EASA money pit
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EASA money pit
Having been head down in unproductive paperwork for the new EASA part M maintenance approval I had rather missed the new scale of charges from the CAA.
According Maurice Colson in the latest Loop the maintenance approvals will form 2008 cost £1552pa for the M3 approval and £3482.50pa for the EASA part M subparts F&G.
All this extra money to pay for the aprovals just allow us to to do what we are doing now!
The cost for the approvals in 2004 was £654pa.
That is a price hike of £4380pa over four years............. That is why maintenance prices will have to rise and not a penny of it wll end up in the hands of the engineering company's.
According Maurice Colson in the latest Loop the maintenance approvals will form 2008 cost £1552pa for the M3 approval and £3482.50pa for the EASA part M subparts F&G.
All this extra money to pay for the aprovals just allow us to to do what we are doing now!
The cost for the approvals in 2004 was £654pa.
That is a price hike of £4380pa over four years............. That is why maintenance prices will have to rise and not a penny of it wll end up in the hands of the engineering company's.
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That is why maintenance prices will have to rise and not a penny of it wll end up in the hands of the engineering company's.
If you simply want to continue to provide maintenance then there has not been any significant increase in costs.
If you want to provide extra services then there will of course be extra costs involved in gaining the extra approvals.
If you are correct in describing the paperwork catch-up exercise you have to do as unproductive, please explain how productive you organisation will be without having completed the catch-up exercise?
You could also explain just what paperwork you are so far behind with?
Did you just discover EASA part M etc last month. I seem to remember it being common knowledge (if not in final form) for almost a decade.
This is like the CAA - Oh ICAO have decided to change R/T for climb clearances. Shock Horror. We have not have time to assess the impact and we can not change our procedures until we have an assessment and consultation..............Was your man at the ICAO meeting asleep? Did they have memory loss after the meeting? Did they simply claim the expenses and go shopping in Montreal instead?
You are correct to say that not everyone is in the same boat and it is not a level playing field............most have recognised what work if any was needed years ago and are sitting happy. Unfortunately, Jonny'd dog ate their homework and they have to stay behind to catch up.
So sit in your office and put up your prices.....remember that the cost of approval represents very few hours at UK engineer rates....what do you do with the income from all the other hours income? Don't complain when other maintenance organisations get your work.
Regards,
DFC
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My guess is what will happen is that a lot of maintenance facilities will do the work and get a chap from another firm (which has paid for the approvals) to come in and sign the papers.
The people who actually do aviation maintenance are in many cases kinds who can barely pick up the right end of a screwdriver. This is JAR/EASA 145 I am talking about, too.
The people who actually do aviation maintenance are in many cases kinds who can barely pick up the right end of a screwdriver. This is JAR/EASA 145 I am talking about, too.
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DFC
Just how thick are you? or is it you are on some anti-mantenance company agenda?
All the extra approvals are needed JUST TO DO THE WORK THAT AN M3 COMPANY IS DOING AT THE MOMENT! not anything extra.
Why should the maintenance companys have to take the hit just so EASA and the CAA can employ more people to push paper that had very little to do with safety.
The fact is it will encourage the low end of the business to cut corners.
we have been on this project for about 18 months and the reason for all the paperwork it that EASA keeps moving the goalposts, just a few weeks or so back they published LAMP to replace LAMS...................yet another paperwork re-hash to pander to EASA if you are an aircraft owner you will get a CAA LTO on the subject soon.
All the extra approvals are needed JUST TO DO THE WORK THAT AN M3 COMPANY IS DOING AT THE MOMENT! not anything extra.
Why should the maintenance companys have to take the hit just so EASA and the CAA can employ more people to push paper that had very little to do with safety.
The fact is it will encourage the low end of the business to cut corners.
we have been on this project for about 18 months and the reason for all the paperwork it that EASA keeps moving the goalposts, just a few weeks or so back they published LAMP to replace LAMS...................yet another paperwork re-hash to pander to EASA if you are an aircraft owner you will get a CAA LTO on the subject soon.
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Moreoever these costs are an issue of economy of scale.
Like any regulatory costs they may be better absorbed by larger concerns.
However, some of the best engineers do not fall into that category. There life long work has been in this business - they are as good as any, and better than most when in comes to working on some of the ageing and traditional GA fleet.
I know Maurice well and he most certainly falls into that category.
If he, or any others like him, were unable to continue in business because of these signficant increases it would be a very sad day.
Maurice has devote a great deal of his time to this matter and he is to be congratulated for doing so in my view.
Like any regulatory costs they may be better absorbed by larger concerns.
However, some of the best engineers do not fall into that category. There life long work has been in this business - they are as good as any, and better than most when in comes to working on some of the ageing and traditional GA fleet.
I know Maurice well and he most certainly falls into that category.
If he, or any others like him, were unable to continue in business because of these signficant increases it would be a very sad day.
Maurice has devote a great deal of his time to this matter and he is to be congratulated for doing so in my view.
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I have more sense than to believe your excuse for putting up your prices.
I also have more sense than to restrict my maintenance to just UK based organisations when better value is available elsewhere.
I remember the UK training organisations moaning about how much their prices would have to rise because of JAR-FCL. One particular Balckbushe operator was very up front in saying that JAR-FCL was going to cause price rises in his organisation............which went under in shady circumstances shortly after.
I know that there is noting new in EASA Part M that has not beein known about for a long long time.
There is the class of engineer who listens and learns and prepares for the future then there are those at the back who are constantly playing catch-up.
This is that I use top of the class Maintenance because in the long run it costs less and do not listen to the old..........ah if you get maintenance done in xyz EASA country we won't touch your aircraft back in the UK.
Isn't eradicating that attitude what EASA was all about?
I can pay a UK engineer £60 per hour or I can pay a French one EUR60 for the same product i.e. EASA certified maintenance. That is a big difference when it comes to certain scheduled maintenance.
Regards,
DFC
PS Must remember to moan to my employer about the bookwork I have to do every 6 months just to keep up to speed as a professional pilot. Not very productive being in the classroom is it?
I also have more sense than to restrict my maintenance to just UK based organisations when better value is available elsewhere.
I remember the UK training organisations moaning about how much their prices would have to rise because of JAR-FCL. One particular Balckbushe operator was very up front in saying that JAR-FCL was going to cause price rises in his organisation............which went under in shady circumstances shortly after.
I know that there is noting new in EASA Part M that has not beein known about for a long long time.
There is the class of engineer who listens and learns and prepares for the future then there are those at the back who are constantly playing catch-up.
This is that I use top of the class Maintenance because in the long run it costs less and do not listen to the old..........ah if you get maintenance done in xyz EASA country we won't touch your aircraft back in the UK.
Isn't eradicating that attitude what EASA was all about?
I can pay a UK engineer £60 per hour or I can pay a French one EUR60 for the same product i.e. EASA certified maintenance. That is a big difference when it comes to certain scheduled maintenance.
Regards,
DFC
PS Must remember to moan to my employer about the bookwork I have to do every 6 months just to keep up to speed as a professional pilot. Not very productive being in the classroom is it?
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DFC
Please help me, I dont understand your point.
How can light aircraft maintenance for the average owner operator or even small flying school be a level playing field?
Most people are far too busy to have the time not so much to get the aircraft to some far flung maintenance organisation but more to the point to get back. I doubt that many owners take their aricraft far from their local field, if they even do that.
A days loss of income may represent 20% or so of the total cost of an annual, so going further afield will often end up costing more.
Moreover there can be all sorts of other hassels associated with doing so not least including the weather hampering plans to move aircraft around, particularly if there is no let down at the maintenance organisation base and having to use other MOs if there are minor snags between checks to name but two.
How do you square the circle?
Please help me, I dont understand your point.
How can light aircraft maintenance for the average owner operator or even small flying school be a level playing field?
Most people are far too busy to have the time not so much to get the aircraft to some far flung maintenance organisation but more to the point to get back. I doubt that many owners take their aricraft far from their local field, if they even do that.
A days loss of income may represent 20% or so of the total cost of an annual, so going further afield will often end up costing more.
Moreover there can be all sorts of other hassels associated with doing so not least including the weather hampering plans to move aircraft around, particularly if there is no let down at the maintenance organisation base and having to use other MOs if there are minor snags between checks to name but two.
How do you square the circle?
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If the aircraft can not go to the maintenance organisation then the maintenance organisation can come to the aircraft.
Worth trying some figures regarding maintenance. Try looking at the cost of an Eastern Europe EASA qualified engineer based at your school but working for you and your local owners in terms of supervision and day-to day rectification with further support drawn in from the home country EASA approved based maintenance organisation for larger maintenance tasks.
Remember that a 50hr in a PA28 is not rocket science.....that is why a PPL can do it if operation is private.
Now compare the charge for a UK maintenance organisation to provide the same level of cover.
Of course, with EASA taking over, we will eventually end this rather silly situation where group owned aircraft and club aircraft and aircraft used for training are public transport.
There is absolutely no reason for club trainng aircraft to be certified for public transport. A point hopefully EASA will pick up on.
I am not anti-engineer, I am anti leading people down the garden path.
Regards,
DFC
Worth trying some figures regarding maintenance. Try looking at the cost of an Eastern Europe EASA qualified engineer based at your school but working for you and your local owners in terms of supervision and day-to day rectification with further support drawn in from the home country EASA approved based maintenance organisation for larger maintenance tasks.
Remember that a 50hr in a PA28 is not rocket science.....that is why a PPL can do it if operation is private.
Now compare the charge for a UK maintenance organisation to provide the same level of cover.
Of course, with EASA taking over, we will eventually end this rather silly situation where group owned aircraft and club aircraft and aircraft used for training are public transport.
There is absolutely no reason for club trainng aircraft to be certified for public transport. A point hopefully EASA will pick up on.
I am not anti-engineer, I am anti leading people down the garden path.
Regards,
DFC
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If the aircraft can not go to the maintenance organisation then the maintenance organisation can come to the aircraft.
So help me out a bit further please?
I dont understand how the maintenace organisation can come to the aircraft?
Are you suggesting some sort of travelling workshop?
Setting up new maintenance companies with labour from outside the UK may seem like an idea - but I dont beleive it is. It is very easy to under estimate the cost of setting up the operation. The pay back period would be considerable. Then there is the minor matter of finding premises - which are in short supply. Of course even if th einitial underlying labour costs are a little less you can guess how quickly they will rise as the engineers realise what they need to earn to live in the UK!
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what planet ... ?
DFC wrote ...
Aye, that'll really keep the costs down. OK for you being able to nip over to France but those of us 3-4 hrs north ain't got much option.
I agree, but don't see EASA changing this soon. Bit of a pisser for me and hundreds of others who are now forced to re-engine aircraft for 'public transport' (ie. flying club) ops. All because CAA re-interpreted the engine TBO rules and insist 12years/2000hrs means whichever comes first. At the stroke of a pen some faceless bureacrat has written off 800hrs of remaining engine life and just cost me £20k. 
Your faith is touching. I heard that the CAA claimed their re-interpretation of the engine TBO rules was forced on them by EASA. Easy to blame someone else ... ?
"rather silly" is a slight understatement when you view the costs involved. Perhaps someone can explain how things are safer as a result ? I guess I've now just got £20k less to spend on other stuff like Mode S transponders, fuel, landing fees etc..etc..
If the aircraft can not go to the maintenance organisation then the maintenance organisation can come to the aircraft.
There is absolutely no reason for club trainng aircraft to be certified for public transport. A point hopefully EASA will pick up on.
Of course, with EASA taking over, we will eventually end this rather silly situation where group owned aircraft and club aircraft and aircraft used for training are public transport.
"rather silly" is a slight understatement when you view the costs involved. Perhaps someone can explain how things are safer as a result ? I guess I've now just got £20k less to spend on other stuff like Mode S transponders, fuel, landing fees etc..etc..
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Aah now I understand DFC!
So it is now clear some Eastern European turns up in and the maintenance gets done, it must be very interesting to see how he gets the hangar and it's equipment in the back of the van.
The fact is back of the van maintenance is not sustanable if you are looking for quality, a few years back I had cause to look over an aircraft that had had a 150 hour check done in a field from the back of a van, the bloke took half a day to do the check and there was no evidence of some safety critical landing gear work having been done (because the guy did not have the jacks in his van). If that work is not done the gear will fail to free fall in the event of a Hydraulic failure.
What price is "back of a van" maintenance then?
50 hour check Yes as DFC says a PPL can do this but what he can't do is any inspections that are the subject of an Airworthiness Directive, most AD's are 100 hour items so a PPL will have to get a LAME in to do these items on the second 50 hour check in the cycle.
CAA costs & the small business most of the small maintenance outfits are probably looking after about 40 aircraft so the new CAA charges will come to £109 pa per aircraft or about £1.50p extra per flying hour for the average private owner in extra CAA fees. DFC please note this is fact not leading you down the garden path you just have to do the sums.
What I am tyring to make clear to DFC is EASA Part M only brings lots more paperwork and CAA charges, you don't get is any extra "hands on" maintainence and in the area of duplicate inspections of flying controls and other critical systems the EASA system is a real errosion of safety standards.
DFC we all know that paperwork is required and I have no problem with this but what I don't like is extra paperwork that has no benifit to the industry or the customers.
Now I am going to take a stab in the dark and guess that DFC professionaly fly's long haul for Big Airways and spends too much time in the cruise thinking of ways to save a penny or two.............. but on this I could quite well be wrong.
The fact is back of the van maintenance is not sustanable if you are looking for quality, a few years back I had cause to look over an aircraft that had had a 150 hour check done in a field from the back of a van, the bloke took half a day to do the check and there was no evidence of some safety critical landing gear work having been done (because the guy did not have the jacks in his van). If that work is not done the gear will fail to free fall in the event of a Hydraulic failure.
What price is "back of a van" maintenance then?
50 hour check Yes as DFC says a PPL can do this but what he can't do is any inspections that are the subject of an Airworthiness Directive, most AD's are 100 hour items so a PPL will have to get a LAME in to do these items on the second 50 hour check in the cycle.
CAA costs & the small business most of the small maintenance outfits are probably looking after about 40 aircraft so the new CAA charges will come to £109 pa per aircraft or about £1.50p extra per flying hour for the average private owner in extra CAA fees. DFC please note this is fact not leading you down the garden path you just have to do the sums.
What I am tyring to make clear to DFC is EASA Part M only brings lots more paperwork and CAA charges, you don't get is any extra "hands on" maintainence and in the area of duplicate inspections of flying controls and other critical systems the EASA system is a real errosion of safety standards.
DFC we all know that paperwork is required and I have no problem with this but what I don't like is extra paperwork that has no benifit to the industry or the customers.
Now I am going to take a stab in the dark and guess that DFC professionaly fly's long haul for Big Airways and spends too much time in the cruise thinking of ways to save a penny or two.............. but on this I could quite well be wrong.
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Now I am going to take a stab in the dark and guess that DFC professionaly fly's long haul for Big Airways and spends too much time in the cruise thinking of ways to save a penny or two.............. but on this I could quite well be wrong.
There are a few people (3 or 4) on here who stir up a lot of hot air. My approach is to ignore them unless they state something which could lead somebody to waste time/money.
Pprune is quite a good forum, with some real expertise over a broad area, but only provided one avoids taking the baits that pop up with much regularity.
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Thanks IO540
Just to add to the debate under EASA part M PPL's will no longer be able to do a 50 hour check without approval from the part M company that they have the aircraft maintenance contract with.
So DFC you will have to stop doing those 50 hour checks untill an engineer is checks you out and is happy that you are up to the job!
So DFC you will have to stop doing those 50 hour checks untill an engineer is checks you out and is happy that you are up to the job!
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I know one club in the South of the UK who lease hangar space to a local UK maintenance organisation that then charges thema fortune for crap maintenence. The club could take control of it's own maintenance and that of many local owners and do a far better job of it than at present. Of course employing people from a country with a highly skilled and well established aircraft design and production industry always makes sense.....but that does not describe the UK anymore unfortunately.
They (the club) are in prime position to think on a wider basis.
A and C,
When I come from there always has been the requirement that a pilot was trained by a qualified on type maintenance engineer in how to do the 50 hour check, had the appropriate manuals and that the maintenance engineer was available for advice or assistance if required. EASA changes nothing there.
To do otherwise would permit the PPL who does not know a spanner from a wrench to do a 50hour check and thus render a serviceable aircraft an unairworthy piece of future aluminium rain.
The engine overhaul periods are applied by the manufacturer. The CAA was permitting "uncertified" engines to be used in "certified" aircraft. EASA was quite right to question that practice.
Of course, while the CAA may think otherwise, EASA does not think that if Lycoming or Continental say that the engine they designed, built and had certified is good for 2000 hours or 12 years whichever is first and then requires an overhaul..........then one can still call the engine a certified engine with 15 years since overhaul.
I would love to have an aviation authority like that. Hi, I would like to certify this aero engine. I can show that a TBO of 2000 hours is appropriate.........CAA response - Yes great we will accept that and give it a TBO of 8000 hours.
Perhaps you would like to explain that one.
Regards,
DFC
They (the club) are in prime position to think on a wider basis.
A and C,
When I come from there always has been the requirement that a pilot was trained by a qualified on type maintenance engineer in how to do the 50 hour check, had the appropriate manuals and that the maintenance engineer was available for advice or assistance if required. EASA changes nothing there.
To do otherwise would permit the PPL who does not know a spanner from a wrench to do a 50hour check and thus render a serviceable aircraft an unairworthy piece of future aluminium rain.
The engine overhaul periods are applied by the manufacturer. The CAA was permitting "uncertified" engines to be used in "certified" aircraft. EASA was quite right to question that practice.
Of course, while the CAA may think otherwise, EASA does not think that if Lycoming or Continental say that the engine they designed, built and had certified is good for 2000 hours or 12 years whichever is first and then requires an overhaul..........then one can still call the engine a certified engine with 15 years since overhaul.
I would love to have an aviation authority like that. Hi, I would like to certify this aero engine. I can show that a TBO of 2000 hours is appropriate.........CAA response - Yes great we will accept that and give it a TBO of 8000 hours.
in the area of duplicate inspections of flying controls and other critical systems the EASA system is a real errosion of safety standards
Regards,
DFC
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I know one club in the South of the UK who lease hangar space to a local UK maintenance organisation that then charges thema fortune for crap maintenence. The club could take control of it's own maintenance and that of many local owners and do a far better job of it than at present. Of course employing people from a country with a highly skilled and well established aircraft design and production industry always makes sense.....but that does not describe the UK anymore unfortunately.
Aircraft out of service cost money - and the best time to do some of the work is after hours.
However, the capital cost of setting up such an organisation is significant.
Schools find it almost impossible to make money anyway, unless they are involved in commercial training - and there are very few of them.
I dont suppose you will find many going into this business without some history these days, or if they do, they dont last long, which says something about the industry.
Now what would make senses is a structured system of continous maintenace - but that would be far too simple.
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Approval Costs
Gents - I think there are some misunderstandings around. At a briefing on Part M approx three months ago at Stansted Regional Office, the CAA stated that discounts were applicable to maintenance organisations needing multiple approvals. They cited the case of an organisation needing Part M Subpart F and G+I plus M3. They said that the highest price approval would be at the full rate, with second and subsequent approvals being charged at only 25% of the rate.
In this case the fees would be:
Subpart G+I - full price
Subpart F - 25%
M3 - 25%
As ever, the CAA is its own worst enemy. Why wo'nt it put an article in the mags or put up a spokesman for interview, so that everyone can get the gen? The info is probably tucked away in the middle of their website somewhere, but how can you find out?
In this case the fees would be:
Subpart G+I - full price
Subpart F - 25%
M3 - 25%
As ever, the CAA is its own worst enemy. Why wo'nt it put an article in the mags or put up a spokesman for interview, so that everyone can get the gen? The info is probably tucked away in the middle of their website somewhere, but how can you find out?
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Duplicate Inspection
DFC as you no doubt know after maintainance of a critical aircraft system (usualy a flying or engine control system) this has to have to have two independant inspections.
Under the CAA system this has to be two licenced engineers or some one with a CAA approval (very unusual)
The EASA system requires the second inspection but the person doing the second inspection can be nominated by the maintenance company, they dont have to be a licenced engineer or CAA approved.
I see this as a loop hole that the bottom end of the market will use to get the tea boy to do safety critical inspections.
Under the CAA system this has to be two licenced engineers or some one with a CAA approval (very unusual)
The EASA system requires the second inspection but the person doing the second inspection can be nominated by the maintenance company, they dont have to be a licenced engineer or CAA approved.
I see this as a loop hole that the bottom end of the market will use to get the tea boy to do safety critical inspections.
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Yes I am aware of the requirements for a duplicate inspection. However, there is no link to licensing. After all, UK major airlines have operated safely for years with very few licensed engineers among the many people who inspect and maintain their aircraft. Company approval worked well under the CAA and could work just as well under EASA.
You forget that the UK CAA ignores the requirement for duplicate inspection in respect of many aircraft on the register.
To say that an unqualified and unknown person can sign off a duplicate inspection is not quite true now is it.......please let everyone know the real requirements for the person (not a licensed engineer) who performs the inspection to confirm that the first person has not reversed the controls or similar.
Regards,
DFC
You forget that the UK CAA ignores the requirement for duplicate inspection in respect of many aircraft on the register.
To say that an unqualified and unknown person can sign off a duplicate inspection is not quite true now is it.......please let everyone know the real requirements for the person (not a licensed engineer) who performs the inspection to confirm that the first person has not reversed the controls or similar.
Regards,
DFC
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There are a few people (3 or 4) on here who stir up a lot of hot air. My approach is to ignore them unless they state something which could lead somebody to waste time/money.
I guess because they don't fly they love to read rule books and other documents.
Makes me chuckle to myself when I find this out
