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Get Rich Quick...........who?
Bose-XQute...........
A&C you and I never going to agree on this, however don't think that I am stupid enough not to know the rules or have a lack of business knowledge to allow you to insult me into having the wool pulled over my eyes.
As ususal you seem to think that the light aircraft engineering busness is getting rich at your expence (and that of all aircraft owners), I don't see the owners of these businesses riding around in big cars and playing the tables at Le Touquet. The guys on the hangar floor are only making £15-18/hour with the businesses charging £45-50/hour for labour. By the time you take out rent, heating, CAA fees, manual subscriptions and all the other nif-naff & trivia you are not left with a lot of proffit, I only wish that I made 10% of what Bose-X thinks I make out of this game.
I don't need to pull to wool over your eyes you do that yourself with your "rip off UK" attitude that is no doubt fuelled by the wisdom aquired from reading the Daily Mail. The fact is most CAMO's are not making much money at all, for that you need to look at the likes of the CAA to who cost is no object as they have the CAMO's over a barrel.
IO540
WE have an IT guy on the case but it is only of limited help as the info has to be drawn from a number of sorces all with different sysyems.
A&C you and I never going to agree on this, however don't think that I am stupid enough not to know the rules or have a lack of business knowledge to allow you to insult me into having the wool pulled over my eyes.
As ususal you seem to think that the light aircraft engineering busness is getting rich at your expence (and that of all aircraft owners), I don't see the owners of these businesses riding around in big cars and playing the tables at Le Touquet. The guys on the hangar floor are only making £15-18/hour with the businesses charging £45-50/hour for labour. By the time you take out rent, heating, CAA fees, manual subscriptions and all the other nif-naff & trivia you are not left with a lot of proffit, I only wish that I made 10% of what Bose-X thinks I make out of this game.
I don't need to pull to wool over your eyes you do that yourself with your "rip off UK" attitude that is no doubt fuelled by the wisdom aquired from reading the Daily Mail. The fact is most CAMO's are not making much money at all, for that you need to look at the likes of the CAA to who cost is no object as they have the CAMO's over a barrel.
IO540
WE have an IT guy on the case but it is only of limited help as the info has to be drawn from a number of sorces all with different sysyems.
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Bose with your business acumen and your in depth knowledge of aircraft maintenance, why don't you set up a maintenance company at Deenethorpe? We would all bring our aircraft to you given the low costs you can give compared to others, it would be a little gold mine.
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WE have an IT guy on the case but it is only of limited help as the info has to be drawn from a number of sorces all with different sysyems.
but in my business (electronics) all regs are approached with massive cynicism, and complied with accordingly.When BS5750, later ISO9000, became trendy, 99% of firms hired a consultant (sometimes in-house) with a brief to generate the forms and the rubber stamps, but nobody changed the end product (which, as things are, was often crap). Now, one gets "ISO9000 compliance" questionnaires all the time, with crap questions like "do you segregate defective product" (no, Sir, actually we mix it up with the working stuff and send it ALL out
).Then we got ROHS. A load of bollox. Every carton coming from China has ROHS stamped on it. Job done.
Now we have the bollox REACH directive. More bollox. Nobody can actually verify all the substances used in every component (every resistor, etc). So you rubber stamp all the forms with NO all the way down and send them off, and the customer's REACH compliance officer (a £40k post, no doubt) is happy. He couldn't care less.
So............. I am sure it is not beyond the wit of man to work out something to, shall we say, "streamline" Part M?
Especially in aviation maintenance, where "streamlining" not only the paperwork but the actual job is a pretty common activity
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It is clear that this issue has caused at lot of confusion and expense.
It is true that the cost and change to the industry has been considerable, and unfortunately these extra costs do have to be passed on to the customer, either by a general increase in costs, or as a specific charge for the service.
However, it appears CAMOs have a very varied way of charging, and indeed how they conduct their busines, and I feel that a lot of scare-mongering has gone on.
The Part M system is nothing significantly new. Aircraft have to be maintained, to an approved schedule (sorry programme!), and their paperwork has to be kept current for the CofA to be valid. Nothing new here.
The 'controlled environment' and having an aircraft 'managed' is only new by allowing an organisation to be specifically approved for this purpose, where as before the owner/operator was completely responsible for the continued airworthiness of their aircraft. The actual task of this 'management' is not all that difficult, but for a CAMO to do it there has to be a contract in place between that CAMO and the aircraft owner/operator and much time has to be spent by the CAMO in keeping logs up to date, informaing owners when/what maintenance is due - lots of time pushing around paperwork.
Owners have a choice. You can have someone (a CAMO) manage your aircraft, in which case you have to pay, or you can do the task yourself, in which case the aircraft falls into an 'uncontrolled environment'.
For an aircraft kept in an 'uncontrolled environment' the ARC has to be renewed at year following an Airworthiness Review. The ARC cannot be extended (as it can be if the aircraft is fully compliant within a controlled environment, however the ARC can only be extended twice, so each third year requires the full Airworthiness Review').
The Airworthiness Review is not a particularly great task, but does require the CAMO to survey the aircraft, and fully review all the paperwork for the aircraft, including the Flight Manual, docs, TCDS, recent maintenance records etc. The full Airworthiness Directive compliance has to be established, as well as the status of life limited components, modifications, repairs and maintenance. However, again, nothing is new here - this has always been required for an Annual (was all in the old LAMS schedule), and had to be confirmed to the CAA for the old COfA renewal (Star Annual). So if a company has known an aircraft for a period of time they should already have this information properly recorded, otherwise they haven't done it right in years gone by.
For an aircraft new to a CAMO, it doesn't take all that long to establish it's compliance (provided the owner provides the relevant logs/docs), but it's often found that work has to be done to make it complaint (from replacing missing placards, sorting out missed ADs to replacing out-of-life parts etc) albeit these issues should have been resolved under the old system, unless an issue had arisen between maintenance inspections.
For most private use aircraft, I firmly believe, that the 'uncontrolled environment' is the most cost effective way forward. Yes you have to do the AR every year, but the cost of this (especially if done at the same time as a annual when the aircraft is already opened for inspection) is less than the cost of the management service. Typically management costs between £500-1000pa, whereas the Airworthiness Review and ARC renewal is being charged at a few hundred pounds - do the math! (The fees payable to CAA for the ARC validity is the same regardless of how the aircraft is managed).
If anyone has a specific quiery then you can PM me. And yes I am a Licenced Engineer and ARC signatory working for a Part M approved company (F&G, and M3 for you non-EASA bods), currently overseeing around 125 EASA aircraft.
It is true that the cost and change to the industry has been considerable, and unfortunately these extra costs do have to be passed on to the customer, either by a general increase in costs, or as a specific charge for the service.
However, it appears CAMOs have a very varied way of charging, and indeed how they conduct their busines, and I feel that a lot of scare-mongering has gone on.
The Part M system is nothing significantly new. Aircraft have to be maintained, to an approved schedule (sorry programme!), and their paperwork has to be kept current for the CofA to be valid. Nothing new here.
The 'controlled environment' and having an aircraft 'managed' is only new by allowing an organisation to be specifically approved for this purpose, where as before the owner/operator was completely responsible for the continued airworthiness of their aircraft. The actual task of this 'management' is not all that difficult, but for a CAMO to do it there has to be a contract in place between that CAMO and the aircraft owner/operator and much time has to be spent by the CAMO in keeping logs up to date, informaing owners when/what maintenance is due - lots of time pushing around paperwork.
Owners have a choice. You can have someone (a CAMO) manage your aircraft, in which case you have to pay, or you can do the task yourself, in which case the aircraft falls into an 'uncontrolled environment'.
For an aircraft kept in an 'uncontrolled environment' the ARC has to be renewed at year following an Airworthiness Review. The ARC cannot be extended (as it can be if the aircraft is fully compliant within a controlled environment, however the ARC can only be extended twice, so each third year requires the full Airworthiness Review').
The Airworthiness Review is not a particularly great task, but does require the CAMO to survey the aircraft, and fully review all the paperwork for the aircraft, including the Flight Manual, docs, TCDS, recent maintenance records etc. The full Airworthiness Directive compliance has to be established, as well as the status of life limited components, modifications, repairs and maintenance. However, again, nothing is new here - this has always been required for an Annual (was all in the old LAMS schedule), and had to be confirmed to the CAA for the old COfA renewal (Star Annual). So if a company has known an aircraft for a period of time they should already have this information properly recorded, otherwise they haven't done it right in years gone by.
For an aircraft new to a CAMO, it doesn't take all that long to establish it's compliance (provided the owner provides the relevant logs/docs), but it's often found that work has to be done to make it complaint (from replacing missing placards, sorting out missed ADs to replacing out-of-life parts etc) albeit these issues should have been resolved under the old system, unless an issue had arisen between maintenance inspections.
For most private use aircraft, I firmly believe, that the 'uncontrolled environment' is the most cost effective way forward. Yes you have to do the AR every year, but the cost of this (especially if done at the same time as a annual when the aircraft is already opened for inspection) is less than the cost of the management service. Typically management costs between £500-1000pa, whereas the Airworthiness Review and ARC renewal is being charged at a few hundred pounds - do the math! (The fees payable to CAA for the ARC validity is the same regardless of how the aircraft is managed).
If anyone has a specific quiery then you can PM me. And yes I am a Licenced Engineer and ARC signatory working for a Part M approved company (F&G, and M3 for you non-EASA bods), currently overseeing around 125 EASA aircraft.
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A and C
A perfect summary.
And one that shows that the CAA were more than a little economical with the truth when describing it to us at the outside.
I wrote down a quote at one CAA presentation on Part M
"The pricing has been made to discourage use of the "Uncontrolled environment".
At the original presentations the fact that the ARC renewal was cost-free led us to believe there were no associated costs in the intervening 2 years.
Any chance of GA having a crack at the CAA as a class action???
A perfect summary.
And one that shows that the CAA were more than a little economical with the truth when describing it to us at the outside.
I wrote down a quote at one CAA presentation on Part M
"The pricing has been made to discourage use of the "Uncontrolled environment".
At the original presentations the fact that the ARC renewal was cost-free led us to believe there were no associated costs in the intervening 2 years.
Any chance of GA having a crack at the CAA as a class action???
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Yakker, A&C, thats what I love about PPrune, as soon as someone tells a few home truths you have to resort to personal insults!! Try coming back with a robust argument that justifies why some maintenance organisations can charge very little extra in order to cover Part M and others are making eye watering charges.
When type your responses try and do it with a little logic rather than resorting to low brow insult.
When type your responses try and do it with a little logic rather than resorting to low brow insult.
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The simple fact is that some CAMO's hide the cost within the labour rate, others are up front about the cost.
My guess is that under BCAR all the paperwork costs were hidden in the Labour rate as you would be dealing with one company.
As subpart G requires a seperate corperate identity (with all the costs of another company) the subpart F & G will require seperate billing, The subpart F & G are seperate approvals that are audited ( and paid for) seperatly and so you get an invoice from both companys.
The fact of the matter is that the subpart F bill should be a little smaller however as most of the parts for aircraft are sorced in US$ (or Euro for Robin) I would guess that the bills have gone up due to the weekness of the GB£.
The only true indicator of a ripp off is if th Subpart F labour hours have not fallen a little.
Bose X I hope that this is logical enough for you however I would like to see you try to run a CAMO, I am sure that you would soon change your tune.
My guess is that under BCAR all the paperwork costs were hidden in the Labour rate as you would be dealing with one company.
As subpart G requires a seperate corperate identity (with all the costs of another company) the subpart F & G will require seperate billing, The subpart F & G are seperate approvals that are audited ( and paid for) seperatly and so you get an invoice from both companys.
The fact of the matter is that the subpart F bill should be a little smaller however as most of the parts for aircraft are sorced in US$ (or Euro for Robin) I would guess that the bills have gone up due to the weekness of the GB£.
The only true indicator of a ripp off is if th Subpart F labour hours have not fallen a little.
Bose X I hope that this is logical enough for you however I would like to see you try to run a CAMO, I am sure that you would soon change your tune.
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Just to add my experiences as a kind of 'joker' amongst UK based aircraft owners.
Part M is nearly the same as the French system which I have used for 10 years on my French registered aircraft. Under that system a 3 yearly CDN airworthiness review took a mornings work and cost around 200 Euros. Now under EASA part M the same airworthiness review is called an ARC in English and a CEN in French. The review can be done on any EASA aircraft by any CAMO (with the required approvals) in any member state. So far the reaction of UK CAMOs to my request for an airworthiness review on my EASA aircraft has been comical. First they are aghast that I expect them to look at the documentation only as far back as the last review. Second that I do not require any maintenance and have myself carried out and released the last three annuals under French rules. Thirdly since I know exactly how much work is involved and how long it should take, I expect and insist on the bill not exceeding £300. After 28th Sept 2010 I will no longer be able to release my own annuals, but by that time a number of French CAMOs will be up and operating offering ARC/CEN renewals at a fraction of the current rip off UK fees.
Part M is nearly the same as the French system which I have used for 10 years on my French registered aircraft. Under that system a 3 yearly CDN airworthiness review took a mornings work and cost around 200 Euros. Now under EASA part M the same airworthiness review is called an ARC in English and a CEN in French. The review can be done on any EASA aircraft by any CAMO (with the required approvals) in any member state. So far the reaction of UK CAMOs to my request for an airworthiness review on my EASA aircraft has been comical. First they are aghast that I expect them to look at the documentation only as far back as the last review. Second that I do not require any maintenance and have myself carried out and released the last three annuals under French rules. Thirdly since I know exactly how much work is involved and how long it should take, I expect and insist on the bill not exceeding £300. After 28th Sept 2010 I will no longer be able to release my own annuals, but by that time a number of French CAMOs will be up and operating offering ARC/CEN renewals at a fraction of the current rip off UK fees.
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A and C
You're not quite correct in stating that the Subpart F (or 145) and G have to be seperate companies, in fact most approved compaines have both approvals. There has to be some independancy within the organisation - the person who makes the airworthiness review recommendation should not have active involvement in the continued airworthiness management of that aircraft. However this only applied to aircraft being 'managed' within a controlled environment. The ARC signatory can be same person as the certifying engineer for whatever work has happened at the ARC renewal.
Vee-tail
You are techincally correct that the review period is only supposed to be looking at the time since the last ARC renewal, however a CAMO has to be certain of the facts, and most are not prepared to risk overlooking someone else's mistake. Albeit for a simple aircraft establishing the status of the aircraft does not take long, and as I previously stated there is nothing massively new about part-m
You're not quite correct in stating that the Subpart F (or 145) and G have to be seperate companies, in fact most approved compaines have both approvals. There has to be some independancy within the organisation - the person who makes the airworthiness review recommendation should not have active involvement in the continued airworthiness management of that aircraft. However this only applied to aircraft being 'managed' within a controlled environment. The ARC signatory can be same person as the certifying engineer for whatever work has happened at the ARC renewal.
Vee-tail
You are techincally correct that the review period is only supposed to be looking at the time since the last ARC renewal, however a CAMO has to be certain of the facts, and most are not prepared to risk overlooking someone else's mistake. Albeit for a simple aircraft establishing the status of the aircraft does not take long, and as I previously stated there is nothing massively new about part-m
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After 28th Sept 2010 I will no longer be able to release my own annuals, but by that time a number of French CAMOs will be up and operating offering ARC/CEN renewals at a fraction of the current rip off UK fees.
however a CAMO has to be certain of the facts, and most are not prepared to risk overlooking someone else's mistake
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<< however a CAMO has to be certain of the facts, and most are not prepared to risk overlooking someone else's mistake >>
What mistake? In the case of French registered aircraft, the NAA made the rules, approved the maintenance programme, issued the ADs, approved the mods, and carried out all airworthiness reviews on the aircraft since it was constructed.
For a UK CAMO to suggest that a back to birth inspection is needed in case 'someone made a mistake' is just pure extortion.
Same deal for G reg aircraft, where the CAA did the inspections before issuing a new C of A. No it seems to me that some engineers are using the new part M as a money making enterprise.
What mistake? In the case of French registered aircraft, the NAA made the rules, approved the maintenance programme, issued the ADs, approved the mods, and carried out all airworthiness reviews on the aircraft since it was constructed.
For a UK CAMO to suggest that a back to birth inspection is needed in case 'someone made a mistake' is just pure extortion.
Same deal for G reg aircraft, where the CAA did the inspections before issuing a new C of A. No it seems to me that some engineers are using the new part M as a money making enterprise.
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Vee-tail-1
I would think that those CAMO's who have taken the "back to birth" stance with ARC renewals have most likely done so because of badly kept log books and tech records. These are usualy found asscociated with aircraft that have had a lot of different maintenance companys looking after them over the years. This is normaly as result of owners playing the field in search of what they think is a better deal.
I cant see any CAMO going "back to birth" with a good set of books avalable for inspection.
We have been looking after an aircraft that was on another European register, this has been a problem in the fact that some of the paperwork looked very suspect to the CAA, This resulted in a lot of delay while the CAA checked that the documentation met the national requiements of the state of origin, The delay has cost us time and the owners money but all was (eventualy) found to be in order. Some might have said that the delay and extra cost was down to us as the CAMO by being too fussy but we presented the paperwork to the CAA and they delayed things while investigations took place, in the end the CAA excepted the paperwork as first presened to them.
I would not have recomended buying this aircraft had I been asked, not because it was a bad aircraft but because the paper trail was unusual (not wrong in any way) and likely to result in delays to issue the ARC when it was put on the UK register.
Well so much for a united European aviation industry under EASA!
I would think that those CAMO's who have taken the "back to birth" stance with ARC renewals have most likely done so because of badly kept log books and tech records. These are usualy found asscociated with aircraft that have had a lot of different maintenance companys looking after them over the years. This is normaly as result of owners playing the field in search of what they think is a better deal.
I cant see any CAMO going "back to birth" with a good set of books avalable for inspection.
We have been looking after an aircraft that was on another European register, this has been a problem in the fact that some of the paperwork looked very suspect to the CAA, This resulted in a lot of delay while the CAA checked that the documentation met the national requiements of the state of origin, The delay has cost us time and the owners money but all was (eventualy) found to be in order. Some might have said that the delay and extra cost was down to us as the CAMO by being too fussy but we presented the paperwork to the CAA and they delayed things while investigations took place, in the end the CAA excepted the paperwork as first presened to them.
I would not have recomended buying this aircraft had I been asked, not because it was a bad aircraft but because the paper trail was unusual (not wrong in any way) and likely to result in delays to issue the ARC when it was put on the UK register.
Well so much for a united European aviation industry under EASA!
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A and C
Excuse my frustration at the way part M has been interpreted here. As I understand it, EASA intended 'harmonisation' of maintenance throughout the EU, but it seems there is way to go before that happens.
Excuse my frustration at the way part M has been interpreted here. As I understand it, EASA intended 'harmonisation' of maintenance throughout the EU, but it seems there is way to go before that happens.
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Vee-tail
The problem is a political one, all the national aviation authoritys are trying to avoid the fact that they are soon to just be an EASA local office.
Some are gold plating EASA regulations, some are trying to hold on to national regulations, some are just being obstructive and the French just do what the French want to do.
All resent the power going to EASA and All are in fear of jobs disapearing to EASA.
So while this lot have a bun fight over who gets the power we have a mis-regulated industry that has to pay for the bun fight.
Vee-tail I agree with you!
Some are gold plating EASA regulations, some are trying to hold on to national regulations, some are just being obstructive and the French just do what the French want to do.
All resent the power going to EASA and All are in fear of jobs disapearing to EASA.
So while this lot have a bun fight over who gets the power we have a mis-regulated industry that has to pay for the bun fight.
Vee-tail I agree with you!
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I still don't see a difference in actual prosecution risk between
1) a MO not spotting an illegal mod done before on a part M Annual
2) a MO not spotting an illegal mod done at any previous time
Either way, when they sign off the Annual they are signing a (highly technically) bogus release to service. But some 90% of planes are technically illegal to fly, anyway. If the CAA busted "technically bogus" releases to service, every single MO in GA would be gone tomorrow.
Like the old management accounting proverb "cash is king, everything else is conjecture", in this case "prosecution risk is the bottom line, and everything else is just paperwork".
Obviously, if a plane comes with obviously crap paperwork then one cannot sign it off, but if it comes with history which looks "OK" but just happens to come via a number of different companies, their signatures must be taken on trust. That's how maintenance/certification works. Otherwise, it is ripping off the customer.
1) a MO not spotting an illegal mod done before on a part M Annual
2) a MO not spotting an illegal mod done at any previous time
Either way, when they sign off the Annual they are signing a (highly technically) bogus release to service. But some 90% of planes are technically illegal to fly, anyway. If the CAA busted "technically bogus" releases to service, every single MO in GA would be gone tomorrow.
Like the old management accounting proverb "cash is king, everything else is conjecture", in this case "prosecution risk is the bottom line, and everything else is just paperwork".
Obviously, if a plane comes with obviously crap paperwork then one cannot sign it off, but if it comes with history which looks "OK" but just happens to come via a number of different companies, their signatures must be taken on trust. That's how maintenance/certification works. Otherwise, it is ripping off the customer.
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Our shop has been doing all maintanance on out 172sp for several years.
They keep a log and tell us what needs to be done at every service. A 100 hours service we have been able to do in a long day with the help of one of the aircraft owners. Usually app. 10-12 hours have been invoiced where the major parts of the hours where used on paperwork.
With part M can we expect a lot of change? The shop is offering a fixed rate CAMO service. Paying the fixed rate must be substituting all the paperwork hours, making the service bill far less???
They keep a log and tell us what needs to be done at every service. A 100 hours service we have been able to do in a long day with the help of one of the aircraft owners. Usually app. 10-12 hours have been invoiced where the major parts of the hours where used on paperwork.
With part M can we expect a lot of change? The shop is offering a fixed rate CAMO service. Paying the fixed rate must be substituting all the paperwork hours, making the service bill far less???
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Aviator1512
While you are quite correct that subpart F & G don't require different companys however the subparts have to maintain a "distance".
When this Part M first anounced and the CAA held a number of "roadshows" the direction was very much on the lines of two companies.
We decided to go along the two companies route (after the first roadshow) so that we could offer subpart G services to companies that might not want the subart G stuff and wanted to just get on with the subpart F business.
One of the expences of Part M was the ever moving goalposts, for example just as I had got all the stuff for the controled enviroment for my C152's they withdraw the requirment........... more useless work!
I see one of the problems for the maintenance business is the new system has resulted in a bit more transparency in charging as with the maintenance split between two companies the customer gets two bills and can see what he is paying for.
The CAA charges and audits these as two approvals and so one insted of two days so my time is given to this rather than paying work, this all adds up to more paperwork and cost.
Some above are very quick to charge the maintenance business with overcharging but cant see the level of investment in time and effort required to meet these new regulations, I only wish we could charge the same hourly rate as the CAA charge for engineering investigations, then we would be making the sort of money that Bose -x thinks we are!
When this Part M first anounced and the CAA held a number of "roadshows" the direction was very much on the lines of two companies.
We decided to go along the two companies route (after the first roadshow) so that we could offer subpart G services to companies that might not want the subart G stuff and wanted to just get on with the subpart F business.
One of the expences of Part M was the ever moving goalposts, for example just as I had got all the stuff for the controled enviroment for my C152's they withdraw the requirment........... more useless work!
I see one of the problems for the maintenance business is the new system has resulted in a bit more transparency in charging as with the maintenance split between two companies the customer gets two bills and can see what he is paying for.
The CAA charges and audits these as two approvals and so one insted of two days so my time is given to this rather than paying work, this all adds up to more paperwork and cost.
Some above are very quick to charge the maintenance business with overcharging but cant see the level of investment in time and effort required to meet these new regulations, I only wish we could charge the same hourly rate as the CAA charge for engineering investigations, then we would be making the sort of money that Bose -x thinks we are!
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th
I have no idea how your particular business model works and you have not stated your fees to my knowledge so was making no assumptions about how much money you make.
I merely pointed out that I know what the rules are as I work for an organisation that holds Part 145 and CAMO. I still maintain that there are no justifications for the figures that people are quoting on here and that many engineers are using Part M as a reason to 'lift the skirts' of customers by charging for work that should already have been done if they were anywhere near competent as engineers.
The excuse for charging an owner whose maintenance they have been doing nearly a decade for a back to birth inspection of the books - £3000 for the paperwork, is indefensible. Sadly this is not an isolated case.
en we would be making the sort of money that Bose -x thinks we are!
I merely pointed out that I know what the rules are as I work for an organisation that holds Part 145 and CAMO. I still maintain that there are no justifications for the figures that people are quoting on here and that many engineers are using Part M as a reason to 'lift the skirts' of customers by charging for work that should already have been done if they were anywhere near competent as engineers.
The excuse for charging an owner whose maintenance they have been doing nearly a decade for a back to birth inspection of the books - £3000 for the paperwork, is indefensible. Sadly this is not an isolated case.