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Old 7th Aug 2009, 22:28
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What really p*ss*s me off is the way the CAA were writing to us all telling us we had to sign up with a CAMO and setting up a pricing structure that made it cost-effective to lock into a 3-year deal with a CAMO.

Now they say it isn't necessary, but its too late - we are locked in.....

Another letter to my MP I think........
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Old 7th Aug 2009, 23:28
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Originally Posted by vee-tail-1
Not so! have a look at the CAA link posted above by David Roberts.
Vee-tail-1

I'm intimately familiar with the contents of the AIRCOM, but your post is still wrong!

As I stated, an aircraft in the uncontrolled environment cannot have its ARC extended by a Part-66 engineer or even by a CAMO. What the alleviation for ELA-1 aircraft now allows is for an approved Part-66 LAE to conduct the airworthiness review, rather than requiring the review to be done by a CAMO. Having done the airworthiness review the Part-66 LAE cannot extend the existing ARC, and cannot issue a new ARC. Rather, he makes a recommendation to the CAA, and they issue a new ARC. See 6.3 of the AIRCOM.

If a CAMO with the appropriate privilege conducts the airworthiness review for an aircraft in the uncontrolled environment then he can issue a new ARC directly - i.e. prints it off and hands it to the owner. He does not extend the existing ARC. See 6.2 of the AIRCOM.

The option to extend an ARC is only available where the aircraft has been in the controlled environment for the last year. This is, in a way, a special privilege because it is done without the requirement to conduct an airworthiness review. The extension is done by the CAMO completing a certification on the existing ARC regarding the controlled environment.

If that doesn't make sense to you, try this: look at Figure 1 in the AIRCOM and find the two boxes that say "Extend ARC for 2nd/3rd year" - you can only get to these via the "Aircraft is in a controlled environment" box!!!
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Old 8th Aug 2009, 09:27
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All true.

My CAMO charges me £800 per year for their service, based on the cost of setting up and running their CAMO organisation divided by the number of aircraft.

From conversations with CAMOs, the CAA and others it was made clear that the whole thing was to make going 'controlled' the cheaper option.

The reissue of the ARC in years 2 and 3 was going to save money over the annual full event.

This new Aircom proves this to have been false.

The CAA new about this last October - there was a draft of this letter ready in December- in other words before we were strong-armed into the rushed implementation in January.

So they waited until we've all pretty much signed up, then publish the ELA1 arrangements.

As a result it will have no effect for me.

Why they couldn't have waited like the rest of Europe????
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Old 8th Aug 2009, 10:10
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giloc if your understanding of the situation is correct, then part M is even more of an anti-safety bureaucratic pile of sh**t than even I might have thought.

The only option for people like me who up till now have done ALL the maintenance on our C of A aircraft, is to go to the EU member state with the lowest regulatory costs.

At present that seems to be France, and that is where I will go to renew my ARC. However if the French authorities take the same attitude as the CAA, then my aeroplane will become an ornament in my barn until sanity or a revolution removes this obscene paper mountain.
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Old 8th Aug 2009, 10:52
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The anger that I have expressed will be as nothing once French owners are exposed to part M in September this year. Sadly it is going to seem like a stitch-up by Les Anglaises because of our CAA's premature actions.
Competent French owners have long been legal to do their own maintenance with personalised and approved type-specific maintenance programmes. This will not be possible under part M as the permitted pilot maintenance is pitifully inadequate. Many owners, like me simply could not afford an aeroplane if we had to pay an engineer to maintain it.
So far the GSAC seem to be aware of the problem and are offering a restricted part 66 licence under 'Grandfather Rights' to owners who can show proof of their competance. I hope and expect that the French are going to throw quite a few spanners into the part M works after September.
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Old 18th Aug 2009, 22:42
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An Alternative Viewpoint

All

As one of those approved to sign off the ARCs, I would like to offer an alternative viewpoint to those expressed by the owner/pilot community above. I must be either a graduate engineer or a licensed engineer with at least 5 years experiance in airworthiness management and be at a senior level in the organisation, I can confirm that I have a great deal more experience as a time served apprentice, graduate maintenance manager, at all levels, than the required 5 years. That combined with the cost of approvals soon adds up.

I am currently working in a number of sectors, including private light aircraft, however, I have a strong commercial airline background. I must admit that I am disappointed in the standard to record keeping and adherence to requests to provide information. Simple requests to provide utilisation data to the Part M organisation are met with deaf ears, or questions of why do you want that? How can the Part M plan on effectively nothing? One operator how has not being supplying data for almost three months, not through lack of trying, is now in the position of requiring a variation to their next check, whose falut is that?

I have seen operators state, that they do not want to see any e-mails with airworthiness data, this include FLM amendments and operation changes imposed by the OEM. Out of a supported fleet of 20 private aircraft the vast majority can not respond to simple requests for data, or the aircraft, they do not carry madatory documentation on-board and have no understanding of the basic requirements of airworthiness management regardless of who is providing it. I would have grave doubts of these individuals could manage their aircraft in an "un-controlled" environment.

To blame the service providers is unfair, as it is equally unfair to blame the regulator, the industry, including the owner/operators have to shoulder their share of the responsibility for the position where the regulations were required. I have been present when pilots have requested licensed engineers sign off major defects, thses were structural defects, because that last three maintenance providers have done that, I supported them when they would not. Perhaps a little more inward review is required all round.

I look forwad to the comments and brickbats.
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Old 19th Aug 2009, 07:31
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Doing Whats Needed

While I am sure that everything you say is true, it strongly suggests that the "system" which operated before was failing in safety terms. As far as I'm aware light aircraft were not falling out of the sky all over the UK due to poor or indeed lack of maintenance. CAA didn't think so either!

The "new" system, which is unarguably costing the industry a vast amount of money is predicated on safety grounds; this is and was self-evidently un-necessary as there was NO general safety problem with light aircraft due to maintenance failures.

What this was, is and will continue to be about is CONTROL; this is increasingly the major interest of Governments, both elected and in the cse of the EU unelected, and particularly the unelected and largely unaccountable organisations which they set up to CONTROL anything and everything they can! And that's what EASA is.

From this a vast bureaucratic machine is developed, "employing" large numbers of individuals who then become "dependent" on that system for their living, and who therefore have no interest in unscrambling the bureaucracy for something "lighter" and more efficient (and cheaper!)

That is the reason that the whole Part M debacle is causing maintenance organisations to charge for "contracts" (or in many cases quit the industry), which in turn is making aviation unaffordable.

There was never a "safety case" made for this system, because there wasn't one.

Sadly, EASA doesn't seem to have heard - "if it ain't broke don't fix it."

Last edited by rgsaero; 19th Aug 2009 at 08:05.
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Old 19th Aug 2009, 08:30
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I have said it before and I will say it again. Part M is the goose that lays the golden egg for maintenance organisations.

Many bleat on about how much it cost to get the approvals and all the work involved, but none of them are fessing up to the vast amount of extra work they have gained from all the lifed components or about the fact that many raped you on the grounds of getting you up to Part M standards. My own recent annual came to over 7k for replacement of components that are now lifed under Part M. Do you think the maintenance company did that work for free?

My friend just paid a certain well know organisation FOUR THOUSAND pounds in admin charges to be brought under Part M. Charged engineer rates for doing paperwork and other minor tasks that it turned out his own daughter was doing as part of her job as a summer assistant!!! It would have been cheaper to pay her to stay at home!!!
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Old 19th Aug 2009, 09:07
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Many bleat on about how much it cost to get the approvals and all the work involved, but none of them are fessing up to the vast amount of extra work they have gained from all the lifed components or about the fact that many raped you on the grounds of getting you up to Part M standards. My own recent annual came to over 7k for replacement of components that are now lifed under Part M. Do you think the maintenance company did that work for free?
And of course thats their fault, isnt it!


My friend just paid a certain well know organisation FOUR THOUSAND pounds in admin charges to be brought under Part M.
Perhaps they saw him coming, or is one of those they could do without! Its no good blaming the M(G)s - be a little pro-active and search around for a better deal FFS. That way youll drive out the leg-lifters.
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Old 19th Aug 2009, 09:22
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Compents have not just been lifed because of Part M, they have always been lifed in the OEMs maintenance planning documents, it is just now that people, me for one, are certifying that they have been managed properly. It is not in the long-term interests for maintenance providers to over-charge, they will be killing the "golden-goose", and I have no desire to commit professional suicide.

Blaming Part M, is a way of keeping heads in the sand with regard to what was not done previously. This is new for everybody, in this sector of the industry, it will take time to straighten out, as it did when introduced to the airlines. It pushes owners/operators to think about longer term relationships and not just the next check. There needs to be an incentive for the provider to invest time and effort to developing systems to improve service and cut cost.

Owners should think about personalised AMPs, rather than LAMP, it will provide far more flexibility to the owner and the Part 145/Sub-part F organisation.

As ever always willing to discuss!

Doing Whats Needed
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Old 19th Aug 2009, 12:37
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All this about "lifed components" and who's changing them and for how much is once again missing the point!

Most of these lifed components were designed and fitted YEARS before this bureaucratic system came into being. Their failure wasn't causing aeroplanes to fall out of the sky before this "lifing" regime came in and wouldn't be doing so now if they weren't being changed under this system.

My associate has just had to take a PA28-180 off-line at his flying school
and sell shares in it as the engine, with 1250 hours on it has passed 12 years old! It's no more or less safe because of that!

Back to basics - this is about an all controlling bureaucracy. It's nothing to do with safety - and as EASA has SAFETY in its name it should be or it shouldn't be happening.

No-one seems to be addressing this aspect of the discussion!
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Old 19th Aug 2009, 15:15
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My associate has just had to take a PA28-180 off-line at his flying school and sell shares in it as the engine, with 1250 hours on it has passed 12years old! It's no more or less safe because of that!
AWN 35 had the same hours & calender provisions that GR24 has now, Lycoming say 12 years TBO, you're still lucky enough to get the CAA's 20% extra for ""PT" use, so why blame Part M for this? Nothing has changed here and your associate is no better or worse off in this respect. In fact he should be thanking the Campaign Against Aviation for keeping GR24 alive.
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Old 19th Aug 2009, 15:21
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"My associate has just had to take a PA28-180 off-line at his flying school
and sell shares in it as the engine, with 1250 hours on it has passed 12 years old! It's no more or less safe because of that!"

In Lycomings opinon it is less safe! that is why they reccomend you overhaul it at 12 years or 2000 hours.

This is nothing new!
You can get a 20% extension to both the engine hours and callinder life, its all in Generic Recquirment 24 which used to be Airworthiness notice 35?

Lycoming also allow you to do more hours than the standard TBO if you are running the engine extensivley I think the figure is around 40 hours a month (its a while since I read the SB on it).

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Old 19th Aug 2009, 16:55
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I think the comments from malcom and Just Local show that there is a need for a prefssional airworthiness management structure in place, and that was with a percieved aviation professional not somebody in their kitchen trying to understand lifing statements issued by the OEMs or perhaps it was!

I would be interested where this mis-conception that component life is an invention of EASA comes from; ever since my earlist days on the tools some aircraft components had a life, others, those defined as not airworthiness critical by the designer were put on-condition.

I notice that those complianing about cost do not mention the cost of car maintenance, significantly higher that the the rate they will pay for a licensed engineer or an airworthiness signatory. Additionally, they will be required to part with their cash before they can pick up their car, not fly off and argue the invoice when it comes through later.

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Old 19th Aug 2009, 17:04
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Malcolm and Just-local - While the AWN35 reference is true, not so long ago, if an aircraft was maintained to "public cat" standards it could be used for instruction and examination of its beneficial owners (assuming more than 5% held) I believe. That's gone now. And no - this has nothing to do with Part M except my key point (on which no-one has commented) - the growth of bureaucracy.

No-on, including EASA, has made a proper case for this vast increase in bureaucratic activity and personnel time, on the grounds of SAFETY, which is surely the point of maintenance etc. (and what EASA is supposed to be "for".

Again. A/c were not falling out of the sky all over Europe or UK before Part M was put in place due to poor maintenance.

So what, precisely has been the benefit to the "industry" apart from more bureaucracy?
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Old 19th Aug 2009, 17:41
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I agree with many of the posts on here, there is lots of bureaucracy and a large amount of paperwork which all ends up being passed on to the customer, if they don't fly off and withhold payment that is!!!

I also think that when an engine is at its TBO plus 20% you have had value for money and if the engine manufacturer thinks its ready for an overhaul, at this point I tend to think they no more than myself or my engineer.
If your car had covered 275000 miles on the same engine you would think you had had excelllent value for money so why would a Cherokee or similar be any different.

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Old 19th Aug 2009, 17:54
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More power to Doingwhats for posting I suppose - but some of his quotes just beg for contradiction.

To quote him There needs to be an incentive for the provider to invest time and effort to developing systems to improve service and cut cost. I struggle to see where this is in the present incarnation of Part M.

These machines are to be blunt primitive, even an agricultural engineer would be appalled by the lack of technology. Aircraft maintenance is not about high technology, it is about simple wear and tear, almost always mechanical wear and corrosion. Comparisons with motor mechanics actually set the payment scheme and level. A light aircraft can usually be maintained with little more than a DIYer's toolkit - try that with a modern vehicle.

As for the need for 'professional' aircraft maintenance - show me the need! Simple machines that usually deteriorate more through lack of use than over use - simple inspection is the requirement. Sophisicated reliability based maintenance schemes? You are joking! The vast majority of aircraft engineers are incapable of fault finding basic electrical generation problems, any complex items - sent away to people 'who know' how to overhaul them.

At the moment most maintenance companies are reaping the 'benefits' of being able to charge for paperwork. Very few of these companies have any expectation of being in business in 5 years so the majority have little compunction in charging as much as they think the punters will bear. Professional maintenance management? I don't think so. I've spent most of my days in the maintenance / inspection area and nothing I have seen in aircraft impresses me. Most of what I've seen in light aircraft is rubbish and nothing short of ignorant.

If you want to look professional when you 'create' the controlled environment how can you possibly not offer a bespoke maintenance schedule? One size cannot and does not fit all - and yet the vast majority of CAMOs have simply carried on doing what they used to do and charging more for it.

If companies want to look like maintenance professionals there are a lot of things CAMOs should do as a matter of course - if only to look professional and actually prove they are worth paying for. If they are simply collecting hours and implementing a standard LAMS they are taking the pi**.
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Old 19th Aug 2009, 19:18
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Part M is total bureaucratic nonsense.
For a simple SEP aeroplane there is no need for a CAMO to manage the paperwork, or for LAEs & mechanics to service it.

For the last ten years I have done all of that, including annuals & maintenance up to 1000 hrs and 6 year checks. I use a personalised & approved type-specific manufacturers maintenance program which tells me what to do, how to do it, and when to do it. I have subscriptions with the airframe manufacturer, the engine manufacturer, and the propeller manufacturer. They send me the latest SBs and ADs, as do EASA via their AD subscription service. The reason that I as an owner/pilot have been able to do this up til now is that my Robin ATL is French registered. Also no one at my home airfield objects to my working in the hangar. And the local engineering facility are happy to allow me to use calibrated tools and test equipment.

I also service my own car.
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Old 19th Aug 2009, 19:52
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I confess to knowing little about Part M (being on the N-reg and maintaining to Part 91 requirements, with extras here and there) but today I spoke to the director of a small Part M firm (who I know personally) and mentioned to him some of the stuff mentioned here, and his reply was that these people are taking the p*ss and are a load of crooks.

However, this

Also no one at my home airfield objects to my working in the hangar.
is hugely exceptional. On the UK GA airfield-political scene, it is almost impossible to find a hangar in which you are allowed to do maintenance. In my hangar, I am allowed to use a hoover, maximum. A freelance maintenance bloke I know used to have such a hangar but it was a highly discreet arrangement and, for me, 1hr flying time away! So my 50hr checks are done outdoors; we have to pick a reasonable Sunday, and in the winter we stick our frozen fingers between the still-warm cylinders to keep warm. It is ghastly and makes me curse GA airfield politics and the people who wield the power in it.

And the local engineering facility are happy to allow me to use calibrated tools and test equipment.
That is feasible if you give them "some" work. I actually bought most tools needed (just ordered an oil filter cutter for £130) but normally to get a "relationship" like this you need to let somebody do the Annual, for example. This game is all about relationships.

But one has to start the right way from the very outset (at a particular location); if you get some firm to do the Annual and the 50hr checks, and then take away the latter and do them yourself, they will probably just tell you to p*ss off altogether.

Gasax is right about most firms being unprofessional.
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Old 19th Aug 2009, 21:31
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IO 540 Goes to the important points in airfield politics. It is vital to have good relationships with other pilots and engineers.
I have been helpful in one or two ways, and have been helped in return.
As for working on aircraft in the hangar. Since most in my hangar are on an LAA permit (many C of A aircraft owners having given up, or moved to micros!) owners doing work is not such a rarity down here.
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