Thank you for shedding light on how the ARC system works, I tried hard to find practical guidance on the ARC system, written in words that an experienced aircraft owner can understand from the CAA website but gave up after many hours of reading pages of useless blurb. As Aerofurb explains, the whole system seems to be an exercise in form filling and income generation but has no added practical or safety benefit to anyone.
I really do not understand why EASA or the CAA cannot accept that a CAMO, Part M Maintenance organisation and the Licenced Engineer who certifies the scheduled inspections and airworthiness of their customers’ aircraft are not capable of renewing an ARC themselves, just as they used to do with annuals on the old 3-year CofA system. After all the CAMO, Maintenance organisation and licenced engineer are all fully licenced and continually reviewed by the CAA, and pay hefty fees to them for the privilege; what’s more they actually see aeroplanes and get their hands dirty working on them, unlike CAA or EASA office workers.
Everyone involved in light aircraft maintenance under the EASA rules seem to be more concerned with getting all this form filling correct, lest they are lined up against a wall and shot, than they are with the practicalities of actually maintaining and ensuring the airworthiness of the aircraft.
Is there anyone who disagrees with my view that the ARC system is illogical, gives no safety benefit compared to the previous one, adds significant cost to aircraft ownership and is a prime example of unnecessary red tape?
Is there anyone who disagrees with my view that the ARC system is illogical, gives no safety benefit compared to the previous one, adds significant cost to aircraft ownership and is a prime example of unnecessary red tape?
What you are hearing is the sound of silence…..
This is the kind of European nonsense which makes being N-reg worth so much – for the right sort of (basically “pro-active”) aircraft owner.
The common train of thinking is that the ARC is far more involved and complicated than ‘the good old days’.
Sorry to disappoint you…. Sure, we now have to have and pay for an additional approval – Part-M Subpart G. Add to that ‘I’ privileges and we can complete the ARC paperwork on line with the CAA and the ARC is instantly renewed/extended. Perhaps I’m missing something despite many years pre-EASA and quite a few now under EASA.
The process is much the same as before apart from we don’t have to go through the nause of the air test every 3 years at CofA renewal time. With the best will in the world, to complete the CofA airtest and paperwork took a minimum of one person one day’s labour. The aircraft had to be (normally) ballasted to MAUW, pilot flies the air test then there was a 13 page air test form (IIRC) to complete. This time of year you could wait days to get a weather window for the air test.
On top of that was the AD202 CofA renewal recommendation form to complete. That then had to be sent (or taken) to the CAA Regional Office for the CofA to be issued. And the CAA’s cost for the CofA renewal was more than three years of ARC costs now.
At the time that EASA arrived, some maintenance organisations panicked and employed extra admin staff etc for the perceived extra paperwork. If they’d sat back and got on with it then they would have found the panic wasn’t necessary. For those of us who were doing it properly pre-EASA pretty much carried on with a similar workload (hangar and office) as we did before. We used to assess Service Bulletins and check Airworthiness Directives for compliance and raise workpacks before and still do. We always used to have current continuing airworthiness data and still do. Arguably CAMO/MOs have to charge something to cover the costs of maintaining the approval. Some CAMO/MOs jumped on the band wagon by charging by the flight hour/entry to complete log books etc. Some of us carried on as we had before completing them as part of the service.
What took the time (and money) initially was actually applying and gaining EASA approvals when Part-M arrived as no one, not even the CAA surveyors really knew what was wanted as far as organisation manuals etc.
In summary, the ARC is a simple form filled in to say that the maintenance and continuing airworthiness for the previous 12 months all up to speed on the aircraft and emailed to the CAA. Immediately the ARC certificate appears in the Inbox. Hit print, stamp and sign it, scan it, email the signed copy back to the CAA and put the original in the aircraft docs folder. Hardly difficult!
Perhaps someone can tell me how the old system was better and safer? The air test result was open to a sharp pencil by unscrupulous owners/pilots/MOs so you can’t claim that was a benefit!
If people feel the costs have escalated out of all proportion post EASA, ask their CAMO/MO to actually show them why….
I knew someone (who earns his most ney with that) would come up with something “positive” about it. Sorry, but merely the length and complexity of what you said will make it it hard to attract people to that line of thinking I’m afraid.
That said, it may be that the new system does contain isolated improvements for those on the G-reg. But ask people operating, say, on the D-reg (and I guess also on the F-reg). For them, maintenance used to be a much more straightforward process in the past.
I confess to not having got my head around Part M (despite attending some seminars on it) but it reminds me of a popular plague in my own business: ISO9000.
Every year, every ISO9000-approved customer we have sends us a form with about 100 questions. The 1st one is “are you ISO9000 approved” and if so, enter your approval # in the box and skip questions 2-99. Questions 2-99 are idiotic banal stuff like “do you segregate defective materials” to which I am sorely tempted to reply “actually, Sir, we mix them up with the good stuff and sell the whole lot” but it would not be a good idea because an ISO9000 manager with a sense of humour has never existed.
To get ISO9000 I would call in a – you’ve guessed it – ISO9000 consultant and he generates a load of forms we fill in as we make the products. If we make crap, we continue to make crap under ISO9000, but we have to do so with a specific consistency.
Basically the solution to ISO9000 is via an internal documentation system, and this can be IT-automated to a high degree.
I think the aircraft maintenance companies which had problems with Part M are those whose paperwork was totally disorganised. A lot of very good people operating at the bottom end of the business have been like that… so Part M favoured the top-heavy ones – or the ones which have a clever IT guy who sets up a system which spits out 200 pages of paper every time a plane leaves their hangar (I had Annuals done a few times by one such firm – the ticked boxes bore only a 50% relation to work actually done because they simply refused to do it).
GA maintenance is a business in which a lot of differently organised firms have operated, and some people like that, and some people don’t like that. Where you stand will depend on your own “ownership experience” with company maintenance. Mine is really poor and I am quite cynical about the organisational approval approach. But other owners love their company…
I commend Aerofurb for doing an excellent job of explaining the ARC process, despite how uselessly complex it is.
That post illustrates how insane this has become. Silvaire, you hear me?
Yes, its like something out of a 1950s science fiction novel.
Seems to mee most of the problems are due to people taking advantage of a system rather than the system itself. Not that the system is great to start with.
I work for a 145 organisation and before that ran an M3 organisation including the transition from national approval to EASA Part-M Subparts F and G with I privileges.
It was certainly not a ‘top-heavy’ company, nor am I an IT guru. The same goes for where I work now. I taught myself basic computing skills for the internet, emails, Word and Excel.
There might be companies at each end of the scale as described by Peter but not everyone by far is at either extreme. The industry was forced to change and whilst I agree that Part-M hasn’t made it easier and wasn’t really necessary it isn’t quite the impossible struggle that some like to claim it is – on both sides of the maintenance fence.
Unfortunately, there are some rip-off merchants in the GA maintenance industry. I’m sure that others on this forum know of rip-off merchants in their chosen industry/business/employment, too. Some of us are fine upstanding members of the aviation community [ :-) ] and exist as aircraft owners, builders, pilots and engineers.
Unfortunately, many owners see maintenance (scheduled and defect rectification) as a complete waste of their flying funds. Spend that money on shiny paint, comfy seats or glittering avionics and that’s fine. Maintenance? Nope. Nothing good ever comes from it – even the oil is too clean once it’s been changed to read it on the dip stick…..
