Small Operator Maintenance.

[Shiny Side Up]

As mentioned above, promoting enterprise is not the mandate of TCCA.

Actually it is, by your own words above.

To serve the public interest through the promotion of a safe and secure, efficient

The problem being that in the operations of TCCA "safe and secure" take way more precedence. Of course the main way to achieve that is the "nobody moves, nobody gets hurt" principle. From experience I've run into people in TCCA who's clear opinion is that small operators should largely be annihilated, usually by the same reason that "If it works for Air Canada, it can work for you" ignoring some of the obvious problems with that model. One might add that this model does not serve the public interest.

To me, if you get into an industry and subsequently find out that it costs more than you are willing to fork out to meet all of the regulations, that's poor business planning.

To a point I would agree with you, unless said regulation makes it impossible to serve the public interest at reasonable cost to said public.

[photofly]

I'm not sure why I'm being told that "if you get into an industry and subsequently find out that it costs more than you are willing to fork out to meet all of the regulations, that's poor business planning. The entrepreneur should have done more homework before opening his door" - that seems like a straw man argument. Trivially true, but not called into question anywhere.

Regardless, your helpful business advice ("Your planning sucks! Plan better!") doesn't help operators who were able to function profitably under previous regulatory regimes but who have been driven out of business by expensive changes imposed on them after many previously successful years. (I believe that's the scenario that kicked off this discussion.)

One might hope that one goal of government, overall, was to foster enterprise. Ottawa claims it to be so. It's reasonable therefore to expect all government departments to play their part in achieving that. It's no more acceptable for TC to say "sorry, we don't care about small businesses" than the CRA, or IC. If it's government policy to care then - care they must.

If TCCA has the goal of "serving the public interest" - one way to fail to achieve that goal is to implement regulatory regimes that are so expensive to comply with that the public is left with much reduced choice in the market place. I'd like to see TC work on ways to reduce the regulatory burden from it's present level while maintaining proper safety. It's not acceptable to hear "this is the best it can be." It needs to be improved.

[robertw]

As mentioned above, promoting enterprise is not the mandate of TCCA.

Actually it is, by your own words above.

I'm not sure where you get this from. If you are taking "Efficient" and making it mean "Promoting Business" I think you are wrong.

To serve the public interest through the promotion of a safe and secure, efficient

The problem being that in the operations of TCCA "safe and secure" take way more precedence.

So you're saying that you'd rather have a system that caters more to ideals other than safety and security??? Yikes! Safety and security need to be top priority.

Of course the main way to achieve that is the "nobody moves, nobody gets hurt" principle.

I don't think we're anywhere near that in Canada.

From experience I've run into people in TCCA who's clear opinion is that small operators should largely be annihilated, usually by the same reason that "If it works for Air Canada, it can work for you" ignoring some of the obvious problems with that model. One might add that this model does not serve the public interest.

I don't think that there's any argument to be made that an AMO that services small Cessna's, Beech, Piper is going to have the same requirements as an AMO that services 737's, 767's etc... What will be the same (and what I've been advocating for here all along) is that both AMO's will have to comply with regulations requiring them to have a system of maintenance control that provides for a higher measure of safety than one would get with an AME working out of his truck. Both AMO's will have systems that will be scaled to what their capabilities are. This is what serves the larger public interest. When you talk about the current regulatory model not serving the public interest, reading between the lines what I hear is the the current regulatory model does not serve the operators financial interest, and you equate this with not serving the public interest.

Regardless, your helpful business advice ("Your planning sucks! Plan better!") doesn't help operators who were able to function profitably under previous regulatory regimes but who have been driven out of business by expensive changes imposed on them after many previously successful years. (I believe that's the scenario that kicked off this discussion.)

I see your point on this, but unfortunately times and regulations change in all industries. When they do and if they make your business no longer viable, you as the business owner have to make a change. Sometimes it means going out of business. I'm not saying that this is fair, but it is reality.

One might hope that one goal of government, overall, was to foster enterprise. Ottawa claims it to be so. It's reasonable therefore to expect all government departments to play their part in achieving that. It's no more acceptable for TC to say "sorry, we don't care about small businesses" than the CRA, or IC. If it's government policy to care then - care they must.

I think that TCCA has shown it's concern for the industry (as pointed out by PilotDAR)by allowing industry committees to give input while making regulations.

If TCCA has the goal of "serving the public interest" - one way to fail to achieve that goal is to implement regulatory regimes that are so expensive to comply with that the public is left with much reduced choice in the market place. I'd like to see TC work on ways to reduce the regulatory burden from it's present level while maintaining proper safety. It's not acceptable to hear "this is the best it can be." It needs to be improved.

Ok, I'm not an owner or operator, so maybe I don't understand what the excessive regulatory burden is here. I realize that going to an AMO will involve more labour cost than going to an AME. How much more expensive is it? Is this the extent of the "excessive regulatory burden"? Is there more than just costs that are causing issues for operators?

[photofly]

Ok, I'm not an owner or operator, so maybe I don't understand what the excessive regulatory burden is here. I realize that going to an AMO will involve more labour cost than going to an AME. How much more expensive is it? Is this the extent of the "excessive regulatory burden"? Is there more than just costs that are causing issues for operators?

Every kind of business difficulty comes down to cost, because (almost) every problem can be solved by throwing enough money at it.

But let me give you an example of how the AMO requirement might cause difficulty for a small operator. If you're going to maintain an aircraft or two for flight training or air taxi then you're going to have maintenance issues that crop up. You're really going to need to have maintenance available at your base airport. If that maintenance has to be done by an AMO then it means it's practically impossible to operate at any airport which doesn't host an AMO already.

There are 200 AMOs in Ontario. A chunk of them don't service "the public". Let's say 150 of them are open for business to fix your C172. (To be honest I think that's generous: lots of them don't do small planes, but never mind.) And lets assume (generously) that each one is at a different airfield. There are around about 600 aerodromes in Ontario. So three quarters of the airfields in Ontario are essentially out of bounds to flight schools and small operators.

How many AMOs are there at small grass-strip airfields? Not many, I bet. That means very few people get the opportunity to learn to fly the old fashioned way, off a tiny grass strip in a tail dragger. Certainly not everyone wants to, but there should be a way to give people that choice.

I don't see why there can't be an intermediate level of inspection and regulation so that a single AME - freelance, or employed by the operator - can't be approved to carry out maintenance. The FAA requires only that an aircraft used for flight training has 100 hour inspections. That's it. Nothing else.

On the subject of the difficulty of obtaining the paperwork for a new flight training unit, I hear this post, ringing in my ears:
http://www.avcanada.ca/forums2/viewtopi ... 39#p879178

At our tiny little FTU here, with a huge fleet of two 172's, after I was SIX YEARS of harrassment into trying to get an MCM approved, I wrote a letter to Transport, telling them to f_ck off.

I might not be too bright, but I hold an Engineering degree from Queen's University, two ATP's, two class 1 instructor ratings, an SAC for over 10 years, over 20 years experience instructing, and have been CFI and PRM at three different FTU's over the decades, and I was working with a retired three leaf (Lt-Gen) Air Force General who used to be deputy commander of NORAD ...

I told TC that if the two of us were unable to push the paper to TC's satisfaction for a tiny FTU, well, TC had a much bigger problem than us, and to come and take the fucking FTU OC away from us.

I would like government to help people earn money by being enterprising. I'm sure there's a way to do that while the right level of safety is maintained.

[Shiny Side Up]

So you're saying that you'd rather have a system that caters more to ideals other than safety and security??? Yikes! Safety and security need to be top priority.

Yes actually, safety and security don't mean a hill of beans if you can't get anything done. See the above NBMNBGH principle above.

Both AMO's will have systems that will be scaled to what their capabilities are.

This is where you're mistaken on TCCA's standpoint. There is no sense of "scale" within their thinking. In their eyes a 172 is the same as a 737, at the end of the day both will have the same pile of paper and require the same levels of manpower to oversee.

Is there more than just costs that are causing issues for operators?

Yes. The time factor has also. Which when one applies time=money means that costs aren't doubling, they're increasing exponentially. While everything comes back to money, the increase in time and manpower requirements has become to a crushing level. In some aspects there's just not enough qualified people out there to fulfill requirements. As PF gives in his example above, these issues have become quite acute in the flight training world, which from a longer view standpoint, is not serving the public interest. On that point one should say that TCCA really doesn't like little flight schools since they require the same work from them as a large flight school - on the point of scale - hence they'd be more than happy to see less but larger flight schools. From all aspects of regulation including aircraft maintenance. GA itself is viewed by a lot of TCCA as a burden on its own resources, right from little aerodromes, little planes, and small businesses. Mostly of course that's its own doing - remember that lack of a sense of scale.

I will say that my experience in the operations of a small uncontrolled aerodrome have been particularly poignant on this subject, where again TC frequently compares us to "this is the way its done at YYC". Much like my three airplane operation has to run like "Air Canada".

[AirFrame]

This discussion has become extremely interesting (at least to me) but it's completely off topic from the thread... Can one of the mods move it to it's own thread somehow?

[DonutHole]

This is where you're mistaken on TCCA's standpoint. There is no sense of "scale" within their thinking. In their eyes a 172 is the same as a 737, at the end of the day both will have the same pile of paper and require the same levels of manpower to oversee.

On paper there is no scale but in reality there is.

The pile of paper Joe bobs ftu has to generate is nowhere near the same height as air Canada. Yeah, you need the people and the manuals, but they are nowhere near as complex as a giant airline. the manuals for the Amo with ftu I worked at fit into three 2" binders... think they're that small at air Canada. so on paper no scale, in reality there is.

Yes. The time factor has also. Which when one applies time=money means that costs aren't doubling, they're increasing exponentially. While everything comes back to money, the increase in time and manpower requirements has become to a crushing level. In some aspects there's just not enough qualified people out there to fulfill requirements. As PF gives in his example above, these issues have become quite acute in the flight training world, which from a longer view standpoint, is not serving the public interest. On that point one should say that TCCA really doesn't like little flight schools since they require the same work from them as a large flight school - on the point of scale - hence they'd be more than happy to see less but larger flight schools. From all aspects of regulation including aircraft maintenance. GA itself is viewed by a lot of TCCA as a burden on its own resources, right from little aerodromes, little planes, and small businesses. Mostly of course that's its own doing - remember that lack of a sense of scale.

1 audit every five years isn't that much of a systemic burden and in reality, from what I have witnessed, they just don't care unless you're a problematic operator... and even then, they don't really care.

You keep talking about this sense of scale. Our last audit took six hours with two inspectors... why does that same audit take a week with four at the larger operator I worked at? They found (somewhat suprisingly) the same deficiencies at both operators but it took twice the manpower and time to find it. If there was no scale the audit would take the same amount of time.

The scale argument is a red herring.

I will say that my experience in the operations of a small uncontrolled aerodrome have been particularly poignant on this subject, where again TC frequently compares us to "this is the way its done at YYC". Much like my three airplane operation has to run like "Air Canada".

Faulty analogy. What does the operation of an aerodrome have to do with the paper push required for an ftu Amo other than creating a convenient straw man to present in your anti authority position?

I'm all for less paperwork for sure. But the creep will happen. Already the limits are pushed to the max, if we loosen the restraints those boundaries will be getting pushed. At some point in time we need to make a mark in the sand.

Besides, if the system your Amo has come up with is working properly everything is tracked and it doesn't take much to fulfill the requirements in the manuals. the maintenance release is still the same fifteen odd words but with the paper push comes real traceability, and most importantly protection for the ame who would otherwise be way out on a limb if he was a privateer.

[Big Pistons Forever]

I am surprised that no one has mentioned that we have a working example of a commercial air service with essentially no regulation, it is the Ultra Light industry. Considering the abysmal accident record of this sector of aviation I would suggest it is a cautionary example of being careful what you wish for.....

[DonutHole]

And on the other side we have completely (pretty much) deregulated Mx happening on a scale with great safety in the om world... yet the aircraft are worth pennies on the dollar.

[photofly]

but with the paper push comes real traceability, and most importantly protection for the ame who would otherwise be way out on a limb if he was a privateer.

Did you really mean that most important thing for you is covering the ass of the AME? And f*ck everyone else? There was I being led to believe it was all about safety for the passenger.

[DonutHole]

but with the paper push comes real traceability, and most importantly protection for the ame who would otherwise be way out on a limb if he was a privateer.

Did you really mean that most important thing for you is covering the ass of the AME? And f*ck everyone else? There was I being led to believe it was all about safety for the passenger.

well somebody had to clear up the impression that Amo's exist only to suck the life blood out of small operators.

I do the job the same whether it's a supercub or a king air, but as an Ame the paper push covers my ass, so yeah for me, as the guy who does the work I appreciate having my ass covered. That's why I like working under an Amo. The government has its own reasons for the paper push. I just know that if a regulation or requirement is there, I need to follow it no matter how much it costs or how loud the customers Bitch.

Being able to back up a logbook entry with actual documented procedures is a great way to shed liability when you're dealing with the Cowboys you find at the base level of aviation.

Just a question... what is your role in aviation? Are you a small operator or a private aMe? Or just some guy who flies planes?

[5x5]

Very interesting conversation. The one point that has been skirted around is the one-AME AMO. As Photofly alluded to, there are lots of airports with no AMO as there isn't enough business to support a big operation. This void is/was filled with single person AMOs. However, as the daunting (to a single person) level of paperwork wears them down, more and more are shutting down or retiring and new guys aren't stepping in. What's the benefit to them? Not only are they subject to all the challenges of an AME - unpaid bills, arguments over unnecessary mtce or repairs and the legal liabilities - they are now at risk of being shutdown by TC due to something lacking in the excess paperwork. Never mind the additional costs and hours over and above actually working on airplanes.

Does this person do better work under the mantle of an AMO than he would as a mere AME? What magic transpires through paperwork to make him diligent after the designation if he wasn't before?

Scale is very much an issue and TCs "one size fits all" approach is having a definite impact on the availability of maintenance services for small FTUs and OCs.

[Cat Driver]

Being able to back up a logbook entry with actual documented procedures is a great way to shed liability when you're dealing with the Cowboys you find at the base level of aviation.

Wouldn't you say that TC's dedication to safety is best demonstrated by trying to keep unsafe cowboys like the Colonel and me out of aviation?

How can one argue with that?

Keep us out of aviation and only let rules and paper work experts run aviation and safety is guaranteed.

[DonutHole]

What's driving Ames away from one person Amo'S Is the lack of business to support the model, not the paper push.

You don't need an Amo (unless you're doing specialized mtc) to service privately registered aircraft... and those small fields with no one person Amo, most of them don't have an operator that would require an Amo anyways.

Small operators aren't dying because tc is running them under with regulation and paperwork, they are dying because nobody is using small aircraft.

Why is this only a problem for fixed wing? I never hear this bitching from single helicopter organizations who have to set up their own amo. .. oh I know... they have work to do.

[DonutHole]

Being able to back up a logbook entry with actual documented procedures is a great way to shed liability when you're dealing with the Cowboys you find at the base level of aviation.

Wouldn't you say that TC's dedication to safety is best demonstrated by trying to keep unsafe cowboys like the Colonel and me out of aviation?

How can one argue with that?

Keep us out of aviation and only let rules and paper work experts run aviation and safety is guaranteed.

Safety is never guaranteed. There are a few Cowboys that need running out of aviation for sure, but as far as I can tell the only thing you and sanders are guilty of is lack of tact in the first degree.

But then again, I haven't audited your paperwork.

[Cat Driver]

But then again, I haven't audited your paperwork.

You never will.

You see it works two ways, I also can make personal judgements based on what people post here.

When I hire an AME I will hire someone who can repair an airplane, not a paper expert AME.

[DonutHole]

But then again, I haven't audited your paperwork.

You never will.

Fine by me. I have enough paperwork to take care of doing my own thing. That being said, I would bet your machines are always in tip top shape, same with sanders, that Maule was gorgeous, and you don't strike me as a guy that would put up with flying crap. Unfortunately, by necessity the regs are set up to service the lowest common denominator with an eye towards the fact that even then the lines will be pushed. I fully realize that what is safe isn't necessarily legal and what is legal isn't necessarily safe. Reconciling those opposing ideas into something I can live with has been one of the biggest battles of my journey Through aviation. Where you draw the line, flying or fixing is a personal test a lot of days and the margins are slim, but they are there.

I read the report on the colonels tribunal and through reading here I feel as if I have a more than passing grasp of the meat grinder they put you through. Neither of you deserved that bullshit and it's absolutely insulting to the rest of Canadian aviation that you guys were driven out.

Regulation should be there to drive out the actual cowboys, not the guys with the balls to stand up to small men with napoleon complex.

I'll see your edit (sneaky sneaky) and raise you one.

I fix the airplane first, properly, then I do the paperwork, properly.

guys that fix the paper airplane have been around forever. I worked for one of the best in that field and left because of it. See I'm not a guy who is afraid to sacrifice money for morals, and it's sad you've judged me as such.

I can do both. I can keep the planes air worthy and the books compliant. If that makes me a pariah in your eyes then I suppose That's okay with me, but it's too bad as I suspect we have more in common than in difference.

[Cat Driver]

Thanks:

I may have been a tad harsh there.

There was a time when there was respect and co-operation between TC and those of us who work in aviation.

The regulator has lost sight of that concept and now rule by power alone with zero accountability for their own actions.

The airport here in Nanaimo used to have a very active private aviation group, it is now the safest stretch of pavement to walk on in this area now because it is empty.

I used to own a fair sized aviation business here both fixed and rotary wing aircraft and my own AMO, there is no way I would even think of trying to run one now because of the cost to operate it.

[DonutHole]

No worries the auditing your paperwork comment was tongue in cheek, sarcasm doesn't travel well when converted to bits, and I had a feeling we were getting our wires crossed.

[Cat Driver]

The best example I can give of the way aviation is regulated today in Canada can be found in the Canada forum of Pprune.

There is a poster asking about multi engine sea plane training in Canada, I suggested using Randy Hanna here in Nanaimo.

Another poster suggested asking me to do the training.

That is not possible because TC will not approve of any training I do.

Now do you understand why I feel Canada is third world, regulatory wise?

[DonutHole]

I've watched two to inspectors walk by a literal pile of bogus parts and only find deficiencies in quality assurance paperwork.

I put them in the middle Of the floor so They would ask about them without me blowing the whistle.

I agree.

[5x5]

What's driving Ames away from one person Amo'S Is the lack of business to support the model, not the paper push.

Well, you certainly talk to different AMEs than I do. But maybe not, in that the amount of work you have to do actually fixing airplanes to pay for all the extra non-productive time doing paperwork (and consultants for developing manuals, conducting audits, etc) is part of the untenable business model I guess.

You don't need an Amo (unless you're doing specialized mtc) to service privately registered aircraft... and those small fields with no one person Amo, most of them don't have an operator that would require an Amo anyways.

If we're going to have a proper discussion, at least keep it real. Do you actually think I, or anyone else here, was suggesting AMOs are needed at the very small airports that don't even have a commercial operator?

Small operators aren't dying because tc is running them under with regulation and paperwork, they are dying because nobody is using small aircraft.

Not sure how many small FTUs you are associated with, but there are lots of them and many people are still taking flying lessons. And at most of the small airports they are being maintained by the one AMO that still exists there. And if that guy ever shuts down, they are really up against it.

[DonutHole]

What's driving Ames away from one person Amo'S Is the lack of business to support the model, not the paper push.

Well, you certainly talk to different AMEs than I do. But maybe not, in that the amount of work you have to do actually fixing airplanes to pay for all the extra non-productive time doing paperwork (and consultants for developing manuals, conducting audits, etc) is part of the untenable business model I guess.

? I've worked at a few small amo's its a myth that the paper push is huge. It's a bit hard in the beginning getting your manual through tc but once they're approved it doesn't take more time to make the entries...

If we're going to have a proper discussion, at least keep it real. Do you actually think I, or anyone else here, was suggesting AMOs are needed at the very small airports that don't even have a commercial operator?

So what you're really making is an argument for a one person amo on the fields where there's an ftu to service?

Supply and demand man, which is my point, there's no small Amo's because there's so few small operators (wwithout their own amo already in place)

What makes an amo unprofitable is lack of customers... which is what's happening to the ftus, a guy isn't going to keep his doors Open to service a fleet of three 172s, there isn't enough money there, with or without an amo.

How many planes does a guy have to work on to make a liveable wage if all he is doing is service? It's way way more than ten.

Not sure how many small FTUs you are associated with, but there are lots of them and many people are still taking flying lessons. And at most of the small airports they are being maintained by the one AMO that still exists there. And if that guy ever shuts down, they are really up against it.

I know a guy right now in that position. Know what he's doing about it? Setting up an amo. He's not complaining about it, he's stoked about it. Now he has another way to make money.

I know at least 10 guys working for 1 - 2 machine helicopter organizations, they never bitch about the amo, in fact they love having their maintenance done in house.

The only people I ever hear bitching in small airplane land are cheap owners and owners of ftus. The guys I know who service private aircraft don't have an amo because it is not required, and even then they're giving up because small aircraft just aren't a big enough market to survive on.

Of course there are the exceptions, but generally speaking one guy isn't going to bother working on aircraft at all if there aren't enough customers.

[5x5]

I know a guy right now in that position. Know what he's doing about it? Setting up an amo. He's not complaining about it, he's stoked about it. Now he has another way to make money.

Good discussion, but I'm having trouble making sense of the above comment. Your basic premise is that it's simple economics that's driving AMOs out of business. Yet you cite the above where an FTU owner (supposedly bitchy and cheap) is going to make money. How does that fit with the following quote?

The only people I ever hear bitching in small airplane land are cheap owners and owners of ftus. The guys I know who service private aircraft don't have an amo because it is not required, and even then they're giving up because small aircraft just aren't a big enough market to survive on.

I do agree that the maintenance work itself is no different for an AME or a 1 person AMO, but I strongly disagree that the overhead of the AMO once established, is negligible. The ongoing oversight and scrutiny by TC demands additional record keeping and administrative time that a one person shop has a lot of difficulty affording - both the time and the money.

[DonutHole]

First, quantify how much additional oversight by t.c. exists. I state that one of the Amos I worked for had a single audit in five years, it cost about 2k to fix the deficiencies, that's working out to a dollar a day to tc bullshit over the span of those five years.

It's the paper push at the beginning that is the big cost, I've heard between 5 to 20k to push the manuals through.

Computers make this stuff easy. Set it up and keep putting good bullshit in.

The cars are the same for everybody, bogus parts is bogus parts... The Amo is just the system you use to prove you're complaint.

The only time I've seen it get really expensive is when people get lazy. Keep up on your responsibilities and it's easy to be compliant, open up a paperwork clusterfuck and you deserve what you get.

Regarding the apparent contradiction. He is going to be into his amo for a little over 10k, but now he's paying an ame wage and saving a good deal (more than 50%) on shop rate by not outsourcing. That 10k is going to be paid off pretty quick. Also, not that there is another small operator on the field, but he will have an ame to service a field full of private ac, there aren't any privateers where I'm from.

The other place I see cost problems is in stores. If your stores system is screwed it can be very expensive to fix. I've seen stores departments create 10s of thousands of dollars in bogus parts... just shake my head.

If you're doing what you should be doing anyways via cars, the amo overhead isn't that much, if you don't have a good system, and this goes extra for private Ame's, then you're not doing it properly anyways.