Engine TBO - CAA interpretation ?

[PH-UKU]

Help.

OK, here's the story. Aircraft has a 20 year old engine. TBO 1500hrs. Due to being offline (sometime in 1990s), and nature of flying has low total time ie.TTE 750 - though this is now increasing and averaging 100 hrs pa in recent years.... so about 7 years to go before new engine required...or so I thought.

Always serviced/oil-changed etc... correctly and legally. Runs like a dream, compressions good.

Operated on public cat - so available for rental.

CAA bombshell due new legislation introduced last year says .....

...to keep ac on public cat, because engine is over 12 years old it has to replaced :mad: :mad: :eek: !!!

Is this true - or just some local interpretation by the CAA ?
Anyone else or any clubs been hit like this ?

I am PH-:mad:-ing angry

[DFC]

I think that you will find that it is a Manufacturer requirement that EASA is ensuring that operators comply with.

Something like TBO = 1500 hours or 12 years whichever first.

Perhaps you should ask the engine manufacturer for an extension to the 12 year limit and see what they say.

Regards,

DFC

[Say again s l o w l y]

This "little" problem is causing no end of mayhem amongst most of the owners I know.

There does seem to be some interpretation however, with one lot of engineers disagreeing with another.

Our owners are in the same boat with a 172XP and the Pitts being affected, though the 172 seems to have got away with it for another couple of years since it has over 2 years left before it's CofA is due.

I would dearly love to find some guidance from someone who isn't interpreting or guessing. None of us have found this legislation anywhere in CAA land, but I haven't seen any EASA doc's. (Do they exist?)

Anyone operating on a permit will have a bonanza of cheap engines this year! (Stop rubbing your hands with glee Stik!)

[A and C]

This 12 year thing has only appered since EASA came into being and is because of the differences in interpritation of "public transport".

In most of continental Europe A public transport C of A is only required for work that requires an AOC, in the UK a public transport C of A is required for anything except srictly private flying.

This means that Flying training (for instance) requirs a public transport C of A in the UK But this is not required in the rest of europe.

The problem is that there is no joined up thinking at the CAA and rather than change all the rules at the same time the maintenance part of the CAA is embracing the EASA rules but the rest of the CAA seems to be in a time warp and has yet to change the rules to enable flying training to be carried out without a PT C of A.

When C of A is next renewed on your aircraft there will be no private or PT clasification it will be just a C of A and it will be up to the opperator to ensure that the maintenance conforms to the requirments of private or PT use of the aircraft.

The whole thing is a mess and shows that the CAA simply fails to understand the effects that the rule changes have on the industry that it (miss)regulates and for this stupidty we now have to pay charges that have increased far above the rate of inflation.

[IO540]

It's not just flight training that needs a PT CofA (or, when CofA are no longer issued, maintenance to the PT CofA regime).

It's any kind of renting, including the case of a plane owned by a limited company of which you are a 100% owner and the plane being rented back to you by the company. Obviously the actual operation is identical to you owning the plane directly. The technical rental is done to avoid getting hit for the Inland Revenue Benefit in Kind, if any portion of the flying is for private purposes.

One solution to the above situation is to go N-reg, where this isn't an issue.

IMHO the CAA have gone way over the top in trying to screw down the options for freelance cowboys doing flight training out of the back of a Ford Escort. Years ago, a CFI explained to me once how he proposed to run a school using Private CofA planes, by making each student a Director (or something like that). Later, he vanished after embezzling a load of money from the school. One could of course ask why on earth does GA end up with so many crooks and cowboys. It's at least as bad as double glazing / central heating / loft insulation / cavity wall insulation has been, in their respective darkest days. That's why we have the stupid incomprehensible ANO wording, the stupid rules about not advertising for passengers (PPL cost sharing) except on a noticeboard in a club, etc.

[robin]

We have a similar issue - a 900 hour engine 12 years since overhaul on a Public Cat.

At the moment we are able to rent out to the local club or other suitably qualified pilots to help defray cost

Our Star Annual this year will coincide with the change to an EASA 'Normal', we think. Apparently when the annual is done, we will be asked if the aircraft is to be used for Public Transport/Aerial work and the maintenance will be so annotated.

However, because the engine will have reached the 12 year life, we can't actually use her for rental purposes. I don't believe this is recorded anywhere on the documents, just makes it illegal to do so.

On another thread there was mentioned that there were issues of group owned aircraft and maintenance advising that they should be maintained to public transport standards as group ownership could, in certain circumstances, be considered to be rental.

I've had lots of conversations with staff at the CAA and have received no help whatsoever. They don't seem to understand how we work in the real world of general aviation. I had to explain the consequences of the rules to them, and it was like talking to a member of staff in Dixons!

As a result we'll have to look at how we can still allow those who we wish to keep flying our baby to do so. It may mean operating her as a limited company rather than as a group, but it is a bit of a fag.

[A and C]

One of the things that I am now lookig at is registering my fleet in another EEC/EASA state so that I can continue to opperate without the excessive charges and administrative stupidity that the CAA seem to be so good at. What could the CAA do about it ?

Any one Know what the position is on the FM immunity issue !?.

[IO540]

"registering my fleet in another EEC/EASA state "

You would be caught by the old Article 115 (article 140 in the 2005 ANO) prohibiting aerial work in a foreign reg plane without the permission of the Secy of State (which, as they explain on the DfT website, won't be forthcoming except for specified owner-training cases).

Somebody, "2 Donkeys" I believe, posted on the flyer.co.uk forum recently that he was told by the DfT that EASA aircraft are exempt from this (I think this was in the context of the proposed eviction of foreign reg planes from the UK) but that is not what the ANO actually says. So I would get this in writing first.

My GUESS is that if one could do UK based flight training in any EASA reg plane it would have been done, but I haven't seen it anywhere.

I have in the past managed to get written (and intelligent) responses from the CAA to some suprising questions, but most of the time they will just tell you to get your own legal opinion. This gives them all the options. They can a blind eye (as they do to many things anyway) or they can prosecute, according to whether they want to make a point.

[A and C]

I would be seeking to opperate on the same basis as say Ryanair, that company opperates Irish registered aircraft that are based in the UK.
As far as I can see if you are an EEC based company with aircraft registered in the EEC on EASA maintenance then you can opperate from any EEC state.

[IO540]

You may well be right A and C but that firm runs under an AOC. It IS possible for an AOC holder to get DfT permission to use foreign reg aircraft, subject to commercial need and subject to their UK competitors not objecting.

I read the above, pretty clearly stated, on a CAA or DfT website when researching the whole business of rental / dry leases (the subject of many megabytes of disinformation in various places) as applicable to N-reg planes in private use. Eventually I phoned up Roger Kinsey at the DfT who confirmed that for private flying it's all a redherring and there is no problem. Obviously I did not pursue the AOC side because it doesn't apply to me. Since then I have not found anything disproving the foregoing; however I am taking about noncommercial use whereas you are looking at flight training.

It could be that some more recent EU law supercedes Article 140, however. In which case not many people know about it!

[robin]

IO540

>>Eventually I phoned up Roger Kinsey at the DfT who confirmed that for private flying it's all a redherring and there is no problem<<

Could you elaborate on this. What is the red herring?

[IO540]

No need for a dry lease. This is not relevant to A&C's issue, however.

[ACX]

Well back to the original question and the confusion that seems to be.
1. EASA maintenance regulations – PART M – currently only apply to aircraft operating on an AOC. They will affect the rest of us from Sept 2008.
2. In PART M under maintenance programmes in states about using manufacturers recommended life’s. However, there is a get out clause, which basically says “unless varied by the Authority”. In this case the CAA has varied the requirement and we have Notice 75 which gives some alleviation. Having spoken to the CAA they have no intention of removing this Notice. Many countries are sticking strictly to the manufacturer’s recommendations.
3. And this is where there has been a slight change which has caught me out and probably other engineers. Notice 75 was revised last year to come into affect this March. The change was to put into the Notice the manufacturer’s calendar life reference. Many of us engineers appear to have been signing engines out on extension under the old notice based on the hours only. It made no reference to the calender life and so we appear to have been ignoring that by mistake. The CAA have now put the calender life into the Notice, thus it is now govened by the 20% extension only rule for PT work. I think a lot of engines will be caught by this in March!!!
4. Regarding various CofA queries. EASA has come into effect here. All CofA’s for EASA aircraft are now deemed to be EASA CofA’s. It does not matter if you still have the old CAA type with the category on it. It is still deemed an EASA CofA. The CAA are just replacing them at the next CofA renewal rather then in one go. You can do Public Transport even if your old CAA CofA says Private Category. You just need to make sure you have the correct equipment fitted and maintained to PT requirements.
5. And finally, A&C. Ryan Air operates under an EU directive that gives rights for AOC operators to operate into other EU countries without the need for permissions. The directive does not apply to Aerial Work. This was referenced in the old ANO Article 114 or 116.
Best of luck
ACX

['India-Mike]

My club has 2 O-200's affected by this issue. Teledyne Continental SIL98-9A gives 12 years OR 1800 hours. However, there is no 'whichever occurs first'. Does this imply a choice between the two? The lack of a 'whichever occurs first' does not appear to be simply semantics, 'cos the very next paragraph pertains to aerial spraying, where the recommendation is 12 years OR 1200 hours WHICHEVER OCCURS FIRST (my capitalisation). Definitely no choice there then.
Doesn't the wording of CAP 747 GR24 still allow the CAA to grant 'extensions' (don't have it in front of me but my recollection is of a 'decision tree' diagram to this effect)? It's specifically a CAA extension, not one granted by a maintenance organisation.
Having spoken to a CAA chap, it's been suggested that a written case for extension (on a case-by-case basis) submitted to CAA might help. What's folk's views on that? (steps back to fit kevlar before retreating to bunker)

[robin]

Thanks ACX

According to Para 4, the issue for me is because the new regs now include calendar time, we cannot operate the aircraft for rent from the date 12 years after the last major overhaul, irrespective of the Cof A status, as the engine is now lifed from that date.

For CAA Private Cat with an engine within limits they can shift to 'old' Public Cat, so to speak, by letting the maintenance organisation know that the owners might want to do so.

Bit of a pigs ear, really

[DFC]

If you want the manufacturer of your engine to give you a special exemption then simply ring them.

I'm awaiting the "brave" pilot who makes a non-gps world breaking record simple phonecall to the manufacturer of their own engine!

If you don't ask you don't get!!!

All those who have been told NO to the question shout here and we can then take it further? Where??!

Regards,

DFC

[PH-UKU]

http://www.caa.co.za/press_files/2001/pr0823.pdf

This statement was written in 2001 (I haven't been able to find out if it has been superceded), and the logic applies to Teledyne's Service Information Letter SIL98-9 (current issue is SIL98-9A, but I believe the wording of initial paragraphs remains the same - only the list of engines has been amended).

Worth reading the SA CAA logic from para3.3 onward.

And picking up from wot A+C wrote
In most of continental Europe A public transport C of A is only required for work that requires an AOC, in the UK a public transport C of A is required for anything except srictly private flying.

This means that Flying training (for instance) requires a public transport C of A in the UK But this is not required in the rest of europe.

If this is true then it might strengthen arguments against the CAA interpretation .... so is it really true ... ? If so can an appeal be made to EASA over the heads of CAA for fair and equitable application of the rules ? Would be interested in hard evidence (web links/pdf docs etc..) of any other countries that don't require Flying Club rentals to be classed as Air Transport Ops?

It is interesting to note (para2.5) that NZ require servicing for Air Transport operations ... does anyone know if that includes flying club rentals or instruction ?

[A and C]

The only real change that I see in the regulations is that the CAA have in CAP747 GR 24 picked up on the calender life that in most cases is 12 years but this also can be extended by 20% giving a total time in service of 14.4 years.

I cant see a lot of "real" public transport opperations being effected by this as even runnung a Lycoming O-235 with a TBO of 2400+20%= 2880 this relates to 200 hours per year and I dont know how one could stay in business with that rate of use.

The people who it is going to hurt is the private owner who rents out his aircraft ocasionaly to help with the running costs.

As for a "fair and equitable" application of the rules the CAA has a long and proud history of dogmaticly applying rules that are out of step with the rest of europe be these rules to the advantage or (more usualy) dis-advantage of the UK industry, in most European states the local administrators apply the rules to the best advantage of the local industry however the Britsh burocrat (not just the CAA) seems to be unable to see that his wages depend apon the industry that they administer.

[ACX]

Sorry for quoting Notice 35 earlier, but 20 years of calling it that is hard to change.

I think the changes - in GR24 - may affect more private operators. The requirement to use the extension requires the aircraft to have been operated on the G reg for the preceeding 200hrs before coming to either the calender or hours life. Many private aircraft imported over the last few years have probably not done the 200hrs and the engines are over 12 years old. Thus in March they are technically grounded!!!!!! I am talking to the CAA regarding a couple of aircraft in this situation.

ACX

[A and C]

You actualy said notice 75 in your post but I guessed it was a slip of the pen!

[Keef]

I came cross this about ten years ago, when our engine with about 1100 hours but 14 years old let go with a bang, and the aircraft landed 50 yards offshore and was written off.

The AAIB "recommended" in the report that the process for engines with low hours but high ages (12+) should be subject to further consideration. I never heard what that was.

Since our present engine is well over 12 years old (and at 2400 hours) but has been signed off through several annuals and Cs of A, I assume there is some sort of inspection regime but not an absolute requirement for replacement (on a Private Cat C of A).

[ACX]

A&C Yes, just a slip. All the number changes are hard to remember at the moment

Note on engine extensions, per the GR. During a recent CAA survey of an aircraft we wee asked to provide the oil comsumption figures for the last 50hours, per the GR, to justify giving the engine an extension. Needless to say that has slowed down the annual as the owners have no records. Just one to watch for!!!!!

ACX

[Mandator]

There are still some engines where the manufacturer does not specify a calendar time limitation on its overhaul life. Most notable of these is the Gipsy series. Already the CAA has floated a draft Mandatory Permit Directive to impose a caledar backstop (of ten years) on all jet engines used in Permit to Fly aircraft.
They are also working on doing the same for those piston engines where the manufacturer has not seen fit to make any calendar limitation. This will be imposed by amendment of GR 24. Watch out for any consultation document and if you are affected, make your views known.
The CAA line will be that they are out to catch those engines fitted to aircraft which are operated for the purposes of public transport. Those engines operated for the purposes of private flight will be allowed to continue under the 'on condition' assessment stated in GR 24.

[PH-UKU]

I cant see a lot of "real" public transport opperations being effected by this as even runnung a Lycoming O-235 with a TBO of 2400+20%= 2880 this relates to 200 hours per year and I dont know how one could stay in business with that rate of use.

The people who it is going to hurt is the private owner who rents out his aircraft ocasionaly to help with the running costs.


Which probably accounts for quite a few aircraft around the country.

As all the costs increase every year, and as usage goes down and down, I think this may well be the final squeeze for some clubs.

Once again the CAA bites the (admittedly tiny) hand that feeds it. I think it has now been nibbled away to the shoulder. :*

[foghorn]

Can someone put this simply for a simple person? This thread is going well above my head.

I speak as the part owner of a twenty-seven year old Lycoming O-360 on 1400 hours.

Should we expect to have to replace it? Only if we're maintaining to the public category (which we do currently)? Will dropping to private category maintenance allow us to keep it running? Or should we not be worried at all?

Cheers,
foggy:confused:

[IO540]

You can drop down to the Private Cat maintenance, unless there is

a) renting, or

b) training for the initial award of any license or a rating (except for a 100% owner which is permitted, or the training is done by an instructor who is doing it for free which is also OK), or

c) an owner owning less than 5%, or

d) any use that requires Transport CofA maintenance.

Hope I got that right :O

[foghorn]

I guess back to the private category it is, then. We only went up to the public category to allow some cheap training for members.

[Say again s l o w l y]

Has anyone heard anymore about this little gem?

I have had it confirmed to me that the CAA aren't going to budge, but are placing the blame squarely on to EASA, but aren't going to do a thing about it.

I have two a/c that are going to be affected and time is obviously running out quick smart.

Has anything been done, or is there some campaign to get in touch with?

If not, let's start one.

[Mandator]

I think that the CAA is trying to put the blame for all of these issues onto EASA when it is, in fact, the CAA itself which wants these regulations implemented. Yesterday I was at a conference and listened to Sir Roy McNulty from the CAA, Patrick Goudou from EASA and David McMillan from the Department for Transport. The noises from the CAA and the DfT were clear - if they thought that EASA had got it wrong on safety, then they would impose their own UK-only requirements. Mr Goudou admitted that he was largely powerless to intervene in these cases.
The CAA has already floated a draft Mandatory Permit Directive to impose a calendar life on jet engines in warbirds/permit to fly aircraft. They have already talked about introducing their own calendar life (12 years?) for all engine types which do not have a calendar life imposed by the manufacturer (eg Gipsy series). The bad news for the Gipsy is that a recent forced landing was caused by a fractured crankshaft. All commercial operators of the Gipsy should now be making their plans to get their engines overhauled if they are more than 14.4 years out of overhaul (12 years + 20%). Dont ask where the engineering/overhaul shop capacity is going to come from, or all the approved spare parts. This instruction has the potential to kill a lot of aircraft.
The bottom line remains as stated in CAP 747, Generic Requirement 24:
If your aircraft is "operated for the purposes of public transport" then you can extend manufacturer's operating hour and calendar limits by 20% max.
If your aircraft is "operated for the purpose of private flight" then, subject to the satisfactory completion of certain checks every year (eg compressions, oil consumption etc) you can run 'on condition'. There is a lot more detail in GR 24, but it would only confuse. Thus, it is true that for the average private owner there is no effective change to the status quo.
As someone said earlier in this thread, the CAA is out to nail the commercial and public transport operators because they see this as a high risk area with a poor safety record.
Simple, isn't it!

[gaxan]

Wow ! Now I am confused and very worried! I have a Tiger Moth on a Public C of A
God knows how old the engine is - must be 50 years old at least, but about mid time- so whats going to happen ? It will be about 17 grand to replace- so that will be the end of my Tiger!

['India-Mike]

Re. Gypsy Majors. I spoke to propulsion Dept. at CAA recently to find out what action they might take regarding calendar life limits. If I understood the response correctly, lifing won't necessarily be 12 years as that figure is a manufacturer (Continental/Lycoming) specified number. No such age was specified by the Gypsy's manufacturer, hence CAA will deal with it by AD. This could in principle mean that the life limitation is <12, or >12. The recent failure mentioned by Mandator probably means that the AAIB recommendation following Stampe G-OODE losing its prop, will now be actioned by CAA following a period of consultation with 'the industry' ie us.

I was PIC for the recent failure - subject to AAIB investigation of course so don't want to speculate, but the engine is a wreck, and looking at the engine, the pessimist in me worries that there may be other implications as well - but calendar lifing is in my humble opinion, inevitable.

[gaxan]

Thanks for that India Mike. I had forgotten about that bit of excitement with the Stampe. Fingers crossed that there will be a sudden outbreak of common sense - some how I doubt it !!

[Mandator]

GAXAN - there is no need to be confused. You and your Tiger are one of the targets of what will probably become the CAA's next campaign. As India-Mike says, >12 or <12 years is still to be decided. However, if you are flying "for the purposes of public transport" you will need to think about getting some dosh together. If, despite the Transport Cat CofA, you are only flying "for the purpose of private flight" then go on-condition. It is the use of the aircraft which matters in this situation.

We should congratulate India-Mike on getting the bird safely down on the beach - we now have the evidence which MIGHT show that it was not corrosion of the crankshaft which initiated the failure. However, turning to the wider issue of assuring the integrity of Gipsy engines, this is where the going gets tough. We need to know why India-Mike's engine let go. That information needs to be considered, together with the crank failures on the Redhill Stampe and the Brize Chipmunk (remember that one?), together with overhaul data from Deltair and VinTech.
The danger here is that there is no design organisation for the Gipsy and new spares have not been manufactured for forty+ years. Deltair has the design data but they are not a design organisation. So, the CAA has no design authority to turn to and propose sensible solutions. More importantly, the CAA has no organisation (other than itself) to take responsibility and liability for the solution, whatever it might be. Hence, the CAA is faced with taking decisions which do not sit confortably with its role as the regulator. Also, the CAA is stuffed with lawyers and as a result is risk averse. That is the problem that could sink the Gipsy and the aircraft which fly behind it. As the CAA would say, safety cannot be put in second place to financial or commercial issues.
The only way out of this dilema is to get a proper design authority for the Gipsy. This must be a credible organisation with the knowledge and expertise to develop a sensible solution to the problem and to take responsibility and liability for it. That organisation then needs to get critical spares (such as crankshafts, exhaust valves etc) back into production. Deltair is unable to do this because it is not a design organisation and it cannot validate the drawings (which will probably need material and process changes) for new production to begin.
There will be many people working very hard to resolve this situation in a sane and sensible manner. Hopefully, with the right people round the Gatwick table a measured approach can be devised, but it will not be easy. The situation we now face behoves all Gipsy operators, public or private, to make sure that their engine maintenance is top notch - without the steadying influence of an active design organisation, other failures could sound the death knell for sensible operating hour and calendar time overhaul limitations.

[Say again s l o w l y]

I do hope the CAA have the data to back up these assumptions they seem to be making.
A/C have been operating for many years with engines older than 12 years, why are they now changing the goal posts? If they have no real impirical data for this stance, I reckon there could be a few court cases heading their way.
Let's see how "risk averse" they are then.

[Mandator]

Well said S-A-S. I am pretty sure that your argument will be one of the many posed to the CAA in the debate which is bound to occur.

[smarthawke]

Whilst not wanting to sound defeatist in any way, the calender life enforcement is apparently only bringing us into line with the rest of Europe and most of the known world. It will be a difficult one to fight.

[Mandator]

Smarthawke, you are right. However, we have to try and retain the status quo, especially if the failure rate is not getting worse. Trouble is, it seems to be!

[IO540]

What is the data supporting this position?

[Captain Mayday]

Perhaps some-one could shed some light on two issues that have been raised in this discussion ....

1 - General flying club ops in Europe are not required to be Public Transport under EASA, but they are in the UK ? Is this true ?

2 - The CAA consider that Public Transport ops require engine replacement every 12 years, but operating privately it can continue 'on condition'.

Examining the logic of #2 in terms of safety. Are they saying that one operation is less safe than the other ? Or that there is a lesser chance of an engine failure. Surely if the engine is considered by the CAA unsafe for Public Transport, then it must be equally unsafe for Private flight ? Or, if it is considered safe for Private flight, then why is it not considered safe for Public flight.

If we further examine the logic of flying club ops.

Q -Who is likely to fly in a flying club aircraft ?
A - PPLs who prefer to rent or who cannot afford to buy their own plane/share, and their friends.

Q - Who is likely to fly in a private aircraft ?
A - PPLs who can afford to buy an aircraft/share, and their friends.

Q - So basically it is exactly the same people who would fly in both cases.
A - yes

Q - So why is one flight considered safe and the other not?
A - Good question.

Q - So are the CAA infringing my rights by discriminating in this manner.
A - who knows

Q - Who are the CAA answerable to in their determination of what is safe/unsafe?
A - no-one, least of all the GA community.

Q - So can I appeal to any higher authority/political body/EASA
A- Who knows?

Q - What about registering an aircraft in another EASA country and operating it under EASA rules in the UK ?
A - ???

['India-Mike]

My club wrote to CAA seeking extensions beyond calendar life + 20% for two O200's. Result entirely predictable. No.

GR24 makes provision (or at least implies that it does) for extension beyond calendar+20% with written permission of CAA. Authority's reply to us clarifies this option - only to be used 'to provide for operators who are experiencing an unforseen circumstance and require a small variation to the 20%'. They quantify 'small' as a month or so. Also tried to point out difference between wording of Teledyne Service leaflet, and GR24 in terms of life or hours 'whichever comes first'. GR24 uses the latter for all applications, the SIL uses it only in relation to engines used for crop-spraying. No joy.

Pity that harmonisation of engineering (GR24) hasn't been matched by operations harmonisation - doesn't continental europe class club operations as 'private'? Ho hum.

[stuartforrest]

My Bonanza A36 has been affected by this problem. I purchased a low hours plane (500 hours) and put it on the N reg but last year decided after al the N reg fuss to move it back to the G reg to try to tow the european line and had a top end overhaul done at the same time at a cost of many thousands of pounds. During the transfer process the CAA dropped the bombshell that I now need a new engine as it was 12 years old which I was not best pleased about but then agreed to a 20% extension so I have about another 18 months and then I can

a. use it entirely privately (which wont work as I rent it to myself and a couple of others)

b. Buy a new engine despite my current one probably only being on 800 hours and just been part overhauled

or

c. Go back to the N reg. I will probably choose this option as I wont be able to afford anything else.

I am staggered at the outrageous rule mongering that makes peoples life hard for no justifiable reason. I do not believe that the U.S. does not care about safety and they have a much larger G.A Fleet than Europe to make these judgements on. W**kers make these rules up!

[Morgo]

Could someone please clarify any item about 'engine replacement' for me? Is a major overhaul of the engine considered sufficient, or does one literally need to install a brand-spanking new engine after the required period?

[stuartforrest]

No I think it means an overhaul but in many cases the price isnt much different as far as I can work out.

[Morgo]

No I think it means an overhaul but in many cases the price isnt much different as far as I can work out.

That's a relief! Either way the cost is high (overhaul against full replacement) but the former could save a few grand. I have been trying to look for official documentation regarding this on both the EASA and CAA website but can't find anything. More than likely I am looking in the wrong place or am missing the text after drowing in what can only be described as poor, officious language!

['India-Mike]

Morgo

Document you're looking for is CAP747. It's huge but accessible via the CAA search facility.

[Morgo]

Morgo
Document you're looking for is CAP747. It's huge but accessible via the CAA search facility.

Many thanks for that! You are quite right, a rather huge document. I see that all the pertinent information is at the end of the file and happily confirms that engine life is all with regards to the period between overhaul.

[camlobe]

Hi folks. In the past six weeks or so, I have tried to get full clarification from the CAA over this issue.

OK,OK. You can stop rolling around the floor now.

As you can all see from what has been posted above, there is more clarity here than within the corridors of the Belgrano.

My own surveyor, a very senior surveyor and GA experienced man, has done his best to assist me in this muddy issue.

Two things have rocked the boat at the CAA. The first was an aircraft that had an engine still installed after 46 years. Now, you and I would consider that a testament to the designer for getting it pretty right, the owners/operators for looking after it properly, and the engineers for maintaining it correctly. The CAA have looked at it rather differently.

The second issue is AD's. There is a rumour that an overhauler has whined to the CAA about AD's that are due at overhaul. We concentious engineers have been certifying engines on TBO extension, aware that when the engine finally gets overhauled that the relevant AD's due at overhaul will be done at that time.

Crunch time. The CAA legal beagles have advised the CAA that, in order to ensure that the CAA is not found wanting (i.e. exposed in a 'sue- everybody' world) that the manufacturers recommendation of TBO is to be used to decide when an AD due at overhaul is to be complied with.

What this means is that EVERYBODY with an engine running on TBO extension in accordance with GR 24 that is subject to AD's due at overhaul, will be GROUNDED until the AD's are complied with, once the CAA publish the ruling. It will not matter if your engine is on calendar or hours extension.

By my loosest reckoning, this will affect around 2000 aircraft. Picture the scene - 1500+ owners queing at the overhaulers and deciding if it is worth one visit for the AD compliance followed a relatively short time later for an overhaul.

In this age of supply and demand, I suspect that overhauler rates will rise to welcome this desperate influx of work.

If it is true that an overhauler has indeed rocked the boat over this issue, then the cinic in me believes that this is not a safety issue, but purely greed. You decide.

[robin]

So what happens when all 2000 aircraft suddenly turn up for the ADs to be complied with - are we all grounded while we wait for our toys to reach the head of the queue

Nice planning CAA

Or should we run this past EASA and ask them for a judgement?

Any ideas AOPA/PFA?

[Say again s l o w l y]

So that's 1/5th of the entire fleet of G registered aeroplanes. Are they have a laugh?

What planet are they living on?

[HiFranc]

So that's 1/5th of the entire fleet of G registered aeroplanes. Are they have a laugh?
What planet are they living on?

Probably the same planet, indeed the same country, where school trips are being cancelled just because the accident liability is too high.

{edit}I can see both sides of the arguement. I do feel that, as a society, we are less able to judge risk as previous generations. However, looked at from CAA point of view, engine failure is a problem that can be addressed and, from a precautionary point of view, if 20% of the aircraft will be affected then maybe there's something wrong with the way GA is run in Britain.

The arguements on both sides will run and run.

[IO540]

What is the safety data supporting this?

We all know most GA planes are old wrecks, but they have been for as long as most people can remember and I am not aware of planes plummetting down everywhere with failed engines.

[stuartforrest]

IO you are tempting fate now. Engine will expire for sure this weekend! :)

[ACX]

Camlobe

If you have any engines on extension that have AD’s applicable at overhaul, you had better inform the owners that they are possibly flying without a valid CofA !!!!!

See GR24 para 3.1.1 for items that must be complied with, in particular (b)

“Compliance being shown with any applicable Airworthiness Directive which
requires compliance at engine overhaul, unless otherwise agreed by CAA.”

I have never been able to get CAA agreement to extend any of the applicable AD’s.

ACX

[camlobe]

ACX, your point is completely valid.

However, at this moment, the CAA have not published a ruling stipulating compliance with AD's due at overhaul to be complied with at manufacturers stated figures.

The CAA have been accepting that, as the engine is not being overhauled yet, then these AD's are not due yet. When the engines are overhauled, then all applicable AD's must be complied with. It is the CAA's interpretation of this which is about to change, following advice from their legal department.

Those customers of mine presently enjoying TBO extensions have been personally briefed by myself giving them as much forewarning as possible of the potential ruling and its implications. This includes the potential invalidation of C of A's until compliance with aforesaid AD's.

It has also been my experience that the CAA do not extend AD's.