EASA 12 year engine rule for instructional (commercial) flight
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EASA 12 year engine rule for instructional (commercial) flight
Hi,
no doubt been discussed before but I could not find a thread history. (please point me to one if so)
What are the latest rules for using an EASA CofA aircaft for instructional flights for reward. Not private owner training, but as a generally available aircraft for training (for example loaned to a flying school).
Specifically as regards engine being used significantly beyond the manufacturer "recommended" TBO period . For example a Lycoming O320A2B that's well beyond 12 years since new/overhaul.
I'm not sure what the rules are these days for this, what with the various ongoing changes... AMP etc. I know they have been that beyond 12 years (recommended TBO period) you'd have to rip out a perfectly good engine.
Anyone with any simple insight or pointers towards the relevant regs. Thanks in advance.
Pup Flyer
no doubt been discussed before but I could not find a thread history. (please point me to one if so)
What are the latest rules for using an EASA CofA aircaft for instructional flights for reward. Not private owner training, but as a generally available aircraft for training (for example loaned to a flying school).
Specifically as regards engine being used significantly beyond the manufacturer "recommended" TBO period . For example a Lycoming O320A2B that's well beyond 12 years since new/overhaul.
I'm not sure what the rules are these days for this, what with the various ongoing changes... AMP etc. I know they have been that beyond 12 years (recommended TBO period) you'd have to rip out a perfectly good engine.
Anyone with any simple insight or pointers towards the relevant regs. Thanks in advance.
Pup Flyer
Last edited by Pup Flyer; 20th Jul 2020 at 20:34.
Pup Flyer
There is no general fixed rule on this. For most Lycoming/Teledyne Continental engines in general use you can apply through your maintenance engineer for an extension, on condition, of 20%. This 20% may also apply to the time limitations, so the 12 years may possibly be extendable to 14.4 years. You really need to ask your engineer who will advise you best for your particular engine..
There is no general fixed rule on this. For most Lycoming/Teledyne Continental engines in general use you can apply through your maintenance engineer for an extension, on condition, of 20%. This 20% may also apply to the time limitations, so the 12 years may possibly be extendable to 14.4 years. You really need to ask your engineer who will advise you best for your particular engine..
Maoraigh1
My previous post as far as it can be relied upon does answer the question.
There is normally no limit to the accrued hours or years for private use but once over the TBO the private use will still require a licenced engineer to sign off the engine at the prescribed intervals. The 20% extension where applicable applies to hire and reward use when a Release to Service is required. I repeat: each engine type may be treated differently even the same engine type could fall fowl dependant on the engine serial number. Some engines cannot be extended at all other than for for private use. Therefore for an authoritative answer, for a particular engine, refer to a licensed engineer.
My previous post as far as it can be relied upon does answer the question.
There is normally no limit to the accrued hours or years for private use but once over the TBO the private use will still require a licenced engineer to sign off the engine at the prescribed intervals. The 20% extension where applicable applies to hire and reward use when a Release to Service is required. I repeat: each engine type may be treated differently even the same engine type could fall fowl dependant on the engine serial number. Some engines cannot be extended at all other than for for private use. Therefore for an authoritative answer, for a particular engine, refer to a licensed engineer.
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Thanks both.
as you describe it is my understanding too. The engine in question is well over the manufacturer recommended TBO period (it did have a top overhaul more recently).
i wondered if anyone knew the actual reference to EASA regulation on this matter? The restriction on using “on condition” engines for reward (instruction).
Yes my engineer will likely know, was seeing if I could find out without troubling them.
Pup Flyer
as you describe it is my understanding too. The engine in question is well over the manufacturer recommended TBO period (it did have a top overhaul more recently).
i wondered if anyone knew the actual reference to EASA regulation on this matter? The restriction on using “on condition” engines for reward (instruction).
Yes my engineer will likely know, was seeing if I could find out without troubling them.
Pup Flyer
Pup Flyer- there is no such EASA regulation of the general kind that you appear to be looking for.
Put simply, If your engineer is able to issue a Release to Service then the aeroplane can be used for instruction and hire and reward. If not then it cannot be used as such. But, to be helpful, if an engine has a TBO of 2000 hours and can be extended, then at that point, based on condition, the engineer can after inspection issue a Release to Service, which will commonly be for another 50 hours but this period can be different. This, depending on condition, can be repeated until the 20% extension limit is reached: i.e. in this example the maximum hours for hire and reward will be limited to 2400 hours and the 12 years becomes 14.4 years. The detail is found within the maintenance schedule for your individual aeroplane. it is not in a general regulation, at least not all in one place, those days have gone. All this will be made clear (sic) within the maintenance schedule normally kept with the aircraft logbooks. I can only repeat, speak to your engineer because that is what they do and only then will all become clear to you. Note: if an aeroplane is used for hire and reward then the aircraft must be maintained wholly by a licenced engineer.
You may also be required to engage a CAMO (Continuing Airworthiness Management Organization) Again you engineer will clarify and advise.
Put simply, If your engineer is able to issue a Release to Service then the aeroplane can be used for instruction and hire and reward. If not then it cannot be used as such. But, to be helpful, if an engine has a TBO of 2000 hours and can be extended, then at that point, based on condition, the engineer can after inspection issue a Release to Service, which will commonly be for another 50 hours but this period can be different. This, depending on condition, can be repeated until the 20% extension limit is reached: i.e. in this example the maximum hours for hire and reward will be limited to 2400 hours and the 12 years becomes 14.4 years. The detail is found within the maintenance schedule for your individual aeroplane. it is not in a general regulation, at least not all in one place, those days have gone. All this will be made clear (sic) within the maintenance schedule normally kept with the aircraft logbooks. I can only repeat, speak to your engineer because that is what they do and only then will all become clear to you. Note: if an aeroplane is used for hire and reward then the aircraft must be maintained wholly by a licenced engineer.
You may also be required to engage a CAMO (Continuing Airworthiness Management Organization) Again you engineer will clarify and advise.
Last edited by Fl1ingfrog; 22nd Jul 2020 at 21:57.
Pup Flyer. The following is an example of what I have been trying to explain. It may not be relevant to your questions but I have noted that you have given your name as Pup Flyer. All Beagle Pups appear to hold a restricted C of A. If the following is relevant: the aircraft may only be used for private purposes and cannot be issued with a Release to Service allowing Instructing or any commercial use.
EASA SPECIFIC AIRWORTHINESS SPECIFICATION for BEAGLE B121 PUP
UK Build Standard
Model B121 Series 1
Model B121 Series 2
Model B121 Series 3
SECTION 4: Other Limitations
Limitation applicable to B121 Series 2, serial Number B121/004 only:-
Operation of this aircraft is limited to flights for Private purposes.
EASA SPECIFIC AIRWORTHINESS SPECIFICATION for BEAGLE B121 PUP
UK Build Standard
Model B121 Series 1
Model B121 Series 2
Model B121 Series 3
SECTION 4: Other Limitations
Limitation applicable to B121 Series 2, serial Number B121/004 only:-
Operation of this aircraft is limited to flights for Private purposes.
In an engine installed in an aircraft used for flying training/private hire, the engine can be operated in 'extension' but must be overhauled at TBO +20% hours and/or calendar time, whichever occurs first.
You cannot offer non-private instruction (i.e. an EASA ATO or RTF) on an aircraft when the engine is operated on condition. So on a Lycoming IO360 for example that would be 2000hrs TBO + up to 400 hrs extension OR 12 years. However in a flying school environment the calendar time is likely to be irrelevant on anything other that an aircraft purchased with a significant amount of time since last OH.
Flying Frog hinted that the 20% extension also applies to calendar time but I don't believe that is the case, the extension only applies to TBO hours.
You cannot offer non-private instruction (i.e. an EASA ATO or RTF) on an aircraft when the engine is operated on condition. So on a Lycoming IO360 for example that would be 2000hrs TBO + up to 400 hrs extension OR 12 years. However in a flying school environment the calendar time is likely to be irrelevant on anything other that an aircraft purchased with a significant amount of time since last OH.
Flying Frog hinted that the 20% extension also applies to calendar time but I don't believe that is the case, the extension only applies to TBO hours.
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I've seen a scheme mooted whereby the prospective student buys a share in an aircraft that doesn't comply, to enable them to learn under the rule that says you can learn on your own aircraft. In this case, the calendar and TBO requirements don't apply. I think for a person new to aviation, they are being led a bit into at best a 'grey area' of risk. i think they would need to have the differences and implications explained to them in a thorough and transparent manner.
The tone of the latter part of the OP's post seems to suggest that they feel that the manufacturer's recommendations are specious. They might say that after a certain period, their product is no longer 'perfectly good' and carries an increasing risk of failure. Lycoming engines are particularly susceptible to failure if left for a period without operating, hence the calendar restriction.
You CAN carry out ab initio instruction on an 'on condition' engine, but not in a 'commercial' setting.
TOO
The tone of the latter part of the OP's post seems to suggest that they feel that the manufacturer's recommendations are specious. They might say that after a certain period, their product is no longer 'perfectly good' and carries an increasing risk of failure. Lycoming engines are particularly susceptible to failure if left for a period without operating, hence the calendar restriction.
You CAN carry out ab initio instruction on an 'on condition' engine, but not in a 'commercial' setting.
TOO
TOO, flight instruction is considered commercial flying: The old category “Arial work” went years ago.
From the CAA website;
Use of National Permit to Fly for flight instruction and self-fly hire
Guidance on using National Permit to Fly for flight instruction and self-fly hire
Flying instruction and hire of aircraft, is considered to be a commercial operation. Article 42 of the Air Navigation order (ANO) 2016
So, changing to a ‘Permit to Fly’ could have advantages. See the following documents:
ORSA No. 1393
Light Aircraft Association (LAA) Technical Leaflet TL 2.09 'Pilot Training, Introductory Flights and Self Fly Hire.'
A chat with the LAA could be worthwhile but again a licenced engineer may well be up to speed on this also..
From the CAA website;
Use of National Permit to Fly for flight instruction and self-fly hire
Guidance on using National Permit to Fly for flight instruction and self-fly hire
Flying instruction and hire of aircraft, is considered to be a commercial operation. Article 42 of the Air Navigation order (ANO) 2016
So, changing to a ‘Permit to Fly’ could have advantages. See the following documents:
ORSA No. 1393
Light Aircraft Association (LAA) Technical Leaflet TL 2.09 'Pilot Training, Introductory Flights and Self Fly Hire.'
A chat with the LAA could be worthwhile but again a licenced engineer may well be up to speed on this also..
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I am missing one pice of information - in which country? After Brexit and with a complex mixtures of CAA & EASA & whatelse a general statement is not possible on the low level of a forum. I tend to suspect the terms commercial training and TBO will not come together, but would have to dig out the old ICAO folders. Even if there are local rule-holes, I think to remember it was forbidden on global agreements a long time ago.
To put things in perspective the flying club in Canada that I belong to, has Transport Canada approval to run their C 172's ( 2000 hr TBO) to 3500 hrs. All the engines have made it with no problems. The key to success is regular maintenance and frequent use. The school airplanes typically will hit the 3500 hr mark in less than 5 years of use.
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At least one operator in the UK used to have a similar approval on their Seneca fleet to run on condition based on enhanced inspections and the aircraft flying both day training and night freight - from memory their approval allowed up to 3500-4000 hours between major overhauls, and most of the engines made it. Very few issues between normal checks in those hours, just because the aircraft were either flying or being maintained. Perhaps a concept that might return in due time in the UK post-January 2021, as the UK CAA continue the idea of Risk Based Regulation.
To put things in perspective the flying club in Canada that I belong to, has Transport Canada approval to run their C 172's ( 2000 hr TBO) to 3500 hrs. All the engines have made it with no problems. The key to success is regular maintenance and frequent use. The school airplanes typically will hit the 3500 hr mark in less than 5 years of use.
The 12 year bit came in due to manufacturers concerns re internal corrosion considerations, remember hollow crankshafts were also subject to a calendar check.
TBO considerations were easier to contend with for engines in regular use, and sometimes also in line with oil sampling.
However there is no 'right' to an extension as it is up to the engineer in question and very much an individual issue based on knowledge of actual engine if he is the CAMO. If you change CAMO there is no guarantee of further extensions. In Holland they had a comprehensive cardex system with maintenance that laid out what needed to be done to continue engine use above TBO. Oil sampling and regular logged engines runs were also required.
TBO considerations were easier to contend with for engines in regular use, and sometimes also in line with oil sampling.
However there is no 'right' to an extension as it is up to the engineer in question and very much an individual issue based on knowledge of actual engine if he is the CAMO. If you change CAMO there is no guarantee of further extensions. In Holland they had a comprehensive cardex system with maintenance that laid out what needed to be done to continue engine use above TBO. Oil sampling and regular logged engines runs were also required.
I've just been told in the last hour, by a licenced engineer, that the 20% allowance went away in March. He said the CAA no longer take that responsibility and any extension has to be the CAMO's liability, making insurance very messy. I do not have references. Any licenced engineers care to comment?
It is not my understanding that the GR24 has been withdrawn but it has been re-written within the updated CAP 747 published during March 2020. The rewrite includes as follows:
3.1.1 Under the provisions of this Generic Requirement (GR), engines that have reached the operating time or calendar time limitation of a recommended overhaul period may continue in service for a further period of operation not exceeding 20% of the recommended operating time or calendar time, whichever occurs first, subject to compliance with a), b), c), d) e) and f).
Note: the 20% extension applies to both the engine hours and also the calendar time. A CAMO ensures that all maintenance has been complied with but will not accept liability. The CAMO will require overhaul and maintenance reports on the engine condition from the aircraft maintenance engineers. The CAMO never decides and does not give permission ever. They only advise the owner whether all is in compliance and remains in line with the current regulations. As with your tax accountant you remain responsible. The CAMO will not of course issue any certificates such as the ARC or any paperwork required of them if things are not correct, again similar to your accountant.
If you are importing an aircraft the new GR24 gives clear advice with regards to what is required of the engine so worth a read.
3.1.1 Under the provisions of this Generic Requirement (GR), engines that have reached the operating time or calendar time limitation of a recommended overhaul period may continue in service for a further period of operation not exceeding 20% of the recommended operating time or calendar time, whichever occurs first, subject to compliance with a), b), c), d) e) and f).
Note: the 20% extension applies to both the engine hours and also the calendar time. A CAMO ensures that all maintenance has been complied with but will not accept liability. The CAMO will require overhaul and maintenance reports on the engine condition from the aircraft maintenance engineers. The CAMO never decides and does not give permission ever. They only advise the owner whether all is in compliance and remains in line with the current regulations. As with your tax accountant you remain responsible. The CAMO will not of course issue any certificates such as the ARC or any paperwork required of them if things are not correct, again similar to your accountant.
If you are importing an aircraft the new GR24 gives clear advice with regards to what is required of the engine so worth a read.
Last edited by Fl1ingfrog; 3rd Aug 2020 at 18:43.
Emeroid Eng, if you are a light aircraft engineer perhaps you can help. EASA as always stimulates more questions than answers. The CAA advice and explanation is still not complete while they themselves grapple with all the changes that took place in March. It seems to me from the reading that is available that Part M light gives far greater discretion than the current Part 24 rules which is why part 24 is no longer part of it. Just the same it can be used as useful guidance for the owner operator if they so wish. EASA have emphasised that the manufacturers engine TBO is only a recommendation and should not be considered the end of its useful life. For those whose aircraft will continue subject to Part 24 the rules are now much clearer.
It appears to me that it has become possible for an engine beyond the 20% extension figures to be used by flying clubs because they are not 'commercial carriers' within the meaning of this phrase. As some have commented: they would rather fly behind a 3000 hours flying club engine which has been used daily and unlikely to be more than 3-5 years since major overhaul. Many privately operated aircraft may tale 12 years to reach half those hours and presumably will have had long periods of inactivity. Part ML allows the aircraft history to be part of the consideration for ongoing use.
It appears to me that it has become possible for an engine beyond the 20% extension figures to be used by flying clubs because they are not 'commercial carriers' within the meaning of this phrase. As some have commented: they would rather fly behind a 3000 hours flying club engine which has been used daily and unlikely to be more than 3-5 years since major overhaul. Many privately operated aircraft may tale 12 years to reach half those hours and presumably will have had long periods of inactivity. Part ML allows the aircraft history to be part of the consideration for ongoing use.
Last edited by Fl1ingfrog; 4th Aug 2020 at 15:32.
