GA Engineering - Part M Regulatory Impact Assessment
aceatco, retired
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GA Engineering - Part M Regulatory Impact Assessment
I don't profess to understand this but it is a copy of a letter sent by a well respected person in GA, particularly vintage, engineering [and published here with his permission] to the CAA's Head of Maintenance and Policy. Those of you that understand what it is about may wish to make your own representation.
Quote
It has just been drawn to my attention that a document is in circulation in the form of a Questionnaire from a qango organisation titling itself "Air Eurosafe", purporting to be carrying out a "Regulatory Impact Assessment" concerning the implementation of Part M. This document is, I understand, directed at owners, operators and organisations and seeks views on the impact of Part M on existing M3 organisations.
I am an owner and an operator, yet I have never been contacted by any department of the CAA for my views on this matter. Furthermore, from a quick canvass of colleagues and many others who own, operate and maintain aircraft, neither has anyone else.
I am advised that the deadline for replies is 7th December. This is wholly inadequate for this fundamental change, especially in view of the likely catastrophic effect on General Aviation of the change to Part M.
Part M will impose virtually all the burdens of Part 145 on the already parlous state of the GA M3 maintenance industry, both economically and in terms of time-wasting, at a time when there is a chronic dearth of skilled manpower and a great many existing proprietors are retiring or otherwise giving up and leaving in droves, rather than face the avalanche of bureaucracy facing the industry for no gain in continued airworthiness. For the same reason enterprise, management and recruitment into the industry is virtually nil because the rewards, neither financial nor "job satisfaction", faced with the new requirements, are not worth the trouble and responsibilities of setting up.
Furthermore, the "theft" from personally licensed engineers of their ability to exercise their skills and the privileges of their qualifications independently, as journeyman engineers - a fundamental right, hard won and exercised by skilled craftsmen for centuries - has caused great bitterness and many will leave the industry.
This matter is so important that you MUST NOT conclude this Assessment prematurely without fully consulting EVERY owner, operator and organisation IN PERSON, as is the stated aim of the Assessment.
Meanwhile, please will you let me have a copy of the relevant documents in order to make my own comments.
Yours faithfully,
Unquote
Quote
It has just been drawn to my attention that a document is in circulation in the form of a Questionnaire from a qango organisation titling itself "Air Eurosafe", purporting to be carrying out a "Regulatory Impact Assessment" concerning the implementation of Part M. This document is, I understand, directed at owners, operators and organisations and seeks views on the impact of Part M on existing M3 organisations.
I am an owner and an operator, yet I have never been contacted by any department of the CAA for my views on this matter. Furthermore, from a quick canvass of colleagues and many others who own, operate and maintain aircraft, neither has anyone else.
I am advised that the deadline for replies is 7th December. This is wholly inadequate for this fundamental change, especially in view of the likely catastrophic effect on General Aviation of the change to Part M.
Part M will impose virtually all the burdens of Part 145 on the already parlous state of the GA M3 maintenance industry, both economically and in terms of time-wasting, at a time when there is a chronic dearth of skilled manpower and a great many existing proprietors are retiring or otherwise giving up and leaving in droves, rather than face the avalanche of bureaucracy facing the industry for no gain in continued airworthiness. For the same reason enterprise, management and recruitment into the industry is virtually nil because the rewards, neither financial nor "job satisfaction", faced with the new requirements, are not worth the trouble and responsibilities of setting up.
Furthermore, the "theft" from personally licensed engineers of their ability to exercise their skills and the privileges of their qualifications independently, as journeyman engineers - a fundamental right, hard won and exercised by skilled craftsmen for centuries - has caused great bitterness and many will leave the industry.
This matter is so important that you MUST NOT conclude this Assessment prematurely without fully consulting EVERY owner, operator and organisation IN PERSON, as is the stated aim of the Assessment.
Meanwhile, please will you let me have a copy of the relevant documents in order to make my own comments.
Yours faithfully,
Unquote
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Bl**dy hell ATCO - this is monstrous. Is it a wind up?
Edited to include:
Air EuroSafe
Air EuroSafe is a European Economic Interest Grouping and therefore a non-profit organisation. It was formed in September 1997 by the UK Civil Aviation Authority, Air EuroSafe Germany, Bureau Veritas from France and SENASA from Spain.
It represents a unique gathering of bodies, experienced in regulation, with more than a thousand experts available and brings a significant improvement in the support of aviation safety.
The Mission of Air EuroSafe
"Based on a European approach, Air EuroSafe supports the work of ECAC and ICAO safety assessment programmes and assists with the development of aviation safety worldwide by the provision of technical support services to assist states to fulfil and maintain their responsibilities under the Annexes to the Chicago Convention."
Services offered by Air EuroSafe
Assistance for any country or organisation to update their aviation system and/or develop a national/local aviation safety system.
Temporary national/local aviation safety service (i.e. provide safety oversight advisory services) until the local system is sufficiently developed to take over all functions.
On the job training for persons or organisation to perform safety oversight functions and to apply and interpret rules for:
the industries of new JAA member states and candidate member states
the industries and authorities in non-member states
Contributions to the ECAC and ICAO assessment programmes by providing resources when personnel are not otherwise readily available or when specific knowledge is required.
Assistance to states to form regional groupings for safety oversight purposes.
Contact Details
Air EuroSafe
Rond Point Schuman 6
Box 5
Brussels B-1040
Belgium
Tel : +32 2 234 78 13
Fax : +32 2 234 79 36
Web-site: www.aireurosafe.com
Executive Manager : Ms Ingrid LaGarrigue
Anyone else never heard of this and what is it costing US and for what and whose benefit?
Edited to include:
Air EuroSafe
Air EuroSafe is a European Economic Interest Grouping and therefore a non-profit organisation. It was formed in September 1997 by the UK Civil Aviation Authority, Air EuroSafe Germany, Bureau Veritas from France and SENASA from Spain.
It represents a unique gathering of bodies, experienced in regulation, with more than a thousand experts available and brings a significant improvement in the support of aviation safety.
The Mission of Air EuroSafe
"Based on a European approach, Air EuroSafe supports the work of ECAC and ICAO safety assessment programmes and assists with the development of aviation safety worldwide by the provision of technical support services to assist states to fulfil and maintain their responsibilities under the Annexes to the Chicago Convention."
Services offered by Air EuroSafe
Assistance for any country or organisation to update their aviation system and/or develop a national/local aviation safety system.
Temporary national/local aviation safety service (i.e. provide safety oversight advisory services) until the local system is sufficiently developed to take over all functions.
On the job training for persons or organisation to perform safety oversight functions and to apply and interpret rules for:
the industries of new JAA member states and candidate member states
the industries and authorities in non-member states
Contributions to the ECAC and ICAO assessment programmes by providing resources when personnel are not otherwise readily available or when specific knowledge is required.
Assistance to states to form regional groupings for safety oversight purposes.
Contact Details
Air EuroSafe
Rond Point Schuman 6
Box 5
Brussels B-1040
Belgium
Tel : +32 2 234 78 13
Fax : +32 2 234 79 36
Web-site: www.aireurosafe.com
Executive Manager : Ms Ingrid LaGarrigue
Anyone else never heard of this and what is it costing US and for what and whose benefit?
aceatco, retired
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Working Hard, no, it is not a wind up. I can personally vouch for the integrity of the person who sent it. As I said, I don't understand it, or even your reply! 
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Vintage ATCO - i simply copied from the pages on their website so that all here can see what they are about. It does seem to be a quango that few of us may know little about and yet seems to be in a position to have a remarkable impact on aviation in the UK and the rest of EU. Reading the "blurb" really suggests they came into being to help other less well developed countries with safety programmes. If that is the case then why are they getting involved in the UK for example? Cannot our own CAA cope? Do we really need outside assistance to destroy what little remains of independant engineers and hard won rights and skills?
Perhaps they should start by going about 4000nm S where Belg,Fr, GY and Sp, had their Colonies and start their `help` down there, first..!!!!!!!!
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I also received a copy of the letter from Eurosafe, but I got it from a friend (who incidentally is not an owner) only one day before the deadline, so, too late to reply.
If Eurosafe claim be acting in our interests, why didnt they get all of our names and addresses from G-INFO and write to us directly?
Miffed Owner
If Eurosafe claim be acting in our interests, why didnt they get all of our names and addresses from G-INFO and write to us directly?
Miffed Owner
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I got this email from AOPA on Monday...
Dear Member
The document available for download from the web addresses at the foot of this note details some key areas that are set to change when light aircraft maintenance become subject to EASA rules. If you are an aircraft owner then this issue will be of interest to you because the proposed changes may increase the cost of maintaining a light aircraft to the end user ( i.e. the owner).
AOPA believes that any change to the current UK system should be evidence driven rather than " we think that it is a good idea"- any increase in cost must be balanced against demonstrable safety benefits.
As we only have a short time frame in which to respond can we please have you initial comments, if you have any, by no later than the 12th December.
We believe that there will be a formal consultation early next year however your views would be helpful.
Thank you
Regards
Martin Robinson
CEO AOPA UK
Word Document: http://www.aopa.co.uk/newsfromaopa/assessment.doc
PDF Document: http://www.aopa.co.uk/newsfromaopa/assessment.pdf
Dear Member
The document available for download from the web addresses at the foot of this note details some key areas that are set to change when light aircraft maintenance become subject to EASA rules. If you are an aircraft owner then this issue will be of interest to you because the proposed changes may increase the cost of maintaining a light aircraft to the end user ( i.e. the owner).
AOPA believes that any change to the current UK system should be evidence driven rather than " we think that it is a good idea"- any increase in cost must be balanced against demonstrable safety benefits.
As we only have a short time frame in which to respond can we please have you initial comments, if you have any, by no later than the 12th December.
We believe that there will be a formal consultation early next year however your views would be helpful.
Thank you
Regards
Martin Robinson
CEO AOPA UK
Word Document: http://www.aopa.co.uk/newsfromaopa/assessment.doc
PDF Document: http://www.aopa.co.uk/newsfromaopa/assessment.pdf
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Well - for one, could EASA start giving us longer timescales for consultation. The document states the deadline is set by regulation - well, that's all very well, but there are a lot of people who need to be involved in this consultation and they shouldn't rush it.
This is the 4th or 5th such exercise in 6 or so months. We aren't paid to do this sort of stuff, but if we don't do it each and every time, regulations will come in that will badly affect the lower end of the fraternity.
Fortunately, for the moment Annexe II exclusions aren't counted, but there are quite a few other who'll be caught out
This is the 4th or 5th such exercise in 6 or so months. We aren't paid to do this sort of stuff, but if we don't do it each and every time, regulations will come in that will badly affect the lower end of the fraternity.
Fortunately, for the moment Annexe II exclusions aren't counted, but there are quite a few other who'll be caught out
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I am an owner of an M3 company and an aircraft owner.I have not been contacted by Air Eurosafe.I have been told by the CAA that my company would obtain part M with out much trouble.Still if it costs to much to keep the part M,then you aren't going to have to many takers.Still this doesn't make much differance to me as we have had so little business,we are now closeing down.
