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Approvals

Presently the company approvals consist of the following aircraft types:

Part-M Subpart G (with ARC privileges):

  • Piper single & twin piston engine series below 2730kg
  • Cessna/Reims Cessna single piston engine series below 2730kg
  • Bolkow single piston engine series
  • Mooney single piston engine series
  • Apex (Robin) single piston engine series
  • Diamond DA40
  • Cirrus single piston engine series

Part-M Subpart F

  • Piper single & twin piston engine series below 2730kg
  • Cessna/Reims Cessna single piston engine series below 2730kg
  • Bolkow single piston engine series
  • Mooney single piston engine series
  • Apex (Robin) single piston engine series
  • Diamond DA40
  • Cirrus single piston engine series
  • Vulcanair (Partenavia) P68

A Brief Explanation of Part-M Subpart G and Subpart F Maintenance Organisation Approvals

 

There has been much coverage in the aviation press of the introduction by EASA of new rules and regulations for Maintenance Organisations commonly known as 'Part-M'. I hope this brief explanation will provide an insight as to the changes and how it will affect the maintenance of your aircraft.

Although the changes were announced some years ago and the implementation date set of 28 September 2008, it has only been since that date that the new requirements have become even remotely static. Whilst the majority of Europe has decided to delay implementation of Part-M until at least 28 September 2009, the UK CAA informed the UK industry at the end of September 2008 that we had until 05 January 2009 to gain the new approvals. This has caused a huge workload for maintenance organisations and the CAA alike to get the new approvals into place by the due date and many are still waiting to complete their approval process.

Airways Aero Associations Ltd has now gained Part-M Subpart F and Subpart G approvals with ARC privileges. This next year will be very much an experiment as we, the CAA and you, our customers (present and future), settle into the new regulations. The early signs are that the new system will work and that it is not in reality that far removed from what we used to do.

Most certified aircraft now carry an EASA Certificate of Airworthiness (CofA) rather than a national one - in the UK, that was a CofA issued by the UK CAA. Unlike the UK CofA, the EASA one does not expire, instead it is validated by the issue of an Airworthiness Review Certificate (ARC).

Certified aircraft that no longer enjoy factory support have been orphaned by EASA and come under the rules and regulations of what is called 'Annex II'. These aircraft remain under the control of national authorities and continue to hold a national CofA. In the UK an example of this is the DHC.1 Chipmunk.

Organisation Approvals

 

1. EASA Subpart G (with ARC privileges)

The Subpart G part of Airways Aero Associations Ltd is also known as a Continuing Airworthiness Management Organisation (CAMO). This part of the company manages the aircraft on behalf of the owner/operator to ensure all scheduled maintenance, defect rectification and any Airworthiness Directives or Service Bulletins are carried out as required. It also raises the workpacks for scheduled maintenance, basically informing the maintenance organisation exactly what tasks need to be carried out.

In line with EASA guidelines, it is envisaged that the owners of aircraft maintained by Airways Aero Associations Ltd will enter into an annual contract with AAA Ltd in its role as a CAMO and this means the aircraft will benefit from being kept in the 'Controlled Environment'. The main advantage of this is that the Airworthiness Review Certificate (ARC) will last for 3 year rather than 1 year once the aircraft has remained in the Controlled Environment for a continuous period of 12 months after a contract has been signed.

Similar to the 'old' CofA system, the aircraft ARC will expire after 3 years having been revalidated twice since it was issued. The annual scheduled maintenance programme therefore becomes once again:

1. Star Annual - ARC issue.
2. Annual - ARC revalidation.
3. Annual - ARC revalidation.
4. Star Annual - ARC issue - and so on.

AAA Ltd also holds 'Subpart I ARC privileges' and can therefore revalidate and renew ARCs 'in house'.

If an aircraft owner/operator does not enter into a contract with a CAMO, it is deemed to be operating in the 'Uncontrolled Environment'. The advantage of this is that maintenance does not have to be carried out by an approved organisation. The disadvantages are that the ARC has to be renewed every year (i.e. every year is a Star Annual inspection) and the services of a CAMO still have to be employed annually when the ARC is renewed to review the continuing airworthiness status of the aircraft.

It does not appear to be of any financial (or otherwise) benefit for any aircraft owner/operator of an aircraft maintained by AAA Ltd to not exist in the 'Controlled Environment' and for that reason annual contracts will be agreed between AAA Ltd and all customers' aircraft. The contract is produced from an example produced by the CAA and there is no apparent reason to change this. There will be an annual charge for this contract agreement but this will only cover the cost to AAA Ltd of maintaining the Subpart G approval charged by the CAA, split between the aircraft managed by AAA Ltd. This cost will be charged at the time of the aircraft's Star Annual and Annual inspection. Most other CAMOs are charging far more than this which seems strange as there is not that much more extra work involved in managing the continuing airworthiness of the aircraft. For instance, we will not be charging customers for completing aircraft log book flight times as that is a service we have always provided as part of the service.

2. EASA Subpart F

The Subpart F part of AAA Ltd performs the actual maintenance of the aircraft and carries out that maintenance in accordance with the requirements of the Subpart G organisation. There is no real difference between the maintenance programme under the UK regulations and that enforced by EASA. The scheduled maintenance programme used to be called the Light Aircraft Maintenance Schedule (LAMS) and is now the Light Aircraft Maintenance Programme (LAMP). In addition to LAMP, any requirements of the aircraft manufacturers' Maintenance Manual have to be closely adhered to.

The charge for the actual maintenance will be as before, i.e. as it is carried out. Although the CAMO will raise the paperwork workpack for all scheduled maintenance, the cost of this will be kept as part of the actual scheduled maintenance task. Many organisations are keeping their scheduled maintenance task charges the same but charging significantly more than AAA Ltd for the CAMO contract so effectively their customers are being charged twice for the generation of the workpack.

We at AAA Ltd think that we have come up with the fairest deal for our customers but should you have any questions or queries concerning the above and how it affects you and your aircraft please do not hesitate to contact us.

Dave Sarney
Chief Engineer

Contact Information

Wycombe Air Park,
Booker, Marlow
Bucks, SL7 3DP

Tel: 01494 443 737

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