Part M Light

[Ray_A]

Hello,
A question mainly for aircraft owners I guess.

How far is your maintainer going towards implementing Type M Light now that it appears to be up and running for ELA1 ? When I asked mine they claimed to know nothing about it.
So far silence after several subsequent requests.

If I was cynical I would suggest that some engineering firms are concerned that it could reduce their revenues excessively, but to be fair to them maybe EASA is going to charge them so much to set it up that it would not be worthwhile for them in the short term.


I have tried to study some EASA and CAA Docs on the subject but so far not learned much really so trying to get more educated on the subject, in particular finding out which firms are or will be implementing it.

[Jan Olieslagers]

Excuse me but the question doesn't even begin to make sense with me. Are you talking navigation light or landing light or what? Perhaps some web link or pointer might help.

[mfalcon]

The CAA posted the following earlier in the year:
http://www.caa.co.uk/docs/224/20150729%20Minimum%20inspection%20programme.pdf

The introduction of the MIP precedes the new Part M Light regulations that are expected to be adopted in summer 2016. Aircraft owners will then be able to choose either Part M or Part M light and the MIP will then extend to aircraft between ELA1 (1,200kg) and ELA2 (2000kg).

[Ray_A]

Thanks for supplementing the info for my question mfalcon, perhaps I should have provided a link.

I had assumed that any potential answerer would already recognise the term.

Ray

[ChickenHouse]

Sorry, I still don't get the question.
We do have ELA1 now, which potentially makes life easy for non-commercial non-complex aircraft below 1.2 tons MTOW.
We will have ELA2 above 1.2 tons MTOW for non-commercial non-complex, which will be different but simular to ELA1.
We have Part M for commercial aviation and a lite version of it, where complex non-commercial NCC is under discussion.
What is the question?

[Ray_A]

Sorry, the basic question (reworded) is:-

Does anyone know of maintenance companies (UK / EU obviously) that are implementing part M lite or have done so already (IE working with their aircraft owner Customers in order to simplify maintenance procedures).

My A/C is ELA2 so I know it is not applicable to me just yet, its just that I have been asking my maintainers about it and they claim to know nothing about the scheme which I find strange.

thanks
Ray

[ChickenHouse]

No, I do not know of maintenance organizations already implementing the Part M lite rules. Afaik the rules implications are still under discussion and no clarity is reached what exactly is needed. I am pretty sure for ELA1 the first ones will be ready around years turn, but ELA2 - no idea how long that'll take.

There are some consultancy companies already selling documents for it, derived from commercial ops, but that may be far too heavy for what is really needed!

So, to my knowledge it is too early to say anything definite. For first impressions you may look into this famous german open documents bib for some freely distributed manuals https://www.pilotundflugzeug.de/dyn/ops/AirdocsHome .

[Ray_A]

Thanks, that information was very helpful, I now realise maybe I'm being a little impatient with my maintenance company and that my expectations are premature at this time.

I should give the maintainers more time to study part M light (or lite) and get themselves organised but looking forward for a positive outcome.

regds
Ray

[Marchettiman]

I think you need to have a deep and meaningful conversation with your maintenance company.

Although I am not a great fan of the European Project I think this is the first piece of legislation that I see as common sense and cuts through the mindless regulation that has made owning and operating a private aeroplane so difficult and expensive in recent years.

If you have a privately used ELA1 aircraft and want to take the legal responsibility for writing your own maintenance programme you now have every right to do so. As of July 2015 that's the law. The maintenance schedule has to be at least the same as EASA's new MIP schedule but you can make your own decisions on whether to incorporate recommended TBO's on components. I would simply suggest that you make informed decisions on what to incorporate into your maintenance schedule and vice versa.

If your maintenance company suggest that they won't agree (and therefore renew your ARC) go to another one who has a more enlightened attitude to aircraft maintenance...there are plenty of them.

[cessnapete]

A friend of mine already changing to 100hr Manufacturers recommended check cycle vs 50 hr. on his 172. Will still do 50 hr. oil/filter change.
(Quite a saving, my last 50hr for a 182 cost nearly £500)
The mandatory 6 year prop overhaul also looks like changing to on condition on his plane.

[Capt Kremmen]

In a way its a bit of a shame to see all those beneficial changes. All that bureaucracy and its attendant expense was very useful in the promotion of the attractions of owning and operating Permit aircraft.

[Bob Upanddown]

Marchettiman ELA 1 maintenance
I think you need to have a deep and meaningful conversation with your maintenance company.

If you have a privately used ELA1 aircraft and want to take the legal responsibility for writing your own maintenance programme you now have every right to do so. As of July 2015 that's the law.

If your maintenance company suggest that they won't agree (and therefore renew your ARC) go to another one who has a more enlightened attitude to aircraft maintenance...there are plenty of them. If as un-enlightened as some I have found, good luck.
Some are deliberately not buying into this (for obvious reasons - it will kill a lot of their income) but most haven't a clue about it.
Back when Part M was coming in, the CAA had seminars for engineers and the local CAA surveyor knew all about it and would, at least, give some guidance. I am told all that has changed. The CAA haven't done anything to inform maintenance organisations or engineers and no-one has seen a CAA surveyor for months.

If we saying this compares to a Permit to Fly annual, I have seen owners and LAA inspectors knock those off in a day. Against the usual "couple of weeks in the Hangar" annual completed by most firms, that's a huge loss of income. Don't expect to be welcomed when you ask if you can switch to the MIP.

[cessnapete]

Thats the whole idea! To start cutting the the huge costs of GA in UK. Isn't the owner of the aircraft responsible for the maintenance of his aircraft?
Surely if the Manufacturer says 100 check cycle is fine why insist on the present 50 hr.?
My last routine 50hr. for a C182 cost nearly £500, unsustainable.

[Bob Upanddown]

Thats the whole idea! To start cutting the the huge costs of GA in UK.

My point is that there are people living out of the huge charges made to owners. Is it in their interests to support you if you write your own maintenance programme that reduces their bill to 20% of what it was?

[cessnapete]

Then move to a Maintenance company which will carry out your requirements.
The lowering of costs may kickstart some more people into a more afordable GA, more business.
I friend and I a year or so back owned Cessna 180,s his N reg on 100 hr. check cycle, mine G reg on the UK 50 hr. (we both did 50 hr engine oil/filter)
His maintenance costs nearly half mine with no discernible serviceability issues. Surely we shouldn't "Gold Plate" Manufactures maintenance requirements to suit the finances of maintainers.

[Capot]

From what I hear about an EASA Workshop earlier this week on its review of the Airworthiness Review Process, and the comments that came from the stage about "Part M Light" and its introduction, I think we should all lower our expectations of real progress from EASA, if indeed you can lower them any more. EASA appears, so far as Continuing Airworthiness regulation is concerned at least, to be being sucked downwards into a whirlpool of more and more regulations that try to put previous regulations right, and instead make matters worse.

The hilarous absurdity was the presence of the QAMs of many very large airlines, with fleets of A380s, B777, B787, B747 etc etc, in the same room as representatives from sailplane clubs (yes, there was one at least, according to the attender list) to discuss an NPA about Airworthiness Reviews on the basis of a common interest.

Again from what I hear, the NPA was torn apart as unworkable by the large airlines, let alone the small GA organisations.

PS; I realise that EU 2015/1088 was a step towards a better life, but there's a lot more bureaucracy surrounding NPA 2015-08 as EASA ties itself in knots trying to achieve a futile and unnecessary consistency among its regulations for large CAT and small non-CAT aircraft. It describes this consistency as desirable, without any evidence why that should be so, except to a bureaucrat trying to achieve "one rule fits all".

[wigglyamp]

The recently introduced MIP only apply to ELA1 aircraft - those below 1200Kg. A typical C182P is certified at 1338Kg so can't go onto MIP and therefore needs to stay within a Part M environment to get it's ARC issued or renewed. As a consequence, GA maintenance companies can't make the savings in regulatory fees by dropping Part M and just having ARC privileges on their Part 145 unless they only maintain the lighter weight aircraft. There are rumours that MIP will be extended to ELA2 aircraft - those below 2000Kg, but no dates yet published that I'm aware of.

[cessnapete]

Later 2016 for ELA2 I believe.

[Capot]

Yes, well, don't hold yor breff for that.......maybe it will, maybe it won't.

To quote, unforgiveably, from my own post....

there's a lot more bureaucracy surrounding NPA 2015-08 as EASA ties itself in knots.....blah blah blah

Here's an extract from EASA's presentation;

NPA 2015-08 published on 09 July 2015:

 Proposed a Light Part-M with certain features which may interface with NPA 2015-17. In particular:

 Created as a new Part-ML (new Annex VI to Regulation 1321/2014). Organisation requirements (CAMO, Subpart F organisations) kept in Part-M.

 Applicable to all ELA2 aircraft plus those helicopters certified for up to 4 occupants up to 1200 Kg MTOM, regardless of type of operation.

 Owners/operators can choose to apply Part-M or Part-ML.

 Airworthiness review by maintenance organisations together with the annual/100h inspection.

 Airworthiness review by independent mechanics together with the annual/100h inspection for sailplanes, balloons, hot-air airships and ELA1 aeroplanes.

The presentation also says that the Opinion and the CRD for NPA 2015-08 will both be published in March 2016. I take leave to doubt that. But if I'm wrong, it will come into force about 3 weeks later. Let's be positive and hope. The problem is that phrase "interface with NPA 2015-07" when that NPA needs serious redrafting before even going out to consultation.

Isnt't it odd how you cannot separate bureaucrats from their pet projects. How did we ever manage without an Airworthiness Review to go with the Annual /100 hour inspection?

[francoisnk]

Only 13 days late w. respect to planing :-)
https://www.easa.europa.eu/system/files/dfu/Opinion%20No%2005-2016.pdf
https://www.easa.europa.eu/system/files/dfu/draft%20Annex%20I%20to%20the%20draft%20CR%20%28Opinion%20No% 2005-2016%29.pdf

[BoeingBoy]

I am in the ELA2 category and my maintenance company are not buying into Part M lite as the last changes EASA made were cancelled and altered at the last minute costing them, and a lot of other companies money.

Once all is clear, decided and put in writing (for more than a week) then we may see some progress.

I have stayed in uncontrolled maintenance in the hope of seeing some light at the end of a European tunnel, or maybe even a Brexit showing hope of having something sensible of our own.

[David Roberts]

Part M-Light is at the stage now where EASA has published an Opinion (which is part of the legal due process). This Opinion is then considered by the EU Member States in the EASA Management Board (confusingly titled as it is not EASA people, but member states' representatives) in the process known as comitology. So this proposal, which has been worked on for a year or more with industry experts and NAAs is not yet EU law but one can reasonably expect it to be so later this year.
It is now 10.5 years since organisation I speak for raised the red flag at EASA - on 5 November 2005 - about the original (2003) Part M which was expected to be applied equally to CAT / airlines and the lightest end of civil aviation. It has been a painful road to this, but at last we seem to have a framework that provides a sensible degree of flexibility for pilot / owners operating aircraft non-commercially, up to 2,730 kg MTOM (I think, need to check it has gone beyond the ELA 2 limit of 2,000 kg being talked about earlier in the process).

Instead of some folks continuing to moan, why don't we for once recognise EASA has been moving in the right direction, albeit at a relatively snail's pace. You will never get rid of the legal constructions that make it complex to read because this is EU law and lawyers rule supreme (unfortunately) in Brussels. A layman's version of Part M Light would of course be welcome.