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  1. #1
    Captain Randombloke's Avatar
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    Orphaned microlights - the rules and process

    Quote Originally Posted by Paul Dewhurst View Post

    First thing here to realise is that itís CAA who make the rules - the associations have approval to administer the processes and are audited by CAA to make sure they are doing that in strict accordance.
    The CAA make the rules but sometimes they're not sure what rules they have made or who actually is running the show.

    When I wrote the e-mails published in MF this month, I received a mail back from Rob Hughes that assured me that:

    "The tech office has a CAA-approved system in place for dealing with orphan aircraft. Clearly, an orphan aeroplane is not going to be as easy as one supported by a commercial entity but the tech office deals with orphan enquiries as they arise. The P&M situation does risk an increased number of enquiries and the tech office is ready to respond. So far CAA has not declared P&M aircraft as orphans but already we are prepared for this."

    I therefore asked the CAA via a FoI request to provide me with the the information thus:

    The CAA has an approved system for dealing with orphaned permit to fly microlights which it has agreed with the BMAA and LAA.

    An orphaned microlight is one where the holder of the airworthiness approval (either as a manufacturer or importer) has gone out of business and no other organisation has stepped in to take up the necessary support for the aircraft in question.


    Please may I have a copy of this approved system or method.

    I was told by way of reply:

    Thank you for your email. The CAAís General Aviation Unit have reviewed your below request and they have suggested that you would be best to contact the British Microlight Aircraft Association (BMAA) as it is a process initiated and managed by them rather than the CAA.

    This seem to contradict Rob Hughes, so the there was a need for clarification.

    I replied that there was going to be a rather big debate about this in the post P&M demise period and asked them to check their facts.

    Two weeks later I get the following reply, rescinding effectively the previous one:

    Having considered your request in line with the provisions of the Freedom of Information Act 2000 (FOIA), we are able to provide the information below.

    The approach we take is detailed on the CAA website at http://www.caa.co.uk/General-aviatio...phan-Aircraft/. This includes reference to CAP562 Leaflet B-90. An assessment will be carried in accordance with the principles of this Leaflet on a case by case basis.


    For the UK specification factory built/amateur built microlight aircraft, this would be determined in association with the BMAA/LAA who hold CAA approvals. The BMAA and the LAA have their own generic approach for dealing with amateur/homebuilt orphan aircraft, however in most cases the BMAA or LAA propose a set of procedures bespoke to the circumstances involved; this is in turn is reviewed and accepted by the CAA. Thereafter the BMAA/LAA would take the responsibility for the day to administration of the type, subject to CAA continuing oversight.

    As an example. the BMAA has published their generic approach to ďOrphan AircraftĒ as a technical information leaflet on their website: https://www.bmaa.org/information-lib...rmation---tilsĒ.


    This seems to be an organisation with so many rules it doesn't even know the length and breadth of all the rules it has, makes or is responsible for. In contrast I have had direct, simply to understand and correct answers first time from the Tech Office on the questions they have been asked, either directly or the enquiries Rob Hughes has made to clarify things from his point of view.

    It turns out Rob Hughes got it right first time as a volunteer but the professionals didn't.

    I'm hoping to discuss the general state of the orphanage problem without it being too much of a discussion about any particular manufacturer.

    The big question is:

    Who do the complex rules that Paul refers to serve? What are they there for? Not us, the pilots of orphaned aircraft. The overall administrators can't even get them right first time.

    I have now started downloading the linked masses of CAA paperwork in parallel with the BMAA documentation on the same.

    On the CAA side, all I'm seeing is a pile of red tape that someone made a career and probably a good living out of writing.

    The outgoing Chief Technical Officer thinks that the orphan procedure is a mess.

    However, the Tech Office needs to implement it to CAA satisfaction for the oversight to agree it, and for the delegation to remain in place, it's therefore time we all learn this pile of rules so we can look at ways to consigning them to history.

    I'm planning some Winter reading, until then there's a Summer and paragliders and microlights to fly.
    Steve U.
    PG, HG & microlights
    "Weekend bimbler, day to day car driver & genuinely undeserving Southern oik who has never done anything of any worth"

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  3. #2
    Test Pilot Paul Dewhurst's Avatar
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    What complexity is bothering you Steve, and what do you suggest for simplification?

    The act of classifying whether a type is an orphan can be bothersome. The Eurostar just now - not easy to get any parts out of the UK agent - but he has the approval, so we are stuck, and canít buy direct from the manufacturer or other countries agents.

    But once a type has been orphaned my impression having worked with it is the process is fairly logical - define the part - materials, construction and dimensions and processes. Agree that. Make it to that. Show invoices for materials, inspect it, fit it, approval issued.

    The challenges it it seems to me are:

    defining the part and material without access to the original drawings.

    sourcing the correct material

    getting material economically - in small enough quantities.

    the orphan system being for individual parts manufacture - if it gets industrialised then it falls into requiring a company approval.

    peoples expectations - often they act first without researching the approval aspect, then it gets all messy trying to do it after the fact - makes a big chore for tech office, and often the owner is all grumpy at that point and thinks itís all ridiculous and blames BMAA.

    Clearly it being a lot more work to make it yourself / organise manufacture than just buy and fit. For a lot of owners itís just too much hassle.


  4. #3
    Co-Pilot Wexfordair's Avatar
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    from my outside view it seems the easiest answer for orphaned aircraft is to remove them from any regulatory oversight, akin to SSDR. But then how do you ensure that they are up to a minimum quality and not going to break up?
    Isnt that what having modification approval and permit inspections are about in the first place. So then its about making that process much easier and less expensive, but what fat is there left on these bones to remove?
    Who ensures that the passenger is legally safe?


  5. #4
    Captain Randombloke's Avatar
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    Quote Originally Posted by Paul Dewhurst View Post
    What complexity is bothering you Steve, and what do you suggest for simplification?

    The act of classifying whether a type is an orphan can be bothersome. The Eurostar just now - not easy to get any parts out of the UK agent - but he has the approval, so we are stuck, and canít buy direct from the manufacturer or other countries agents.

    But once a type has been orphaned my impression having worked with it is the process is fairly logical - define the part - materials, construction and dimensions and processes. Agree that. Make it to that. Show invoices for materials, inspect it, fit it, approval issued.

    The challenges it it seems to me are:

    defining the part and material without access to the original drawings.

    sourcing the correct material

    getting material economically - in small enough quantities.

    the orphan system being for individual parts manufacture - if it gets industrialised then it falls into requiring a company approval.

    peoples expectations - often they act first without researching the approval aspect, then it gets all messy trying to do it after the fact - makes a big chore for tech office, and often the owner is all grumpy at that point and thinks itís all ridiculous and blames BMAA.

    Clearly it being a lot more work to make it yourself / organise manufacture than just buy and fit. For a lot of owners itís just too much hassle.
    You've outlined some of the complexities yourself better than I could. You have an incredible backdrop of knowledge, and you can navigate this, as you are familiar with and understand all the rules.

    Others don't and will just do it on the quiet, and hope no one finds out, or give up and sell the aircraft on for parts, as there will be other owners also struggling.

    However, there is that fundamental question that is more important that being able to jump through the hoops.

    Why are the hoops there in the first place? Who are they there to serve? Until we answer this question, we can't look at the technical proportionality of them.

    Have they now ceased to work and are they having effects that were not intended, grounding aircraft rather then helping them to continue to fly safely?

    I'll be answering your question about exactly what needs to change when I've read through the mountains of dross on the subject, but what I would say, having come from aviation sports that are relatively new, there is a big advantage to a clean sheet of paper.

    The system we have has just grown up over the years, with so much baggage.

    I agree that the BMAA gets wrongly blamed, the technical side of this is simple, the Tech Office have to comply with the rules, and they make it as painless as they can for us. However, I'd like to see a bit more of the BMAA that got us SSDR finding a way to slacken things off a bit for two seaters.

    Quote Originally Posted by Wexfordair View Post
    from my outside view it seems the easiest answer for orphaned aircraft is to remove them from any regulatory oversight, akin to SSDR. But then how do you ensure that they are up to a minimum quality and not going to break up?
    Isnt that what having modification approval and permit inspections are about in the first place. So then its about making that process much easier and less expensive, but what fat is there left on these bones to remove?
    Who ensures that the passenger is legally safe?
    There's a simple answer to this. The CAA isn't that worried about the passenger, they're worried about how much they are considered to be in control of the process, and how good a job they are seen to be doing.

    There is a large amount of fat to remove. Look at the system under which the whole of Europe certifies tandem paragliders. There are dual HG & PG, and they are deregulated with voluntary airworthiness. Why aren't we all dying like flies?

    The paraglider is presented to a test house. The test house tests the paraglider for load and flight characteristics. Details of materials are passed to the testing house. There is some material testing for fatigue. When the glider passes, the manufacturer undertakes to use the certification sticker only on examples with the exact dimensions and materials, within tolerances.

    Repairs are made using the materials listed in the parts list. They can be done by the manufacturer or any repair business. The repair businesses have some sort of internal audit, like an ISO, as do the manufacturers. However, it's just cloth and lines, and the lines are available direct from the line manufacturers.

    So, it's slightly more complicated for a hang glider/flexwing, but just as in the paraglider example, the manufacturer makes stuff to what they have certified. When the business fails, or is sold on, the new company again takes on the agreement to make stuff to what was certified. This was how Avian Hang Gliders took on the Aerial Arts Clubman. Steve Elkins decided he wanted different tubing and cloth, so he recertified to the BHPA CoA for HG. He sold the business to Tim Swait, who makes stuff to what either he or Steve Elkins certified. Now, a flexwing microlight has the same hang glider wing, they are children of the same father. Notice the words CAA or any other oversight has not been mentioned.

    With the exception of Germany, no European country has ever seen the need for the CAA style oversight for free flying. There are far more paragliders flying in the UK than BMAA microlights. Maybe less than BMAA/LAA combined, but the numbers are huge in Europe. The world's biggest flex wing manufacturer is able to run a business without CAA oversight. Maybe that's why that country has 4 flex wing manufacturers still.

    My proposal would be something along the lines of orphaned aircraft spare parts being self certified by the new spares parts manufacturer. We might start with the BMAA/LAA making sure that the manufacturer had bought/obtained the drawings or had in some way come up with a process that copied the parts sensibly, but after that, we'd let them get on with it. The manufacturer would just declare that they had made the parts to the original spec or to a similar spec but with a one off check with the BMAA, then replicas made of that. There would be no approval process outside that.

    This is not that far off what we are doing now but having to do paperwork for each replacement, or go through an expensive approval process.

    After a trial period with minimal oversight, we'd remove it. The gold plating applied to these matters doesn't prevent crashes. Even with no oversight, when I was BHPA Airworthiness Panel co-ordinator, the vast majority of incidents were pilot error. My investigations only covered a tiny proportion of all incidents.

    The maintenance intervals for paragliders are voluntary. They are adhered to. No tandem pilot wants to be standing up in court telling everyone that the passenger was injured because they saved £150 for a two yearly check up. No manufacturer of spare parts wants to be in court for manslaughter or negligence. That's the real deterrent.

    In the early 1990s we had a lot of debate about the hang glider and paraglider certification standards, and how the rival standards failed to serve the pilots they claimed to protect.

    I made a pile of all the paperwork, read through it all and and wrote it up for the magazines with an interest. The first comparison on paragliding standards took three months to finish, and on hang gliders eighteen months including getting it translated. I'm still involved with the paraglider one and about to join BSI as an expert on the same.

    I can see I'll have to do the same with the CAA stuff, and there is a huge mountain of interlinked, badly written stuff starting with Section S. I say badly written because the newer airworthiness standards have simple pass/final criteria or criteria for grades of pass, where as Section S is very, very "wooly".

    It can wait until Winter, though. We need to educate ourselves to argue our case because I can't see anyone arguing it for us. We just accept what we are told, because we haven't read the documents we're being told about.

    Your role models are Aneurin (Nye) Bevan or Martin Luther. The stuff needs to be nailed to the door.
    Steve U.
    PG, HG & microlights
    "Weekend bimbler, day to day car driver & genuinely undeserving Southern oik who has never done anything of any worth"

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  7. #5
    Test Pilot Paul Dewhurst's Avatar
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    I think you are mixing up a hell of a lot of stuff Steve - section S is not relevant to orphan aircraft repairs - so set that aside please ( and actually having worked with all the other codes around Europe for microlights I think I you are wrong - but thatís for another time)

    On one level the orphan aircraft parts procedures are there to help the owner. Having an experienced technical team and inspectors to help you is a great boon. There are very few owners with the technical expertise to go it alone. And thatís what the procedures are designed for.

    What they are not designed for is approval of companies making stuff industrially.

    That falls under CAA approval. There are different levels of that - and parts manufacture is the simplest one. But still has to use CAA time and charges. And CAA are much more geared to certified aviation than microlights with blokes drilling tube and swaging wires. So it takes a strong business case and some knowledgable and tough individuals to go down that path.

    The CAA has been talking about investigating deregulation of microlight manufacturers and giving it to BMAA and LAA to accept individuals / companies. But thatís a bit of a poisoned chalice to define and insure for and will inevitable end up with sets of procedures not dissimilar to what is there now. But hopefully with a lighter and more pragmatic touch and lower fees.

    But like all these projects it wonít be quick to make any progress - Brexit is stalling everything just now ( just had an email
    Saying the 600kg project is being delayed because of it and CAA overwork).

    A simplification of manufacturing approval has been pushed for by BMAA for well over a decade. I waited patiently but decided that we needed to just get on with it and get the A8-1and A8-9 approval for Flylight before we all reach retiring age..

    So key thing in the first instance is that if we have a big demand for orphan parts that the processes are streamlined as much as can be under the current legal restraints and there is lots of info out there so itís as clear as can be and owners donít fall into traps of ignorance of what needs to be done.


  8. #6
    Captain MadamBreakneck's Avatar
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    Quote Originally Posted by Randombloke View Post
    ... snip... or give up and sell the aircraft on for parts...
    Now there's a business model: buy up all those permit-failed orphaned hangar queens, strip 'em down, and sell the serviceable parts as spares. OK, to stay legit there's the minor matter of TIL058 paperwork to look after and suitable storage and cataloguing of the parts, but I'd warrant that there's a small business to be had for an interested individual or group (a type-operators' support group comes to mind).



    Back to just bimbling in the TST.

    No longer instructing - just pontificating..
    and now a Tai Chi instructor


  9. #7
    Captain Randombloke's Avatar
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    Quote Originally Posted by Paul Dewhurst View Post
    I think you are mixing up a hell of a lot of stuff Steve - section S is not relevant to orphan aircraft repairs - so set that aside please ( and actually having worked with all the other codes around Europe for microlights I think I you are wrong - but that’s for another time)
    I know it's not, but it's just an example of the huge pile of interlinked rules.

    Another example:

    If you follow this link to the CAA policy on orphanage:

    http://www.caa.co.uk/General-aviatio...phan-Aircraft/

    it links to CAP 562, which then links Issue 8, Amendment 1 of BCAR A, and so on. I've got six or seven PDFs to read on that issue alone via links and backgrounders.

    On one level the orphan aircraft parts procedures are there to help the owner. Having an experienced technical team and inspectors to help you is a great boon. There are very few owners with the technical expertise to go it alone. And that’s what the procedures are designed for.

    What they are not designed for is approval of companies making stuff industrially.

    That falls under CAA approval. There are different levels of that - and parts manufacture is the simplest one. But still has to use CAA time and charges. And CAA are much more geared to certified aviation than microlights with blokes drilling tube and swaging wires. So it takes a strong business case and some knowledgable and tough individuals to go down that path.

    The CAA has been talking about investigating deregulation of microlight manufacturers and giving it to BMAA and LAA to accept individuals / companies. But that’s a bit of a poisoned chalice to define and insure for and will inevitable end up with sets of procedures not dissimilar to what is there now. But hopefully with a lighter and more pragmatic touch and lower fees.
    And it's the CAA approval that's killing it. You can look at the processes run by the likes of Gin and Ozone in factories in world wide locations. That's how to make and maintain affordable aircraft. Or Wills Wing. Or Moyes. They build to a simple certification model. Their own reputation at stake and the internal oversight they provide is more than good enough. They know the product, not the guy with the six figure salary in the South of England killing the product with no added value.

    We're trying to offer affordable aviation.

    The acid test is that we took single seaters out of this. Are we seeing a problem from lack of oversight?
    Steve U.
    PG, HG & microlights
    "Weekend bimbler, day to day car driver & genuinely undeserving Southern oik who has never done anything of any worth"


  10. #8
    Trainee Pilot Mick Broom's Avatar
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    The acid test is that we took single seaters out of this. Are we seeing a problem from lack of oversight?[/QUOTE]

    I wish you luck in your efforts Steve on this one , something the BMAA should have sorted years ago.
    I can confirm that the orphan system which on paper is fine , in practice it did not work for me. When the Shadow was orphaned I obtained the original drawings with the approval submissions , these were updated to a Cad drawing for the newer CNC machines and submitted through the BMAA.
    You cannot get any easier than that when producing parts to the original specification, we still required to submit and get a signature from four independent persons of different abilities and fit as a mod. We eventually got bored with it all and signed them off as from donor planes as it was easier.
    When the new undercarriage which was classed as a series modification was made it required 37 signatures before it left the workshop and was passed on to others for approval.
    The system is geared for commercial operations and not the cottage industry we have and nobody has come up with a justification on safety grounds which is what its all about at the end of the day.
    Make the supplier responsible for the part or machine as fit for use by the end user and cover it with spot checks when thought necessary.
    End of problem
    My suggestion would be to bring in this change on a maximum weight stage by stage and monitor the result but as Steve says with the single seaters the signs so far are very good and that's without any oversight.
    Keep it simple

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