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ELA1 / ELA2 maintenance (merged)

EASA released CRD 2015-08 and Opinion 05/2016

Mostly good stuff in there, except that the minimum inspection program (MIP) mandates a pitot-static and transponder operational check every 100h / 1 year regardless of VFR / IFR operation.

Last Edited by Guillaume at 14 Apr 15:24

Guillaume,

I heard some comments which, if true, would be horrible.

One commentator sais, it would mandate things like the Cessna SID as well as necessitate a risk analysis for each aircraft component before each flight, with consultation with the manufacturer, if interpreted as many CAA’s are known to most restrictively interpret things.

AMC ML.A.302(c) Aircraft maintenance programme

Page 11 classifies as HIGH RISK : All owner maintained and owner managed airplanes, all IFR flights, all Single engine airplanes, All ELA2 airplanes (ELA1 are medium risk) concerning weight, all airplanes used less than 50 hours per year.

This risk classification would present in itself a high risk for CAA’s to introduce measures to “protect” against these high risks.

Alone the fact that IFR is high risk, combined with single engine as high risk is quite threatening.

I do wonder what about the high risk in aircraft weight for ELA2 airplanes, while LSA’s and UL’s are looked at as low risk and the heavier ELA2 planes are medium? What sense does that make? In terms of overloading, I’d think the highest risk would be in the UL class, where overloading is pretty much standard? What about the ELA1 planes, quite a few of which are downgraded to 1999 kgs and fly constantly overloaded?

Then the note on page 12 concerning the MIP:

Note 1: use the manufacturer’s maintenance manual to accomplish each task/inspection.

As far as I know, the Cessna SID became a problem because it is written into the maintenance manual. So this note would suggest that if you have to use the mm for the minimum maintenance, it would declare any such instruction as compulsory. Therefore, the SID would become compulsory for all EASA registered Cessnas, which would see a lot of Cessnas becoming worthless.

What looks pretty good is the self-declared maintenance program section, apart from the fact that it specifies that it has to include the MIP requirements including the ones above, which would suggest that all such instructions such as the recommendations in the maintenance manuals have to be followed…

Page 30:

AMC
ML.A.403
Aircraft defects
Aircraft equipment should be declared as defective if the re is a significant risk that it will fail to perform the functions required at a level of performance consistent with the acceptable level of safety of the operation

So do I have now to perform a risk analysis on each component of my plane before each flight?

I am not a specialist, these are some concerns I hear from some who are now looking through this new programme. They seem to fear that the competent authorities will find sufficient angles to keep their restrictive gold plating despite EASA’s efforts to the opposite.

Last Edited by Mooney_Driver at 15 Apr 09:34
LSZH(work) LSZF (GA base), Switzerland

Mooney_Driver wrote:

They seem to fear that the competent authorities will find sufficient angles to keep their restrictive gold plating despite EASA’s efforts to the opposite.

I agree with you. The previous exeperiences with EASA regulations show that it leaves too much room for interpretation.

However, from the way I read it, AMC ML.A.302 says :


….
Nevertheless, as allowed by ML.A.302(c)(7) and explained in GM ML.A.302, when the owner issues a declaration for the maintenance programme, they do not need to justify such deviations

In my opinion, this leaves little room for interpretation.

Now, regarding the Cessna SIDs, the idea is that only the MIP is mandatory every 100 h / 1 year.
Then, in order to accomplish each tasks listed in the MIP (and not the tasks listed in the manufacturer maintenance manual), you have to use the maintenance manual.
ie when the MIP says :

Engine controlsInspect for defects, improper travel, and improper safe tying

You have to use the manufacturer maintenance manual to check travel and safe tying.

In France it worked quite well for the ELA 1 when commission regulation 2015/1088 was introduced : Cessna SID’s for ELA 1 are no longer mandatory.

The interpretration from some CAA may vary, but that’s really not the idea behind Part-M light.

which would suggest that all such instructions such as the recommendations in the maintenance manuals have to be followed…

The maintenance program template included in AMC. ML.A 302 explicitly offers the possibility to ammend recommandations (check last block of the template).

Last Edited by Guillaume at 15 Apr 11:14

Guillaume,

what do you think about this then:

ML.A.503 Service-life-limited components
1.(a) Installed service-life-limited components shall not exceed the approved service life limit as specified in the AMP and ADs, except as provided for in ML.A.504©.
2.(B) The approved service life is expressed in calendar time, flight hours, landings or cycles, as appropriate.
3.© At the end of the approved service life, the component must be removed from the aircraft for maintenance, or for disposal in the case of components with a certified life limit.

To me this reads like TBO calendar time has just been declared compulsory.

Last Edited by Mooney_Driver at 15 Apr 18:42
LSZH(work) LSZF (GA base), Switzerland

I think this refers to life-limited components as listed in Chapter 4. Typically some helicopter dynamic components or some turbine engine parts. I don’t believe it relates to an overhaul life.

Last Edited by wigglyamp at 15 Apr 18:57
Avionics geek.
Somewhere remote in Devon, UK.

As wigglyamp said, this paragraph applies to life-limited components.
These components are listed under chapter 4 of the maintenance manual.

This is the chapter 4 of the Cirrus maintenance manual.
You can see that only the CAPS and the restraint system are life limited.
This chapter also says that engine and propeller are not life limited.

The EASA maintenance program template makes a clear distinction between life limited components and recommandations included in SB’s (like TBO).

Last Edited by Guillaume at 15 Apr 19:09

Let’s hope that is the interpretation of the “competent” authorities as well…

LSZH(work) LSZF (GA base), Switzerland

Mooney_Driver wrote:

Let’s hope that is the interpretation of the “competent” authorities as well…

That is the interpretation for owner-declared maintenance programmes today, so I don’t why there should be a difference.

ESKC (Uppsala/Sundbro), Sweden

Mooney_Driver wrote:

Page 30:

AMC
ML.A.403
Aircraft defects
Aircraft equipment should be declared as defective if the re is a significant risk that it will fail to perform the functions required at a level of performance consistent with the acceptable level of safety of the operation
So do I have now to perform a risk analysis on each component of my plane before each flight?

No, that is not the intention of the rule. It just states that you should make a remark if it doesn’t work or works unsatisfactory. Another sentence of this part also states that the aircraft owner can defer defects that are not related to critical items without the help of an engineer.

Mooney_Driver wrote:

what do you think about this then:

ML.A.503 Service-life-limited components
1.(a) Installed service-life-limited components shall not exceed the approved service life limit as specified in the AMP and ADs, except as provided for in ML.A.504©.
2.(B) The approved service life is expressed in calendar time, flight hours, landings or cycles, as appropriate.
3.© At the end of the approved service life, the component must be removed from the aircraft for maintenance, or for disposal in the case of components with a certified life limit.
To me this reads like TBO calendar time has just been declared compulsory.

The engine is not considered a servicelife-limited component. ML.A.302 5) explicitly says about TBO: “the following elements shall be taken into consideration as a minimum:”
The intention of the rule is to make TBO completely non-compulsory and it is up to the owner to decide when TBO is due. Unless the annual inspection reveals flight safety critical issues that is. The AMP, if selfdeclared, cannot be challenged by CAMO, maintenance personnel or CAA.

Regarding the SID an interesting document was just released by the FAA on that topic:
Special Airworthiness Information Bulletin HQ-16-14

This fact is not clearly written in the draft for Part-ML. We should try to get EASA to make some kind of similar statement.

ESSZ, Sweden

The engine is not considered a servicelife-limited component. ML.A.302 5) explicitly says about TBO: “the following elements shall be taken into consideration as a minimum:”
The intention of the rule is to make TBO completely non-compulsory and it is up to the owner to decide when TBO is due. Unless the annual inspection reveals flight safety critical issues that is. The AMP, if selfdeclared, cannot be challenged by CAMO, maintenance personnel or CAA.

The Conti Diesels are TBR, not TBO. So would the authorities regard TBR and TBO in the same light? In the USA you can fly with them beyond TBR if operating under Part 91 (Non Commercial Ops), so that reinforces the case here in Europe. Plus one would continue to monitor the state of the engine through oil analysis. Thoughts?

Private field, Mallorca, Spain
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