HB/GE,
Thanks a ton for the input. I believe HB nailed it also. I went through the application for exemption 33 to test it (did not submit) and, while it appears it would get to the correct department, it doesn't seem to explicitly cover the temporary invalidation of COA due to maintenance issues. If you look at the attachment below for example, is a copy of the form used by Turks/Caicos and is similar to other countries. It specifically asks for the details of why the aircraft is unairworthy and what has been done to verify 'safe for flight'. Regardless, I think this would work and I thank you for your sleuthing. I could not find that.
For the D084 discussion, the way it works in the US if the flight becomes un-airworthy for an item (overfly an inspection, placard missing, radio inop, missing medical kit, minor damage slightly outside limits etc) that our maintenance team determines does NOT affect the safety of flight, then we can authorize the flight with
no further discussion with the FAA under our D084 OpSpec approval. We have our own authority to authorize the flight as long as we follow our approved procedures. This allows us to quickly move the aircraft for repair without having to wait for a response from the FAA and the subsequent adding workload to them for minor issues. Keep in mind this only applies to specific items. Other items not within our approval require a direct contact via an FAA form 8130-6 to gain direct approval (8130-7)from the FAA for the Special Flight Permit, which is (as HB pointed out) covered in FAA order 8130.2J.
HB mentions that the CAA would want to see the documentation and in the case of the 8130-7, we would have it from the FAA. For the D084 continuing authorization, we have our own documentation and release, but it is produced by our own maintenance department without FAA input.
My second question was "Would the CAA allow a continuing authorization under our own approval, similar to US for overflight of UK airspace?" I would love to chat with the CAA as HB suggests, but have not had a response in over a week. I suppose I could fill out the application, pay the fee and then simply ask my questions on the application and see the response.
Perhaps if anyone knows a CAA airworthiness guru I could cover all the pints and have an informal roundtable discussion on my next LHR layover!
Thank you again for your time gents!
AM