Workshop on revised part M for non-commercial GA
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Workshop on revised part M for non-commercial GA
Everything you need to know about the revised part M for non-commercial light aircraft. Workshop on Thurs 3rd July in Cologne (09.00 - 16.30)
Open to everyone: pilot/owners, MOs, NAAs, CAMOs, etc. But first come first served due limited space.
See: http://www.easa.europa.eu/ws_prod/g/g_events.php (The events page on the EASA website)
Particularly the changes to part M brought about by the consultation process and opinion 2/2008.
The events page has not yet been updated on the EASA website, but see 4/5th July 2007 workshops on part M for details of venue, who to contact, hotels, etc. ("Past Events" page)
Open to everyone: pilot/owners, MOs, NAAs, CAMOs, etc. But first come first served due limited space.
See: http://www.easa.europa.eu/ws_prod/g/g_events.php (The events page on the EASA website)
Particularly the changes to part M brought about by the consultation process and opinion 2/2008.
The events page has not yet been updated on the EASA website, but see 4/5th July 2007 workshops on part M for details of venue, who to contact, hotels, etc. ("Past Events" page)
Last edited by vee-tail-1; 30th May 2008 at 13:05.
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Can you imagine a web conference using all the official European languages, and their versions of the language of aviation 
Nothing beats eye to eye contact and even better, discussions over a litre or two of German beer afterwards.
There have been shed loads of disinformation on EASA and part M on this and other forums. So now's the chance to get the real info from the horses mouth.
Nothing beats eye to eye contact and even better, discussions over a litre or two of German beer afterwards.
There have been shed loads of disinformation on EASA and part M on this and other forums. So now's the chance to get the real info from the horses mouth.
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Is it true that EASA are considering a Part M Light/Lite for aircraft under 2370kgs? If so, couldn't they consider recommending the UK's M3 system as this has worked very satisfactorily for ages! 
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Oh dear. Have you not been following the Part M development since 2003? There have been many rounds of consultation etc by EASA. And the big mistake in this country is to think that, under the European agenda (a political matter), the EASA proposed rules should be based solely on what the UK wants and what suits the UK best. That is not the political or practical reality. The agenda is based on a standardisaton (not harmonisation) criteria for 27 countries. Much as many of us do not want Europeanisation in this field, the reality is that is the only legal game in town, as determined by the political masters. Those of us who have been representing the UK GA interests in Europe for some years have fought hard to get some common sense into the process and have won many points and succeeded in getting many changes. That is after we fought to stay out of this, but once dragged through the one way revolving door we determined to fight from the inside rather than throw stones from the outside. But like any multi lateral negotiation one can't win all the points one wishes to. There has to be give and take. We pressed hard for a Part M 'Light' over the last year or more, even by getting a UK person from the air sports sector to chair the EASA working group M.017, but a Part M Light alternative was not accepted by EASA. Read the NPA 2008-03 (I think is the number) on the EASA website - it explains why they reached this decision. The sooner folks accept the inevitable then the sooner they will engage with the process and adapt to it. It is not perfect, but it is the penalty for winning the war (I mean 39-45).......!
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DR
I have been trying to follow what's going on with Part M but as your post implies there have been so many different twists and turns with the various proposals it's hard to keep up with what's going on. Even if a concrete set of rules eventually emerges it presumably will be up to each of the 27 countries National authority to interpret them. I wonder how this will be policed? I really can't imagine some of the newest entries into the EU being so disciplined as the UK but then I omit to being a bit of a cynic. In the meanwhile I think there should be a bit of a moratorium in the UK until a firm specification is on the table and each country has signed up to it. This would save a lot time wasting and heartache within the light aircraft maintenance community.
I realise that you're only the messenger not the reason for this mess.
"What is the problem we're trying to fix", comes to mine!
I have been trying to follow what's going on with Part M but as your post implies there have been so many different twists and turns with the various proposals it's hard to keep up with what's going on. Even if a concrete set of rules eventually emerges it presumably will be up to each of the 27 countries National authority to interpret them. I wonder how this will be policed? I really can't imagine some of the newest entries into the EU being so disciplined as the UK but then I omit to being a bit of a cynic. In the meanwhile I think there should be a bit of a moratorium in the UK until a firm specification is on the table and each country has signed up to it. This would save a lot time wasting and heartache within the light aircraft maintenance community.
I realise that you're only the messenger not the reason for this mess.
"What is the problem we're trying to fix", comes to mine!
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"What is the problem we're trying to fix"
EASA has made possible the installation of any mod previously approved elsewhere in the EU. This is a massive advance in the crappy "system" for approving modifications which plays into the hands of "design authority" sharks charging 4 digits for paperwork.
What EASA could have done is brought in a streamlined system for handling mods, particularly small mods, FAA-style, but they haven't done that. However the reality of the 'universe' (most things are made in the USA) is that despite all the hardball they are likely to eventually accept FAA STCs (like the UK CAA used to do under the now dead FAA-CAA mutual STC treaty) and that would be a massive step forward towards reality. Australia already has a blanket acceptance of FAA certification if it has an STC or has been processed by an FAA DER.
The old CAA system was pretty arbitrary. Many many mods were done under the table, with no logbook entries, because few people understood the system.
When it comes to straight maintenance, much of the industry is in such a state that you can take the plane in for an Annual and all they do is spray WD40 on the joints. Some of the worst practices are done by EASA 145 companies - the bigger the better (worse I mean). I don't think the surrounding paperwork will change this.
Will the stupid and pointless 150hr check survive under EASA? This drives owners into stupid stunts like stopping flying at 150hrs till the Annual or doing the Annual at the 150hr mark.
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[Can you imagine a web conference using all the official European languages, and their versions of the language of aviation]
Yes, I can - but there is no need. The International language of aviation is still English - and I have been sent a new bit of licence telling me that I speak it sufficiently well to get by. No doubt all other pilots in Europe will have received something similar, albeit with better grades of fluency.
In the scheduled event, what will they be doing? Presenting in 27 languages?
[Nothing beats eye to eye contact]
Sure - especially when you can see the whites of their eyes. But it's a bit late for that.
[and even better, discussions over a litre or two of German beer afterwards.]
I don't drink the stuff. Pointless drunken yack most likely. It's a done deed isn't it? What is there left to discuss?
[There have been shed loads of disinformation on EASA and part M on this and other forums. So now's the chance to get the real info from the horses mouth.]
Surely any speculation has been due to the failure of good communication from EASA, the press and organisations such as the LAA, BMAA etc.. A presentation in Cologne to a select few isn't going to help thousands of private pilots all over Europe. Much like being invited to attend a vogon constructor fleet convention on the moon. Few people might make it, but it won't help Arthur Dent.
Yes, I can - but there is no need. The International language of aviation is still English - and I have been sent a new bit of licence telling me that I speak it sufficiently well to get by. No doubt all other pilots in Europe will have received something similar, albeit with better grades of fluency.
In the scheduled event, what will they be doing? Presenting in 27 languages?
[Nothing beats eye to eye contact]
Sure - especially when you can see the whites of their eyes. But it's a bit late for that.
[and even better, discussions over a litre or two of German beer afterwards.]
I don't drink the stuff. Pointless drunken yack most likely. It's a done deed isn't it? What is there left to discuss?
[There have been shed loads of disinformation on EASA and part M on this and other forums. So now's the chance to get the real info from the horses mouth.]
Surely any speculation has been due to the failure of good communication from EASA, the press and organisations such as the LAA, BMAA etc.. A presentation in Cologne to a select few isn't going to help thousands of private pilots all over Europe. Much like being invited to attend a vogon constructor fleet convention on the moon. Few people might make it, but it won't help Arthur Dent.
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When it comes to straight maintenance, much of the industry is in such a state that you can take the plane in for an Annual and all they do is spray WD40 on the joints.
WD40 costs money so never use that.
Take some of the new engine oil and place in an oil can, drain some fuel from the tanks to thin it out and place lid on before applying to various joints. That is how a few UK organisations do it.
English is not the language of aviation. ICAO specify several languages and the EU use a few more.
As has been said, these workshops are for people (or thie representatives) to go along and find out the truth about what is happening rather than relying on rumour or people trying to profit from the lack of understanding.
No doubt the CAA will go along like they do with ICAO etc and spend the time asleep. Then when something comes out a year later that was discussed, the UK will say that they can't implement it because they were not aware and need to conduct a safety review.
AOPA will no doubt be there. They will then publish the wrong info with incorrect guidance in their mag sandwiched between complaints about the CAA and an article on how great Old Sarum Flying Club management are and everyone should follow their example.
So if you can - go yourself or get someone you trust to tell you what happened.
Regards,
DFC
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Several points ' answers, not in anyn particular order:
1. Europe Air Sports - EAS - (of which I am a board member) and the EASA MDM.032 working group (of which I am a member) pressed EASA in 2006-07 to hold public briefing sessions to explain Part M as the changes to the original were developing. EAS organised briefings by EASA officials on Part M in the late summer / autumn of 2007 during the last consultation excercise. The briefings were held in 6 EU countries, Denmark, Switzerland (an associate member of the EU for civil aviation), Germany, France, Czech Republic and UK. The UK event was held at the PFA (now LAA) HQ at Turweston on 4 September. The event was widely publicised in the UK air sports and aviation mags, websites etc but the turnout was 31 people (!). By contrast, in Denmark there were over 100 people, likewise Germany, Switzerland and the Czech Republic. Something about horses and water comes to mind.
2. English is the official language of the EU and of its agency, EASA. In this we are fortunate as it makes life somewhat easier in the working groups for us Brits. The EASA officials all speak and write very good English, and all business and presentsations at EASA are in English. It's some of the other EU members on these groups that are at a disadvantage.
3. The (likely) final version of Part M was published on the EASA website on 16th May. As I have posted in earlier this month, it is now the Opinion of EASA (an official communication to the Commission) and the Commission's review working group of member states is unlikely to change the text now, particularly as it needs to become EU law in time for the transition clauses to kick in well before 28 Sept 08. It can be viewed at:
http://easa.europa.eu/ws_prod/g/rg_opinions_main.php
Scroll down the page to the table 02/2008 and it is Opinion 02/2008.
4. Once EU law, implementation is in the hands of members states (Uk = DfT and CAA).Underpinning the Implementing Rules (which are what have been revised over the last 2.5 years since EAS created a big fuss about Part M at a conference with EASA in Cologne in Nov 05) are the 'Acceptable Means of Compliance' (AMC) and 'Guidance Material' (GM).
5. EASA has a standardisation division, whose responsibility is to oversee / check implementation in member states. So CAA will be subject to review as to implementation, in due course.
6. The CAA has been well aware of the changes to Part M as the changes have developed. Legally, however, they could not anticipate the changes as they were and still are bound, as I understand the position, by the extant Part M from 2003, even though implementation of the original Part M was deferred until 28 Sept 08 for aircraft < 5.7mt used non commercially.
7. The problem EASA has been trying to fix is not what you might imagine (i.e. a UK maintenance system that works....?) but a problem created by the EU political system (and a problem common to many other walks of life not just civil aviation), and that is the drive by the EU and its member states to STANDARDISE everything that moves, speaks, thinks and breathes. This is not the same as harmonisation (a common misapprehension about the EU).
8. The concept behind Part M - the separation of responsibility for oversight of continuing airworthiness from actual hands-on maintenance, which is only part of continuing airworthiness - was designed in France many years ago and its author is one of the senior EASA officials. The German system is also modelled on it, but applied in a pragmatic if German way.
9. As I0540 alludes to it, there are some good points about what EASA is doing, such as EU-wide acceptance of modifications in one country in all countries. No longer should the UK CAA require a mod to be re-certified if it has already got certification in another EU country.
10. Although far from perfect (by comparison with what we have been used to in the UK), the final Part M is workable and has a certain logic to it even if difficult to comprehend on first, second or third reading. It appears at first sight as very bureaucratic, but then the purpose of the bureaucracy is to pinpoint responsibilties for safety compliance. I would venture to suggest that certain parts (not all) of the UK 'continuing airworthiness' industry could do with a dose of that.
11. The EASA concept for maintenance is to derive the maintenance schedule from the manaufacturer's handbook. Quite logical providing the manufacturer (if still in business) has taken the trouble to risk assess the aircraft in terms of service life of parts etc. Chain of responsibility again. Though it smacks of 'if it goes wrong, sue the party you think is at fault, but don't come to the regulator'.
12. IAOPA (through which UK AOPA is represented) have not, as far as I am aware, been half as active as EAS on pursuing EASA over Part M either at the working level or the strategic level this last two years. Just maybe I did not see their people in Cologne very often, whereas EAS people have practically occupied the building. But as with all representative organisations relying mainly or almost exclusively on volunteers, our human resources have been extremely stretched this last two years or more with all this regulatory activity, staffed on the official side by a great many professional expert regulators.
1. Europe Air Sports - EAS - (of which I am a board member) and the EASA MDM.032 working group (of which I am a member) pressed EASA in 2006-07 to hold public briefing sessions to explain Part M as the changes to the original were developing. EAS organised briefings by EASA officials on Part M in the late summer / autumn of 2007 during the last consultation excercise. The briefings were held in 6 EU countries, Denmark, Switzerland (an associate member of the EU for civil aviation), Germany, France, Czech Republic and UK. The UK event was held at the PFA (now LAA) HQ at Turweston on 4 September. The event was widely publicised in the UK air sports and aviation mags, websites etc but the turnout was 31 people (!). By contrast, in Denmark there were over 100 people, likewise Germany, Switzerland and the Czech Republic. Something about horses and water comes to mind.
2. English is the official language of the EU and of its agency, EASA. In this we are fortunate as it makes life somewhat easier in the working groups for us Brits. The EASA officials all speak and write very good English, and all business and presentsations at EASA are in English. It's some of the other EU members on these groups that are at a disadvantage.
3. The (likely) final version of Part M was published on the EASA website on 16th May. As I have posted in earlier this month, it is now the Opinion of EASA (an official communication to the Commission) and the Commission's review working group of member states is unlikely to change the text now, particularly as it needs to become EU law in time for the transition clauses to kick in well before 28 Sept 08. It can be viewed at:
http://easa.europa.eu/ws_prod/g/rg_opinions_main.php
Scroll down the page to the table 02/2008 and it is Opinion 02/2008.
4. Once EU law, implementation is in the hands of members states (Uk = DfT and CAA).Underpinning the Implementing Rules (which are what have been revised over the last 2.5 years since EAS created a big fuss about Part M at a conference with EASA in Cologne in Nov 05) are the 'Acceptable Means of Compliance' (AMC) and 'Guidance Material' (GM).
5. EASA has a standardisation division, whose responsibility is to oversee / check implementation in member states. So CAA will be subject to review as to implementation, in due course.
6. The CAA has been well aware of the changes to Part M as the changes have developed. Legally, however, they could not anticipate the changes as they were and still are bound, as I understand the position, by the extant Part M from 2003, even though implementation of the original Part M was deferred until 28 Sept 08 for aircraft < 5.7mt used non commercially.
7. The problem EASA has been trying to fix is not what you might imagine (i.e. a UK maintenance system that works....?) but a problem created by the EU political system (and a problem common to many other walks of life not just civil aviation), and that is the drive by the EU and its member states to STANDARDISE everything that moves, speaks, thinks and breathes. This is not the same as harmonisation (a common misapprehension about the EU).
8. The concept behind Part M - the separation of responsibility for oversight of continuing airworthiness from actual hands-on maintenance, which is only part of continuing airworthiness - was designed in France many years ago and its author is one of the senior EASA officials. The German system is also modelled on it, but applied in a pragmatic if German way.
9. As I0540 alludes to it, there are some good points about what EASA is doing, such as EU-wide acceptance of modifications in one country in all countries. No longer should the UK CAA require a mod to be re-certified if it has already got certification in another EU country.
10. Although far from perfect (by comparison with what we have been used to in the UK), the final Part M is workable and has a certain logic to it even if difficult to comprehend on first, second or third reading. It appears at first sight as very bureaucratic, but then the purpose of the bureaucracy is to pinpoint responsibilties for safety compliance. I would venture to suggest that certain parts (not all) of the UK 'continuing airworthiness' industry could do with a dose of that.
11. The EASA concept for maintenance is to derive the maintenance schedule from the manaufacturer's handbook. Quite logical providing the manufacturer (if still in business) has taken the trouble to risk assess the aircraft in terms of service life of parts etc. Chain of responsibility again. Though it smacks of 'if it goes wrong, sue the party you think is at fault, but don't come to the regulator'.
12. IAOPA (through which UK AOPA is represented) have not, as far as I am aware, been half as active as EAS on pursuing EASA over Part M either at the working level or the strategic level this last two years. Just maybe I did not see their people in Cologne very often, whereas EAS people have practically occupied the building. But as with all representative organisations relying mainly or almost exclusively on volunteers, our human resources have been extremely stretched this last two years or more with all this regulatory activity, staffed on the official side by a great many professional expert regulators.
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Gosh, I didn't know that EASA was like magic and going to cure all the ails of the aircraft industry - abracadabra. It's my experience that since the idea of 'standardisation' within Europe began the bureaucracy with gaining acceptance of PMA & STC parts ex USA has got worse.
Anyway I don't mean to be antagonistic it's just my view of things and I'm very happy with my maintenance organisation and don't want to see it disappear under over regulation and pointless paperwork.
Anyway I don't mean to be antagonistic it's just my view of things and I'm very happy with my maintenance organisation and don't want to see it disappear under over regulation and pointless paperwork.
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It's my experience that since the idea of 'standardisation' within Europe began the bureaucracy with gaining acceptance of PMA & STC parts ex USA has got worse.
To suggest the contrary is to pretend the USA does not exist, that we are not flying planes which are either made wholly in the USA, or have airframes made elsewhere which are then stuffed with 90%+ of stuff that is made in the USA....
Let's be frank... you buy a U.S. made part which comes with Form 1 (EASA-1 form). How do you think that part acquired that magical European document??
It's an industry secret, revealed by me here for the first time.
You have a company, here in Europe, which has purchased (yes purchased, like you purchase an ISO9000 approval) the authority to generate EASA 1 forms.
The part arrives, with some kind of CofC (an 8130-3 but could just be a delivery note with a batch / serial #) at this company. There is a little man in there (all people in certification are little men, usually below 5ft4) who looks at it and writes out the EASA form.
The company then resells the part with a 2x markup (and the EASA form).
I once paid about £11000 for a Hartzell prop with a JAR-1 form which could have been had from the USA for $9000.
This company could generate an EASA 1 form for a Mars Bar (if it came to them with a suitable traceability document).
EASA insistence on Form 1 is going to bring the whole aviation business to its knees and everybody (except the little men, whose employers are busy lobbying EASA for the introduction of "standards"
) knows it.
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IO540, totally agree with your analysis.
EASA is caught in the middle of a spat between the EU and USA. "we'll accept your approval system if you accept ours." As I understand it, it started with the USA being unwilling in broad terms to accept EU approvals on maintenance (CAT we're talking, not our end of the game). Don't know too much of the detail, but that's the essence of it from what I picked up last year. I guess it will all be resolved in due course. In the meantime it leaves a big hole in efficient (?) inter-changeability of parts across the pond, and as IO540 correctly concludes, a rip off for a bit of paper that supposedly provides traceability and provenence.
If this spat isn't sorted soon - or maybe it has by now - then it could infect the forthcoming EU licensing implementation. Would be interesting to see how the US airlines react to the EU refusing to recognise FAA ATPLs to fly into and out of Europe......! Can't think they'll let it get to that stage, but who knows. I am not a poker player.
EASA is caught in the middle of a spat between the EU and USA. "we'll accept your approval system if you accept ours." As I understand it, it started with the USA being unwilling in broad terms to accept EU approvals on maintenance (CAT we're talking, not our end of the game). Don't know too much of the detail, but that's the essence of it from what I picked up last year. I guess it will all be resolved in due course. In the meantime it leaves a big hole in efficient (?) inter-changeability of parts across the pond, and as IO540 correctly concludes, a rip off for a bit of paper that supposedly provides traceability and provenence.
If this spat isn't sorted soon - or maybe it has by now - then it could infect the forthcoming EU licensing implementation. Would be interesting to see how the US airlines react to the EU refusing to recognise FAA ATPLs to fly into and out of Europe......! Can't think they'll let it get to that stage, but who knows. I am not a poker player.
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I think the US/EU argument went along the lines 'you accept our Dreamliner or we won't accept your A380'. As I said earlier there should be a moratorium for a couple of years with all this crazy Part M stuff until there has been a unilateral proposal on the table. Maintenance organisations are tearing their hair out at the moment trying to keep up with what's going on; which is not fair on them. Does anyone know what happened to the House of Commons Transport committee report which was chaired by the Gwyneth Dunwoody in which they concluded that EASA was 'not fit for purpose' and would have an impact on air safety?
Common-sense please! We are not talking about 300 seat airliners but light aircraft used mainly for pleasure and the occasional business trip.
Common-sense please! We are not talking about 300 seat airliners but light aircraft used mainly for pleasure and the occasional business trip.
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The EASA position is based around "reciprocity".
This seems fair enough - hard to argue with that. A bit like the Body Shop having a petition you can put your name to, requesting a stop of all torture. Or Bob Geldof doing a pop concert to stop poverty.
Unfortunately the principle is being applied over a wide spectrum of stuff and I don't think it will be resolved until it gets quite close to heads being banged together. But it will be resolved (it must be).
Partm M is a separate thing; the above would be relevant if one was for example hoping to get an automatic acceptance of FAA certification (like e.g. Australia does). But this is politically very hard. Think of how many thousands of EU careers have been invested in developing "European standards" for everything.
I think one of two things must happen on this, in the long term:
a) EASA will accept FAA FCL and certification more or less unchanged (OK it will be wrapped up in the usual EU symbolism), OR
b) No action will be taken against European based N-reg planes
I know (from the horse's mouth) that EASA knows perfectly well that if they implemented option a), the N-reg scene would dry up. Well everybody knows that!
This seems fair enough - hard to argue with that. A bit like the Body Shop having a petition you can put your name to, requesting a stop of all torture. Or Bob Geldof doing a pop concert to stop poverty.
Unfortunately the principle is being applied over a wide spectrum of stuff and I don't think it will be resolved until it gets quite close to heads being banged together. But it will be resolved (it must be).
Partm M is a separate thing; the above would be relevant if one was for example hoping to get an automatic acceptance of FAA certification (like e.g. Australia does). But this is politically very hard. Think of how many thousands of EU careers have been invested in developing "European standards" for everything.
I think one of two things must happen on this, in the long term:
a) EASA will accept FAA FCL and certification more or less unchanged (OK it will be wrapped up in the usual EU symbolism), OR
b) No action will be taken against European based N-reg planes
I know (from the horse's mouth) that EASA knows perfectly well that if they implemented option a), the N-reg scene would dry up. Well everybody knows that!
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[Is Northampton that alien to Devon?]
Dunno what you mean. It's a bitch of a drive (took my daughter 8 hours yesterday just to get back to London). Public transport would need about seven hours to get there. A middle-of-nowhere kind of place. Like here, but fewer grockles with caravans.
I had a house in Olney in the mid eighties; Northampton wasn't far. It used to be a major centre for boot & shoe making, but that moved abroad a long time ago. Does that make it alien? It might make a suitable backdrop for filming some of CP Snow's books, but apart from that . . . I give up. What's the alien thing about? Lots of immigrants? So what?
Dunno what you mean. It's a bitch of a drive (took my daughter 8 hours yesterday just to get back to London). Public transport would need about seven hours to get there. A middle-of-nowhere kind of place. Like here, but fewer grockles with caravans.
I had a house in Olney in the mid eighties; Northampton wasn't far. It used to be a major centre for boot & shoe making, but that moved abroad a long time ago. Does that make it alien? It might make a suitable backdrop for filming some of CP Snow's books, but apart from that . . . I give up. What's the alien thing about? Lots of immigrants? So what?
