Implementation of Part M

[MikeGodsell]

Like it or not Part M is due in Sept this year.
The French are way ahead of the game with their “Guide to implementation of Part M” on the GSAC website. www.gsac.fr This takes the form of two manuals, aimed at small maintenance workshops, & owners of GA aircraft non public transport, normal category CofA.
The manuals are the MOM (manual for maintenance organisations) and the MGN (manual for Airworthiness management organisations)
The MOM contains nothing new to us in UK, but the MGN is entirely new and is the only source that I found giving the “nuts & bolts” of how Part M will work. I have been reading through the MGN (with difficulty as it is in French) and for us recreational flyers of certified aeroplanes it is both good & bad news.
French speakers can access www.gsac.fr and on the menu page click on “Transition part M”, then click on annex 1 au fascicule P-54-XX

Part M concerns the relationship between 4 entities:
1) The Aircraft Owner/Operator: Flies the aeroplane and pays the bills.
2) The NAA (CAA, GSAC, etc) enforces regulations.
3) The Maintenance Workshop: services and repairs aeroplanes.
4) The Continuing Airworthiness Management Organisation. (CAMO in UK, L’OG in France) The OG is “the new kid on the block” and manages maintenance programmes, documentation, ADs, amendments, approvals, and renewals of ARCs.

So what is the good & bad news?
Well there are in my experience two type of GA pilots, basically rich & poor!
For those pilots who just wish to fly their aeroplanes and not get their hands dirty the news is bad. There will be more bureaucracy and more expense. They will need a contract with a CAMO, and this contract will require them among other things, to have full understanding of the maintenance programme. They will be required to maintain a Route log, and enter flying hours, landings, engine & hydraulic oil levels, and tyre pressures, after each flight.
They will also need a sub contract with a maintenance organisation, and this or the CAMO, needs to have sub part G & I approval in order to issue an ARC.
So what’s the good news?
Well like I said, there are two types of pilot, and some of us have been operating in a kind of legal grey area. We are the guys with dirty hands. We do our own maintenance & repairs on our certified aircraft, incurring minimum cost. In my case annuals cost nothing other than the price of spare parts, and the cost CofA renewals is kept to a reasonable level.
We have become accustomed to being conspiratorial about how our aircraft are maintained, but now surprise surprise; with Part M we can go legit!
Part M requires a contract with a management organisation, but if that organisation owns the aircraft it manages then no contract is needed, and the owner can become his own CAMO. However Part M says that the person who manages airworthiness cannot carry out the ARC renewal examination, on the same aircraft. (Similar idea to the dual inspection of flying controls)
So our owner/CAMO must find a sub part G & I approved organisation to renew his ARC. But a sub part G & I organisation is Joe Bloggs, your local engineer with his new Part 66 licence. So you ask Joe Bloggs to do the ARC examination, and he agrees but points out that EASA are charging him a huge fee for the privilege and he will have to pass on the cost to you. But you have lots of dirty handed pilots on your airfield and they all need ARC renewals. So Joe Bloggs splits the EASA fee between them and adds his own bill. Result an engineer with a reasonable income, and a bunch of pilots with ARCs renewed at a fraction of the cost of their previous CofA.
Well our CAA might find a way to mess up this excellent state of affairs, but at the moment I feel an unaccustomed optimism regarding Part M.
MG

[MikeGodsell]

Oh another reason for my optimism is Appendix VIII part A/Pilot owner maintenance tasks for powered aircraft.
This practically covers the annual schedule for my aeroplane, and I can issue a CRS for my work.
If pilots get to know the technicalities of their aeroplanes, and are prepared to get dirty, (LAA maintenance courses?) they can save a heap of money. EASA intended to lighten the regulatory burden on recreational GA , and if it has not quite worked out that way yet they are certainly trying.

[MikeGodsell]

GSAC AVIATION CIVILE: Guide to Implementation of Part M.


“ONE MAN BAND”

At a small airfield a group of technically competent pilot/owners and two qualified engineers can form a mutually beneficial organisation under the rules of EASA Part M.

The Part 66 engineer and the pilots do the aircraft servicing, and the other engineer with CAMO status keeps it all legal and issues ARCs.

Engineers have technical qualifications and approvals as required by Part M.

Part M requires pilots to demonstrate and make declarations of technical competence which are verified by the engineers.

For those pilots who are prepared to get their hands dirty, and learn about the technical aspects of their aircraft, much satisfaction can be gained and money saved.

[MikeGodsell]

This optimism thing can get out of hand!
Yesterday the sun came out and I went flying...the daffodils & snowdrops are out. and the CAA sent me their new scale of charges for GA aeroplanes. ORS5-229
What happened...did they miss out a nought, the validification charge for an ARC on an EASA aircraft is just £25 per 500 kgs. (see pages 12 & 13) How can I continue to be horrible to the CAA if they do this sort of thing? No perhaps I missed something, please check it out.
MG