EASA money pit
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From: Not a million miles from EGTF
Forgive me (again)
My understanding of the situation is that the CAA will issue the first ARC with the non-expiring EASA C of A.
After that, if you sign-up with a CAMO in a controlled environment and agree with them the limits of the maintenance, then the costs are reduced. You 'may' also have the ARC extended for up to 2 years, so we have the current situation of Star-Annual-Annual-Star.
In the 'Uncontrolled Environment' where the owner has no agreement with a CAMO, he is not able to raise the work pack and each time he approaches an MO he effectively funds a Star Annual. The costs in this option are significantly higher than in the Controlled case.
Worse, because it becomes prohibitively expensive to change CAMO, they have you by the short and curlies. They can also remove any or all of your rights to carry out pilot maintenance, if they so wish.
This will lead to owners carrying out their own maintenance or getting someone else to help out, and not recording it, in the hope or expectation that no-one will notice.
One of the great joys of looking at EASA legislation is the way that it encourages owners to find ways around the legislation, rather than complying with it. Hardly something that was planned.
Now, this may be different in Euroland, but we are being driven down the preferred CAA view.
My understanding of the situation is that the CAA will issue the first ARC with the non-expiring EASA C of A.
After that, if you sign-up with a CAMO in a controlled environment and agree with them the limits of the maintenance, then the costs are reduced. You 'may' also have the ARC extended for up to 2 years, so we have the current situation of Star-Annual-Annual-Star.
In the 'Uncontrolled Environment' where the owner has no agreement with a CAMO, he is not able to raise the work pack and each time he approaches an MO he effectively funds a Star Annual. The costs in this option are significantly higher than in the Controlled case.
Worse, because it becomes prohibitively expensive to change CAMO, they have you by the short and curlies. They can also remove any or all of your rights to carry out pilot maintenance, if they so wish.
This will lead to owners carrying out their own maintenance or getting someone else to help out, and not recording it, in the hope or expectation that no-one will notice.
One of the great joys of looking at EASA legislation is the way that it encourages owners to find ways around the legislation, rather than complying with it. Hardly something that was planned.
Now, this may be different in Euroland, but we are being driven down the preferred CAA view.
Thread Starter
Joined: Jan 1999
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From: north of barlu
Robin
I think that you more or less understand the plot (more than we can say for DFC!).
It would be my stance to encourage some owner maintenance for those who have the correct attitude, at least this way people will be "up front" about what they are doing and not try to hide things from me.
The good thing about owner maintenance is that it teaches the owner a lot about his aircraft and he soon finds out that good maintenance is not easy, this understanding helps to balance the rubbish spouted by flying club bar flies who think that any one can maintain aircraft.
It would be my stance to encourage some owner maintenance for those who have the correct attitude, at least this way people will be "up front" about what they are doing and not try to hide things from me.
The good thing about owner maintenance is that it teaches the owner a lot about his aircraft and he soon finds out that good maintenance is not easy, this understanding helps to balance the rubbish spouted by flying club bar flies who think that any one can maintain aircraft.
Last edited by A and C; 1st January 2008 at 10:32.
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From: Euroland
we are being driven down the preferred CAA view
Will A and C ever notice that light aircraft mainenance can be completed by a JAR-66 licensed engineer. No contact with a maintenance complay required at all. How much does being able to permanetly steer clear of over priced maintenance organisations who seem to be using this to push their inflated prices further upward.
The requirements for owner maintenance and in the club environment for maintenance by a club member simply require the person to be suitable to the authority. Noting about having some maintenance organisation approve them.
Is that another line you are going to spin to your customers in order to further increase you income?
My final words on the matter are - Owners please check out carefully before you spend unnecessary money with those who seek to exploit your lack of knowledge.
Regards,
DFC
Joined: Feb 2007
Posts: 132
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From: UK
DFC
I so very happy for you in that you are OK with an ARC renewal every year by the CAA, or a CAMO.
I am not.
True, a MO does not need to approve you to work on your plane, but just who is suitable to the authority?
- LAE ? Fine as long as nothing is found wrong.
Worn out seat rail on a C152. 8 screws out, replace rail, 8 screws back in and the job
is done. LAE cannot certify this job.
- Owner? Fine as long as you limit your club plane to 50 hours a year, and nothing goes wrong.
Part M. I would recommend you have a read & inwardly digest.
The problem with having ones head in the sand is that others can only see the bit sticking out.
Best Regards
Malcom
I so very happy for you in that you are OK with an ARC renewal every year by the CAA, or a CAMO.
I am not.
True, a MO does not need to approve you to work on your plane, but just who is suitable to the authority?
- LAE ? Fine as long as nothing is found wrong.
Worn out seat rail on a C152. 8 screws out, replace rail, 8 screws back in and the job
is done. LAE cannot certify this job.
- Owner? Fine as long as you limit your club plane to 50 hours a year, and nothing goes wrong.
Part M. I would recommend you have a read & inwardly digest.
The problem with having ones head in the sand is that others can only see the bit sticking out.
Best Regards
Malcom
Joined: Aug 2003
Posts: 1,579
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From: Not a million miles from EGTF
DFC
>>>The requirements for owner maintenance and in the club environment for maintenance by a club member simply require the person to be suitable to the authority. Noting about having some maintenance organisation approve them.<<<
I'll dig out the chapter and verse on this, but as I read it the CAMO will permit or otherwise any pilot or other maintenance.
You have to inform the CAMO within 30 days of any maintenance carried out and they may require to inspect the work. If they find it not to their taste, they have the authority to limit any pilot maintenance still further. They can also prevent an LAE from doing work on your aircraft if they have grounds for believing it to be below (their) standard.
Under agreements with CAMOs, which we are being 'encouraged' to take out, we have the responsibility for continued airworthiness, but are firmly in the hands of our CAMOs.
>>>The requirements for owner maintenance and in the club environment for maintenance by a club member simply require the person to be suitable to the authority. Noting about having some maintenance organisation approve them.<<<
I'll dig out the chapter and verse on this, but as I read it the CAMO will permit or otherwise any pilot or other maintenance.
You have to inform the CAMO within 30 days of any maintenance carried out and they may require to inspect the work. If they find it not to their taste, they have the authority to limit any pilot maintenance still further. They can also prevent an LAE from doing work on your aircraft if they have grounds for believing it to be below (their) standard.
Under agreements with CAMOs, which we are being 'encouraged' to take out, we have the responsibility for continued airworthiness, but are firmly in the hands of our CAMOs.
Joined: Feb 2007
Posts: 132
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From: UK
Robin,
You dont HAVE to use a CAMO for managing maintenance - it just reads a bit easier at the moment.
DFC has pointed out an owner can do this if he deems himself competent. As I've said before that is a matter for the owners technical competency, his wallet, his technical library, his conscience, & the Board of Enquiry in the event.
This puts you outside the "controlled environment", and then you will only need the CAMO with ARC revalidation privileges (or otherwise go to the CAA) to carry out the Airworthiness review each year - effectively a C of A renewal every year.
If you do use a CAMO to manage maintenance, then you are in the controlled environment, they can approve certain tasks an owner can do. The plus here is that then you can have two CAMO issued extensions to your Airworthiness Review, so a bit similar to the current M3 renewal process, just paying for yet another approval and its upkeep to do the same as at present.
Best Regards
Malcom
You dont HAVE to use a CAMO for managing maintenance - it just reads a bit easier at the moment.
DFC has pointed out an owner can do this if he deems himself competent. As I've said before that is a matter for the owners technical competency, his wallet, his technical library, his conscience, & the Board of Enquiry in the event.
This puts you outside the "controlled environment", and then you will only need the CAMO with ARC revalidation privileges (or otherwise go to the CAA) to carry out the Airworthiness review each year - effectively a C of A renewal every year.
If you do use a CAMO to manage maintenance, then you are in the controlled environment, they can approve certain tasks an owner can do. The plus here is that then you can have two CAMO issued extensions to your Airworthiness Review, so a bit similar to the current M3 renewal process, just paying for yet another approval and its upkeep to do the same as at present.
Best Regards
Malcom
Joined: Mar 2006
Posts: 262
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From: very west
Clarification required
DFC wrote
"Will A and C ever notice that light aircraft mainenance can be completed by a JAR-66 licensed engineer. No contact with a maintenance complay required at all."
If I understand what you appear to be saying, and please correct me if I have failed to, you are suggesting that a JAR 66 Aircraft Maintenance Licence holder can complete and certify ALL maintenance on your 'G' registered aircraft?
You also appear to suggest that you will not require the services of a maintenance company (I am guessing you are referring to what is correctly termed an Approved Maintenance Organisation, be it M3, E4-M5, or Part 145) by contact or contract for any aspect of maintenance on your 'G' registered aircraft.
Hahahahahahahahahahaha
Oh, sorry. Please excuse me, one and all.
You see, up untill now, I was actually convinced that DFC was genuine. I even believed that he may have been a committed aircraft owner or active flying club member who took a deep interest in his aircraft maintenance, as well as being shrewd. I thought it was most commendable of him to stand up to the industry here and try and make his point.
Then I read his post containing the above quote. It was at this point that I realised, we have been had.
As those of us actually involved in aviation know, the CAA require all Annual Inspections (including CAA ex-mil Permit types) and C of A renewals to be carried out within the premisis and confines of an Approved Organisation. EASA similar.
So, either:
a) DFC has never been an aircraft owner, [Milt or wannabee]
or
b) DFC has only owned microlights or PFA/LAA Permit types, [Milt or wannabee]
or
c) DFC has only recently purchased an aircraft, and has believed everything the salesman said, [banana boat crewman]
or
d) DFC has an AML (JAR 66 licence) and does all his own work, [suffers from foot-in-mouth disease and doesn't understand the limitations of his licence]
(or, e) hypothetically, perhaps a certain amount of readies pass between two people once every year in exchange for a quiet signature or two. However, if this has previously taken place, following the high-profile "won't cost me any more" statements in this well viewed thread, the signatory will most probably disappear into thin air to prevent capture and loss of licence, nee income). [golden goose shooter]
I learnded Englische when I was a children. Notwithstanding this fault of mine, looking at the grammer and spelling contained in DFC's posts, and considering the 'precise' content of some of his quotes, I wonder if DFC is really a two-year-college-special freshly-churned-out-but-nil-experienced B1 or B2 who falls into d) above. a) may also apply.
camlobe
"Will A and C ever notice that light aircraft mainenance can be completed by a JAR-66 licensed engineer. No contact with a maintenance complay required at all."
If I understand what you appear to be saying, and please correct me if I have failed to, you are suggesting that a JAR 66 Aircraft Maintenance Licence holder can complete and certify ALL maintenance on your 'G' registered aircraft?
You also appear to suggest that you will not require the services of a maintenance company (I am guessing you are referring to what is correctly termed an Approved Maintenance Organisation, be it M3, E4-M5, or Part 145) by contact or contract for any aspect of maintenance on your 'G' registered aircraft.
Hahahahahahahahahahaha
Oh, sorry. Please excuse me, one and all.
You see, up untill now, I was actually convinced that DFC was genuine. I even believed that he may have been a committed aircraft owner or active flying club member who took a deep interest in his aircraft maintenance, as well as being shrewd. I thought it was most commendable of him to stand up to the industry here and try and make his point.
Then I read his post containing the above quote. It was at this point that I realised, we have been had.
As those of us actually involved in aviation know, the CAA require all Annual Inspections (including CAA ex-mil Permit types) and C of A renewals to be carried out within the premisis and confines of an Approved Organisation. EASA similar.
So, either:
a) DFC has never been an aircraft owner, [Milt or wannabee]
or
b) DFC has only owned microlights or PFA/LAA Permit types, [Milt or wannabee]
or
c) DFC has only recently purchased an aircraft, and has believed everything the salesman said, [banana boat crewman]
or
d) DFC has an AML (JAR 66 licence) and does all his own work, [suffers from foot-in-mouth disease and doesn't understand the limitations of his licence]
(or, e) hypothetically, perhaps a certain amount of readies pass between two people once every year in exchange for a quiet signature or two. However, if this has previously taken place, following the high-profile "won't cost me any more" statements in this well viewed thread, the signatory will most probably disappear into thin air to prevent capture and loss of licence, nee income). [golden goose shooter]
I learnded Englische when I was a children. Notwithstanding this fault of mine, looking at the grammer and spelling contained in DFC's posts, and considering the 'precise' content of some of his quotes, I wonder if DFC is really a two-year-college-special freshly-churned-out-but-nil-experienced B1 or B2 who falls into d) above. a) may also apply.
camlobe
Joined: Dec 2005
Posts: 1,581
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From: England
Well the current LAMS, (I wont go into LAMPS as I dont understand it fully yet) says in section 5 page ""certification of maintenance-non commercial air transport""
Defined as aircraft operated without an AOC.
Annual inspection may be certified by the holder of a UK AMEL or Jar 66 licence.
Star inspection must be completed under the supervision of an approved organisation.
The wording was changed a number of years ago to remove the statement that it had to be carried out at the premises of an approved organisation. I reckon the change was made about 7-8 years ago.
Camlobe
You must know something I don't.
Being a sad git I just do what the approved maintenace schedule tells me to do!!!!!!!!!!
Defined as aircraft operated without an AOC.
Annual inspection may be certified by the holder of a UK AMEL or Jar 66 licence.
Star inspection must be completed under the supervision of an approved organisation.
The wording was changed a number of years ago to remove the statement that it had to be carried out at the premises of an approved organisation. I reckon the change was made about 7-8 years ago.
Camlobe
You must know something I don't.
Being a sad git I just do what the approved maintenace schedule tells me to do!!!!!!!!!!
Joined: Mar 2002
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From: Euroland
This is not great but it gives you a compact idea.
http://www.easa.europa.eu/doc/Events...esentation.ppt
Note that EASA said that it would be OK to continue using LAMS. What a pity the CAA representatives are usually sleeping off their hangovers at the back of the room when such things are mentioned.
Or is it simply work creation to bring in the LAMP?
People like camlobe would like to have owners thinking that they have to have maintenance done at expensive maintenance facilities.
Just more of the mis-information that is being spread.
Only fools will be paying more for their maintenance on their private light aircraft as a result of EASA.
Regards,
DFC
http://www.easa.europa.eu/doc/Events...esentation.ppt
Note that EASA said that it would be OK to continue using LAMS. What a pity the CAA representatives are usually sleeping off their hangovers at the back of the room when such things are mentioned.
Or is it simply work creation to bring in the LAMP?
People like camlobe would like to have owners thinking that they have to have maintenance done at expensive maintenance facilities.
Just more of the mis-information that is being spread.
Only fools will be paying more for their maintenance on their private light aircraft as a result of EASA.
Regards,
DFC
Joined: Feb 2007
Posts: 132
Likes: 0
From: UK
That link opened a Part M presentation dated 1 December 2006 - isn't that a bit over a year old and out of date by now ?? If that is current gospel, then .................................(stuff).
Up to date is what you need to be reading, not old hat EASA "oops - they dont seem to like that very much - we had better think again - see if they like this instead then" back-pedalling.
Best Regards
Malcom
Up to date is what you need to be reading, not old hat EASA "oops - they dont seem to like that very much - we had better think again - see if they like this instead then" back-pedalling.
Best Regards
Malcom
Joined: Dec 2005
Posts: 1,581
Likes: 73
From: England
According to LAMPS, certification is made in accordance with Part M MA 801 and MA 803 for non AOC aircraft.
803 is pilot maintenance, I'll leave that.
801. This is for aircraft not released by Part 145 organisations.
Basically it says that post maintenance a release to service can be issued by
1 Appropriate certifying staff from a subpart F approved maint org.
2 (Except for Appendix 7 tasks) By certifying staff in compliance with Part 66, i.e licensed engineers. Appendix 7 corresponds more or less to the old AWN Notice 3 tasks requiring special techniques e.g welding, bonding, major structural work.
3 I.A.W MA 803 i.e pilot maint.
So it seems to me that a licensed engineer can sign for an annual or any other work within the scope of his licence providing an AOC is not in force.
Malcolm you say that a liceensed engineer cannot change a seat rail that is screwed down.
I think you are in error. Appendix 7 covers seat rails but not those that are screwed down.
803 is pilot maintenance, I'll leave that.
801. This is for aircraft not released by Part 145 organisations.
Basically it says that post maintenance a release to service can be issued by
1 Appropriate certifying staff from a subpart F approved maint org.
2 (Except for Appendix 7 tasks) By certifying staff in compliance with Part 66, i.e licensed engineers. Appendix 7 corresponds more or less to the old AWN Notice 3 tasks requiring special techniques e.g welding, bonding, major structural work.
3 I.A.W MA 803 i.e pilot maint.
So it seems to me that a licensed engineer can sign for an annual or any other work within the scope of his licence providing an AOC is not in force.
Malcolm you say that a liceensed engineer cannot change a seat rail that is screwed down.
I think you are in error. Appendix 7 covers seat rails but not those that are screwed down.
Last edited by ericferret; 3rd January 2008 at 23:53.
Joined: Dec 2005
Posts: 1,581
Likes: 73
From: England
Yes, but I believe that this is being caused by low steam pressure in my computer system combined with easterly winds!!!!!!!!
Just gave it a go, got to the Part M pdf in about a minute, which is pretty good by my usual efforts.
Just gave it a go, got to the Part M pdf in about a minute, which is pretty good by my usual efforts.
Last edited by ericferret; 4th January 2008 at 11:54.
Joined: Dec 2005
Posts: 1,581
Likes: 73
From: England
What is to stop an owner going to a different CAMO at each ARC if he so choses.
Once the initial ARC is issued by the CAA only work carried out between that point and the next renewal needs to be reviewed.
For many private owners this will be minimal, probably a calendar 50 and an annual.
Providing the log books, maint schedule and associated documentation are in good order, the only requirement would be an AD search and an aircraft survey.
The cost of this in a competitive environment should not be excessive.
It has been suggested that the CAMO needs to generate a workpackage before a maintenance check can be carried out. If the schedule and associated documents are in order this need not be the case. The person certifying the check for a simple aircraft can easily extract this information and carry out the required work as they do now.
I believe that any regulation that forced an owner to stay with a particular CAMO due to the excessive costs in changing CAMO's, would be viewed as anti-competitive and therefore in breach of European law.
Once the initial ARC is issued by the CAA only work carried out between that point and the next renewal needs to be reviewed.
For many private owners this will be minimal, probably a calendar 50 and an annual.
Providing the log books, maint schedule and associated documentation are in good order, the only requirement would be an AD search and an aircraft survey.
The cost of this in a competitive environment should not be excessive.
It has been suggested that the CAMO needs to generate a workpackage before a maintenance check can be carried out. If the schedule and associated documents are in order this need not be the case. The person certifying the check for a simple aircraft can easily extract this information and carry out the required work as they do now.
I believe that any regulation that forced an owner to stay with a particular CAMO due to the excessive costs in changing CAMO's, would be viewed as anti-competitive and therefore in breach of European law.
Last edited by ericferret; 5th January 2008 at 13:41.
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From: Not a million miles from EGTF
Eric
There is nothing to stop you changing CAMOs each year. In fact that would be the situation if you went into the 'uncontrolled environment'. But the problem that would result from this is that each ARC would effectively be a Star Annual.
The CAA have already stated that they would prefer us to have a long-term arrangement with our MOs and so by staying the in the 'controlled environment' we have the current situation of Star-annual-annual-Star annuals, which should cost a lot less.
There is nothing to stop you changing CAMOs each year. In fact that would be the situation if you went into the 'uncontrolled environment'. But the problem that would result from this is that each ARC would effectively be a Star Annual.
The CAA have already stated that they would prefer us to have a long-term arrangement with our MOs and so by staying the in the 'controlled environment' we have the current situation of Star-annual-annual-Star annuals, which should cost a lot less.
Joined: Dec 2005
Posts: 1,581
Likes: 73
From: England
At the moment I can't envisage how the whole process will work and what it will cost.
It is just that if you are not in the controlled environment it has been suggested that the CAA would renew the ARC at enormous cost.
I am suggesting that you could go to a CAMO on a one off basis at £?????
This must be possible otherwise what happens if a CAMO closes it's doors for any reason. You would have to start from scratch then.
I think that once the paperwork is at the required standard which it should be for the initial issue of the ARC by the CAA then the year to year maintenance of it should not be a difficult or costly matter ( for a simple aircraft).
Basically I am looking for the loopholes and pitfalls in the system. They will be there as anyone who has looked at the EASA legislation so far will be forced to concede. Those drafting it are not very bright!!!!!!!!!!!!!!! Nice but dim!!!!!!!!!!
It is just that if you are not in the controlled environment it has been suggested that the CAA would renew the ARC at enormous cost.
I am suggesting that you could go to a CAMO on a one off basis at £?????
This must be possible otherwise what happens if a CAMO closes it's doors for any reason. You would have to start from scratch then.
I think that once the paperwork is at the required standard which it should be for the initial issue of the ARC by the CAA then the year to year maintenance of it should not be a difficult or costly matter ( for a simple aircraft).
Basically I am looking for the loopholes and pitfalls in the system. They will be there as anyone who has looked at the EASA legislation so far will be forced to concede. Those drafting it are not very bright!!!!!!!!!!!!!!! Nice but dim!!!!!!!!!!
Joined: Aug 2003
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From: Not a million miles from EGTF
I'm baffled.
You do not go to a CAMO on a one off basis. That would be ludicrous under the scheme as planned.
What would happen is that the new CAMO would have to go through your documentation in great detail, raise the paperwork for the issue of an ARC , suck in their breath and say 'did you realise that your last MO didn't do this, that and the other, so we'll have to do it all over again....' They'd even question your own record keeping, as they have a responsibilty to EASA (as well as having to fund their aprovals)
On the other hand, you could sign up with a CAMO who would do the work, keep the records and for up to 2 years you don't have the effort or cost of a full Star Annual - the CAA and EASA really want this to happen, so have loaded the costs accordingly.
Now if you have shedloads of money or are unhappy with your MOs, then you can 'be a tart' and move between organisations. Otherwise we are being 'encouraged' to stay with an organisation that knows our a/c.
Problems come when our chosen MO decides not to carry on, or when we buy an a/c from another area of the country. That will really hurt
You do not go to a CAMO on a one off basis. That would be ludicrous under the scheme as planned.
What would happen is that the new CAMO would have to go through your documentation in great detail, raise the paperwork for the issue of an ARC , suck in their breath and say 'did you realise that your last MO didn't do this, that and the other, so we'll have to do it all over again....' They'd even question your own record keeping, as they have a responsibilty to EASA (as well as having to fund their aprovals)
On the other hand, you could sign up with a CAMO who would do the work, keep the records and for up to 2 years you don't have the effort or cost of a full Star Annual - the CAA and EASA really want this to happen, so have loaded the costs accordingly.
Now if you have shedloads of money or are unhappy with your MOs, then you can 'be a tart' and move between organisations. Otherwise we are being 'encouraged' to stay with an organisation that knows our a/c.
Problems come when our chosen MO decides not to carry on, or when we buy an a/c from another area of the country. That will really hurt
Joined: Dec 2005
Posts: 1,581
Likes: 73
From: England
My point exactly. I can see no reason why the new CAMO should have to go through the old paperwork in great detail?.
That will have been done previously. All that is required is to review the paperwork since the issue of the last ARC. Probably a 50/Annual and AD's. This should be a minimal cost.
This is how C of A's have been carried out previously. You only review the paperwork since the last C of A. Why the need to reinvent the wheel?
This system should work in many ways in the same way as the old system except for the fact that the paperwork (CAMO) and maintenance organisations may not be one and the same.
The fact that the CAA want owners to strike up a long term relationship with the CAMO/Maint org is nothing new they have been banging that drum for 30 years.
A long term relationship beneficial to both parties is a good thing. However what people are afraid of is being trapped in an unsatisfactory relationship and being unable to move.
This CAMO system was designed for commercial air transport operations with an AOC in force. Even EASA are looking at modifying it almost before it is operational. It is clearly a sledge hammer to crack a nut.
That will have been done previously. All that is required is to review the paperwork since the issue of the last ARC. Probably a 50/Annual and AD's. This should be a minimal cost.
This is how C of A's have been carried out previously. You only review the paperwork since the last C of A. Why the need to reinvent the wheel?
This system should work in many ways in the same way as the old system except for the fact that the paperwork (CAMO) and maintenance organisations may not be one and the same.
The fact that the CAA want owners to strike up a long term relationship with the CAMO/Maint org is nothing new they have been banging that drum for 30 years.
A long term relationship beneficial to both parties is a good thing. However what people are afraid of is being trapped in an unsatisfactory relationship and being unable to move.
This CAMO system was designed for commercial air transport operations with an AOC in force. Even EASA are looking at modifying it almost before it is operational. It is clearly a sledge hammer to crack a nut.
