CAMO is cancer, General Aviation is dead

CAMO concept is cancer. General Aviation is dead. Aggressive cancer destroys it across the world. I'd argue that even for airlines, this so called CAMO concept does not address actual issues of continued airworthiness it was intended to address. Some people just don't realize it yet.

In a nutshell:

  • Owners are FORCED to surrender complete and total control over the VALUE of the asset is given to a third party (CAMO), who is not known to the owner of the asset, and subsequently there is NO guarantee that the value is going to be preserved;
  • CAMOs protect only their own interest - if there's any conflict, they will never protect the owner/operator interests, instead protecting themselves from the Authority (or anyone else);
  • If you (as owner/operator) really need something (adding an aircraft, writing a MEL, doing an airworthiness review, embodiment of an STC, etc.), you are at a mercy of "someone else" (CAMO) - they'd do it as it fits *them*, not you, and they *never* rush (there are weekends, holidays, wifes, kids, etc.);
  • They cost a lot every single month, even though little work is done:
  • a) Maintenance planning is done by the owner/operator anyway (based on printouts from tracking systems, for which CAMO doesn't spend a single minute).
  • b) If maintenance is done (for example, a GA owner flying just 120-150 hours a year, it would typically be 1-2 times a year), all CAMO guys typically do is send it to CAMP technical analysts. Though, even if some of the do check it, it takes just a few hours A YEAR.
  • c) 120-150 hours year means 50-60 flights, even less flying days, so say 30-40 TLB pages. How much time do you think it would take A YEAR to enter it?
  • d) there's other work, like dealing with MEL open items, etc. BUT…
  • ...do you think that kind of work cost 1500-2500 or more EUR a month? For such an amount, people work 8 hours a day, 5 days a week, doing hard work.
  • Process to get CAMO approval is designed in a way that it takes at least 6 months to complete, all this time one would have to pay people (for nothing). 6 months to read a standard template Requirements are designed in a way that only a handful of people can fulfil. People who often doesn’t exist.

This is understandable to some degree, as regulations require a lot of moving elements in a CAMO, people employed, and people typically want money every month. So, requirements say have a lot of people, but in reality, people run idle.

YET with all the CAMO overregulation, requirements, audits:

  • MOST IMPORTANTLY, ALL THAT does NOT in ANY WAY change or improve ACTUAL engineering work (reading maintenance records, page by page, reading documentations, understanding ADs, SBs, determining the truth on the ground like correct PNs and SNs, sometimes going deeper than just looking into Cescom 10 component list (!), talking with mechanics and many many other things, which are not even mentioned in CAME!) - people are the same, worse, as their heads are filled with irrelevant training (think SMS and human performance and limitations).

  • I have found so much f**ked up aircraft records when doing initial airworthiness review after getting documents from an approved CAMO that I can't even count (no records in airframe/engines' logbooks, unneeded inspections costing A LOT of money, MISSING inspections, components OVERDUE OR VERY expensive components replaced WITHOUT A NEED!) No CAME, SMS, audits can teach discipline!

  • For a lot of manufacturers of light/midsize jets, things are done in systems like CAMP, which provide so called technical analysts (guys who take papers you send them, published ADs, SBs, AMM/EMM changes, and do changes in aircraft tracking status among other things), who do 95% of *actual* work, and that's a problem because:
  • a) CAMO employees DO NOT really check the work done by such analysts, as it would essentially mean double work, why work if you don't have to (apparently)?
  • b) CAMP is NEVER a part of any real CAMO audits (iaw CAME of an actual CAMO) as it's considered just a tool. And I am not offering to have CAMP really audited, if you had that thought, then that's the problem, right there.

  • Things listed above are masked and sometimes impeded by the formal processes, and tons of papers, which have little or no sense - size of the administrative machine required does not match the size of operation (at all), which adversely affect actual operation, and in the end makes it ECONOMICALLY UNVIABLE. What took 1 day before now can take 10. Every day on the ground costa A LOT of MONEY.

  • People, who are actually experienced, but without formal papers (didn't have time to raise their heads while working), are no longer allowed to take official positions. YET CAA staff, while also having formal requirements, most of the time DO NOT meet such requirements! Some who meet format requirements do not have experience, and we all know that experience in such matters is the main thing.

Nobody bothers to justify these regulatory changes with some kind of real measurable KPI. (We can also talk about safety indicators in an SMS for an operation with less than 3 aircraft, yes?...) So everything that happens after is a big lie. They say "safety improved" without any research that it's their new regulation, which made the change. CAMO concept does NOT have any grounds. And there are samples where life on a much larger scale is quite happy without it (surprise, FAA and some others).

CAMO concept is just a part of the whole picture. Every other part is becoming alike:

  • Maintenance - prices balooning (different reasons, some greedflation, a lot of overregulation, which stiffles their processes, inflation of part prices, lack of qualified engineers, etc.). I once got a quite of 150 000 USD (yes, 150k) for a single C550 wheel assy.
  • Ground handling - proces balooning like crazy (here it's just greed, as a result of envy - well known gaskets, so called agents, who don't do any actual work, mail forwarders, just add thousands to invoices, handlers started wanting a cut, but it's a common knowledge that there's a severe lack of staff due to increasingly lower pay, lack of equipment), while actual service is in nosedive. Have you heard of a 160 EUR coffee in Spanish airports?
  • ATC services - while we suffer from CTOTs with no apparent reason (they cheat, further you go west - they often declare weather and staff shortage whereas there's no weather, etc.), prices are exorbitant. Nobody wants to resolve staff shortage, yet they don't forget to collect funds. Why there are no discounts for CTOTs? Got one for an hour, minus 2 hours from the invoice! Things would normalize quickly.
  • Other regulations - all costs a lot of money without any actual increase in safety (as there was no decrease in the first place), and without any increase in income.
  • Brokers is another aggressive cancer severely distorting the market.
  • Known training providers (FFS) are in reality a duopoly. They just multiply prices every year by some factor (and I am not exaggerating, I have facts), it's just pure greed. Services are again going down, nobody is analysing what is actually needed to make it effective.
  • A lot of other smaller things...

Worst thing is that a lot of CAA people don't even realize it, they are happy to go into that trap, they love EASA, love ATFM (even when country-speficic situation screams "no!") . Well, it's too late when smartest of them realize... And currently, there's no way back.

RESULT?

People who would otherwise go for their own aircraft (bigger than a C172), simply CAN'T do it. People who are still in are in the process of going out or at least seriously considering it.

Whole industry is feeding of a small number of UHNW individuals, the pool that is currently drying up. These guys realize they are milked, or currently exiting the UHNW status... :)

Industry has no incentive to work for volume (and hence lower individual prices). Little innovation is happening (if you think adding more touchscreens to an aircraft is innovation, you better go get some real experience to make a judgement, and no other real innovation is happening, same FADECs, same wings, ideas from 70s and 80s like smart winglets). Things are on manual control, not evolving naturally, feedback loop is broken. It used to take PWC JUST ~4 years to develop and bring to market the PT6A, a completely new design. Nowadays it would most probably take at least 10 years if not more and some 10B USD, hence impossible.

There was a General Aviation boom (both piston and light jets) many years ago, it was mostly OK until beginning of 2010s (when EASA expanded and accelerated their toxic approach to everything - 90% of its workforce is NON-aviation professionals without any aviation-related education and/or experience), but with all this bullshit we are seeing now and in front of us - another boom will never happen again. NEVER. GA GRAVE IS READY, just awaiting for the corpse. Airlines will follow (even guys like Lufthansa are now crying), because history teaches us that such things ALWAYS happen BOTTOM UP, not the other way around. With the only exception - military innovation, which almost always just stays military.

Gents, I spend 90% of the time writing different kind of documents (OMs, MELs, AMPs, filling applications, etc.), which nobody EVER READS! Or if they do sometimes read, find stupid issues like missing commas and wrong TOC. Instead of DOING REAL WORK (flying, training pilots, etc.)

#saveGA #saveAviation #repelCAMO #startThinking #getBackCommonSense
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