AD-ENG-4 under attack.
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AD-ENG-4 under attack.
AOPA spokesman advises;
“I advise that we will this week submit to CASA to cease all unique Australian AD".
One supposes this includes AD-ENG-4 which allows many Australian aircraft in the private category to keep flying after the manufacturers recommended TBO and the imposed 12 year life span but subject to periodical inspections.
Notwithstanding the possibly overall good intent of the action, the removal of this AD will impact greatly upon many private operators.
“I advise that we will this week submit to CASA to cease all unique Australian AD".
One supposes this includes AD-ENG-4 which allows many Australian aircraft in the private category to keep flying after the manufacturers recommended TBO and the imposed 12 year life span but subject to periodical inspections.
Notwithstanding the possibly overall good intent of the action, the removal of this AD will impact greatly upon many private operators.
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Here's another one from the same spokesman;
"Let's get some comments in and see how many others cannot comprehend the place of AD ENG4 in stuffing GA".
This bloke wants to repeal the AD, (because it's peculiar to Australia), but can't comprehend repealing it would send us back to the prescriptive days.
It does not bring us in line with the US recommendations.
"Let's get some comments in and see how many others cannot comprehend the place of AD ENG4 in stuffing GA".
This bloke wants to repeal the AD, (because it's peculiar to Australia), but can't comprehend repealing it would send us back to the prescriptive days.
It does not bring us in line with the US recommendations.
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Hello, Bob.
Did the AOPA spokesperson give any indication why they consider that AD-ENG-4 is "stuffing GA"?
What are the chances of CASA stopping Oz-only ADs anyway? This is all a reaction to the legendary "3000 planes" AD of a couple of weeks ago. CASA did themselves no favours with that one.
Walrus
Did the AOPA spokesperson give any indication why they consider that AD-ENG-4 is "stuffing GA"?
What are the chances of CASA stopping Oz-only ADs anyway? This is all a reaction to the legendary "3000 planes" AD of a couple of weeks ago. CASA did themselves no favours with that one.
Walrus
Last edited by Walrus 7; 27th Mar 2008 at 04:34. Reason: crook punctuation
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Yes mate he did, but I am still working my way through the convoluted details. He is quoting some amendment 7 not inclusive of the amendment 10 which is curently in fashion. Also he is orientating in time and space with turbine vs piston aircraft and PVT and AWK vs paying pax. He branches out into test bed cells for overhauled engines which are not the subject of the AD.
I can't talk with the man or the organisation, all who see any one that opposes or questions their ideas as hostile and open to ridicule and attack. I must admit I give some stick as well, so perhaps you can broker a deal to at least simplify or civilise the matter at hand.
I can see where he is coming from but can't see an alternative if they manage to have the AD "repealed". The way I see it things go back to how they were before. ie. the prescriptive 2000 hrs or whatever or 12 years which ever comes first. Mention is made of a $20,000 overhaul. Struth, when did he last get an engine overhaul.
My late legal advice is that the previous status is no longer there because of the AD, BUT this doesn't necessarily mean things automatically revert to the US "recommendations".
Other advice from within the fortress Canberra mention things like "over my dead body" etc. I think this gives an indication of the chances of success. Give Office of Legal Counsel a buzz, they are always helpful with honest and simple advice.
At this stage one should consider the oft used phrase "if it ain't fkuced, don't fix it".
I don't understand what motivates CASA "spokesmen" to manufacture statements like the 3000 grounded aircraft. I am beginning to believe they are trying to kill GA in this Country.
Remember, just because your paranoid doesn't mean they are not out to get you.
I can't talk with the man or the organisation, all who see any one that opposes or questions their ideas as hostile and open to ridicule and attack. I must admit I give some stick as well, so perhaps you can broker a deal to at least simplify or civilise the matter at hand.
I can see where he is coming from but can't see an alternative if they manage to have the AD "repealed". The way I see it things go back to how they were before. ie. the prescriptive 2000 hrs or whatever or 12 years which ever comes first. Mention is made of a $20,000 overhaul. Struth, when did he last get an engine overhaul.
My late legal advice is that the previous status is no longer there because of the AD, BUT this doesn't necessarily mean things automatically revert to the US "recommendations".
Other advice from within the fortress Canberra mention things like "over my dead body" etc. I think this gives an indication of the chances of success. Give Office of Legal Counsel a buzz, they are always helpful with honest and simple advice.
At this stage one should consider the oft used phrase "if it ain't fkuced, don't fix it".
I don't understand what motivates CASA "spokesmen" to manufacture statements like the 3000 grounded aircraft. I am beginning to believe they are trying to kill GA in this Country.
Remember, just because your paranoid doesn't mean they are not out to get you.
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Am I missing something here? - there is a difference between recommendations and AD's - there always has been, hasn't there? I can't see the leap between cancelling unique Australian AD's, and then doing anything different to what the US does.
What will be the difference?
What will be the difference?
Grandpa Aerotart
Indeed. OEM TBOs are recommended in the USA.
The only way this could be disastrous is if manufacturers decide to change recommended to mandatory TBO. I think that would cause an absolute uproar in the US and their politically savvy alphabet groups would surely knock it on the head as 'unconstitutional' or some such.
The basic fact is that the most dangerous period from an engine failure point of view is the first 3-400 hrs post overhaul/from new. If the engine is running fine at 1700 hrs it likely will be at 2400 hrs.
In the end though I suppose most GA engines are not doing the annual hours that helps ensure trouble free running post TBO. That is a double edged sword too....low utilisation is likely to mean the engine has been topped pre TBO...which means the engine is even MORE likely to be safe beyond TBO.
Lets face it, the bottom ends are pretty bullet proof.
Are we facing a situation where fear of litigation is negating the very design basis of the engines where individual parts can be exchanged as needed, cylinders, valves, magnetos etc, rather than overhauling the engine just because a date or time in service has arrived?
I overhauled my IO550B at TBO+ 10% and did so with a heavy heart as it was running like a swiss watch. Had I known then what I know now that engine would be 400 hrs past TBO today and likely still running strong. The cylinders only had 800 hrs (the engine had been topped long before I bought the aircraft) in service when I pulled them during overhaul and replaced them with new Millenniums. The bottom end/crankcase are as delivered from the factory, merely checked and found to be within tolerances and reinstalled
Or are we dealing with a meddling moron?
The only way this could be disastrous is if manufacturers decide to change recommended to mandatory TBO. I think that would cause an absolute uproar in the US and their politically savvy alphabet groups would surely knock it on the head as 'unconstitutional' or some such.
The basic fact is that the most dangerous period from an engine failure point of view is the first 3-400 hrs post overhaul/from new. If the engine is running fine at 1700 hrs it likely will be at 2400 hrs.
In the end though I suppose most GA engines are not doing the annual hours that helps ensure trouble free running post TBO. That is a double edged sword too....low utilisation is likely to mean the engine has been topped pre TBO...which means the engine is even MORE likely to be safe beyond TBO.
Lets face it, the bottom ends are pretty bullet proof.
Are we facing a situation where fear of litigation is negating the very design basis of the engines where individual parts can be exchanged as needed, cylinders, valves, magnetos etc, rather than overhauling the engine just because a date or time in service has arrived?
I overhauled my IO550B at TBO+ 10% and did so with a heavy heart as it was running like a swiss watch. Had I known then what I know now that engine would be 400 hrs past TBO today and likely still running strong. The cylinders only had 800 hrs (the engine had been topped long before I bought the aircraft) in service when I pulled them during overhaul and replaced them with new Millenniums. The bottom end/crankcase are as delivered from the factory, merely checked and found to be within tolerances and reinstalled
Or are we dealing with a meddling moron?
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To try to simplify matters, can someone check that I have this right.
1. Everyone is concerned that if AD-ENG-4 is repealed, no-one will be able to run engines on condition anymore.
2. AOPA wants all Oz-specific ADs repealed and FAA and manufacturers' recommendations used instead.
3. AOPA contends that AD-ENG-4 isn't needed anymore because the ability to run on condition is enshrined in CAR42B, which takes precedence over AD-ENG-4.
Have I got that straight?
Walrus
1. Everyone is concerned that if AD-ENG-4 is repealed, no-one will be able to run engines on condition anymore.
2. AOPA wants all Oz-specific ADs repealed and FAA and manufacturers' recommendations used instead.
3. AOPA contends that AD-ENG-4 isn't needed anymore because the ability to run on condition is enshrined in CAR42B, which takes precedence over AD-ENG-4.
Have I got that straight?
Walrus
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Walrus;
1) That IS what I am concerned about.
2) The FAA AND manufacturers don't make recomendations, the manufacturers say hard time no extensions, zero full stop.
3) My last maintenance release notes the following;
Schedules/System of Maintenanceapplicable to this aircraft= CASA CAR 42B Maintenance schedule 5 (which is the system of maintenance for the aircraft periodical), and AD/ENG/4.9 Appendix "A" which is for the engine. I don't follow how CAR 42B takes precedence over AD/ENG/4.
Have I got that right?
1) That IS what I am concerned about.
2) The FAA AND manufacturers don't make recomendations, the manufacturers say hard time no extensions, zero full stop.
3) My last maintenance release notes the following;
Schedules/System of Maintenanceapplicable to this aircraft= CASA CAR 42B Maintenance schedule 5 (which is the system of maintenance for the aircraft periodical), and AD/ENG/4.9 Appendix "A" which is for the engine. I don't follow how CAR 42B takes precedence over AD/ENG/4.
Have I got that right?
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Why is it that dealing with CASA documents is like trying to solve the riddle of the Sphinx (which has been solved but it took hundreds of years)?
The way I read it is that CAR42B does include the engine (as noted in AWB 85-004 Par 3) and that AD-ENG-4 specifies a schedule of condition checks. Therefore, if we obsolete AD-ENG-4, all we lose is the schedule of checks. The impact of this would need to be taken into account.
So, am I getting close?
Walrus
The way I read it is that CAR42B does include the engine (as noted in AWB 85-004 Par 3) and that AD-ENG-4 specifies a schedule of condition checks. Therefore, if we obsolete AD-ENG-4, all we lose is the schedule of checks. The impact of this would need to be taken into account.
So, am I getting close?
Walrus
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Facts as I recall are;
1) Prior to ED/ENG/4 amendment 7 there were NO on condition piston engines. All were specified in ANO's as hard time overhauls.
2) Engine manufacturers recommend fixed times.
3) The airworthiness bulletin has dubious legal ramifications (still checking), to make engine extensions. CAR 42B does and always has had engine checks as part of the system of maintenance and in the case of schedule 5 is the CASA schedule. All piston periodicals I have had anything to do with included spark plugs, oil filters etc. AD/ENG/4 is the instrument that extends hard times to on condition subsequent to condition checks including oil uptake etc.
I fear that to obsolute AD/ENG/4 would take us back to some obscure ANO and fixed hard times between overhauls.
Why not just leave this one alone. I refer you to your own first paragraph of your last post.
1) Prior to ED/ENG/4 amendment 7 there were NO on condition piston engines. All were specified in ANO's as hard time overhauls.
2) Engine manufacturers recommend fixed times.
3) The airworthiness bulletin has dubious legal ramifications (still checking), to make engine extensions. CAR 42B does and always has had engine checks as part of the system of maintenance and in the case of schedule 5 is the CASA schedule. All piston periodicals I have had anything to do with included spark plugs, oil filters etc. AD/ENG/4 is the instrument that extends hard times to on condition subsequent to condition checks including oil uptake etc.
I fear that to obsolute AD/ENG/4 would take us back to some obscure ANO and fixed hard times between overhauls.
Why not just leave this one alone. I refer you to your own first paragraph of your last post.
How do insurance companies handle engines that are running fine on condition but past the manufacturers recomended overhaul time.
What if your TBO is 2000 hrs and you are on condition at 2500 hrs and have a failure. Do the insurance companies have grounds for denying a claim?
What if your TBO is 2000 hrs and you are on condition at 2500 hrs and have a failure. Do the insurance companies have grounds for denying a claim?
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No More Catering
AD eng 4/7 is an alternate system of maintenance available to operators of piston engines beyond TBO and or Calendar renewal time limits only private and airwork.
It is not a casual tick and flick thing, there are substantive reqirements in the AD to make sure the LAME and C of R holder are acting responsibly.
Yes the aircraft is insurable, which is quite different from the issues in the adoption of the FAA Manufacturers Recommendation position.
It is all but impossible to insure an aircraft in the US operating beyond Manufacturers recommendation for public liability that will allow operation into a mainstream FBO airport.
It is a legal fact that if you go outside manufacturers recommendation for ANY product at any time you void any liability the manufacturer has in respect to operation of the product, servicing of the product and warranties that may have been in force over the product. You are on your own.
In the Aviation case in Australia the adoption of AD eng 4/7 allowed operators to continue to use their aircraft legally beyond TBO and time limits within the Aviation Regulatory framework. A quite unique set of circumstances comparitively world wide.
We all need to be careful what we wish for, change for the sake of change is rarely a good thing, old aviation saying,"If it aint broke, don't fix it", meddling with this AD is fraught with the potential to create a regulatory nightmare and real danger of substantive cost penalties on Airwork Operators putting a lot of Flying Schools out of action.
This issue is not just about Insurance, nor is it operating "on the cheap" AD eng 4/7 was negotiated responsibly by folk who knew what they were doing and it has operated successfully for a long time with a very good history of outcomes.
AD eng 4/7 is an alternate system of maintenance available to operators of piston engines beyond TBO and or Calendar renewal time limits only private and airwork.
It is not a casual tick and flick thing, there are substantive reqirements in the AD to make sure the LAME and C of R holder are acting responsibly.
Yes the aircraft is insurable, which is quite different from the issues in the adoption of the FAA Manufacturers Recommendation position.
It is all but impossible to insure an aircraft in the US operating beyond Manufacturers recommendation for public liability that will allow operation into a mainstream FBO airport.
It is a legal fact that if you go outside manufacturers recommendation for ANY product at any time you void any liability the manufacturer has in respect to operation of the product, servicing of the product and warranties that may have been in force over the product. You are on your own.
In the Aviation case in Australia the adoption of AD eng 4/7 allowed operators to continue to use their aircraft legally beyond TBO and time limits within the Aviation Regulatory framework. A quite unique set of circumstances comparitively world wide.
We all need to be careful what we wish for, change for the sake of change is rarely a good thing, old aviation saying,"If it aint broke, don't fix it", meddling with this AD is fraught with the potential to create a regulatory nightmare and real danger of substantive cost penalties on Airwork Operators putting a lot of Flying Schools out of action.
This issue is not just about Insurance, nor is it operating "on the cheap" AD eng 4/7 was negotiated responsibly by folk who knew what they were doing and it has operated successfully for a long time with a very good history of outcomes.
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Why don't some of those bureaucrats learn what risk management really means?
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Priorities, AOPA!
How about a friendly letter to AOPA management, pointing out that the interests of pilots and aircraft owners may be better served if they used their resources to fight for better T's&C's in the current employment market, rather than trying to fiddle with minute details of technical regulations???
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Priorities;
There is a conundrum.
Pilot Unions would argue over the fact that AOPA originally stood for aircraft owners and their pilots. More recently after having lost the majority of the owner group, possibly and probably as a consequence of "CASAGATE" they now need the pilot group which are divided around the numerous Unions and other alphabet soup mobs. Although the AOPA spokesman does assert they represent of all GA?
To be fair, they did attempt to support entry level pilots to the system, but once the students were out of the melting pot they, (the students), went their own predictable way.
Too many fish and chip shops in the same street now catering for some 20,000 Aussie pilots.
There is a conundrum.
Pilot Unions would argue over the fact that AOPA originally stood for aircraft owners and their pilots. More recently after having lost the majority of the owner group, possibly and probably as a consequence of "CASAGATE" they now need the pilot group which are divided around the numerous Unions and other alphabet soup mobs. Although the AOPA spokesman does assert they represent of all GA?
To be fair, they did attempt to support entry level pilots to the system, but once the students were out of the melting pot they, (the students), went their own predictable way.
Too many fish and chip shops in the same street now catering for some 20,000 Aussie pilots.