you should ask EASA for clarification
Never done anything similar, but it gave me a good chuckle 
There are actually several occasions where EASA has told the CAA that they are wrong. Then they will have to correct it.
Dan wrote:
Never done anything similar, but it gave me a good chuckle
I was once in a similar situation but in that case EASA was actually more up to speed than German LBA and it turned out an easy task.
But I still do not understand the issue of this case. The plane came with an engine from the factory and that engine is still on the plane. As the plane was at least part of its life in Germany the Germans did not give anything about any airframe/engine/prop logbooks. Many German planes do not even have them. Each year they must have produced a table with component times also listing serial numbers of the engine. So if you have any serious portion of the planes paper history you should have many editions of those component times. Those lists should also contain the hours of the airframe at the inspection date etc. and are usually signed by an inspector. So the engine serial number and time should be clear. Assuming the worst case no overhaul was ever done the total time and age of the aircraft will be max that of the airframe?
Playing the devil’s advocate here:
Sebastian_G wrote:
The plane came with an engine from the factory and that engine is still on the plane.
How do you know if there is no documentation at all?
Sebastian_G wrote:
Each year they must have produced a table with component times also listing serial numbers of the engine.
“engine log” is indeed an FAA-term that doesn’t exist for EASA airplanes – but beyond that “wrong name” my understanding of this case is that the problem exactly is that non of these documents in the “paper history” exist.
Btw.: Very same would happen in Germany as well. If you have an airplane without the documentation of component serial numbers, times, etc. and the only document you have is a valid ARC from last year, no inspector would sign a new ARC. You would have to do a full overhaul/replacement of every part where you can not in some way prove the status.
Sebastian_G wrote:
Assuming the worst case no overhaul was ever done
The worst case would be that the engine (and or the airplane) had a prop strike or other type of crash and the proper treatment has not be performed after that. How would you identify such cases without some kind of documentation?
Malibuflyer wrote:
my understanding of this case is that the problem exactly is that non of these documents in the “paper history” exist.
Ok I see so it is not the log missing but no paperwork at all. Then things are difficult. I would try to locate the previous owners and ask what shops they used. At least most of the German shops will have very old papers stored. When I get into a shop they usually have a wall full of folders. Each folder with a callsign sometimes maybe dating back from when the shop did open…
Malibuflyer wrote:
an airplane without the documentation of component serial numbers, times, etc. and the only document you have is a valid ARC from last year
But then how do you deal with a situation where a component on an aircraft is of uncertain or disputed provenance?
E.g. your maintenance engineer says he is not happy about component X and wants to see paperwork for it before he can sign the ARC. As the owner, you reply that to the best of your knowledge that component is the original one fitted to the aeroplane and thus no specific paperwork for it is required (or exists).
Where is the burden of proof? In the case of the OP, one ‘option’ would have been to get hold of an old blank engine logbook and go to work with many different pens and coffee stains etc to create an apparent record of the engine being with the airframe since manufacture. I’m sure this has been done before.
We had a similar issue to this maybe eight years ago (when our then-CAMO was an EASA CAMO) and due to some company politics (the chief engineer who we liked left, and a new guy came in who tried to wash his hands of everything the company had done to date) – we were given a big, impossible list of things that paperwork was required for before our ARC would be signed. It took quite a ‘firm’ meeting with the boss and threats of reporting to the CAA to resolve, the obvious position being that internal company politics are not our problem as a customer and just because you’ve had a change of personnel you can’t declare unsatisfactory stuff your company has been signing off for years. One occasion where the European obsession with approved organisations worked in our favour.
There is a thread here where a guy dropped off a Robin for some work, the ARC expired, and the maint company (who had by that time stripped the plane for some avionics work) refused to do it, claiming a tail strobe was not legally fitted in 1972. The result, eventually, was an abandonement of the plane and a loss of about 30k€ for avionics…
Horrible, but it can and does happen. There is a good number of planes parked in Europe which were abandoned in these situations. It could never happen with an N-reg unless you did an Export CofA first (in error, perhaps, or by not being able to get it accepted onto another registry).
That is a massive error in planning, to allow an ARC signed off by one company to expire while another company has it in bits.
By asking them to do an ARC you entitle them to have an opinion on the tail strobe. If you’re not asking them to do it, the tail strobe is none of their damn business.
I’m smiling at the idea that the existence and repair status of a prop strike should be determined by demanding documentation. I assume the assumption here is that some authority is watching when you fly and would invariably ground the plane as though it were a military aircraft?
Undocumented prop strikes occur when no authority is watching, and the propeller is replaced or repaired without additional engine work. Therefore no relevant engine documentation exists. The most you’re going to find in the aircraft records is a prop overhaul, and that won’t be in the engine maintenance records.
Graham wrote:
But then how do you deal with a situation where a component on an aircraft is of uncertain or disputed provenance?
In the end, the burden of proof is with the owner/operator.
I did not buy my airplane factory new, so I can’t share the experience of what you get or do not get in terms of documentation when you do that.
When I bought my used plane, however, I got a list of all of all (relevant) components with serial no., install date (if not factory delivered), runtime, limits, etc.
