Engine TBO - CAA interpretation ?
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Engine TBO - CAA interpretation ?
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
!!!
Is this true - or just some local interpretation by the CAA ?
Anyone else or any clubs been hit like this ?
I am PH--ing angry
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
!!!Is this true - or just some local interpretation by the CAA ?
Anyone else or any clubs been hit like this ?
I am PH-
-ing angry
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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
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
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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!)
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!)
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Easa ?
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.
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.
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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.
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.
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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.
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.
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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 !?.
Any one Know what the position is on the FM immunity issue !?.
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"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.
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.
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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.
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.
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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!
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!
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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?
>>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?
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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
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
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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)
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)
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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
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
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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
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
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.. how they interpret it in South Africa ..?
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
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 ?
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.
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.
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 ?
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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.
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.
Last edited by A and C; 21st Jan 2006 at 15:15.
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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
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