about?

*fair in an engineers estimation.

[Malcom]

This bit of banter going on reminds me of sports commentators:
- those that can do - do,
- those that cant do - talk about it

Whats the issue here - CAMOs overcharging or owners dumb enough to pay ridiculous amounts? Nobody is tied to a CAMO unless they have put themselves in that commercial position, my costs are marginally up - but nothing to get uppety about, are to be expected and I am happy with the situation.

In truth everybody - MO/CAMO/Owner has been led down the garden path by our glorious knee-jerk CAA to no safety benefit except the emptying of everybodys wallet requiring mass & balance recalcualtions. Requirements mis-interpreted at the outset by the CAA such as lifed items and back to birth research at the outset have naturally filtered through the system and only now are starting to be put right. Dont blame the CAMO for doing what the've been told from above - its not cricket. If only they would let go of their empire more gratiously, we would all get along a lot better.

Flight Manuals are the latest saga - how on earth can it be a good idea and safe to have two identical planes with two different flight manuals. FFS!

[robin]

Spot on Malcolm.

Last year there was a lot of fuss about Cessna seatbelts being lifed items. Can't remember which way round but I think the C152 belts weren't calendar lifed but the C150s were. So owners had to have then replaced purely on calendar life and not condition.

I note that in Germany they have fought and won an exemption from this.

There is no doubt that the villain of the piece was the CAA who still don't see there is anything wrong.