EASA part M what are you doing?

[Johnm]

I'm signing up with a fairly large but reputable outfit. They are just doing my annual and after they'd taken the aircraft to pieces the engineer walked me round every little part and discussed the action plan in copious detail, this discussion was orchestrated by the senior management of the company.

He showed me all the dodgy elements and was certainly thorough but in no sense attempting to over-engineer the maintenance of a 40 year old aeroplane.

In discussion we also agreed to overhaul the engine and I shall be seeking advice on run in and engine management from experts here and elsewhere in due course

The overhaul shop are also happy for me to go and look at their work and I probably will next week

I have no doubt that the final bill will be an eye watering 5 figure sum but I shall have an aeroplane I thoroughly understand in good nick and I'll then try and keep it that way through regular maintenance.

I will get the EASA C of A via CAA and the rest of the paperwork. I can and will do some of the maintenance myself going forward, but there are practical issues. I have a good set of tools and I'm mechanically competent but I don't have a hangar and maintenance in the middle of a field is not ideal!

[giloc]

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.

I don't think that's correct. For aeroplanes < 2730Kg, if a CAMO has recommended that the CAA renews or reissues the ARC, then the fee to the CAA is £25 per 500Kg MTOW. The CAMO has already done the Airworthiness Review, so you don't pay the CAA their £122/hour to do it.

[robin]

You should remember, though, that the CAA has priced its part of the process actively to discourage owners using the CAA.

They (and EASA) want our a/c to be in the controlled environment and will be making life in the 'uncontrolled environment' expensive and inconvenient

[Malcom]

Confusion reigns again! It is either the CAA or the CAMO who recommend the ARC revalidation. If you're in the uncontrolled environment you can choose between finding a CAMO who will take you on for the occaison, or go direct to the CAA

If the CAA does the ARC, £25/500kg plus £122/hour is proposed.

If a CAMO does the ARC £25/500kg plus whatever their charge is.

[giloc]

It is either the CAA or the CAMO who recommend the ARC revalidation.

There is now a third option for ELA1 aircraft (includes aeroplanes < 1000Kg). For these aircraft, the airworthiness review may be performed by appropriately qualified independent certifying staff for two consecutive years. In this case, the airworthiness review must be performed by a CAMO or by the CAA once every three years. See M.A.901(g)

[robin]

The ELA1 line is still only a proposal, isn't it? At least until they get round topassing the necessary legislation

[IO540]

Can anybody say what is the latest proposal for 1000-2000kg?

[vee-tail-1]

Part M is based on the present French system for EASA aircraft: The owner signs a "Declaration of Maintenance" acknowledging full responsibility for maintenance of the aircraft. Includes full understanding of the maintenance program, repetitive and one off ADs, service letters, etc. Owners are expected to have subscriptions with manufacturers for Service letters, and to keep updated on ADs via the GSAC website and/or EASA website which will automatically send all new ADs to subscribing owners.
The type specific maintenance program is obtained in my case from Robin/Apex and it has to be "personalised" for the state of equipment, engine type, etc and then submitted to GSAC for approval. The approved program has my name and signature printed on each page and becomes legally binding on me. I am entitled to carry out all work in the program myself, or contract some or all of it to a maintenance organisation/engineer. No matter who does the work I am responsible for it and will be held liable if the MO screws up.
This is the cultural difference I mentioned earlier. If you have been in the habit of giving your aircraft to the MO and "letting them get on with it" you are putting yourself at risk. For if by using LAMS or LAMP the MO misses something and there is an incident, YOU the owner are responsible. You should have supervised the MO and ensured they were doing the work correctly using the appropriate documentation etc. Up till now UK MOs have used LAMS/LAMP with all that entails. There was no need for manufactures particularly French ones to provide an English language type specific program. I had to translate my Robin program into English for my own use, but the approved version is in French. It may be that UK owners can submit programs to the CAA for approval in the original French, pointing out that French is one of the official EU languages! Whatever happens don't try to maintain your aircraft using LAMS/LAMP if you are not an experienced engineer. for you will surely miss something vital. Type specific makes it easy to achieve proper maintenance. ELA 1 may well be similar with perhaps a lighter touch.

[IO540]

For if by using LAMS or LAMP the MO misses something and there is an incident, YOU the owner are responsible

I wonder how that squares up with that other weird concept: the law? Surely, in cases of negligence... Also one cannot expect the owner to remove all the inspection covers etc after the firm has done the Annual.

I wonder how this is supposed to work in practice.

Whatever happens don't try to maintain your aircraft using LAMS/LAMP if you are not an experienced engineer. for you will surely miss something vital. Type specific makes it easy to achieve proper maintenance.

LAMS is a ripe area for all kinds of practices, ranging from minimal (but legal) maintenance, all to way to outright cowboy practices.

For example I have a TB20, for which the Socata maintenance manual specifies a huge long list of stuff to be done. I am sure nobody in the UK does that whole list. It would take "too long". Most UK MOs do the inspections listed (they are quick) and the lubrication is done with an aerosol can instead of dismantling/re-greasing (bearings with grease nipples are done with a grease gun, but many don't have nipples). This is OK if you don't fly in the rain too much, or keep the plane outdoors... but it complies with LAMS.

Now, on the N-reg, I do all the real lube on the pilot maintenance; the 50hr checks. The Annual is just a legal requirement on which little is done beyond the inspections.

[robin]

If you have been in the habit of giving your aircraft to the MO and "letting them get on with it" you are putting yourself at risk. For if by using LAMS or LAMP the MO misses something and there is an incident, YOU the owner are responsible. You should have supervised the MO and ensured they were doing the work correctly using the appropriate documentation etc.

And that is what worries me. As a reasonable pilot but next to useless maintainer of mechanical equipment, I shouldn't be trusted with a screw-driver. It is ludicrous to expect me to supervise my highly-experienced and trusted MO.

In fact, in English law, there is likely to be a test of 'reasonable-ness', but that would take a few cases to end up in court to establish it, and that could take shedloads of money and time.

Owners are expected to have subscriptions with manufacturers for Service letters, and to keep updated on ADs via the GSAC website and/or EASA website which will automatically send all new ADs to subscribing owners.

Really - this is the first I have heard about this

[vee-tail-1]

Look up:-
http://ad.easa.europa.eu [EASA Airworthiness Directives Tool] Very useful just enter your aircraft type in the search box and all relevant ADs are displayed.

www.gsac.fr click on "telechargements" and on "Consignes de navigabilite" also includes the guides to implementation of part M, and much other useful stuff. All documents, forms, the Declaration of Maintenance, responsaibilities of owners, responsibilities of maintenance orgs, etc, available on this easy to use website.
If you have a piece of equipment which might be subject to AD action, enter the manufacturers name in the Resp for navigabilite section and the ADs will come up. EG: enter "MT Propeller", or "Becker radio", "Lycoming", etc.

http://www.apex-aircraft.com/

Click on support, and support-navigation for list of ADs, SLs, SBs, etc.
Being a commercial outfit, they will charge you money for details of the SBs, SLs, and type specific maintenance programmes which are part of the French language manuals.

[ProfChrisReed]

vee-tail-1 wrote:

Look up:-
http://ad.easa.europa.eu [EASA Airworthiness Directives Tool] Very useful just enter your aircraft type in the search box and all relevant ADs are displayed.

Unfortunately not so. I tried this for my glider (Schempp-Hirth Open Cirrus, first manufactured 1967) and the site said no ADs. I know this is not true!

Looking at the search boxes, the earliest ADs you can search for seem to be from 2003. If, as with my aircraft model, there have been no reported problems in recent years, then the site returns no matches.

I suppose if you know all ADs to date have been complied with this might be OK, but as someone pointed out previously there are recurrent ADs which, if older than mid-2003, this site won't show.

The User Guide section specifically states that the site is to inform users about new or amended ADs, so it might be worth registering to get these automatically via email. For older ADs you need a different source (the BGA site for gliders, for example).

[diso]

A and C and all,

You are wrong with your initial post, only aircraft of over 2730kG MTOM and aircraft operated as CAT have to be managed by a CAMO by Sept 2008.

Details of the proposals can be found in this document

http://www.easa.europa.eu/ws_prod/r/...ublication.pdf

Read page 12 paragraph 42 to to 45.


The first thing to remember is that EASA will be providing an extension to the existing system for at least one year to allow the changes they propose to make to Part M to come into effect. So don't panic unless your aeroplane is over 2730 Kg MTOM or you operate as CAT.

Under the new proposals, as I understand it, your continuing maintenance will depend on a number of things,

1 are you an owner/operator.
2 are your operations classed as CAT
3 the MTOM of the aircraft
4 aircraft is non complex or complex

The proposals are, that if your aeroplane is non complex and under 1000 kg MTOM (EA1) and you are an owner/operator, you will not have to enlist the services of a CAMO, therefore you will not have to operate in a controlled environment. Your maintenance engineer (as I read it any licensed engineer and not necessarily belonging to a subpart F organisation) can look after your aircraft with much of the work being undertaken by the pilot/owner if he wishes to or wants to undergo some training or is deemed to be competent enough. The licensed engineer should be able to renew the ARC twice with the third being done by recommendation to a CAMO or National Authority by the licensed engineer (very similar to the old CAA system with star annual every third year).

It must be assumed that if the MTOM is in the next band ie 1000 - 2000 kg (EA2) or is a complex aircraft you will fall under the CAMO umberellea, the same goes for aircraft between 2000 Kg and the upper limit of 2730 Kg MTOM



I too own an Annex II aircraft on a CofA and therefore will take no part in all this EASA stuff, but I have been following the maintenance side of things as I work with a licensed engineer who is a one man band and not tied to an organisation.

Piper Classique

As I understand it they will relax the rules on aircraft used as glider tugs so the practise can continue with the LAA if necessary, but I'm interested to know what information you have regarding Annex II aircraft and their continued airworthiness. I have contacted somebody in the LAA regarding this and it would appear that there will be approx 350 aircraft left on Annex II with a legitimate CofA. There is no information coming from the CAA about what organisations will be allowed to look after them. The only thing I have learned is that M3 organisations will continue to be licensed as such at no extra cost when they apply for EASA Subpart F approval from the CAA. I too hope that Annex II aircraft all end up on LAA PtoF but, unless de Havilland Support go under and cease to support all the aircraft they hold the Type Approval Certificates for, I doubt that this will happen. Please PM me for further.

[S-Works]

I have just had my first ARC done and it was no different from any other year. My engineer does not seem worried so at the moment I am relaxed about the situation. If it changes then I will review it. No part in getting worked up over it!!

[giloc]

The ELA1 line is still only a proposal, isn't it? At least until they get round topassing the necessary legislation

It is already included in EASA's Opinion 02/2008.

I have just had my first ARC done and it was no different from any other year.

In the UK, the processes for issuing the initial non-expiring C of A and the ARC are essentially unchanged from existing national arrangements. The new requirements will apply from 28 Sep 08 (or 09 depending on what the CAA decide on the transitional arrangements.)

[Malcom]

Diso,

Proposals aren't the law. Opinions aren't the law. You have to go with the law as it stands.
> Part M as it stands will be the law as of 28-9-08.

All EASA types will have to be managed to be in the Controlled Environment unless these proposals to amend Part M do become law.

What if the proposals to change dont go through? What if they change yet again some more?

It was said by the CAA some time ago there would not be any extensions to that date, but now look!


Bose-x

Youv'e just had a "Transitional" C of A and ARC Issue, issued the same way as a M3 recommendation. It is the next one that you should think about.

[diso]

Malcom

I accept what you say, but the eurocrats change the law based upon recommendations made by governing bodies such as EASA. I doubt that these recommendations or opinions will be objected to do you? So I think you can be pretty sure that the transitional provisions will be implimented.

If our dear old CAA said that there would not be any extensions to 28/09/08 it was probably based on information fed to them by EASA. EASA make the rules not the CAA.

I agree that Bose-x has just had a transitional CofA or ARC, and his next one will almost certainly be transitional as well but after that ?????

[giloc]

Proposals aren't the law. Opinions aren't the law. You have to go with the law as it stands. Part M as it stands will be the law as of 28-9-08.

An EASA Opinion is essentially a draft of legislation sent to the European Commission. The Commission, or the Council of Ministers, or the European Parliament could reject it, but at this stage that seems unlikely, so I'd say it's wise to plan for it being 'the law'.

[robin]

I agree that it is quite likely to become law, but the guys at the Belgrano only follow the actual law in place at the time.

Think of how many times governments promise to change the law and then fail to do so.

In this case, the work is still on-going until the law is actually changed

[giloc]

The point is that aircraft owners, maintenance organisations, competent authorities, etc, need to plan for the changes that Part-M will bring. After an extensive process of consultation and refinement involving several NPAs, consultations, and CRDs it's clear that such planning should be based on the latest draft amendments to Commission Regulations 1702/2003 and 2042/2003 that have now emerged from that process.