12 year engine life farce

[stuartforrest]

I am in the process of putting my Bonanza onto the G Reg and have been told today that my engine will need to be replaced because it is twelve years old although it has only done 600 hours so is nowhere near TBO.

This is apparently because the Bonanza is now an EASA aircraft and the new EASA rules specifiy that the engines must be replaced at 12 years or tbo whichever is sooner.

To say I am shocked and p**sed off is an understatement. How did my engine get less safe because it passed the 12 year old mark I will never know.

I have spent hours tonight on the EASA website trying to find details of this regualtion which my maintenance shop think is applicable. Can anyone here help point me to where I can read about this.

Easa (http://www.easa.eu.int/home/index.html)

[Cyclic Hotline]

Are you sure it isn't a Manufacturers recommendation, that is being mandated by the register you are moving the aircraft to?

I seem to recall a 12 year "recommended" TBO for these engines, which may well be were this is originating.

Edited to include the answer.

In answer to my thoughts above, see this Service Information Letter (http://www.tcmlink.com/serviceBulletins/pdf/sil98-9.pdf) which does indeed specify the manufacturers "recommended" TBO of 12 years.

[stuartforrest]

Only thing is that the document you have pointed to was dated 1998 but I know this limit didnt wasnt mandatory to CAA Public or Pivate CofA's and apparently only now has come in under EASA. What I want to know is where in the rules it says this.

Can anyone help?

[Flyin'Dutch']

Can anyone help

Oh dear, you're not having a good time with reg swapping.

Consider leaving it on the N until you either have to change and then flog it to the States.

[stuartforrest]

Yes I have thought of that but then that begs the question of whether it is worth doing that either because I have not got an FAA IR and I cant see my finding time to do it in the next couple of years due to work and children.

Also I am not sure it would be worth it given the seemingly inevitable charge to ban N Reg ops in the UK which is a different debate.

Does anybody know about EASA and this engine life rule. Please help?

[robin]

There was an earlier thread on another forum which implied that for 'Private' use the time limit did not apply. Not sure if this applies to new registrations though.

http://forums.flyer.co.uk/viewtopic.php?t=9315

[justsomepilot]

Stuart,

I've come across the same problem recently, on a G aircraft, and while it was not on an engine it was concerning the previously-optional and now-under-EASA-mandatory overhaul of a certain airframe component.

As nobody had previously overhauled this component (no need to, ever) the manufacturer has never bothered to produce the right parts for the overhaul. Now, suddenly, a number of owners are stuffed with having to do this completely unnecessary job.

You should have stayed on N. Why did you go N originally?

If you have the IMC Rating and are a good current instrument pilot, then (having first passed the IR written in the UK, a few months' revision for a family man like you or me who can spare little time) you can get an FAA IR in Florida in 2 weeks max. With the right training over here (plenty of freelance CFIIs about) you can do it in a Monday-Friday session. YOU'VE GOT TO DO THIS CR@P ONLY ONCE PER LIFE and then you will have fantastic privileges, worldwide.

And if you aren't flying much then a transfer to N never made sense; N is more expensive than G on practically every maintenance front. N is for high-time pilots who use IFR to go places.

It also doesn't make sense to go N to G just because you have bought into the fears exactly as certain parties want you to do. In the unlikely case the DFT finds a way to kill off N, they will have to give everybody plenty of time. THEN you can go back to G, or sell the aircraft to somebody outside the UK.

There is no way all of Europe will ban N unless EASA do it and that would take years. Their latest proposals are actually not to ban N but to subject it to EASA maintenance requirements. But EASA is gradually taking FAA certification on board anyway, much to the CAAs disgust.

[ABCX]

There seems to be a lot of myths being passed around regarding EASA. For private operations EASA are currently only responsible for certification issues. Maintenance stays with the CAA until 2007/2008, when EASA Part M comes in. Even than there will be few changes to the actual maintenance requirements.

With the exception of changes the AWN 75 (Prop inspections) there have been no changes to maintenance requirements because of EASA. There is no extra work or overhauls to do because of EASA.

Stuart
If your engine meets the requirements of AWN 35 (Piston engine O/H lifes), which I think it does based on the information supplied, there is no reason why it should not go G-

[QDMQDMQDM]

Isn't this something to do with crankshaft corrosion / cracks in Lycomings over 160HP?

QDM

[stiknruda]

So what are the new wobbly prop changes?

Thanks

Stik

[MLS-12D]

the new EASA rules specifiy that the engines must be replaced at 12 years or tbo whichever is sooner.Wow! :ooh: Can that really be correct?

If it is true, I will certainly hold off buying an airplane: since our North America secondhand market will presumably soon be glutted with perfectly good ex-European aircraft (or engines, anyway). :E

Doesn't make any sense. :rolleyes:

[stuartforrest]

I am afraid it is true as I have had the documentation through from the CAA now. If you put a plane on the G Reg it must have its engine replaced (or overhauled) after a specified time or hours. The specified time in my case and most engines was 12 years but after that time it seems it can be used on a private use basis but on condition of a 100 hours engine inspection.

You can have a 20% time or hours extension and continue to use it for public use but only if it was previously on the G Reg for the last 200 hours before it expired. You can also appeal to the CAA against this and that is what I am currently doing. Hopefully the fact that my engine is only 600 hours old and had a top end overhaul 0 hours ago will see sense prevail.

It looks like there will be many planes making it back across the Atlantic before their time expires here.

Ironically I purchased this plane from Germany just before the engine was 12 years old. The owner was selling it because he didnt want to go to the expense of putting a new engine in as Germany have had the 12 year rule for some time I believe.

[slim_slag]

Stuart, just flog the damned thing to the next unprepared newbie and go buy a boat.

[stuartforrest]

Hmm thats a daft comment. Thats not allowing for the aeroplane bug. I know it is not common sense to own a plane but then for the few precious days when my family go to France for lunch and back to Northern England I will pay the price I suppose.

[Yankee]

Stuart

Please check you PM's, we are in a similar dilemma and would like to pick you brains.

[DFC]

What we are seeing here is another clasic case of the CAA changing the rules to the new EASA rules (they have no choice) but failing to check how the EASA rules will affect other related unique CAA Rules.

This EASA rule does not have such an effect in other countries because unlike the UK, aircraft on a private C of A can be used for;

Flight Instruction; and

Hired for private use.

In other countries Flight Instruction is not Aerial Work so most of the training fleets are on private category C of As.

Thus the CAA have taken away one part of their own unique system but kept the bits that should go also so that there is no real change.

Regards,

DFC

[MLS-12D]

And people wonder why there is so much Euroskepticism ... :hmm:

[Morane]

Hi Stuart,

for privat used aircraft in Germany there is no 12 year life time
limit and also no TBO hour limitation, you fly it on condition (my O200 is now 16 years old).

If your aircraft is already in the german register,
leave it there. It´s no problem. As non-german you
are legaly allowed to own an airplane registered in Germany.

The only thing that have to be done by a certified person
in germany is the annual inspection (costs me 250€ each year).

Maybe I could helf you a little.

Joachim

[stuartforrest]

Actually my plane is currently on the N Reg but being moved to the G Reg.

It appears that for private use only this will be pretty much the case in the UK too. It just means I cant hire it out though.

Thanks for the advice.

[david viewing]

My engineer is interpreting this as meaning that engines in aircraft used for what was called 'public cat' under CAA will have to comply with manufacturers recommendations, which are 10yrs plus 20% extension for Lycomings and 12 yrs apparently for Continental. I wonder how many operators in the US comply with these 'recommendations'?

If the aircraft is used 'privately' then it can go on condition as before, but I am not sure of the implications of the 100Hr 'engine check' referred to above. Will EASA allow 100Hr airframe checks as well, in line with their 'manufacterers recommendation' policy?

Of course the law of unintended consequences may apply here because in reality most 'public cat' engines would reach 2000 hrs long before 10yrs, so no problem. The difficulty is with aircraft that have changed use or the case where occasional public cat operations are convenient to otherwise private owners.

[justsomepilot]

Under FAA the rules are different. They have part 91 and part 135 but these correspond to private/public cat only loosely.

One gotcha in this is with sole owners whose plane is company owned and who rent it to themseleves occasssionally. Under G, that plane has to be maintained to transport cat requirements, 50hour checks, 150hour checks, etc. even though the one person only ever flies it, privately. Pointless.

Under N, it can be part 91, and no 100hr checks unless the owner is training other people in it (FAR91.409). Much more sensible.

[stuartforrest]

Yes my engineer is interpretting it the same. In fact the CAA seem to have confirmed this is the case. I am able to run this engine to 20% over its 12 years but they dont have to accept it on the G Reg however if they are satisfied with its history they will.

There is more updates on my blog.

Beech Bonanza A-36 Blog (http://www.gotoair.com/gtablog.htm)

[MLS-12D]

One gotcha in this is with sole owners whose plane is company owned and who rent it to themseleves occasssionally. Under G, that plane has to be maintained to transport cat requirements, 50hour checks, 150hour checks, etc. even though the one person only ever flies it, privately. Pointless.I dislike petty bureaucracy; but in this case, my heart doesn't bleed for such an 'owner' (who, after all, has the option of transferring title from the corporation to himself, if the 'gotcha' is a problem).

Legally speaking, the corporation is a separate person from its sole shareholder. Presumably there are tax or other advantages to the legal fiction of the corporation's ownership, and that's why the original decision was made to register ownership in the company's name. But you can't have it both ways ("I don't own it (wink); but really I do").

[IO540]

In the UK, there are good reasons for company ownership of a plane. It clarifies VAT and Inland Revenue issues, and clarifies mixed private/business usage.

It also protects the owner from personal liability resulting from an incident when somebody else is flying the plane.

One can always de-incorporate, repaying the VAT to Customs on the current market value :O

[High Wing Drifter]

Legally speaking, the corporation is a separate person from its sole shareholder.
It also protects the owner from
personal liability resulting from an incident when somebody else is flying the plane.
Is that really the case? With the advent of corporate manslaughter, I'm not so sure. I would venture a guess that the opposite might be true.

[Flight Safety]

StuartForrest, the reason the regs deal with the issue of low hour aging engines is because of the corrosion and accelerated wear that can occur inside an internal combustion engine that sits for long periods between runs. This is due to the fact that moisture and other contaminants can get inside an engine and begin to corrode it, when it sits for long periods without being run. This happens with autos and trucks and boats as well as airplane engines.

You mentioned that your engine is 12 years old and has only 600 hours, and it just had a top end overhaul with 0 hours since then. Think about why that top end overhaul was required? What is the condition of the rest of the engine?

I do think however that a sensible way to deal with this in the regs, is for an older low time engine to be inspected at set periods, to make sure it is not suffering from any corrosion problems. If an engine is found to be OK upon inspection, then it should be allowed to remain in service.

[stuartforrest]

Yes I do now believe in fact that my engine required the top end overhaul because of lack of use during its 12 years so that seems sensible to have inspections but it doesnt seem sensible to get the work done and then the engine is still expiring after 12 years plus 20%.

I dont believe there are great benefits to having it in the name of a company and it seems it is correct that if I rent it to myself then I wont be able to once the 20% expires as that will be public use. It looks like I will either have to get a new engine by then or pay the VAT and make it purely for private use which is probably the option I will choose. That will cost loads of course to pay the VAT £27650 but then I wont need to charge myself VAT in the future.

[IO540]

You also won't be able to reclaim VAT on all the stuff you pay for. These issues are complex; one cannot make blanket statements.

Corporate manslaughter is exceedingly unlikely to apply here - it takes a lot more to make that stick.

But this stuff has been done to death here many times...

[beerdrinker]

Heard the other day ( from Rumour Control) that the very existance of EASA is now in jeopardy because its existence is tied to the EU Constitution which is itself in jeopardy.

[robin]

Nice rumour, but we're too far down the line for them to let us off the hook that easily

[High Wing Drifter]

Corporate manslaughter is exceedingly unlikely to apply here - it takes a lot more to make that stick.

But this stuff has been done to death here many times...
It has been mentioned in passing a couple of times, certainly not done to death. I understand this is a tangent, but I don't think recent events will put victim's families off having a go, so defence costs maybe a consideration!

Anyway, some bedtime reading before I shutup: http://www.corporateaccountability.org/dl/manslaughter/reform/billmar2005.pdf

:)