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Can I run an engine over TBO on D-reg in non-commercial operation?

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I own a Cesna 172S and fly it non-commercially on German registration, although the plane is not based in Germany. My engine is now couple of hours before TBO and not in controlled environment.

I have seen the discussion about new rules under Part M. My question is whether I can go over TBO and what I have to do to be able to do it legally. Technically the engine runs perfectly, no need to open it up. I hope there are other pilots of D-reg planes who are better informed than me not living in Germany.

Thank you for the comments.

Miroc

LZTR, Slovakia

I thought this is an alleviation for ELA1 airplanes (like your Cessna) that is already in force since a couple years. You can declare your maintenance program and not apply the TBO. When you search the Easy Access Rules for Continuing Airworthiness for “declare” you’ll find the legal basis. But for the practical solution I can’t answer as I don’t know the details.
All these alleviations for ELA1 are printed in purple in above document.
Edit: The AMC “M.A.302(e) Aircraft maintenance programme” contains a template for this declaration, that’s how it has to look like. Your CAA probably has its own template (that may not be more restrictive, of course).

Last Edited by ArcticChiller at 31 Aug 14:47

1)
AMC M.A.302(e) for basic maintenance program based
on the minimum inspection program (MIP, M.A.302 lit. i), i.e. to guarantee a minimum level of maintenance mostly for aircraft that do not have manufacturer guidelines for maintenance or if deviation from these guidelines is desired (for example because the manufacturer‘s maintenance guidelines are less thorough than what is mandated in the MIP). Any „limits“ set in AD (airworthiness directives) and the TCDS (Type certificate data sheet) are binding. What my last sentence means in regard to TBO limits set forth without AD/TCDS I don’t know.

2)
Appendix I to AMC M.A.302 and M.B.301(b) for expanded maintenance program. TBO recommendation from manufacturer needs to be listed and, in case not followed, alternate means of maintenance must be specified. LBA NfL 2-292-16 has more on that.

3)
The owner of an ELA1 plane can self declare the maintenance program according to M.A.302 lit. h) S. 1 Number 4.
Note: to deviate from manufacturer TBO you need to specify how the engine will be maintained (eg “…engine will be evaluated based on function condition…”).
This part of the Maint. Program needs to be approved by LBA.

4)
Directly seek maintenance program approval from LBA .

5) Use a camo

EASA CB IR instruction
LOWG, LEBL,

Has it not been the case “since for ever” that in private ops an engine could be run on condition?

There are some strange requirements e.g. in Switzerland but these may be historical.

There are countless German pilots on EuroGA.

Administrator
Shoreham EGKA, United Kingdom

Snoopy wrote:

Note: to deviate from manufacturer TBO you need to specify how the engine will be maintained (eg “…engine will be evaluated based on function condition…”)
This part of the Maint. Program needs to be approved by LBA.

My understanding of part-M (which is shared by my home Competent Authority) is that there is such requirement for approval.

ESKC (Uppsala/Sundbro), Sweden

Peter wrote:

Has it not been the case “since for ever” that in private ops an engine could be run on condition?

In what countries…? Certainly not in mine before the SDMP.

Last Edited by Airborne_Again at 01 Sep 08:46
ESKC (Uppsala/Sundbro), Sweden

I have now specific knowledge about germany, except the fact that planecheck is full of german planes running over TBO.
Our CAA usually wants some rule under which they can approve the increased TBO and calendar time, motivating that as EE is a small country,they lack the operational experience for deciding if the extension is OK.
For lycoming, SI1009 worked fine.

Last Edited by ivark at 01 Sep 08:41
EETU, Estonia

ivark wrote:

Our CAA usually wants some rule under which they can approve the increased TBO and calendar time, motivating that as EE is a small country,they lack the operational experience for deciding if the extension is OK.

My point is that for a SDMP, there is no regulatory basis for approval at all. That’s the whole point of the MP being “self-declared”.

ESKC (Uppsala/Sundbro), Sweden

Airborne_Again wrote:

My understanding of part-M (which is shared by my home Competent Authority) is that there is such requirement for approval.

The German NfL 2-292-16 concerns ATOs specifically. However, this is what it says on the matter.

3.1 nicht gewerblicher Einsatz von ELA1-Luftfahrzeugen
ATO von Vereinen und Verbänden betreiben im Allgemeinen die ELA1-Luftfahrzeuge nicht gewerblich. Für diese Luftfahrzeuge können die IHP auf der Basis des M.A.302 (h) als „Selbsterklärung“ durch die Halter erstellt werden. Der Halter trägt dabei die volle Verantwor- tung für etwaige Abweichungen von den vom Halter der Musterzulassung der Zelle, der Ge- räte und der Komponenten herausgegebenen Instandhaltungsempfehlungen wie z. B. die TBO Zeiten. (siehe auch GM M.A.302(h))

3.1 Non commercial Operation of ELA1-Aircrafts
ATO of clubs and organizations operates normally the ELA1-Aircrafts non-commercial. For these Aircrafts the AMP can be issued on the basis of M.A.302 (h) as self-declaration by the owner. The owner thereby carries the full responsibility for and deviations from the published maintenance recommendations from the owner of the Type Certificate, as e.g. the TBO intervals (see also GM M.A.302(h)

That is to say, there is no need for approval of extended TBO intervals.

ESKC (Uppsala/Sundbro), Sweden

Engine beyond TBO is easy, even for ELA2 planes.
Requires a specific check during annual signed by certified engineer/maintenace company.
Every air service company (in Germany, at least) knows how.

...
EDM_, Germany
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