EASA part M what are you doing?
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EASA part M what are you doing?
On 28 september 2008 all aircraft will have be contracted to an EASA part M maintenance company to keep your aircraft inside a "controled enviroment", If you are an owner what are you going to do? The three options are as follows.
1 Contract (for three years) the whole maintenance to one company that can do the EASA subpart G supervision and the maintenance.
2 Contract just the subpart G supervision to a company and then this would allow you to switch maintenance companys if you wished during the validity of the ARC if you are not happy with the maintenance company.
3 Do it at yourself at much greater cost by getting the CAA to issue the ARC annualy.
What ever option you take this needs action soon to avoid the unnessesary costs of getting trapped in option 3 by doing nothing.
CAA link below
http://www.caa.co.uk/default.aspx?ca...90&pageid=8336
1 Contract (for three years) the whole maintenance to one company that can do the EASA subpart G supervision and the maintenance.
2 Contract just the subpart G supervision to a company and then this would allow you to switch maintenance companys if you wished during the validity of the ARC if you are not happy with the maintenance company.
3 Do it at yourself at much greater cost by getting the CAA to issue the ARC annualy.
What ever option you take this needs action soon to avoid the unnessesary costs of getting trapped in option 3 by doing nothing.
CAA link below
http://www.caa.co.uk/default.aspx?ca...90&pageid=8336
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Why is option 3 more expensive? Other than the hundred quid for the paperwork annually it seems to me that option 3 actually works out cheaper?
If you don't think so please explain why?
If you don't think so please explain why?
Doesn't EASA's Opinion 2/2008 suggest an extension of at least a year to the transitional period?
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Option 3 is proposed to cost a measley revalidation fee of £50 per 500kg plus the additional investigatory charge at £122/hour.
This will be EVERY YEAR since you will be in the "uncontrolled environment"
How long did your last STAR inspection take? Remember that was done by someone who knows your plane!
Cheaper - I cant see it!
Anybody know of any CAMOs for GA types??
This will be EVERY YEAR since you will be in the "uncontrolled environment"
How long did your last STAR inspection take? Remember that was done by someone who knows your plane!
Cheaper - I cant see it!
Anybody know of any CAMOs for GA types??
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“On 28 september 2008 all aircraft will have be contracted to an EASA part M maintenance company”.
Nope…
Option 4 Go LAA and avoid all the crap.
Option 5 Go FAA and avoid some of the crap
Rod1
Nope…
Option 4 Go LAA and avoid all the crap.
Option 5 Go FAA and avoid some of the crap
Rod1
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Do most of the maintenance yourself under the supervision of the person issuing the ARC. Even if you have never fixed a car let alone an aeroplane take a maintenance course with the LAA. Yes I know, for many pilots getting their hands dirty would be a new experience, but that is what EASA allows you to do and it sure saves money 
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Option 3 is proposed to cost a measley revalidation fee of £50 per 500kg plus the additional investigatory charge at £122/hour.
This will be EVERY YEAR since you will be in the "uncontrolled environment"
How long did your last STAR inspection take? Remember that was done by someone who knows your plane!
Cheaper - I cant see it!
Anybody know of any CAMOs for GA types??
This will be EVERY YEAR since you will be in the "uncontrolled environment"
How long did your last STAR inspection take? Remember that was done by someone who knows your plane!
Cheaper - I cant see it!
Anybody know of any CAMOs for GA types??
My engineer tells me that apart from a yearly ARC there is no difference from. So £108 I think it is on top of the annual. My annuals and star annuals and not charged any different as the inspection is the same.
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There is a 1 year delay and the creation of a sub-1000kg and sub-2000kg categories, with different requirements. I spoke to somebody today who has just come off some EASA course. But nobody really knows what will happen by the time it's all done.
Most maintenance companies in the UK don't do a particularly good job, squirting WD40 everywhere. IMHO, the way to do maintenance which is good but at the minimum cost is to get very pro-active. Owners who just take the plane to some company and hope for the best will always get shafted, on quality, on cost, and usually both. And the certification regime merely enables crap work to be done legally - just like ISO9000 supports crap companies making crap products. This is what I like being on N-reg - there is a good choice of freelance maintenance engineers. The freelancers (or one man bands) will always be the best.
Remember that was done by someone who knows your plane!
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This Investigatory charge:
http://www.caa.co.uk/application.asp...pe=65&appid=27
""It has been proposed by EASA, through its CRD, that there shall be a requirement on a Competent Authority, at the request of an aircraft owner, to carry out Airworthiness Reviews itself in respect of non-commercial EASA aircraft of 2,730 kg MTOM and below and all EASA non-commercial balloons irrespective of weight. The current Airworthiness Scheme does not cater for the cost recovery of any Airworthiness Reviews in connection with Airworthiness Review Certificate reissues/extensions that may be undertaken by its staff. Therefore, this consultation proposes to remedy this situation""
The LAMS Annual and the STAR inspection have never been the same thing. Have a read CAP520, even though its out of date. Free STAR Inspection? Lucky person!
http://www.caa.co.uk/application.asp...pe=65&appid=27
""It has been proposed by EASA, through its CRD, that there shall be a requirement on a Competent Authority, at the request of an aircraft owner, to carry out Airworthiness Reviews itself in respect of non-commercial EASA aircraft of 2,730 kg MTOM and below and all EASA non-commercial balloons irrespective of weight. The current Airworthiness Scheme does not cater for the cost recovery of any Airworthiness Reviews in connection with Airworthiness Review Certificate reissues/extensions that may be undertaken by its staff. Therefore, this consultation proposes to remedy this situation""
The LAMS Annual and the STAR inspection have never been the same thing. Have a read CAP520, even though its out of date. Free STAR Inspection? Lucky person!
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Doing it yourself means that you're not working in a 'controlled environment' any maintenance organisation worth it's salt wouldn't be prepared to except this as they have to sign-off all the work done up to the ARC submission. I also understand that if you do decide to go the DIY route it will require CAA surveyor input which will probably cost more than using a Part M maintenance organisation. Now the sad thing is that MOs are going to be landed with a lot more bureaucracy as well extra licensing costs and this ultimately means more costs to owners. It would seem that the UK CAA are as usual interpreting the new rules more stringently than our European counterparts.
I ask the question: what was wrong with the old M3 system?
I know some owners think that their existing MOs are not very good but do you really think they will be any better under EASA; same guys handling the spanners!
Re the LAA - this is fine if you don't want to fly over towns and cities or don't want to fly in IMC or at night and the annual permit renewal is not any cheaper than the annual ARC.
I ask the question: what was wrong with the old M3 system?
I know some owners think that their existing MOs are not very good but do you really think they will be any better under EASA; same guys handling the spanners!
Re the LAA - this is fine if you don't want to fly over towns and cities or don't want to fly in IMC or at night and the annual permit renewal is not any cheaper than the annual ARC.
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Rod 1
I was rather expecting that most people on this forum would be able to work out that the statment all aircraft was applicable to EASA aircraft only. After all the title of the thread was "EASA part M what are you doing?" Apparently I am wrong to assume that you are smart enough to work that out for your self.
Vee-tail-1
EASA part M requires a subpart G company to supervise the paperwork and an approved maintenance company to do the maintenance, this can be a company that holds both approvals. A subpart G company may well not have a licenced engineer and so the company issuing the ARC may well not have the authority to issue the CRS for the work done on your aircraft.
IO540
It would be nice if the CAA would communicate these things to the companys that have applied for EASA part M approval, I have not been told a thing about this by the CAA.
jxk
M3 maintenance was not perfect but on the whole it was a good system, the only problem with it is that it would not keep enough eurocrat snouts in the feed bucket. (annex 2 aircraft will stay on M3 for the time being).
So back to the question, have any of you put in place a contract for your EASA part M maintenance and have you decided on option 1 or 2 ? as option 3 is not a cost effective option at all.
I was rather expecting that most people on this forum would be able to work out that the statment all aircraft was applicable to EASA aircraft only. After all the title of the thread was "EASA part M what are you doing?" Apparently I am wrong to assume that you are smart enough to work that out for your self.
Vee-tail-1
EASA part M requires a subpart G company to supervise the paperwork and an approved maintenance company to do the maintenance, this can be a company that holds both approvals. A subpart G company may well not have a licenced engineer and so the company issuing the ARC may well not have the authority to issue the CRS for the work done on your aircraft.
IO540
It would be nice if the CAA would communicate these things to the companys that have applied for EASA part M approval, I have not been told a thing about this by the CAA.
jxk
M3 maintenance was not perfect but on the whole it was a good system, the only problem with it is that it would not keep enough eurocrat snouts in the feed bucket. (annex 2 aircraft will stay on M3 for the time being).
So back to the question, have any of you put in place a contract for your EASA part M maintenance and have you decided on option 1 or 2 ? as option 3 is not a cost effective option at all.
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Still the penny has not dropped for many people. EASA has changed the rules of the game. Sure you can continue as before and be ripped off by unscrupulous maintenance organisations. & the CAA will goldplate EASA rules to ensure they collect fees for work which EASA never intended.
But part M contains a comprehensive list of tasks that an owner can do on his aircraft. That same owner can take his aircraft to a specialist maintenance organisation and TELL THEM to do the jobs for which he is not competent.
He is then free to take his aircraft to any part m sub part G&I org and request an ARC. If they start to hum & hah he can tell them to get lost and find another usually independent engineer to do the job. Also he could go to any qualified engineer in any EU member state where the costs are much less. PLEASE stop treating engineers and maintenance orgs like gods and start to see that they are there to do what YOU want, not what they think they can get away with. I know cos I am an engineer!
A & C Don't know if you read French but since part M is based on the current French system that would be a good way to understand what is proposed. Go to www.gsac.fr Click on telechargements, then on documents, scroll down to MGM Manual for airworthiness maintenance organisations. This manual gives everything you need to know as to how part M should work in practice. Like I say its a whole new ball game for us in UK...better get used to it, and not try to hang on to the old ways that sometimes amounted to extortion.
But part M contains a comprehensive list of tasks that an owner can do on his aircraft. That same owner can take his aircraft to a specialist maintenance organisation and TELL THEM to do the jobs for which he is not competent.
He is then free to take his aircraft to any part m sub part G&I org and request an ARC. If they start to hum & hah he can tell them to get lost and find another usually independent engineer to do the job. Also he could go to any qualified engineer in any EU member state where the costs are much less. PLEASE stop treating engineers and maintenance orgs like gods and start to see that they are there to do what YOU want, not what they think they can get away with. I know cos I am an engineer!
A & C Don't know if you read French but since part M is based on the current French system that would be a good way to understand what is proposed. Go to www.gsac.fr Click on telechargements, then on documents, scroll down to MGM Manual for airworthiness maintenance organisations. This manual gives everything you need to know as to how part M should work in practice. Like I say its a whole new ball game for us in UK...better get used to it, and not try to hang on to the old ways that sometimes amounted to extortion.
Last edited by vee-tail-1; 22nd May 2008 at 22:33.
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vee-tail-1 you are so so wrong!
To have a part G company issue an ARC you have to stay within the "controled enviroment" of that Part G company. Yes you can change the company that maintains the aircraft but not the part G company that supervises that maintenance.
Once you step outside the "controled enviroment" the CAA fees will cost you dear.
As to the list of things that you can do these have to be approved by your maintenance company and they have to check that you are able to do these tasks, in effect they will have to issue with a "simple & limmited" approval as part of that maintenance company to carry out these tasks.
To have a part G company issue an ARC you have to stay within the "controled enviroment" of that Part G company. Yes you can change the company that maintains the aircraft but not the part G company that supervises that maintenance.
Once you step outside the "controled enviroment" the CAA fees will cost you dear.
As to the list of things that you can do these have to be approved by your maintenance company and they have to check that you are able to do these tasks, in effect they will have to issue with a "simple & limmited" approval as part of that maintenance company to carry out these tasks.
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A and C
EASA gives the owner authority to issue a CRS for work done according to the list of tasks in part M. For the tasks which the owner has requested be done by a specialist organisation, they had better issue a CRS or they don't get paid! So the sub part G organisation has no need for an engineer to issue a CRS and can get on with checking the paperwork prior to issuing an ARC.
What you are saying is probably what the CAA wishes to impose on us as its "goldplated" version of part M. Are you working for the CAA?
But this is against both the letter and the spirit of what EASA intends, and is certainly not the part M that the French propose in their very helpful GSAC manual.
EASA gives the owner authority to issue a CRS for work done according to the list of tasks in part M. For the tasks which the owner has requested be done by a specialist organisation, they had better issue a CRS or they don't get paid! So the sub part G organisation has no need for an engineer to issue a CRS and can get on with checking the paperwork prior to issuing an ARC.
What you are saying is probably what the CAA wishes to impose on us as its "goldplated" version of part M. Are you working for the CAA?
But this is against both the letter and the spirit of what EASA intends, and is certainly not the part M that the French propose in their very helpful GSAC manual.
Last edited by vee-tail-1; 22nd May 2008 at 23:03.
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The main cultural difference brought in by part M is type specific maintenance programs. These are specific to the aircraft type and its mod state. They say what has to be done and when to do it, no interpretation needed. Any competent mechanic (or owner) can achieve full maintenance, and it is easy for the work to be checked. It looked as if LAMS would be ditched, but the CAA managed to keep it by re-branding it as LAMP and getting it into part M as an alternative to the type specific programs. So once again providing scope for "creative maintenance" in some UK organisations.
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OK -so we face cultural change. This ball started roling years ago - when will it stop?
9-08 or 9-09 or when? The uncertainty is what is the problem. We need to know facts - not proposals for a Part M system which is in place!
If you take your car to a MOT Tester and tell him everything is done and "pukker" what will he do? Unless you wrap your **** in a £50 note he will go the extra-picky mile just for the benefit of your wallet.
The ARC is more than a paperwork exercise. Have a look at MA710. Your G&I company will not act any differently to the MOT man. If they have cause to hum and ha, they also hum and ha to the NAA - (MA710h). It is not in their best interest to do otherwise, and not in yours as the owner. They are not there for your benefit - they are there for the NAA's.
And never, never TELL him what to do, always ask him nicely (via a wriiten works order of course) or that extra-picky mile will seem never-ending!
9-08 or 9-09 or when? The uncertainty is what is the problem. We need to know facts - not proposals for a Part M system which is in place!
If you take your car to a MOT Tester and tell him everything is done and "pukker" what will he do? Unless you wrap your **** in a £50 note he will go the extra-picky mile just for the benefit of your wallet.
The ARC is more than a paperwork exercise. Have a look at MA710. Your G&I company will not act any differently to the MOT man. If they have cause to hum and ha, they also hum and ha to the NAA - (MA710h). It is not in their best interest to do otherwise, and not in yours as the owner. They are not there for your benefit - they are there for the NAA's.
And never, never TELL him what to do, always ask him nicely (via a wriiten works order of course) or that extra-picky mile will seem never-ending!
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As has been stated the CAA are/will be the 'competent' authority in the UK and have been interpreting the proposed EASA rules with gold plating. From my knowledge of how the French currently do their maintenance I can't believe that they will accept the kind of rules that the CAA are trying implement in the UK.
And as for owners doing their own maintenance this may be true but how many would want to and how many would you feel happy to see do the work?
Ultimately a MO will have to sign-off the ARC to say that the work done, modifications, fitted equipment, ADs and etc are satisfactory. Would you be happy to let any Tom, Dick and Harry do work on your aeroplane and sign for it?
If you work for a M3 organisation you must know that even as things stand there is an awful lot of research and paperwork to do when it comes to applying for an ARC or CofA (appendix 2). I don't see that the proposed parts F & G do anything more than what's being done today except they involve a lot more red tape and expense for the MOs.
And as for owners doing their own maintenance this may be true but how many would want to and how many would you feel happy to see do the work?
Ultimately a MO will have to sign-off the ARC to say that the work done, modifications, fitted equipment, ADs and etc are satisfactory. Would you be happy to let any Tom, Dick and Harry do work on your aeroplane and sign for it?
If you work for a M3 organisation you must know that even as things stand there is an awful lot of research and paperwork to do when it comes to applying for an ARC or CofA (appendix 2). I don't see that the proposed parts F & G do anything more than what's being done today except they involve a lot more red tape and expense for the MOs.
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Well my engineers interpretation of the rules is the same as Veetail and I don't see any change in my cost of operation as a result of it. If I did I would just head to France and get the work done there.
With all respect to the fine engineers out there, perhaps it is time they starting working to quality and price and not gold plating regs to secure business.
With all respect to the fine engineers out there, perhaps it is time they starting working to quality and price and not gold plating regs to secure business.
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Red tape !
I am still trying to find out if owners intend stay inside the "controled enviroment by taking a contract with a subpart G company to supervise the mantenance of the aircraft and then "shop around" for the maintenance to be done by any company that might be avalable at the time.
OR
Contract both the supervision and the maintenance to one company and do this for three years to stay inside the "controled enviroment".
So far I see a lot of misunderstanding of the system as the CAA intend to apply it in the UK and not a lot of companys yet approved to do any work.
The last time I checked only nine supervision/maintenance approvals under part M had been issued and this with the implimentation date five months away.
OR
Contract both the supervision and the maintenance to one company and do this for three years to stay inside the "controled enviroment".
So far I see a lot of misunderstanding of the system as the CAA intend to apply it in the UK and not a lot of companys yet approved to do any work.
The last time I checked only nine supervision/maintenance approvals under part M had been issued and this with the implimentation date five months away.