Engine TBO - CAA interpretation ?
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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).
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).
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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
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!!!!!
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Engines Without Calendar Time Limits
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.
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.
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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.
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 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.
I say there boy
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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
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
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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
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
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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.
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.
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CAA TRYING TO PUT BLAME ON EASA
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!
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!
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TBO.s
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!
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!
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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.
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.
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Gypsy's
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 !!
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GIPSY ENGINES - THE CAA'S NEXT TARGET?
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.
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.
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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.
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.
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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.
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The final straw ....
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 - ???
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 - ???
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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.
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.