EASA part M what are you doing?

[A and C]

Bose-X

You must have a very nice engineer if he is not going to charge you any extra for all the work that he is going to have to put in to get the required Part M approvals. He will certantly be cutting in to his proffit if this is the line that he is taking. I have to ask if your engineer has got his part M approvals yet?

Please remember the maintenance industry did not ask for or want this European system, it has been forced on us by Brussels but the choice is stark, put up the prices to cover the extra paperwork/approval costs or run the risk of going out of business.

I notice that no one has been able to answer the question that started this thread! perhaps it is because there is so little understanding of what is going to happen.

[Malcom]

A & C

I believe we had this conversation at Xmas - good to see nothing has changed, apart from the posibility of a years grace, and no firm progress with the NPA, but it is still very much head in sand throughout GA.



Malcom

[vee-tail-1]

I guess there's only a small number of pilots who have the competence & confidence to do much of the maintenance work on their aircraft. Also since they would need to work from a type specific maintenance program, this would restrict them to the mainly French aircraft whose manufacturers already provide such programs. Some people should never be let loose with a spanner, and the CAA are probably horrified at the thought of DIY aircraft maintenance.

However the CAA are out of order if they interpret EASA rules to prevent competent owners working in the un-controlled environment. Under my interpretation of part M owners have a choice between the NAA and any CAMO to renew their ARC once a year. In the controlled environment the ARC is renewed every three years, but you have to take out a contract with the CAMO to do the work...no DIY.

[IO540]

I guess there's only a small number of pilots who have the competence & confidence to do much of the maintenance work on their aircraft.

The 50hr checks are easy for anybody who is mechanically competent. It's probably true that most owners can't do it but the system should not prevent it.

Also since they would need to work from a type specific maintenance program, this would restrict them to the mainly French aircraft whose manufacturers already provide such programs.

Do Socata offer this? I haven't seen this.

Some people should never be let loose with a spanner,

most of whom already work at EASA145 certified companies

and the CAA are probably horrified at the thought of DIY aircraft maintenance.

I don't see why, looking at some of the cowboys who they already certify.

The best maintenance my plane gets is when I do the 50hr checks, working with an A&P/IA colleague. It's the only time it gets proper lubrication, with bearings packed with fresh grease instead of a squirt of WD40.

[DFC]

Bose-X is correct in his assessment.

Some maintenance providers are having to get their act together and are having to put some work in to bring their operation up to a minimum acceptable European level.

I simply hope that owners are not as foolish as A and C plus many other maintenance providers would like them to be.

Every manufacturer produces a maintenance program. If you contact your manufacturer they will provide the relevant guidance and documentation.

There is nothing wrong with you drawing up your own program and having it approved.

In the absence of the above 2 then you can simply use the CAA's generic light aircraft maintenance programme with the relevant type specific issues added.

So once again - Nothing much is going to change other than a few bits of paperwork. Many people knew that a long time ago and nothing has changed. It is not a case of head in the sand but a case of having it sorted and not believing those that are trying to cash in on those that do not know better.

Regards,

DFC

[Malcom]

Most maintenance manuals contain an inspection program already, but these dont often contain everything needed to make a suitable maintenance program. LAMP is pretty well ready to go with a component list & AD compliance list. The TB10 manual contains one for normal use and a progressive program too.

In the Controlled environment you can still do your own stuff, provided the CAMO authorises you, assesses your competence, etc.

By all means do your own maintenance - all for it, but your ARC revalidation cost is now a complete unknown. At £122/hour proposed, CAMOs will be in a position to undercut the CAA at £120/hour.

Malcom

[IO540]

The TB10 manual contains one for normal use and a progressive program too.

That's news to me. I enquired about progressive maintenance options for the TB20 and none existed, N-reg or G-reg. This is true for nearly all GA aircraft, anthough progressive maintenance (avoiding Annuals and all other calendar-time-fixed checks) is common on big stuff. PG for GA would be brilliant because the process could be spread over a sequence of 50hr checks, instead of the Annual check being confined to ... the Annual, and this could be used to avoid the dependency on a specific company.

[Malcom]

IO540 - you seem to imply being tied to a MO to be in the Controlled Environment.
You are not going to be tied to any Maintenance Organisation, any Part 145 or Subpart F MO can be used. You are only tied to a CAMO to retain the Controlled environment status.

TB10 inspection program is in the Maintenance Manual section 5. Most recent types have this as a part of their certification process.

Nearly all GA have these inspection programmes in their Maint. manuals.

[jxk]

Regarding owners doing their own 50hr checks. I would like to see how owners check the AD status and sign that they have been complied with the requirements without the necessary access to the information. From my experience those who sign for a 50hr don't work to LAMS/LAMP schedule and often make it a paperwork exercise only. Most just do an oil change and think that's it! I know that some people posting here are competent engineers and do a good job but this isn't always the case. It would also seem that a few here have had a bad experience with their MO and seem bitter about it. I don't believe the introduction of Part M will remedy this!
It would seem that no one on this forum has has really any experience of how Part M will work but I stand to be corrected.

[A and C]

DFC

You can indeed do some of the work on your aircraft but the question is who is going to renew the ARC?

In your case you seem to think that it is just a matter of putting the paperwork to the CAA but the £122/hour to check the paperwork and the day out from the local CAA office to conduct the aircraft survey are going to sting you so hard that you will be in no doubt who the fool in this conversation is.

The strange thing is that as much as I am opposed to the part M thing DFC thinks that the rest of the maintenance industry and myself are trying to rip-off the aircraft owner by fooling them into some sort of bondage, the truth of the matter is that I would like to see aircraft owners get the best from the system however most of you seem to have not given these important issues much time and this is likely to cost you a lot if you take no action.

We are on page two of this thread now and no one has attempted to answer the question that I first asked, I am begining to think that no one knows what this subpart G is all about.

If you own an aircraft you MUST get the with the program on this or you will fall outside the "controled enviroment" and into the hands of the CAA at £122/hour. please don't take the advice of the likes of DFC on these forums but go talk to the a few enginering companys and the CAA and get the true story.

[Piper.Classique]

Ho hum
Got an annex two a/c
Don't want to go LAA, it is a glider tug. So the CAA is now pushing us to go LAA, and that will mean if we accept; that it isn't a glider tug any more

[IO540]

I don't know anybody who does owner maintenance totally alone. Normally it is done as an "owner assist" and obviously you need a friendly engineer to do it with.

The information isn't hard to get. One normally has the last Annual worksheets and return to service schedules of ADs etc complied with and together with mfg data one can work out which ADs need to be done. On the TB20 there is very little in between annuals; nothing I recall recently.

And the manuals ... one can buy "used" ATP CDs on Ebay This also has the wiring diagrams and the IPC, which is very handy. In fact socata.org has the official up to date TB maint manual online, which is even better.

I think owner maintenance has its place - in between Annuals which are rarely doable by the owner for the usual airfield political reasons: cannot work in the hangar, cannot do a lot of work anywhere because it upsets based maint firms, the gossip circuit, etc. But a Sunday morning is perfect for a 50hr check in which everything is properly greased, not the WD40 squirt job which the "proper" MO is doing. When I was on G-reg I used to pay £600 for 50hr checks (JAR145 MO) and no way was that good value.

[DFC]

I would like to see how owners check the AD status and sign that they have been complied with the requirements without the necessary access to the information.

There has always been a requirement for owners to ensure that ADs etc are complied with. They are also required to ensure that any revisions to the maintenance manuals are incorporated.

Far too many owners have simply assumed that the maintenance organisation they ask to complete their maintenance did all that......but the responsibility lies on the owner.

That is why owners must ensure that the manufacturer or in the case of the manufacturer no longer being round the responsible authority have their correct address.

Nothing has changed in this regard either.

-------

A and C,

I have not offered any advice. I have simply stated my position and my opinion on the matter.

Cessna has a progressive maintenance programme that you can get from them and you can have it approved.

IO540,

You need to speak with the manufacturer, they and you can agree on a progressive program. When you have the agreed program in place simply start using it.

In your case you are better placed if you can approach them directly and perhaps with a non-UK address. Don't bother trying it via the UK distributor and hence the non-UK address to avoid stepping on their toes.

Regards,

DFC

[ACX]

I would think that there would be huge differences in the costs between an aircraft in a controlled environment and those that are not.

People seem to be forgetting that in the un-controlled environment, to get the CAA to come out and renew the ARC, you first need a sub-part G to make a recommendation to them to renew the ARC, thus you will need to pay the sub-part G to do a full review and then the CAA costs on top. This is verses just paying the sub-part G an annual fee to do the job anyway.

With regards to owner maintenance, I have no problem with this and know many competent owners who do this and in some cases know more about their aircraft than I do, but I do have to agree that most forget about AD’s and as such, may have just done a very nice 50hr check, but have forgotten about the AD that is due every 50hrs or actually have done it; but an owner can not sign for an AD and thus could find himself flying illegally. Remember that most older GA aircraft have 50hr reoccurring AD’s, whether it be the old magneto switch check or just putting the additive into the oil. They all count as AD's.

ACX

[gasax]

It is surprising just how little many owners seem to know about their responsibilities.

As DFC has pointed out it is all the owners responsibility. The CAA may have licensed the engineers and the company they work for but that is almost irrelevant, the owner is responsible for the content and quality of the maintenace of their aircraft - and amazingly there is case law to back it up. So to a large extent the CAMO stuff is not terribly relevant. It will remain the owners responsibility.

So if you get 'stiffed' by a fairly typical CAA licensed engineering company - it is your fault.... Wonderful situation. Given the present level of competance of UK aero engineering cocmpanies I congratualte myself on choosing a permit aircraft.....

If you have a decent company stay with them, if not it is the usual shop around...

[IO540]

As DFC has pointed out it is all the owners responsibility

That statement may be legally true but is surely meaningless, as the vast majority of owners barely know what an "AD" stands for. Most owners just drop the plane off at their dealer and collect it some time later, not asking any questions.

TBH this is a difficult area because if you (the owner) get pro-active with a MO which has been doing it a certain way for many years, they are going to get cheesed off and may get aggressive. One is immediately into the usual airfield political issues and unfortunately one cannot consider how Mart M etc is going to work without considering these.

For example, I am sure the majority of owners don't use a based MO for their maintenance - they fly away somewhere. Then if there is a dispute re the work, they don't end up doing you know what on your doorstep. One must not fall out with the MO on the airfield - one day you will need their release to service (even if their work is crap - irrelevant) so you can fly somewhere where required work can be done. If the based MO is crap then the only way to not fall out with them is to rarely if ever use them! And that is what you just have to do.

This is why I am unhappy about regs which appear like they tie the owner to a specific MO. In this business so many people have the owner over a barrel already.

[Malcom]

IO540 """This is why I am unhappy about regs which appear like they tie the owner to a specific MO. In this business so many people have the owner over a barrel already."""


I say again:

""IO540 - you seem to imply being tied to a MO to be in the Controlled Environment.
You are not going to be tied to any Maintenance Organisation, any Part 145 or Subpart F MO can be used. You are only tied to a CAMO to retain the Controlled environment status.""

Your CAMO need not be your MO.

As for usng "used" CDs, be very careful - you must use current maintenance data or you invalidate the C of A and insurance, etc.

[IO540]

Your CAMO need not be your MO

How would that work politically - if say the CAMO is on your airfield, and perhaps owns your hangar or even the entire airfield, but the MO you actually use is elsewhere.

[Malcom]

Your choice of CAMO and MO is exactly that - yours. You need to weigh up any politics in your assessment, or move?

The CAMO could concievably be a man in a bedroom somwhere. He is only managing the aircraft - not working on it. He would visit the plane at the MO to do his surveys.

The three of you - owner MO and CAMO will be contracted to each other so any politics will have been dispensed with at the outset.

If you had a combined CAMO/MO on your field, why go elsewhere anyway? But. that is your choice

[IO540]

The CAMO could concievably be a man in a bedroom somwhere. He is only managing the aircraft - not working on it. He would visit the plane at the MO to do his surveys.

The three of you - owner MO and CAMO will be contracted to each other so any politics will have been dispensed with at the outset.

I think that the man I spoke to the other day (just come off the EASA course) was training for just this. He doesn't do actual work, just certification paperwork.

This sounds interesting.

If you had a combined CAMO/MO on your field, why go elsewhere anyway? But. that is your choice

The usual reason for not using a local company is a) to get a decent job done or b) to keep one's own doorstep clean if there is a dispute over the work. As I wrote before, the local outfit must be available for AOG work; if you burn your bridges with them, you are stuffed and are into the realm of travelling engineers which ISTM are pretty rare for G-reg.