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Engine overhauls under Part ML—implications for aircraft used for training

Now that GR 24 has been revoked (CAP 747 Section 2 Part 3, GR No. 24, Page 1, para 1, note d), do engines automatically revert to the manufacturer’s overhaul schedule, or can a Part ML MP override the manufacturer’s schedule even for commercial use?

If the latter, then an engine beyond its calendar or hours TBO could, potentially, still be used for training.


Part ML being so new, I have, so far, not found a definitive answer to this. Can anyone shed light?CAP747_24_03_2020_extract_pdf
SJ
EGTR, United Kingdom

Mistral wrote:

If the latter, then an engine beyond its calendar or hours TBO could, potentially, still be used for training.

The answer is yes, Aircraft can be used for training beyond manufacturers recommendations. The IAA published updated guidance on this for our little EASA state yesterday.

https://www.iaa.ie/publications/docs/default-source/publications/advisory-memoranda/airworthiness-advisory-memoranda-(aam)/piston-engine-overhaul

A good example is the little Aerobat I bought before Covid. The engine was 2007 with 380hrs, and now that can carry on for flight training which is a welcome post covid surprise.

Buying, Selling, Flying
EISG, Ireland

Mistral wrote:

Part ML being so new, I have, so far, not found a definitive answer to this.

If the aircraft is operated commercially then operator has to contract a CAMO/CAO (or be one itself). ML.A.201(e)(1). That means that the maintenance programme must be approved by the CAMO/CAO. ML.A.302(a)(2). Typically the AMP is also developed by the CAMO/CAO. I expect that this approval must be done according to directives given by the Competent Authority (although I can find the paragraph stating that right now.)

That doesn’t mean that you have to follow the manufacturers’s schedule — it only means that the CAA must approve of any such deviations. E.g. in Sweden a 20% extension to engine TBO is normally permitted.

ESKC (Uppsala/Sundbro), Sweden

An interesting comment was made in yesterday’s EuroGA Zoom presentation, which was on Part-ML.

A freelance EASA66 mechanic cannot perform an “overhaul” but can perform a “repair” (which by definition is everything short of the full overhaul procedure in the MM). But if the actions which he performs are everything required for an overhaul, but it is logged as a “repair”, that is legal

I don’t think many owners will want to do the above, however, because everybody is so keen to get “zero timed” logbooks for resale reasons.

Administrator
Shoreham EGKA, United Kingdom
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