EASA money pit
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DFC -
I'm sorry, but you are still missing the point being made.
A EASA Duplicate inspection Authorisation is not issued by a Competent Authority, but by a company. There are many pressures to get things done quickly, cheaply and with a minimum of fuss - this could potentially lead to the potentially less scrupulous operator potentially issuing an authorisation to a potentially unsuitable person.
Using a type rated Licensed Engineer, there is potentially a greater degree of confidence.
Granted some not potentially as good as others. Just as there are potentially poor licensed engineers there are potentially poor companies too, even perhaps some working for those companies.
Since only detailed information will suffice, if you take the trouble to read the BMAA Airworthiness Guide issue 7 page 21 available on the internet, you will find detailed guidance on the use of Duplicate Inspections. I would consider removing wings and things a change to primary strucutre, but I must doff my hat to you and your superioity in not needing to worry about such trivia, but this is digressing away from Part M again.
As for the CAMO, the requirements do not say how things are done, but what must be done, and by whom.
Owner owns plane,pays for everything & takes responsibility, MO Maintains plane as instructed by owner & CAMO, & CAMO controls and manages records, maintenance program maintenance data, & mandatory requirements for the plane.
I have presented the logical extreme extension to the scheme as currently presented. As I have perhaps misinterpreted the Regulations, please would you be kind enough to offer your maintenance scenario for say a PA28, covering contracts, provision and sharing of data / spares / liason etc & the authorisation of non scheduled maintenance between an owner and a seperate MO and a seperate CAMO, and remain in a controled environment?
It could well save me a great deal of aggravation for which I would be eternally grateful.
Fuji - take a peek at the EASA site, MDM032 update. Doesn't say a lot though.
Best regards
Malcom
I'm sorry, but you are still missing the point being made.
A EASA Duplicate inspection Authorisation is not issued by a Competent Authority, but by a company. There are many pressures to get things done quickly, cheaply and with a minimum of fuss - this could potentially lead to the potentially less scrupulous operator potentially issuing an authorisation to a potentially unsuitable person.
Using a type rated Licensed Engineer, there is potentially a greater degree of confidence.
Granted some not potentially as good as others. Just as there are potentially poor licensed engineers there are potentially poor companies too, even perhaps some working for those companies.
Since only detailed information will suffice, if you take the trouble to read the BMAA Airworthiness Guide issue 7 page 21 available on the internet, you will find detailed guidance on the use of Duplicate Inspections. I would consider removing wings and things a change to primary strucutre, but I must doff my hat to you and your superioity in not needing to worry about such trivia, but this is digressing away from Part M again.
As for the CAMO, the requirements do not say how things are done, but what must be done, and by whom.
Owner owns plane,pays for everything & takes responsibility, MO Maintains plane as instructed by owner & CAMO, & CAMO controls and manages records, maintenance program maintenance data, & mandatory requirements for the plane.
I have presented the logical extreme extension to the scheme as currently presented. As I have perhaps misinterpreted the Regulations, please would you be kind enough to offer your maintenance scenario for say a PA28, covering contracts, provision and sharing of data / spares / liason etc & the authorisation of non scheduled maintenance between an owner and a seperate MO and a seperate CAMO, and remain in a controled environment?
It could well save me a great deal of aggravation for which I would be eternally grateful.
Fuji - take a peek at the EASA site, MDM032 update. Doesn't say a lot though.
Best regards
Malcom
On the cost issue this might be of interest 3 years ago charges purely for paperwork and related costs for a 3 year c of a £375.
Under the new scheme for a one year c of a £450.
Under the new scheme for a one year c of a £450.
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Fuji,
It will not have any effect on my maintenance. As owner, I am responsible for ensuring the continued airworthiness of the aircraft. That will not change. I will manage the maintenance to meet the private requirements and will contract the maintenance organisation to carry out the required maintenance.
This is the private pilot forum and we are talking about private aircraft on private level C of A's / maintenance reviews.
We already have the LAMS which the CAA (the appropriate authority) will approve or you can use the Cessna Care programme (or similar) if you like and have that approved.
As owner, I get all the service bulletins and letters as well as the AD's which you can check on the FAA and EASA and NAA websites also.
If my aircraft needs a 100 hour check, I will book it in and have it done. No big change there.
If my aircraft was on an AOC or otherwise commercial flying (note according to EASA club flying, group flying and flight training are not public transport) and there is no limit on the number of members in a group.
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A and C,
One of the reasons why you have so much paperwork to do is because you have to tell how you intend for example to establish and ensure the competence of all personnel involved in each area.
You should be aware that the authority will no longer check that a licensed engineer has recent experience before renewing their licence. It is up to the organisation providing the maintenance to ensure that the certifying staff have the appropriate experience and are current.
The authority will perform spot checks but even for the licernsed certifying staff, it is up to the organisation and not the authority to confirm that everything is done as it should.
You try telling a NAA (or me as a customer) in your manual that you will use the tea boy for a duplicate inspection and you a) will not get approval and b) will not get any business from me.
OK so people can write one thing in a manual and do something else in practice. That has been going on in the UK for years with unlicensed people doing maintenance that is later signed for by a licensed engineer. The amount of checking being up to how risk adverse the engineer is.
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Malcolm,
The only time the BMAA require a duplicate inspection is when doing a mod.
To have it any other way, one could not unfurl the wing, rig and attach it to the trike, fit the training bars and then depart on a paid for trial lesson from the farmer's field behind the customer's house.
Regards,
DFC
It will not have any effect on my maintenance. As owner, I am responsible for ensuring the continued airworthiness of the aircraft. That will not change. I will manage the maintenance to meet the private requirements and will contract the maintenance organisation to carry out the required maintenance.
This is the private pilot forum and we are talking about private aircraft on private level C of A's / maintenance reviews.
We already have the LAMS which the CAA (the appropriate authority) will approve or you can use the Cessna Care programme (or similar) if you like and have that approved.
As owner, I get all the service bulletins and letters as well as the AD's which you can check on the FAA and EASA and NAA websites also.
If my aircraft needs a 100 hour check, I will book it in and have it done. No big change there.
If my aircraft was on an AOC or otherwise commercial flying (note according to EASA club flying, group flying and flight training are not public transport) and there is no limit on the number of members in a group.
----------
A and C,
One of the reasons why you have so much paperwork to do is because you have to tell how you intend for example to establish and ensure the competence of all personnel involved in each area.
You should be aware that the authority will no longer check that a licensed engineer has recent experience before renewing their licence. It is up to the organisation providing the maintenance to ensure that the certifying staff have the appropriate experience and are current.
The authority will perform spot checks but even for the licernsed certifying staff, it is up to the organisation and not the authority to confirm that everything is done as it should.
You try telling a NAA (or me as a customer) in your manual that you will use the tea boy for a duplicate inspection and you a) will not get approval and b) will not get any business from me.
OK so people can write one thing in a manual and do something else in practice. That has been going on in the UK for years with unlicensed people doing maintenance that is later signed for by a licensed engineer. The amount of checking being up to how risk adverse the engineer is.
---------
Malcolm,
The only time the BMAA require a duplicate inspection is when doing a mod.
To have it any other way, one could not unfurl the wing, rig and attach it to the trike, fit the training bars and then depart on a paid for trial lesson from the farmer's field behind the customer's house.
Regards,
DFC
As a matter of fact the CAA won't approve LAMS they will approve LAMP (LIGHT AIRCRAFT MAINTENCE PROGRAM) replacing LAMS. Pity they have told hardly anybody about it.
Its supposed to be detailed in a Letter to operators, but as they haven't distributed it properly. Hardly anyone knows whats going on.
As to the famous NAA websites the GSAC (French) site has been out for over a week.
As I was attempting to renew the C of A on a French aircraft at the time it wasn't a lot of good. Mind you I had some hand written notes taken previously so I used those.
Its supposed to be detailed in a Letter to operators, but as they haven't distributed it properly. Hardly anyone knows whats going on.
As to the famous NAA websites the GSAC (French) site has been out for over a week.
As I was attempting to renew the C of A on a French aircraft at the time it wasn't a lot of good. Mind you I had some hand written notes taken previously so I used those.
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DFC
Sorry I mis understood you ! I had not realsed that you are a EASA part M approved CAMO.
As this is the case you can oversee the maintenance work and tell the company working on your aircraft what work is required.
Have you got this EASA approval just for your aircraft or do you sub-contract to other aircraft owners as well?
I ask because the work required for you to get the approval is rather expensive just to keep just one aircraft inside the controled enviroment.
As this is the case you can oversee the maintenance work and tell the company working on your aircraft what work is required.
Have you got this EASA approval just for your aircraft or do you sub-contract to other aircraft owners as well?
I ask because the work required for you to get the approval is rather expensive just to keep just one aircraft inside the controled enviroment.
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Why do I need approval to be responsible for the maintenence of my sub 2730Kg private aircraft?
Why do I need approval to enter into a contract with an appropriate maintenance organisation (no requirement to be Part 145) to have the maintenance that I ask it to do completed?
EASA is very clear it is the owner's/ operator's responsibility.......even if they wish to farm out the tasks so why let some idiot get you in poo by missing something that causes your C of A to be invalid.
Regards,
DFC
Why do I need approval to enter into a contract with an appropriate maintenance organisation (no requirement to be Part 145) to have the maintenance that I ask it to do completed?
EASA is very clear it is the owner's/ operator's responsibility.......even if they wish to farm out the tasks so why let some idiot get you in poo by missing something that causes your C of A to be invalid.
Regards,
DFC
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DFC, hopefully correcting some inexactitudes, assuming you have an EASA type aircraft:
As Owner you are allowed to manage your own maintenance, if you consider yourself suitably capable of doing so. That is a matter for you, your conscience and the Board of Enquiry in the event. You dont need approval to be responsible for maintenance of your plane - you ARE responsible, regardless of who does what.
You need an awful lot more data than just ADs & SBs to do it though. You cannot manage maintenance if you dont have a current maintenance manual to tell you what & how & when & why to do stuff? What about the IPC, SIDs, SRM?? What about data for the engine & propeller & the equipment fitted & the mods installed? How do you technically asses the data and incorporate it into your maintenance program? A working knowledge of the relevent regulations? In so avoiding the CAMO you are outside the infamous Controlled Environment.
But, by managing yourself, you still cannot avoid using a CAMO, and each year you will need a FULL Airworthiness Review performed byone of them.
(unless you deal directly with the NAA, who have said up front that they will be v. expensive so as to to drive this function to industry)
As an occaisional CAMO user, you will find yourself way down a CAMOs list of priorities. Those with contracts will get prioity, AND will only need their Airworthiness Review once in every 3 years. Either way, the owner will pay more for whats already being done.
You dont need approval to enter into a maintenance contract, you either do - or dont. The choice is yours entirely, but maintenance outside of approved shops again places you outside the controlled environment.
LAMS will not be acceptable for EASA types. You will need LAMP, or your own pre-approved program.
(A & C - Heads-up from the two glass towers - LAMP to be ammended shortly so dont go too mad!!!!!!!!!!!!!!)
Flying Groups used to be limited to 20 people. I must admit I do not know if this is still the case in EASAland .
Public Transport is an ANO definition. It does not have any meaning in EASA terminology, Commercial Air Transport (CAT) is what you meant. However, currently you still abide by ANO Public Transport requiremments if needs be.
MDM 032 update says money changing hands is a commercial activity. How long before paid for Flight training is seen as such and then deemed to be CAT?
So , you could do circuits & local flying non-CAT (Curiously A to A flights are not deemed CAT) but your XC A to B flight will be CAT.
CAT requires Part 145 Maintenance, thus Flying schools will need CAT status and Part 145 maintenance to provide a full learning experience..
Even I would not tell the Authority the teaboy does duplicate inspections. But, an unscruplous company could, potentially, assess a certain Mr T. Boy as
competent to perform the task, and attest to that with a load of old tosh in his authorisation file. Again, a Licence would attest to some knowledge for the file.
The BMAA say Duplicate Inspections should be made on all changes to primary structure or powerplant (including regular maintenance).
If as you suggested earlier you were removing wings surely then this is a change to primary structure?.
If as you are now suggesting the plane is designed to be easily de-rigged & re-rigged then no duplicate would be nesessary, but I would say inadvisable - the RF5 accident at North Weald a very tragic case in point. (Yes i know a RF5 is not a microlight and probably a non EASA type, but the principle is the same)
Best Regards
Malcom
As Owner you are allowed to manage your own maintenance, if you consider yourself suitably capable of doing so. That is a matter for you, your conscience and the Board of Enquiry in the event. You dont need approval to be responsible for maintenance of your plane - you ARE responsible, regardless of who does what.
You need an awful lot more data than just ADs & SBs to do it though. You cannot manage maintenance if you dont have a current maintenance manual to tell you what & how & when & why to do stuff? What about the IPC, SIDs, SRM?? What about data for the engine & propeller & the equipment fitted & the mods installed? How do you technically asses the data and incorporate it into your maintenance program? A working knowledge of the relevent regulations? In so avoiding the CAMO you are outside the infamous Controlled Environment.
But, by managing yourself, you still cannot avoid using a CAMO, and each year you will need a FULL Airworthiness Review performed byone of them.
(unless you deal directly with the NAA, who have said up front that they will be v. expensive so as to to drive this function to industry)
As an occaisional CAMO user, you will find yourself way down a CAMOs list of priorities. Those with contracts will get prioity, AND will only need their Airworthiness Review once in every 3 years. Either way, the owner will pay more for whats already being done.
You dont need approval to enter into a maintenance contract, you either do - or dont. The choice is yours entirely, but maintenance outside of approved shops again places you outside the controlled environment.
LAMS will not be acceptable for EASA types. You will need LAMP, or your own pre-approved program.
(A & C - Heads-up from the two glass towers - LAMP to be ammended shortly so dont go too mad!!!!!!!!!!!!!!)
Flying Groups used to be limited to 20 people. I must admit I do not know if this is still the case in EASAland .
Public Transport is an ANO definition. It does not have any meaning in EASA terminology, Commercial Air Transport (CAT) is what you meant. However, currently you still abide by ANO Public Transport requiremments if needs be.
MDM 032 update says money changing hands is a commercial activity. How long before paid for Flight training is seen as such and then deemed to be CAT?
So , you could do circuits & local flying non-CAT (Curiously A to A flights are not deemed CAT) but your XC A to B flight will be CAT.
CAT requires Part 145 Maintenance, thus Flying schools will need CAT status and Part 145 maintenance to provide a full learning experience..
Even I would not tell the Authority the teaboy does duplicate inspections. But, an unscruplous company could, potentially, assess a certain Mr T. Boy as
competent to perform the task, and attest to that with a load of old tosh in his authorisation file. Again, a Licence would attest to some knowledge for the file.
The BMAA say Duplicate Inspections should be made on all changes to primary structure or powerplant (including regular maintenance).
If as you suggested earlier you were removing wings surely then this is a change to primary structure?.
If as you are now suggesting the plane is designed to be easily de-rigged & re-rigged then no duplicate would be nesessary, but I would say inadvisable - the RF5 accident at North Weald a very tragic case in point. (Yes i know a RF5 is not a microlight and probably a non EASA type, but the principle is the same)
Best Regards
Malcom
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I will just simply repeat what I have said at the start - it will not make any difference to me.
The responsibilities of the private owner with regard to maintenance have not changed. The only ones who will suddenly find that they can't cope with for example having to get a maintenance manual and/or maintenance programme are those who have not been meeting their responsibilities all along.
Similarly the engineering organisations who struggle are those who were in the same boat.
Perhaps you simply need to either wait until the UK gets it's act together or go abroad and find out how the rest of Europe is proceeding with this no real change other than in the rule book.
The best thing to do is to come back in 3 years and I expect that just like Y2K and other great money spinners for those that were willing to take the money from the fools that did not know better, those who do know better will simply say....no change here.
Regards,
DFC
The responsibilities of the private owner with regard to maintenance have not changed. The only ones who will suddenly find that they can't cope with for example having to get a maintenance manual and/or maintenance programme are those who have not been meeting their responsibilities all along.
Similarly the engineering organisations who struggle are those who were in the same boat.
Perhaps you simply need to either wait until the UK gets it's act together or go abroad and find out how the rest of Europe is proceeding with this no real change other than in the rule book.
The best thing to do is to come back in 3 years and I expect that just like Y2K and other great money spinners for those that were willing to take the money from the fools that did not know better, those who do know better will simply say....no change here.
Regards,
DFC
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Malcom thanks for the tip about LAMP but i had to move quickly as I have two aircraft on annual just after new year.
As for DFC well all I can say is Head, Sand, In !!
As for DFC well all I can say is Head, Sand, In !!
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Not at all. Perhaps the opposite even.
My aircraft will not suddenly become unairworthy when it's C of A becomes non-expiring and it is fully under EASA.
If I was able to ensure the continued airworthiness for the past (can't remember but a lot) years what in terms of information available etc has changed to make it harder for me to complete what is my responsibility, has been my responsibility and will in the future (regardless if I pay someone else or not) continue to be my responsibility.
These days, obtaining information is far easier than in the past and pre-internet times.
Perhaps owner's in the UK did not fulfill their responsibilities in the past and simply expected (relied on) the maintenance organisation to do everything.
However, for the owner that can check the required info and make a contract with a maintenance organisation there is no need to pay either that organisation or a third organisation to do it for them.
My aircraft will not suddenly become unairworthy when it's C of A becomes non-expiring and it is fully under EASA.
If I was able to ensure the continued airworthiness for the past (can't remember but a lot) years what in terms of information available etc has changed to make it harder for me to complete what is my responsibility, has been my responsibility and will in the future (regardless if I pay someone else or not) continue to be my responsibility.
These days, obtaining information is far easier than in the past and pre-internet times.
Perhaps owner's in the UK did not fulfill their responsibilities in the past and simply expected (relied on) the maintenance organisation to do everything.
However, for the owner that can check the required info and make a contract with a maintenance organisation there is no need to pay either that organisation or a third organisation to do it for them.
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The latest GASIL has some info on this.
When asked "Should we pay for continued airworthiness management?", the CAA says "it is usually done better when done professionally. So even the CAA says that there will still be businesses out there who will not do it properly and who is responsible when they don't do it right............the owner.
I must check on this point from Malcolm that the CAA will set it's prices at such alevel as to force certain optional requirements on private owners. I am sure that EASA would have something to say about the UK using such a method to limit certain parts of the Law.
Regards,
DFC
When asked "Should we pay for continued airworthiness management?", the CAA says "it is usually done better when done professionally. So even the CAA says that there will still be businesses out there who will not do it properly and who is responsible when they don't do it right............the owner.
I must check on this point from Malcolm that the CAA will set it's prices at such alevel as to force certain optional requirements on private owners. I am sure that EASA would have something to say about the UK using such a method to limit certain parts of the Law.
Regards,
DFC
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DFC
When you've had your non-expiring EASA C of A for 12 months, please explain how you will have it revalidated - without there being any difference to you.
You are quite certain you operate an EASA type, aren't you??
Best Regards
Malcom
A+C Did you realise the ARC was optional, as alluded to by DFC?
When you've had your non-expiring EASA C of A for 12 months, please explain how you will have it revalidated - without there being any difference to you.
You are quite certain you operate an EASA type, aren't you??
Best Regards
Malcom
A+C Did you realise the ARC was optional, as alluded to by DFC?
I find myself in the same position as DFC in many ways.
I maintain my own documentation, I have all the relevant manuals and I am a type rated licensed engineer.
Why should I have to pay someone to do something I have done for the last 14 years without any major problems?
I have yet to see anyone issue a scale of charges for my aircraft and I am waiting to see just what this paper chase is going to cost in reality.
The effort required to maintain it's paperwork with an aircraft only flying 100 hours a year is minimal. There are currently only 9 airframe AD's and only one is repetitive for my aircraft.
I don't mind paying if I am going to get some value for my money.
If this gets really expensive I will apply for the approval myself and contact every owner of the type in the country and do it for cost. It clearly makes more sense to do it on a type basis than have one organisation holding maintenance data for 30 types and charging accordingly!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
How is this wonderfull Part M working in practice.
Well one organisation I know of, is as we speak changing an engine because the Part M failed to tell them that it was timex and they have had another aircraft grounded for over a week because the Part M failed to complete the C of A paperwork in time.
Good job its in house otherwise the legal eagles would be making a killing already!!!!!!!!!!
I maintain my own documentation, I have all the relevant manuals and I am a type rated licensed engineer.
Why should I have to pay someone to do something I have done for the last 14 years without any major problems?
I have yet to see anyone issue a scale of charges for my aircraft and I am waiting to see just what this paper chase is going to cost in reality.
The effort required to maintain it's paperwork with an aircraft only flying 100 hours a year is minimal. There are currently only 9 airframe AD's and only one is repetitive for my aircraft.
I don't mind paying if I am going to get some value for my money.
If this gets really expensive I will apply for the approval myself and contact every owner of the type in the country and do it for cost. It clearly makes more sense to do it on a type basis than have one organisation holding maintenance data for 30 types and charging accordingly!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!
How is this wonderfull Part M working in practice.
Well one organisation I know of, is as we speak changing an engine because the Part M failed to tell them that it was timex and they have had another aircraft grounded for over a week because the Part M failed to complete the C of A paperwork in time.
Good job its in house otherwise the legal eagles would be making a killing already!!!!!!!!!!
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DFC
"""I must check on this point from Malcolm that the CAA will set it's prices at such alevel as to force certain optional requirements on private owners. """
That is not what I said. Please re-read,
"But, by managing yourself, you still cannot avoid using a CAMO, and each year you will need a FULL Airworthiness Review performed byone of them.
(unless you deal directly with the NAA, who have said up front that they will be v. expensive so as to to drive this function to industry)"
Best Regards
Malcom
"""I must check on this point from Malcolm that the CAA will set it's prices at such alevel as to force certain optional requirements on private owners. """
That is not what I said. Please re-read,
"But, by managing yourself, you still cannot avoid using a CAMO, and each year you will need a FULL Airworthiness Review performed byone of them.
(unless you deal directly with the NAA, who have said up front that they will be v. expensive so as to to drive this function to industry)"
Best Regards
Malcom
I have heard from a source not related to this forum that the CAA's intention is to make it prohibitively expensive to use the alternative route.
Given that the CAA has little in the way of direct type expertise these days, I can't imagine they would inspect any aircraft themselves. They would probably subcontract the work to a CAMO!!!!!!!!!!!!!!!!!!!!!!!!
Given that the CAA has little in the way of direct type expertise these days, I can't imagine they would inspect any aircraft themselves. They would probably subcontract the work to a CAMO!!!!!!!!!!!!!!!!!!!!!!!!
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Why should I have to pay someone to do something I have done for the last 14 years without any major problems?
The problem is that there is nothing new for someone like you but those seeking to make some money from the confusion would have you believe that you need to be superhuman to keep the paperwork and maintenance up to date so that there are no issues when the annual is done and the ARC completed.
I like your idea for the single type approval. To manage the maintenance for others you would not need much more than what you already have.
However, on the engine out of time and the late paperwork, nothing new there either. Happens to lots of people under the old system also.
Like I said, just like the JAR-FCL, I will in 3 years time look back and say - this has not affected my operation at all despite all the hipe. Perhaps even like JAR-FCL it will make it cheaper for training organisations to operate and more profitable also than under the old system.
Regards,
DFC
I wish I had your confidence DFC.
You are right about the eng change/c of a mistakes happening previously. However this is specifically what Part M is designed to avoid so there is little improvement although huge amounts of money have been expended.
The cost of maintaining technical libraries can be huge. Single type or single manufacturer would be far more sensible. Costs would be reduced to a minimum.
The worst case scenario would be a maintenance organisation with its own Part G looking after multiple types and trying to recover it's costs.
I seem to remeber that the technical documentation for the Arriel engine alone ran to several thousand pound. So unless the owner can provide the books this cost has to recovered.
I feel that eventually this system will settle down, however I believe I already see them moving the goal posts yet again.!!!!!!!!!!!!!!!!!!
You are right about the eng change/c of a mistakes happening previously. However this is specifically what Part M is designed to avoid so there is little improvement although huge amounts of money have been expended.
The cost of maintaining technical libraries can be huge. Single type or single manufacturer would be far more sensible. Costs would be reduced to a minimum.
The worst case scenario would be a maintenance organisation with its own Part G looking after multiple types and trying to recover it's costs.
I seem to remeber that the technical documentation for the Arriel engine alone ran to several thousand pound. So unless the owner can provide the books this cost has to recovered.
I feel that eventually this system will settle down, however I believe I already see them moving the goal posts yet again.!!!!!!!!!!!!!!!!!!
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DFC and I agree on something at last !
Why should he pay someone to do what he has been doing for the last 14 years?
The answer is becuse you are going to be forced down the EASA road of having your aircraft maintained in a "controled enviroment" simply becuse the charges for going down the other route will be too high.
DFC the big question for you is how much money you are going to put into the EASA money pit? Do you get the CAA in each year and retain your independant position and pay the CAA's fees or do you get a part M to cover the work and get an ARC?
I can see that what I have been saying about this whole part M system is slowly dawning apon you, it is a pointless excersise in paperwork that add's nothing to flight safety and will increase costs to the aircraft owner. It can't be any other way the maintenance companys have to cover the cost of the extra paperwork or they will go out of business.
You of course can do the paperwork yourself but what of the CAA fees?
The bottom line is that you as an aircraft owner are between a rock and a hard place and it is not of the maintenance companys doing.
Why should he pay someone to do what he has been doing for the last 14 years?
The answer is becuse you are going to be forced down the EASA road of having your aircraft maintained in a "controled enviroment" simply becuse the charges for going down the other route will be too high.
DFC the big question for you is how much money you are going to put into the EASA money pit? Do you get the CAA in each year and retain your independant position and pay the CAA's fees or do you get a part M to cover the work and get an ARC?
I can see that what I have been saying about this whole part M system is slowly dawning apon you, it is a pointless excersise in paperwork that add's nothing to flight safety and will increase costs to the aircraft owner. It can't be any other way the maintenance companys have to cover the cost of the extra paperwork or they will go out of business.
You of course can do the paperwork yourself but what of the CAA fees?
The bottom line is that you as an aircraft owner are between a rock and a hard place and it is not of the maintenance companys doing.
One long standing G.A engineer has told me that he expects to see an increaced number of aircraft for sale. It will be a result of increaced costs and people just not wanting the hassle.
Our aircraft has been grounded for the last 2 months largely due to missing paperwork.
That is the c of a paperwork dissapeared twice.
Who was to blame CAA, Post Office, Engineering, who knows.
I know we have an expensive piece of aluminium that cant be flown.
I can put up with the cost, I can put up with the hassle, but both?
Our aircraft has been grounded for the last 2 months largely due to missing paperwork.
That is the c of a paperwork dissapeared twice.
Who was to blame CAA, Post Office, Engineering, who knows.
I know we have an expensive piece of aluminium that cant be flown.
I can put up with the cost, I can put up with the hassle, but both?
Awesome but Affordable
Having ploughed my way though this thread I am even more convinced that Part M is a potential disaster for General Aviation in terms of certificated light aircraft not in Annex II.
Malcom's intial post was a real breath of fresh air that brought the whole Part M house of cards bureaucracy into perspective on a grotty Christmas Eve here at home with a lousy cold.
As far as I know we still await the CRD on the responses made to Part M last autumn. The grapevine seemed to indicate a huge weight of informed opinion that the watering down of Part 145 has proved an utter waste of time and totally inappropriate for general aviation type maintenance. Furthermore that any implementation date should be deferred way beyond September 2008.
Thank the Lord our aircraft is operated on the basis of a PFA administered permit to fly with all the huge benefits in cost that implies in terms of continued maintenance.
Cheers,
Reaper 69
Malcom's intial post was a real breath of fresh air that brought the whole Part M house of cards bureaucracy into perspective on a grotty Christmas Eve here at home with a lousy cold.
As far as I know we still await the CRD on the responses made to Part M last autumn. The grapevine seemed to indicate a huge weight of informed opinion that the watering down of Part 145 has proved an utter waste of time and totally inappropriate for general aviation type maintenance. Furthermore that any implementation date should be deferred way beyond September 2008.
Thank the Lord our aircraft is operated on the basis of a PFA administered permit to fly with all the huge benefits in cost that implies in terms of continued maintenance.
Cheers,
Reaper 69
Last edited by G-KEST; 24th Dec 2007 at 14:50. Reason: spacing of paragraphs