EASA money pit
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DFC
Four pages on now and just about all the posts exceping yours are of the opinion that the introduction of EASA part M maintenance will drive up the cost of opperating an aircraft on the Uk register (not PFA or annex 2).
Are you finaly ready to admit that I might just be right about the costs of introduction of EASA part M?
Are you finaly ready to admit that I might just be right about the costs of introduction of EASA part M?
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>>>I take it that by "Part M" you are referring toPart Manufacturer?
Can't see anywhere in European Law instructions for specific engine maintenance and repair. Lots of it in the Manufacturer's Maintenance, Overhaul and Repair manuals.<<<<
DFC
I don't know if you have seen any of the presentations made about the new regime, but you do seem not to have heard any of the 'horses mouth' stuff we have attended.
The new regime for continued airworthiness is designed to harmonise across EU, but with the local NAAs like the CAA acting as its representative. It is also responsible for sending back to EASA its 'cut' of the costs.
I have just spoken to my own maintenance organisation about next year, and although they have but in their application for approval, they still haven't heard back whether or not they have it. Yet since September they have been trying to get a straight answer from CAA and/or EASA as to what to do.
Some aircraft they have carried out a CofA on are to be moved to Annexe II or to a PFA permit very shortly, thus causing the owners undue expense.
As to my earlier point about being forced into the arms of a cartel, this has already happened to one friend. His maintenance organisation, which has been doing good work for him for years is no longer able to continue to operate to the new policy. He tried to register with the only approved outfit in the area, but they have turned him down - they have enough work with the aircraft based on their site to want to bother with anyone else.
If there is one thing that the UK does have, it is the requirement for an impact assessment of any proposed regulation. EASA does not require this, so when half the GA fleet stops operating because of this regulation there will undoubtedly be a gallic shrug from the French, who do it their own way, and from the CAA who will blame EASA.
Can't see anywhere in European Law instructions for specific engine maintenance and repair. Lots of it in the Manufacturer's Maintenance, Overhaul and Repair manuals.<<<<
DFC
I don't know if you have seen any of the presentations made about the new regime, but you do seem not to have heard any of the 'horses mouth' stuff we have attended.
The new regime for continued airworthiness is designed to harmonise across EU, but with the local NAAs like the CAA acting as its representative. It is also responsible for sending back to EASA its 'cut' of the costs.
I have just spoken to my own maintenance organisation about next year, and although they have but in their application for approval, they still haven't heard back whether or not they have it. Yet since September they have been trying to get a straight answer from CAA and/or EASA as to what to do.
Some aircraft they have carried out a CofA on are to be moved to Annexe II or to a PFA permit very shortly, thus causing the owners undue expense.
As to my earlier point about being forced into the arms of a cartel, this has already happened to one friend. His maintenance organisation, which has been doing good work for him for years is no longer able to continue to operate to the new policy. He tried to register with the only approved outfit in the area, but they have turned him down - they have enough work with the aircraft based on their site to want to bother with anyone else.
If there is one thing that the UK does have, it is the requirement for an impact assessment of any proposed regulation. EASA does not require this, so when half the GA fleet stops operating because of this regulation there will undoubtedly be a gallic shrug from the French, who do it their own way, and from the CAA who will blame EASA.
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Are you finaly ready to admit that I might just be right about the costs of introduction of EASA part M?
I don't see any extra cost in my future maintenance bill as a result of EASA.
I said the same about JAR-FCL and am happy to say I was correct. IN fact JAR-FCL has worked out better than I even expected.
I do see lots of "it's going to cost you to go from imperial to metric pipes" stories being told round the UK.
Like I said - Lets look at this again in 3 years.
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Robin,
The problem is that no one in their right mind is going to be influenced by people on a rumour network who for the most part simply are anti- anything that comes out of Europe - even if it is the CAA that aree causing the problem.
Don't see many Irish, French, Dutch, Belgian, German, Spanish and so on people complaining.
Could be that some are going from annual C of A renewals to a far simpler and cheaper system.
The whole thing about change is to ensure that you win as a result.
Compare the UK aircraft engineering population to Europe - a very small part.
Welcome to democracy.
Regards,
DFC
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>>>The whole thing about change is to ensure that you win as a result.<<<
Hmmm
Perhaps we ought to have a little wager on the side on this. I've not seen any legislation introduced by the CAA or EASA which has given me any 'wins'. Quite the reverse
Hmmm
Perhaps we ought to have a little wager on the side on this. I've not seen any legislation introduced by the CAA or EASA which has given me any 'wins'. Quite the reverse
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DFC
I don't see any extra cost in my future maintenance bill as a result of EASA.
I said the same about JAR-FCL and am happy to say I was correct. IN fact JAR-FCL has worked out better than I even expected.
I said the same about JAR-FCL and am happy to say I was correct. IN fact JAR-FCL has worked out better than I even expected.
Old CAA PPL issued once when you pass skills test, valid for life.
JAR PPL needs to be "renewed" every five years at a cost of £70 a shot.
That is an additional cost in anyones book....all be it minor in the grand scheme of flying costs.
Back to the issue at hand, if the new system requires additional paperwork for regulation, it is an unfortunate fact of business life that an increase in regulatory paperwork usually entails an increase in cost, which is passed on to the customer...
Regards, SD..
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Robin,
Perhaps we should!
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skydriller,
If you had a "for life" PPL then you still have it. No change there.
If like other Europeans you had to renew your PPL every 2 years then only having to do it every 5 years is a great cost saving.
It may not be win/win but it is no change / win.
Add to that the validity of the licence in any JAA state, that is a great saving in admin / hassle / costs.
A law increasing the cost of a bus ride in Newcastle from GBP1.00 to GBP 2.00 while reducing the cost of national train journeys from GBP20.00 to GBP10.00 will have people who never look beyond Newcastle up in arms. Those that uses the system to it's fullest extent will benifit and be glad of the changes......................especially if they live in London!!
Regards,
DFC
Perhaps we should!
---------
skydriller,
If you had a "for life" PPL then you still have it. No change there.
If like other Europeans you had to renew your PPL every 2 years then only having to do it every 5 years is a great cost saving.
It may not be win/win but it is no change / win.
Add to that the validity of the licence in any JAA state, that is a great saving in admin / hassle / costs.
A law increasing the cost of a bus ride in Newcastle from GBP1.00 to GBP 2.00 while reducing the cost of national train journeys from GBP20.00 to GBP10.00 will have people who never look beyond Newcastle up in arms. Those that uses the system to it's fullest extent will benifit and be glad of the changes......................especially if they live in London!!
Regards,
DFC
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Skydriller,
Forgot to say that when I was referring to costs under JAR-FCL, I was referring to the costs involved in operating training organisations and obtaining approvals required.
Having the ability to provide training services across a number of states without separate approvals and different requirements from a single base instantly increased the available market. Many have tapped into this increased market, some simply came back from expensive private flights to Australia and laid off instructors without paying for work done........blaming JAR.
Where is Tony these days?
Regards,
DFC
Forgot to say that when I was referring to costs under JAR-FCL, I was referring to the costs involved in operating training organisations and obtaining approvals required.
Having the ability to provide training services across a number of states without separate approvals and different requirements from a single base instantly increased the available market. Many have tapped into this increased market, some simply came back from expensive private flights to Australia and laid off instructors without paying for work done........blaming JAR.
Where is Tony these days?
Regards,
DFC
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Part M
What DFC doesn't seem to have grasped is the new approvals an organisation must hold under Part M.
No one disputes that continued airworthiness is required. Most owners entrust their maintenance organisation (BCAR M-3 or EASA Part 145) to look after the paperwork review of SB's, AD's etc and accept that this is charged for as part of scheduled maintenance.
What changes with Part M for non-CAT aircraft is that the maintenance organisation has to hold a separate approval, at additional cost, to be able to review the maintenance documentation and raise the workpack. It is the cost of the additional approval and the cost of maintaining the approval that will be recovered from owners as additional fees, NOT additional aircraft paperwork.
To hold this approval as a CAMO, the new Part M sub-part G orginisation takes all the review responsibility away from the M3 or Part 145, including raising workpacks. The CAMO will require independant auditing, just like a maintenance organisation (after all, someone's got to check that they're doing the job correctly), it's own facilities, possibly additional staff (particularly for ARC renewals) and all these EXTRAS, beyond he M3 or 145, have a cost which can't be ignored, and will find their way into the bills of the aircraft owner.
Even if DFC sets himself up to maintain his own continued airworthiness as he's done in the past, he's going to have to apply to EASA for approval and pay the fees himself as well as getting himself audited!
No one disputes that continued airworthiness is required. Most owners entrust their maintenance organisation (BCAR M-3 or EASA Part 145) to look after the paperwork review of SB's, AD's etc and accept that this is charged for as part of scheduled maintenance.
What changes with Part M for non-CAT aircraft is that the maintenance organisation has to hold a separate approval, at additional cost, to be able to review the maintenance documentation and raise the workpack. It is the cost of the additional approval and the cost of maintaining the approval that will be recovered from owners as additional fees, NOT additional aircraft paperwork.
To hold this approval as a CAMO, the new Part M sub-part G orginisation takes all the review responsibility away from the M3 or Part 145, including raising workpacks. The CAMO will require independant auditing, just like a maintenance organisation (after all, someone's got to check that they're doing the job correctly), it's own facilities, possibly additional staff (particularly for ARC renewals) and all these EXTRAS, beyond he M3 or 145, have a cost which can't be ignored, and will find their way into the bills of the aircraft owner.
Even if DFC sets himself up to maintain his own continued airworthiness as he's done in the past, he's going to have to apply to EASA for approval and pay the fees himself as well as getting himself audited!
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Wigglyamp
I have been saying much the same thing for the last three pages but I am sorry to say that all of us must be totaly wrong, after all DFC says that dispite the increased cost of approvals, more paperwork and more company audits costs will not increase.
It is just left to DFC to make it crystal clear how his economic system that has a company's outgoings increse and income stay unchanged with the proffit staying unchanged works, perhaps he would like to enlighten us. I am sure that my accountant would be very interested as if he could get a grip on DFC's economic insight he would make a fortune and so would I.
So come on DFC tell us what you know!
It is just left to DFC to make it crystal clear how his economic system that has a company's outgoings increse and income stay unchanged with the proffit staying unchanged works, perhaps he would like to enlighten us. I am sure that my accountant would be very interested as if he could get a grip on DFC's economic insight he would make a fortune and so would I.
So come on DFC tell us what you know!
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Companies that fail to grasp oportunities and exploit them go down the pan eventually no matter what they charge.
Please explain how going from having a Full C of A renewal every year along with the Annual inspection to having the Annual and a bit of paperwork completed is any different.
Noting is changing.
You may have to play catch-up and your customers may have to suffer the cost of your having to do so but I will see no change in continued airworthiness costs - 2008 is already sorted and it is 2009 that we must plan for.
Regards,
DFC
Please explain how going from having a Full C of A renewal every year along with the Annual inspection to having the Annual and a bit of paperwork completed is any different.
Noting is changing.
You may have to play catch-up and your customers may have to suffer the cost of your having to do so but I will see no change in continued airworthiness costs - 2008 is already sorted and it is 2009 that we must plan for.
Regards,
DFC
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DFC
Suggest you read the EASA scale of charges for 2007/2008 on the EASA website. The initial application fee for a CAMO in accordance with Part M subpart G is Eu 24000, and renewal is 18000. This is the new fee above and beyond the current Part 145 approval or BCAR M3 approval that companies must pay in order to carry out the paperwork for ARC renewal that they currently do as part of scheduled maintenance. If your CAMO can, from September 2008, do this without any additional cost, I suggest you publish their details so all of us can go to them for the ARC - as well as a Part 66 engineer, I also own a PA28, and can't justify the Eu 24000 fee to continue managing my own paperwork!
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If you had a "for life" PPL then you still have it. No change there.
If like other Europeans you had to renew your PPL every 2 years then only having to do it every 5 years is a great cost saving.
It may not be win/win but it is no change / win.
If like other Europeans you had to renew your PPL every 2 years then only having to do it every 5 years is a great cost saving.
It may not be win/win but it is no change / win.
Please excuse my stupidity.
I have a CAA PPL for life, all I have to do is a flight with an instructor once every 2 years, sign the logbook and I am done,no fees to the CAA or EASA. According to the new proposals I will have a new EASA PPL for life but this time I will have to pay X Pounds every 5 years to the CAA or EASA. So please explain to me, Is it a win/win situation or a lose/lose situation?
Maybe you europeans were in a worse situation than us in the UK, I don't know, you might gain as a result of the changes but we are going to lose big time. I am not urprised that you can't see it but we can.
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Suggest you read the EASA scale of charges for 2007/2008 on the EASA website. The initial application fee for a CAMO in accordance with Part M subpart G is Eu 24000, and renewal is 18000. This is the new fee above and beyond the current Part 145 approval or BCAR M3 approval that companies must pay in order to carry out the paperwork for ARC renewal that they currently do as part of scheduled maintenance
If I was in the UK, I would look for the charges here;
http://www.caa.co.uk/docs/33/ORS5~218.pdf
[/I]5.1.1 Initial application charges
In respect of an application to the CAA for the approval or authorisation of a person or
organisation, for the purposes of Part-21 (Subparts F or G) or Part-145 or Part-M
(Subparts F or G), for the investigations required by the CAA, the applicant shall pay on
application:
a) in the case of an approval or authorisation Part-21 Subpart G, or in respect of the
A1 or B1 ratings of Part-145, a charge of £8,640;
b) in the case of an approval in Groups A2, A3, A4, B2, B3, C or D ratings of Part-145,
a charge of £2,160;
c) in the case of an authorisation in Part-21 Subpart F, a charge of £1,070;
d) in the case of an approval in Part-M Subpart G1 for aircraft > 5,700 kg, a charge of
£4,320 and for aircraft up to 5,700 kg, a charge of £2,160. However, where the
applicant already holds a CAA maintenance approval or a BCAR Group E3 design
approval, then a charge of £1,070 will be applied regardless of aircraft weight;
e) in the case of an approval in Part-M Subpart F, a charge of £2,160. However,
where the applicant already holds a CAA maintenance approval then a charge of
£1,070 will be applied;
f) in the case of any other approval, a charge of £2,160.
Provided that for the purposes of sub-paragraphs a) to f) above where the cost of the
investigations exceeds the charge specified, the applicant shall pay a charge of such
amount as may be decided by the CAA having regard to the expense incurred by it in
making the investigations, see paragraph 6.4, but not exceeding £106,000 for any year,
or part of the year, during which the investigations are carried out.
5.1.2 Variation charges
In respect of an application to the CAA for the variation of an approval of a person or
organisation for the purposes of Part-21 (Subpart F or G), Part-145 or Part-M (Subpart F
or G), for the investigations required by the CAA, the applicant shall pay:
a) in the case of a Part-21 Subpart G, Part 145 or Part M (Subpart F or Subpart G), a
charge of £1,070; or
b) in the case of a Part-21 Subpart F, a charge of £535; or
(This Note is not part of the Scheme)
1. If applied for, and without extra charge, the grant of a Part-M Subpart G approval may include a Subpart
I privilege that would permit the applicant to issue Airworthiness Review Certificates.[/I]
There is more if you look at the whole document.
The UK CAA is expensive but not such a drastic expense that some would believe.
---------------
AC-DC,
Us (you and me) Europeans simply have to accept that living in the past is no good.
-----------
Robin,
I think that you will have to include every other country on earth along with the French. ICAO do not recognise it and no UK pilot has ever obtained permission to make use of it outside the UK, CI and IOM.
Regards,
DFC
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Originally Posted by DFC
Us (you and me) Europeans simply have to accept that living in the past is no good.
Hitler, Stalin - hey, even Saddam Hussein - represented 'change' in their own milieu. I think we probably agree that it was bad change.
Tim
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DFC
A lot of text but you are still avoiding the outgings vs income issue but at the same time publishing data that shows an increase in charges for regulation.
Is it not time to admit that you are soon going to have to pay a CAMO to do the technical paperwork that you up untill now have been doing yourself or pick up an even larger bill to do this yourself.
Is it not time to admit that you are soon going to have to pay a CAMO to do the technical paperwork that you up untill now have been doing yourself or pick up an even larger bill to do this yourself.
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DFC
Whislt the CAA curently have the discretion to vary charges, the new charges laid down in the current EASA scheme effective from June 2007 will prevent the UK CAA from offering reduced fees in the future. If you look at Ch IV, Article 14 para 1 (d) of the EASA fee structue, you'll see that in future, the surveillance fees given in Part 3 para 2 (the EU 18000) will apply. Whilst these can be reduced by the multiplier based on turnover, they are nevertheless a significant additional charge not previously required and hence industry will need to recover them from customers or see margins diminish. In addition, the note on the signature page makes clear that the regulation is legally binding in ALL member states - so no get-out, and not applicable ONLY TO PEOPLE OUTSIDE THE EU!
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Just back for a short break, only to find things going from bad to worse. I did see a glimmer of hope for DFC, its just gone out!
""""This EASA law is for Harmonisation if in order to harmonise with the standard you need to do lots of extra work then ask yourself why could this be if you were at the required standard?"""""
If you need to do work to harmonise with a standard, surely this means you were at a different standard to start with, hence the extra work to harmonise with the new standard?
"""""Much of your complaint seems to be with the CAA. So why don't you title the thred CAA money pit...........because as you say, they are the ones charging the large sums of money and making a profit.""""
European harmonisation guff?? Our CAA is required to make a profit, whilst other NAAs are state funded. Level playing field - right?
The CAA act for EASA & do what they are told. When they know, then we find out!
""""""Now back to the paperwork. If your maintenance company completed the Annual and required paperwork exercise to renew your C of A previously and say that cost was X including work, parts, expendibles and paperwork then provided that they are capable of getting the required approvals then they can continue to complete your Annual and C of A paperwork.......then what has changed to justify an increase in costs......unless they were not doing it properly before!"""""
As previously described ad-nauseum, a new approval is required to issue / revalidate your non expiring C of A. THE NEW APPROVAL COSTS MONEY.
""""Again I say...........nothing new for me in all this. If engineering organisations are going to charge more for doing what they were doing (or should have been doing) all along then I can rightly claim that they are profiteering from the confusion surrounding the issue and in many cases, addid to that confusion probably for their own benifit.""""
As previously described ad-nauseum, a new approval is required to issue / revalidate your non expiring C of A. THE NEW APPROVAL COSTS MONEY.
"""""Can't see anywhere in European Law instructions for specific engine maintenance and repair. Lots of it in the Manufacturer's Maintenance, Overhaul and Repair manuals."""""
European Law specifically requires you to use that data, therefore it is part of EU law.
Time to put-up or shut-up DFC, give us the benefit of your insight & business ideals, tell us how you will have your non expiring C of A Issued and revalidated at no additional cost.
Best wishes to all for 2008
Malcom
""""This EASA law is for Harmonisation if in order to harmonise with the standard you need to do lots of extra work then ask yourself why could this be if you were at the required standard?"""""
If you need to do work to harmonise with a standard, surely this means you were at a different standard to start with, hence the extra work to harmonise with the new standard?
"""""Much of your complaint seems to be with the CAA. So why don't you title the thred CAA money pit...........because as you say, they are the ones charging the large sums of money and making a profit.""""
European harmonisation guff?? Our CAA is required to make a profit, whilst other NAAs are state funded. Level playing field - right?
The CAA act for EASA & do what they are told. When they know, then we find out!
""""""Now back to the paperwork. If your maintenance company completed the Annual and required paperwork exercise to renew your C of A previously and say that cost was X including work, parts, expendibles and paperwork then provided that they are capable of getting the required approvals then they can continue to complete your Annual and C of A paperwork.......then what has changed to justify an increase in costs......unless they were not doing it properly before!"""""
As previously described ad-nauseum, a new approval is required to issue / revalidate your non expiring C of A. THE NEW APPROVAL COSTS MONEY.
""""Again I say...........nothing new for me in all this. If engineering organisations are going to charge more for doing what they were doing (or should have been doing) all along then I can rightly claim that they are profiteering from the confusion surrounding the issue and in many cases, addid to that confusion probably for their own benifit.""""
As previously described ad-nauseum, a new approval is required to issue / revalidate your non expiring C of A. THE NEW APPROVAL COSTS MONEY.
"""""Can't see anywhere in European Law instructions for specific engine maintenance and repair. Lots of it in the Manufacturer's Maintenance, Overhaul and Repair manuals."""""
European Law specifically requires you to use that data, therefore it is part of EU law.
Time to put-up or shut-up DFC, give us the benefit of your insight & business ideals, tell us how you will have your non expiring C of A Issued and revalidated at no additional cost.
Best wishes to all for 2008
Malcom
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tmmorris,
If the change is bad for you but good for 2 other people then the change is overall good.
However, you are missing the point I am making - there will not be any change in this. There will not be any major hike is fees for small private operators who know what the system is and make appropriate arrangements.
Do a google search on what other aviation authorities have to say, look at the various power point presentations that are on line from EASA and others, look at the EASA requirements yourself along with the scheme of charges.
Have a good look at what maintenance organisations in other countries are saying in their adverts.
A and C was pointing out that in their opinion the option of having the CAA complete the required ARC was going to be so expensive that no one would be able to afford it and everyone would be forced to use the industry controlled and managed maintenance option. However, what A and C has forgotten (or has not yet learned) is that every fourth certificate has to be completed by the CAA. So if they set the prices very high then all the UK people will have to pay them every fourth time. Thus there is no way of avoiding the CAA fee.
Under EASA you can get your club C172 maintained by a member of your club (subject to conditions), certified by a JAR-66 engineer and the NAA will look after the private C of A /ARC.........just not on the G register yet. Now tell me that is more expensive than going to your local M3 organisation and having to maintain a public transport C of A on your club aircraft.
People simply have not done enough research on this and if they have not made appropriate provision will get fleeced by those that use the favourite UK line - say metric does not fit imperial.
------
Wigglyamp,
You need to do more reading!
I will come back to this in 3 years and then the answers will be clear.
Regards,
DFC
If the change is bad for you but good for 2 other people then the change is overall good.
However, you are missing the point I am making - there will not be any change in this. There will not be any major hike is fees for small private operators who know what the system is and make appropriate arrangements.
Do a google search on what other aviation authorities have to say, look at the various power point presentations that are on line from EASA and others, look at the EASA requirements yourself along with the scheme of charges.
Have a good look at what maintenance organisations in other countries are saying in their adverts.
A and C was pointing out that in their opinion the option of having the CAA complete the required ARC was going to be so expensive that no one would be able to afford it and everyone would be forced to use the industry controlled and managed maintenance option. However, what A and C has forgotten (or has not yet learned) is that every fourth certificate has to be completed by the CAA. So if they set the prices very high then all the UK people will have to pay them every fourth time. Thus there is no way of avoiding the CAA fee.
Under EASA you can get your club C172 maintained by a member of your club (subject to conditions), certified by a JAR-66 engineer and the NAA will look after the private C of A /ARC.........just not on the G register yet. Now tell me that is more expensive than going to your local M3 organisation and having to maintain a public transport C of A on your club aircraft.
People simply have not done enough research on this and if they have not made appropriate provision will get fleeced by those that use the favourite UK line - say metric does not fit imperial.
------
Wigglyamp,
You need to do more reading!
I will come back to this in 3 years and then the answers will be clear.
Regards,
DFC
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DFC.....half the story as usual
As DFC says some maintenance tasks can be carried out by the owners & pilots however they will require to be trained & checked to do these tasks by the maintenance company that they are contracted to.
In effect they will be issued with a task limmited company approval by the maintenance company.
This brings us back to the cost to the maintenance company to get the Part M approvals. The next cost is that to check the owner/pilot can perform the task safely.
So for DFC to get the approval to do what he can now do under LAMS he will have to get checked out by the maintenance company that he will have to be contracted to and have to pay the cost of administering the check out and approval.
Now do we think that if DFC gets the CAA to do the ARC each year they are going to give him a limmited task approval for free ?
In effect they will be issued with a task limmited company approval by the maintenance company.
This brings us back to the cost to the maintenance company to get the Part M approvals. The next cost is that to check the owner/pilot can perform the task safely.
So for DFC to get the approval to do what he can now do under LAMS he will have to get checked out by the maintenance company that he will have to be contracted to and have to pay the cost of administering the check out and approval.
Now do we think that if DFC gets the CAA to do the ARC each year they are going to give him a limmited task approval for free ?