Part M - CAMO - etc
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One would have expected that an AOPA committee member to have been thoroughly au fait with Part M.
When your Annex 1 a/c was last in for an annual in April 2008 it would have been issued with a 1 (not 3) Yr C of A, (or an Annual) to take it beyond 5.1.09 when Part M became mandatory.
Therefore, this April, if it gets through its inspection by a subpart F organisation it will be issued with a non expiring 3 yr ARC by the Subpart G organisation (CAMO) to which it is contracted. This will be renewed by the Subparts G & F organisations annually thereafter.
Issues of ARCs really only started after the beginning of 2009.
All a/c under 2730kg that fall into Annex 1 have to be with a CAMO (a subpart G organisation) and maintained by a subpart F organisation, which can be the same company. Most will be the same.
A/c in Annex 2 can still be maintained by an M3 maintenance company and will be issued with a 3 yr C of A with Annuals being issued at year 1 and year 2 following as in the past. A subpart F organisation can still maintain a/c in Annex 2 as well.
Any a/c in Annex 1 can now be used for Public Transport duties as long as it meets the requirements under EASA - which mainly relate to engine life. (JUST-local is incorrect in his post; as is Bookworm)
If an Annex 1 a/c is contracted with a CAMO then ARCs are issued as above. If it is not it must go to a CAMO who, after a full inspection, can recommend the CAA issue an ARC The CAA will then go to the organisation's premises in their own time and carry out their own inspection and review of paperwork etc. at c.£160 per hour + vat. This will be on top of the subpart F organisation and the engineer’s fees
Signing up an a/c with a CAMO will cost a one off fee of c.£450 (not £2500 as suggested by "robin") dependent upon the quality of previous record keeping and a/d incorporation etc.
If an a/c is put on the D register the same rules as here in the UK will apply. Both come under EASA.
If it is put on the N register this will have no effect on the cost involved in replacing or overhauling manufacturers lifed items, as in "bose-x's" case.
In addition there is a growing move afoot against the regular use of N registered a/c in EASA countries, which could mean that they may not be able to be used in future and will have to revert to an EASA state register.
If a prop needs to be overhauled on a time or hours basis, which one suspects is the case with “bose-x”, then the FAA will still require the work to be carried out if that is what the manufacturer or Type Certificate Holder says has to be done. “bose-x” will still have to pay to have the work carried out wherever his a/c is registered. The CAA are not always behind these requirements – it’s usually the manufacturer through experience of what is best practice.
Anyway anyone who earns a huge income and flies hundreds of hours a year would surely expect their aeroplane to be maintained properly and safely for around £40 per hour, which is considerably less (by at least 50%) than, say, a Porsche dealer will maintain their motor car, if that is what they drive.
Regarding the discussion about the proposed ELA changes involving sub 1000kg MTOW a/c :- ELAC 1 states that there could be a provision for a licensed engineer to be able to issue an ARC in the future, subject to the normal full annual inspection etc. However the CAA have no such procedure in place as yet and it is thought that it could be some while – due to the existing pressures on staff – before the necessary legislation can be drawn up.
Had these good folk spoken to an organisation that has gone to the expense, time and cost of gaining Part M subparts I,F & G, and is already issuing ARCs, they would have had it all explained to them in plain English and prevented unnecessary time wasting and inconsistent speculation from sullying the pages of PPRune in this way!
As you are at Spanhoe, why not do as 'grahama' recommended and try J & J Aircraft Services at Peterborough – Sibson.
When your Annex 1 a/c was last in for an annual in April 2008 it would have been issued with a 1 (not 3) Yr C of A, (or an Annual) to take it beyond 5.1.09 when Part M became mandatory.
Therefore, this April, if it gets through its inspection by a subpart F organisation it will be issued with a non expiring 3 yr ARC by the Subpart G organisation (CAMO) to which it is contracted. This will be renewed by the Subparts G & F organisations annually thereafter.
Issues of ARCs really only started after the beginning of 2009.
All a/c under 2730kg that fall into Annex 1 have to be with a CAMO (a subpart G organisation) and maintained by a subpart F organisation, which can be the same company. Most will be the same.
A/c in Annex 2 can still be maintained by an M3 maintenance company and will be issued with a 3 yr C of A with Annuals being issued at year 1 and year 2 following as in the past. A subpart F organisation can still maintain a/c in Annex 2 as well.
Any a/c in Annex 1 can now be used for Public Transport duties as long as it meets the requirements under EASA - which mainly relate to engine life. (JUST-local is incorrect in his post; as is Bookworm)
If an Annex 1 a/c is contracted with a CAMO then ARCs are issued as above. If it is not it must go to a CAMO who, after a full inspection, can recommend the CAA issue an ARC The CAA will then go to the organisation's premises in their own time and carry out their own inspection and review of paperwork etc. at c.£160 per hour + vat. This will be on top of the subpart F organisation and the engineer’s fees
Signing up an a/c with a CAMO will cost a one off fee of c.£450 (not £2500 as suggested by "robin") dependent upon the quality of previous record keeping and a/d incorporation etc.
If an a/c is put on the D register the same rules as here in the UK will apply. Both come under EASA.
If it is put on the N register this will have no effect on the cost involved in replacing or overhauling manufacturers lifed items, as in "bose-x's" case.
In addition there is a growing move afoot against the regular use of N registered a/c in EASA countries, which could mean that they may not be able to be used in future and will have to revert to an EASA state register.
If a prop needs to be overhauled on a time or hours basis, which one suspects is the case with “bose-x”, then the FAA will still require the work to be carried out if that is what the manufacturer or Type Certificate Holder says has to be done. “bose-x” will still have to pay to have the work carried out wherever his a/c is registered. The CAA are not always behind these requirements – it’s usually the manufacturer through experience of what is best practice.
Anyway anyone who earns a huge income and flies hundreds of hours a year would surely expect their aeroplane to be maintained properly and safely for around £40 per hour, which is considerably less (by at least 50%) than, say, a Porsche dealer will maintain their motor car, if that is what they drive.
Regarding the discussion about the proposed ELA changes involving sub 1000kg MTOW a/c :- ELAC 1 states that there could be a provision for a licensed engineer to be able to issue an ARC in the future, subject to the normal full annual inspection etc. However the CAA have no such procedure in place as yet and it is thought that it could be some while – due to the existing pressures on staff – before the necessary legislation can be drawn up.
Had these good folk spoken to an organisation that has gone to the expense, time and cost of gaining Part M subparts I,F & G, and is already issuing ARCs, they would have had it all explained to them in plain English and prevented unnecessary time wasting and inconsistent speculation from sullying the pages of PPRune in this way!
As you are at Spanhoe, why not do as 'grahama' recommended and try J & J Aircraft Services at Peterborough – Sibson.
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One would have expected that an AOPA committee member to have been thoroughly au fait with Part M.
When your Annex 1 a/c was last in for an annual in April 2008 it would have been issued with a 1 (not 3) Yr C of A, (or an Annual) to take it beyond 5.1.09 when Part M became mandatory.
CofA / Permit: EASA Certificate of Airworthiness Validity Expiry: 06/04/2009
ARC Issue Date: 07/04/2008 ARC Reference: 051371/005/001
ARC Issue Date: 07/04/2008 ARC Reference: 051371/005/001
It is about the fact that highly skilled and trained engineers who have worked hard towards the licences they hold are being told that they are no longer trusted to apply safe judgement to what work is required. This is placing a further burden of expense on GA which in my opinion a number of engineering companies are taking advantage of. There is no need to enter into a controlled environment which severely restricts your choice of engineering and pretty much would allow the unscrupulous engineer to rape you as they see fit. It is also worth owners actually sitting down and looking at the maintenance manual for their specific aircraft and seeing what needs doing REALLY. I have had an interesting eye opener on that front this week.
As I pointed out earlier (but which I assume you ignored in order to have a pop at my income, car etc.) that I have found a Part M company.
I do not expect to cut corners on any aspect of the maintenance of my aircraft, I expect my engineers to be allowed to use their discretion and gve me correct guidance on the work that needs doing. I expect them to give me good advice rather than just advice that is easy for them.
Tell me Yakker, how many ways and at what cost is their to replace the seat belts in a Cessna? Which story are you going to give me?
If an Annex 1 a/c is contracted with a CAMO then ARCs are issued as above. If it is not it must go to a CAMO who, after a full inspection, can recommend the CAA issue an ARC The CAA will then go to the organisation's premises in their own time and carry out their own inspection and review of paperwork etc. at c.£160 per hour + vat. This will be on top of the subpart F organisation and the engineer’s fees
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Signing up an a/c with a CAMO will cost a one off fee of c.£450 (not £2500 as suggested by "robin") dependent upon the quality of previous record keeping and a/d incorporation etc.
Not sure where the 'one-off' bit comes in.
There is supposed to be the 'limited' CAMO arrangement for sub-1000kg but we haven't found anyone who will offer this or tell us how we can achieve it.
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Seems to me everyone is interepreting Part M according to their individual agendas.
But Part M is based on the long established French system, which I have happily used for ten years on my UK based French registered ATL.
I started out with a maintenance contract in the controlled environment. But the cost of annuals became too high for a retirement pension, and since I am an unlicensed engineer and licensed flt engineer, I started to do my own annuals. Then I took a subscription to GSAC/EASA for ADs, and APEX for SBs, and did those as well. Now I do most of the work on the aircraft, only using certain approved workshops for items that I do not have the competance to carry out. Eg: Mag O/Hs, NDT checks, major O/Hs on the engine, detailed inspection/repairs of wooden structures. My CRS has been accepted by the GSAC surveyors when renewing the three year C of A , and I have no reason to doubt that will be the case for issue of the first ARC. After all the ARC is mainly a check of the state of the paperwork, with little actual investigation of the physical condition of the aircraft. That is one of the reasons why I do my own maintenance, then I know it has been done properly, and exactly as laid down in my approved maintenance programme.
Yes for sure most pilots would rather not get their hands dirty, but EASA allows them to save sheds of money if they do some of the maintenance on their own aircraft .
Please don't allow certain engineers to tell you what you MUST do under Part M. EASA have set it up for 'creative interpretation' of the regulations, and that allows much more scope than some would like you to know.
But Part M is based on the long established French system, which I have happily used for ten years on my UK based French registered ATL.
I started out with a maintenance contract in the controlled environment. But the cost of annuals became too high for a retirement pension, and since I am an unlicensed engineer and licensed flt engineer, I started to do my own annuals. Then I took a subscription to GSAC/EASA for ADs, and APEX for SBs, and did those as well. Now I do most of the work on the aircraft, only using certain approved workshops for items that I do not have the competance to carry out. Eg: Mag O/Hs, NDT checks, major O/Hs on the engine, detailed inspection/repairs of wooden structures. My CRS has been accepted by the GSAC surveyors when renewing the three year C of A , and I have no reason to doubt that will be the case for issue of the first ARC. After all the ARC is mainly a check of the state of the paperwork, with little actual investigation of the physical condition of the aircraft. That is one of the reasons why I do my own maintenance, then I know it has been done properly, and exactly as laid down in my approved maintenance programme.
Yes for sure most pilots would rather not get their hands dirty, but EASA allows them to save sheds of money if they do some of the maintenance on their own aircraft .
Please don't allow certain engineers to tell you what you MUST do under Part M. EASA have set it up for 'creative interpretation' of the regulations, and that allows much more scope than some would like you to know.
Last edited by vee-tail-1; 14th Apr 2009 at 15:38.
Any a/c in Annex 1 can now be used for Public Transport duties as long as it meets the requirements under EASA - which mainly relate to engine life. (JUST-local is incorrect in his post; as is Bookworm)
All I said was EASA has a much narrower view of what constitutes "commercial air transportation" than what the CAA classes as "public transport" (which includes rental).
Do you disagree?
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Funnily enough, I heard from a friend that an owner of a Reims-Cessna FR172K had enquired of a Part M (F,G & I) organisation about them carrying out an ARC renewal and Star Annual the other week.
The owner said he was intending to fly the aircraft (ARC and Annual expired and sans ferry permit) to said place for the work to be carried out. Apparently the owner then took the aircraft elsewhere - not that the owner told them of his change of mind.
The maintenance organisation was spending time attempting to source the somewhat rare Maintenance Manuals for the aircraft (build year seemingly orphaned by both Reims and Cessna) and found out through some internet forum that the aircraft had gone elsewhere! They then called the manual hunt off but a bit rude not to let them know, I reckon.
The owner said he was intending to fly the aircraft (ARC and Annual expired and sans ferry permit) to said place for the work to be carried out. Apparently the owner then took the aircraft elsewhere - not that the owner told them of his change of mind.
The maintenance organisation was spending time attempting to source the somewhat rare Maintenance Manuals for the aircraft (build year seemingly orphaned by both Reims and Cessna) and found out through some internet forum that the aircraft had gone elsewhere! They then called the manual hunt off but a bit rude not to let them know, I reckon.
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Yes, something along these lines written in the other place.
Naughty, naughty... 
Incidentally, don't ATP do the CDs for most planes? These CDs come up on Ebay from time to time
Annual expired
Incidentally, don't ATP do the CDs for most planes? These CDs come up on Ebay from time to time
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Blimey, I am glad our aircraft got moved before the CofA expired.
I would hate it if my engineering company breached a client confidence and blabbed about any discussions held with them on the internet.
I managed to get a copy of the manual for my aircraft from the internet and discovered lots of interesting things.
I would hate it if my engineering company breached a client confidence and blabbed about any discussions held with them on the internet.
I managed to get a copy of the manual for my aircraft from the internet and discovered lots of interesting things.
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'I would hate it if my engineering company breached a client confidence and blabbed about any discussions held with them on the internet.'
I totally agree with you about the ethics of breaching client confidence. But if Client 'X' isn't a client by virtue of the fact he had never been a client of that company and that said person had taken his aircraft elsewhere prior to any discussion, that would appear to equal no breach of client confidence.
I totally agree with you about the ethics of breaching client confidence. But if Client 'X' isn't a client by virtue of the fact he had never been a client of that company and that said person had taken his aircraft elsewhere prior to any discussion, that would appear to equal no breach of client confidence.
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Originally Posted by yakker
Had these good folk spoken to an organisation that has gone to the expense, time and cost of gaining Part M subparts I,F & G, and is already issuing ARCs, they would have had it all explained to them in plain English and prevented unnecessary time wasting and inconsistent speculation from sullying the pages of PPRuNe in this way!
All a/c under 2730kg that fall into Annex 1 have to be with a CAMO (a subpart G organisation) and maintained by a subpart F organisation, which can be the same company.
If it is not it must go to a CAMO who, after a full inspection, can recommend the CAA issue an ARC The CAA will then go to the organisation's premises in their own time and carry out their own inspection and review of paperwork etc. at c.£160 per hour + vat.
Regarding the discussion about the proposed ELA changes involving sub 1000kg MTOW a/c :- ELAC 1 states that there could be a provision for a licensed engineer to be able to issue an ARC in the future, subject to the normal full annual inspection etc. However the CAA have no such procedure in place as yet and it is thought that it could be some while – due to the existing pressures on staff – before the necessary legislation can be drawn up.
G
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Wrong. There is already a provision in the existing commission regulation that allows an independent, Part-66 licensed engineer, formally accepted by the NAA, to conduct the airworthiness review on ELA1 aircraft and recommend the renewal to the NAA. (MA901(e)). The UK CAA have as yet failed to put in place a procedure for accepting such engineers, but they are working on it now, and expect to have the procedure in place within "a couple of months".
Fortunately this year's ARC renewal makes no difference in Controlled or Uncontrolled Environments as to cost. Like many I've been holding off to wait for clarity, but the Annual is due next month.
Thank you EASA and CAA.......
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Giloc, let me make it clear, I am not associated with any maintenance organisation. Rather than me trying to give a detailed response to all the questions I would suggest to any of the doubters that all can be verified by picking up the phone to any regional CAA office (easily found from the website) and speaking to a surveyor there.
They are keen to get the message across to private owners and will happily dispel any doubts. They are, however, not likely to get into discussion regarding commercial arrangements between maintenance companies and owners and it should be understood that surveyors are known to have differing interpretations of the rules. This is likely to be the case until the rules have been in play for at least 12 months. At least thats my take on it.
They are keen to get the message across to private owners and will happily dispel any doubts. They are, however, not likely to get into discussion regarding commercial arrangements between maintenance companies and owners and it should be understood that surveyors are known to have differing interpretations of the rules. This is likely to be the case until the rules have been in play for at least 12 months. At least thats my take on it.
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The staggering thing is that there are several people on here who seem to be maintenance people yet they cannot agree on the basics.
This sounds like Part M was designed for the French. You tick all the boxes, sign all the forms, and do what the hell you want. And the personal relationships between the owner and the CAMO are all-important.
This is great if you are a proactive owner who has got himself clued-up, and you have a trusted-relationship CAMO which will do what you actually want them to do and will generate "whatever paperwork" as a separate exercise. That is how a lot of maintenance is done, including most training fleets. I am happy with that.
What I find disturbing are some of the paperwork costs quoted. It cannot possibly cost that much to generate and complete forms. One can automate a lot of it anyway.
But owners who just take the plane to the firm, leaving a blank signed cheque on the seat, are going to get shafted, in most if not all cases. And, in some cases, the work done will be inadequate because even though most engineers think they know everything (because they have been doing it like this for 25 years) they actually don't know everything. So, in this scenario, nothing actually changes
This sounds like Part M was designed for the French. You tick all the boxes, sign all the forms, and do what the hell you want. And the personal relationships between the owner and the CAMO are all-important.
This is great if you are a proactive owner who has got himself clued-up, and you have a trusted-relationship CAMO which will do what you actually want them to do and will generate "whatever paperwork" as a separate exercise. That is how a lot of maintenance is done, including most training fleets. I am happy with that.
What I find disturbing are some of the paperwork costs quoted. It cannot possibly cost that much to generate and complete forms. One can automate a lot of it anyway.
But owners who just take the plane to the firm, leaving a blank signed cheque on the seat, are going to get shafted, in most if not all cases. And, in some cases, the work done will be inadequate because even though most engineers think they know everything (because they have been doing it like this for 25 years) they actually don't know everything. So, in this scenario, nothing actually changes
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The staggering thing is that there are several people on here who seem to be maintenance people yet they cannot agree on the basics.
It seems rare that we agree these days IO but you are bang on.
I talked to a number of maintenance companies who all told my their interpretation of the rules. It was also frightening the figures being quoted for the paperwork exercise which was being seriously overstated by some companies. I had one company tell me that before they could do any work on the aircraft they would need to do 25 hours of paperwork at £42 per hour. Then the annual was on top. I also found that some trying to apply generic Cessna lifes to items rather than looking at my actual aircraft. As it turns out according to the actual service manual for my aircraft half of the stuff that I was told had to be replaced was not required.
The prop overhauls still peeve me but the other stuff is now not as bad as the first impression.
I don't really blame the maintenance companies, I think that some have been a little over zealous but the CAA have done such a crap job of implementing this that it was inevitable it would go wrong.
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IO540
The trouble is that we have had to take on another person and set up a new company to do the part M subpart G paperwork.
I can see how the extra person might not be required by a fleet operator once the inital problems of part m have been overcome but the introducton of Part m had us flat out before Xmas with the CAA/EASA changing the rules by the day.
What Part M is showing up is that the quality of maintenance in the UK was to say the least very vairiable. Those who used the companys at the cheaper end of the market are now hurting ar things that should have been done years ago are now flagged up my a more formal audit system.
Some anomalys have been shown up by the different "recomended" lifes that manufactures put on accessorys, I could quote a number of these items but won't because it will just give the CAA more ideas!
The CAA has now also get it's head around gliding, this it is failing to do with gusto! Some of the policys in this area are so restrictive that I am going down the political route to get them sorted because the CAA seem to be getting rather intrenched.
On one hand they are insisting for powered aircraft that recomended life items in the maintenance manual are hard lifed at this recomendation and in the other hand they won't except the manufacturers mantenance schedule despite it being excepted by the EASA state of origin and part of the aircrafts (glider) type certificate.
I can see how the extra person might not be required by a fleet operator once the inital problems of part m have been overcome but the introducton of Part m had us flat out before Xmas with the CAA/EASA changing the rules by the day.
What Part M is showing up is that the quality of maintenance in the UK was to say the least very vairiable. Those who used the companys at the cheaper end of the market are now hurting ar things that should have been done years ago are now flagged up my a more formal audit system.
Some anomalys have been shown up by the different "recomended" lifes that manufactures put on accessorys, I could quote a number of these items but won't because it will just give the CAA more ideas!
The CAA has now also get it's head around gliding, this it is failing to do with gusto! Some of the policys in this area are so restrictive that I am going down the political route to get them sorted because the CAA seem to be getting rather intrenched.
On one hand they are insisting for powered aircraft that recomended life items in the maintenance manual are hard lifed at this recomendation and in the other hand they won't except the manufacturers mantenance schedule despite it being excepted by the EASA state of origin and part of the aircrafts (glider) type certificate.
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things that should have been done years ago are now flagged up my a more formal audit system
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The only thing which a stricter system can universally change as far as the physical aircraft is concerned is the forced replacement of serially numbered parts - because the CAMO will have to be able to show the traceability documents for these.
Non-serially numbered parts could end up on a different aircraft to the one in whose maintenance records their documents end up
I still think the 6 year prop overhaul and the 500hr mag overhaul are a good idea...
Non-serially numbered parts could end up on a different aircraft to the one in whose maintenance records their documents end up
I still think the 6 year prop overhaul and the 500hr mag overhaul are a good idea...
