It seems Annex II aircraft (including microlights) will no l

[MikeGodsell]

http://www.caa.co.uk/default.aspx?catid ... geid=11683

It seems Annex II aircraft (including microlights) will no longer escape EASA regulation.
The consultation deadline for responses by interested organisations was 24th Dec 2010. The CAA intends to bring in the new regulations early in 2011.
Was there a response by the LAA? How will the new regulations affect our sort of aircraft? I assume there will be a big difference in maintenance & certification requirements between manufactured and home built aircraft.
Manufactured aircraft going onto a non expiring C of A and N ARC, but home built perhaps staying on the existing permit system until EASA figure out a way to regulate them?

[John Brady]

Mike,

I am not sure that your reading of this airworthiness change is correct. It relates to aircraft with a national CofA. These do sometimes fly on a permit (for example for test flights when a CofA is not valid or where an aircraft needs to be ferried following some unservicability which invalidates its CofA). Such a permit to fly is common throughout Europe and is issued by the airworthiness authority for a limited period or purpose. It has nothing whatever to do with the permit to fly issued by the CAA on recomendation of the LAA and BMAA in accordance with their expositions.

This change just aligns the EASA and national processes applicable to maintanance organisations.

I daresay that engineering will be able to tell us about this shortly but meanwhile I don't think there is any cause for alarm.

John

[mikehallam]

Gentlemen,

What is alarming is the short window allowed for response/comment. It didn't appear in either the LAA nor BMAA monthly magazines. Nor was I as an a/c owner given any hint that something was going on.
In fact even if their respective Editor's had been made aware by their parent orgs. or directly by the CAA, there was only time to catch the December issue and thus scant days in the pre-Christmas weather chaos to meditate and respond coherently.

If nothing else, very poor CAA management.

For that reason alone one wonders why such a short access period: perhaps the CAA 'knows best' & needn't trouble us with the matter till it's all decided - as no doubt is intended anyway !

Any change is unsettling, any change which is imposed without LAA time to consider at several levels is worse. Inspectors' duties may be curtailed or legal responsibilities increased, in the latter case they may decide to drop out (it's generally done for love not money).
Moreover owner/pilot maintenance as outlined would be extremely limited and looks as if it's drawing closer towards the 'M' maintenance system ?


I note that the document specifically identifies ALL non EASA a/c in the U.K. with no bottom weight limit and clearly the preamble says that's its aim.


Whatever the motives behind this matter, I think the notification and timing has been so poorly executed that unless done with malice afore-thought, we should be granted an extension to allow the affected parties proper consultation.

mikehallam.

[Bill Scott]

So, we just cross our fingers and hope that we're not the target

I think Mike raises some very valid points, particularly WRT timescales of consultations. Mind you, I see little validity to this notion of consultation as being some representation of democracy/accountability in the European Dictatorship.

Life is good, post Lisbon

[Brian Hope]

I see no reason to get over excited. It has been known for a while that CoA types that were put into Annex 11 and retained the 'old style' national CAA airworthiness regime were going to be brought into line (by CAA not EASA) with a Part M style of airworthiness regime so that the CAA and maintenance organisations would not have to use two different systems for CoA types.
This has nothing to do with LAA Permit to Fly aircraft.
You will note from the introductory letter that this consultation ran from the beginning of October, so stakeholders had a three month period to comment, hardly fair then to start ripping into the CAA for being unreasonable. Suggesting that the CAA want to make some covert changes to the regulations over the Christmas break to catch everyone on the hop is rather silly don't you think?
I suspect LAA has made no comment because it does not directly affect us.

[Martin Ryan]

Well Brian as as LAA member and Annex 2 owner I am surprised . I have received nothing at all from the CAA on this subject so clearly not part of their audience. when it changed for EASA aircraft there was comment that EASA could not force change to those aircraft whose type certificate managed by another certifying authority outside EASA. Guess I need to find a training course to become my own CAMO and then agency to fill in paperwork for CAA/EASA or revert to N Reg!!!! unless LAA are able to negotiate transfer of Vintage aircraft again to their management. Cheers Martin

[Brian Hope]

Hi Martin, I don't think EASA has anything tp do with this at all. It's simply a case of the CAA seeing no sense in retaining two different maintenance regimes for what are the same type of aircraft - CoA. As Part M has been established for the majority, it makes sense for them to put Annex 11 CoA types onto the same system. A friend of mine has an Annex 11 CoA type and he was told a while ago about this, I think by the maintenance organisation he uses. He believes it will make no difference to his situation, he does the majority of work himself and expects to continue to do so. There are currently some concerns over N reg aircraft and EASA regulation. Best check on the long term viability of that option before deciding to go that route.

[Nigelcot]

Well Brian, I too am an LAA member and operate an Annex 11 a/c on a national C of A and the CAA hasn't contacted me to find out what I think in their "consultation" process.
The vagueness of what they are "consulting" on is also typical of an unaccountable organisation which continues to reinforce the impression that it is unfit for purpose.
They appear to be trying to give the impression that this is simply aligning the paperwork systems however I expect I will soon have to find a CAMO and Part M organisation to replace an organisation that has looked after my aircraft for more than 30 years, and are an authority on the type, as they don't hold Part M approval as their business is entirely Annex 11.
But hey as an aircraft operator I can obviously afford anything the civil servants dream up.
Happy New Year

[Nigelcot]

Well Brian, I too am an LAA member and operate an Annex 11 a/c on a national C of A and the CAA hasn't contacted me to find out what I think in their "consultation" process.
The vagueness of what they are "consulting" on is also typical of an unaccountable organisation which continues to reinforce the impression that it is unfit for purpose.
They appear to be trying to give the impression that this is simply aligning the paperwork systems however I expect I will soon have to find a CAMO and Part M organisation to replace an organisation that has looked after my aircraft for more than 30 years, and are an authority on the type, as they don't hold Part M approval as their business is entirely Annex 11.
But hey as an aircraft operator I can obviously afford anything the civil servants dream up.
Happy New Year

[Brian Hope]

Hi Nigel, I spoke with my friend who has Annex 11 CoA and he was told about these proposed changes by the engineering facility he uses, not by CAA directly. There appears to be some reticence by non EASA engineering facilities to go Part M, which is understandable if their customer base is Annex 11 type owners, and no doubt those establishments will have made their situation clear to CAA in the consultation.
I do not profess to have an in depth knowledge in the Annex 11 CoA/EASA Part M field, though there are undoubtedly LAA members that do and their comment on this topic would be useful. My initial comments were to allay fears amongst LAA Permit to Fly aircraft owners that they were going to become embroiled in some major change of airworthiness regime.
If I were an Annex 11 CoA owner I too would have concerns, and I guess my first port of call would be my maintennce organisation to see what information they could give me.