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Case study: Transitioning to Part 43 - a decision made easy
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When the opportunity presented itself in the mid-1990s, transitioning to the new general aviation maintenance rules was a no brainer for a New Zealand (NZ) based maintenance provider.
Robert had owned and operated a maintenance organisation and held a maintenance approval -under the NZ equivalent of a CAR30 approval - for four years before transitioning and operating as an independent licensed aircraft maintenance engineer (LAME) for a further nine years. The business comprised 10 staff – two of which were LAMEs - who moved with him.
The decision to transition to the new rules was easy one to make. He had always held the view there were areas of the aviation industry that were less regulated than others and—for him—there was good opportunity to make money. Robert wanted to support those areas of business by providing maintenance services to freight, ag operations and flying schools. By simplifying his business and reducing his overheads, he was able to offer a service that other people did not. He didn’t need an approval to do this – under the new rules, he just evolved his business models.
“One of the things people need to understand about working under Part 43 is that it doesn’t open-up a freelance environment to enable a LAME to work without controls and structure,” says Robert
“In fact, Part 66 as far as my maintenance licence was concerned had a well-defined structure around it.”
What appealed immediately to Robert was Part 43 really opened-up the scope of the aircraft and systems that he could maintain, particularly the expanded avionics privileges. In a lot of cases an avionic, electrical rated (our B2) LAME was hard to come by – employing people with that skill set was not easy. If he wanted to cover off the electrical instrument and radio work, he could bring an Avionics (our B2) LAME in when required. His LAMEs were all rated either airframes or engines.
When Robert operated as a certificated organisation, he did not pursue any work with instrument flight rule (IFR) aircraft because he simply didn’t know whether the additional work would support the additional costs of setting up for IFR maintenance. After Part 43 came into effect in NZ he could still do an inspection on an IFR aircraft and only needed the services of the avionics LAME when defects were found with the instrument or radio systems.
Under the new rules Robert took on a lot more work than he’d previously taken on under the previous rule set. Even to the point where his business was doing quite complex avionics installations where they would complete all the mechanical aspects including installation of a prewired harness—if available—and then it would be handed over to an avionics LAME for final checks and certification. They would simply do the connections, slide everything into the rack and then test it all within a day.
If he needed to use specialist test equipment or if the transponder was faulty his airframe/engine LAMEs would pull the transponder out and slide another one in. If that didn’t solve the problem, then the avionics LAME was called in. He also had the flexibility under Part 43 to defer the avionic and radio sections of the periodic inspection and then the operator could fly the aircraft to the avionics LAME (B2 equivalent) and get the periodic inspection completed for final certification.
The new rules didn’t require Robert to have any insurance coverage, it was a personal decision as to whether he purchased hanger keepers’ liability insurance. When he transitioned the business to Part 43, he wasn’t the only organisation doing so at the time. The insurance underwriter told him the way to manage this was for him to identify who his licensed engineers were – if one of his engineers left the business or someone new started Robert was to let them know about the change. There were some set parameters around the business’ scope of work and its total turnover - if his income increased it did affect the premium.
“As I employed more LAMEs and my turnover quadrupled, the cost of my insurance premium increased. This had nothing to do with the introduction of Part 43 or the impact the new rule set had on the maintenance environment – it was purely because I grew the business”.
If you want to operate in a manner that allows increased flexibility, enables you to pursue new business opportunities as they arise—while keeping with the maintenance standards and safety required for certified aircraft— and work in an environment where you have a high degree of autonomy about your future, then Part 43 is made for you.
It is absolutely tailor made for a LAME that wants to go out on their own and do something for the private and aerial work sector without having to risk large set-up costs.