Airborne_Again wrote:
The MIP states that the transponder should undergo a “operational check” every 100 hrs. The same terms are used in the new part-M Light. The questions is what this means — the terms are never defined. I’ve asked bookworm who was involved in drafting part-ML and he replied basically that it is better not to ask for precise definitions.
It would be interesting to know how other countries interpret this “operational check” requirement.
Guillaume wrote:
“Operational test can be defined aircraft manufacturer but must pursue the objectives of either “ATC SYSTEM FULL TEST PROCEDURE for transponders mode C and S” (defined page 39 in this document) or “EASA SIB 2011-15R2”.
That’s madness. But that use of “operational” does not agree with other uses in the document you linked to. An “operational check” of HF radio is mentioned and it is clear that this is done by normal use of the radio: “Contact ground stations for operational check (near and far stations) in AM, LSB and SSB modes. Evaluate audio signal quality and transfer function for crew members in cockpit.”
What about all the other stuff in that doc? VOR tests etc. every 2 years for IFR. Is that in the EASA docs anywhere?
Airborne_Again wrote:
That’s madness.
zuutroy wrote:
Is that in the EASA docs anywhere
The test selected and carried out has to reflect (achieve the same) the objective of the DGAC tests.
That does NOT mean that it has to follow the recommended procedure laid out in those documents.
A relevant and significant regulatory difference. Typical regulatory wordsmithing.
Unfortunately, it means that an owner probably has to convince maintenance organizations who want to cover their lower backs…
ch.ess wrote:
That does NOT mean that it has to follow the recommended procedure laid out in those documents.
A relevant and significant regulatory difference. Typical regulatory wordsmithing.
A bit of history :
The previous version of the document (caution, NOT UP TO DATE) did state that airborne tests were acceptable as operational check.
Unfortunately, it got updated and now only bench test objectives are listed.
Doesn’t page 26 (40 in English) of the current document (March 2019) allow an airborne test as the intermediate between 2-3 years?
Even more confusing, the table on the last page of the document shows all txp checks as N/A for IFR?!
After studying the table in annex 4 and para 7 etc (with the caveat that my French is a bit rusty) i would still contend that you would not necessarily need a bench test.
In addition, the French DGAC cannot enforce (legally allowed, that is, in practice they can do a lot) regulation stronger than EASA rules.
The EASA regulation is comprehensive and complete, i.e. national CAAs are not mandated/authrised to add conditions to those areas that have been regulated by EASA (much to the chagrin of, say, the German LBA, who therefore play difficult at every turn).
If EASA does not mandate certain tests, DGAC are not authorised to do so.
ch.ess wrote:
After studying the table in annex 4 and para 7 etc (with the caveat that my French is a bit rusty) i would still contend that you would not necessarily need a bench test.
I will check the reality of that during next annual.
ch.ess wrote:
If EASA does not mandate certain tests, DGAC are not authorised to do so.
I agree, but I’m not sure how to deal with that with EASA.
zuutroy wrote:
Doesn’t page 26 (40 in English) of the current document (March 2019) allow an airborne test as the intermediate between 2-3 years?
Indeed, that’s today’s rules for aircraft flying VFR only for which maintenance program don’t fall under Part-M M.A 302(h).
Bench test every 5 years, airborne intermediate test between 2-3 years.
zuutroy wrote:
Even more confusing, the table on the last page of the document shows all txp checks as N/A for IFR?!
Confusing, indeed.
