Tuesday 10 December 2013 06:53 UTC
Polite discussion about EASA, the CAA, the ANO and the delights of aviation regulation.
Please keep it polite!
Also you can build a much "more useful" aeroplane in 750kg than in 600 or 650kg.
But if it is subject to the full Part M, a lot of the advantage is lost. I have been reading some stuff on the US system and apparently LSA is worse than normal CofA because the FAA approved generic repair regime cannot be used on LSAs.
Within the LSA arrangments it is all tied to the manufacturer.
It is the manufacturer that states the design is compliant with the LSA design code and so it is them that have control over the repair, maintenance etc. As people have become more familiar with it in the US these negative aspects have become much more apparent. The real difference is for E-LSAs - where in the US an E-LSA is subject to a large number of restrictions from the manufacturer - who act much like the LAA does here. So for instance an E-LSA certified RV12 has a very restrictive set of criteria when compared with the standard experimental version.
In the UK subjecting VLA to Part M pretty much scuppers them as far as I can see - there is no 'advantage' in terms of an 'easier' design code, medical, licence......
Certified European LSA Aircraft will also be subject to Part M
Manufacturer control of airworthiness (instead of Certification Authority control which is what one has under ICAO) is very bad because the mfg has a financial incentive to screw customers around at every stage.
You get "non-mandatory" SBs all the time there are lots of affected airframes in-warranty (which means the dealer is not obliged to apply them under warranty, and can even ship brand new aircraft without them), and when the warranty runs out, subsequent SBs become "mandatory". Great stuff.
I suppose the main plus here is that finally the PPL flight training business might get a replacement for the ageing C150/152 fleet (C162).
That hasn't been the US LSA experience so far.
Under FAR Part 91 (N-reg) only ADs are ever mandatory.
But what is the position under E-LSA?
I have long lost track of the UK CAA (and now EASA Part M) position on SBs/MSBs... AFAIK EASA is mandating component life limits, unless a case is made by the CAMO to counter the requirement. What happened on the seat belt business?
VLA has a number of big advantages over LSA as specified in the US. As well as the bigger weight limit there is no speed restriction, no “complex” restrictions and the wing loading is often higher giving a much better ride in turbulence. Add in home built aircraft tested to VLA standard and you get the option of cheaper maintenance and lower airframe cost together with much more freedom on how you kit the aircraft out.
Peter, SBs are not mandatory in EASA land, ADs are. EASA/NAA surveyors have a tendency to interpret recommendations in manufacturers maintenance manuals as compulsory unless an AMC had been successfully argued, this is where the things like the seatbelt stuff comes from - it has nothing to so with SBs.
The first 'airworthy' issue with US LSAs that I am aware of was the Zenair 601xl. The LSA owners had to pay the factory for the upgrades. The E-LSA owners had to implement the modifications on a mandatory basis. The experimental owners picked and chose and some did not modify - although to be fair most did.
In comparison the LAA modifications were quite reasonable - if only becasue they were designed for retrofitting where the Zenair mods were all about getting to a common design status (between old and new).
In a European context it doesn't really bare thinking about. One of the people at the club has had to buy a 'certified' plywood bulkhead for a repair. Material cost - about £40 if cut and laminated from a drawing. Cost with the appropriate form 1? Over £1000!!!!
Unfortuately, under Part M, SBs are indirectly mandatory - that is the real problem with Part M. If you are under continuing airworthiness, you have to maintain the aircraft according to an approved maintenance programme [Part M.A.302 (i)]. This maintenance programm has to comply with the instructions of the type certificate holder [M.A.302.(d)(ii)], which in EASA interpretations includes all manufacturer recommendations and all SBs. You can deviate from this and propose something different [M.A.302.(d)(iii)], but this has to be approoved by a CAMO+, and if it affects safety-related service intervals, it has in addition to be approved by the CAA. Examples include the recommended replacement of seatbelts in Cessnas (Cessna says 10 years). If you want to do the sensible thing - inspect the seatbelts and repair/replace them as neccessary, this needs CAA approval!
So yes, feel free to design your own maintenance programme, but be prepared for a lot of paperwork, and fees.
Or just use the N-Reg.
We have now had 3 meetings of the EASA Part M Task Force to address the various issues raised by the 'industry' over the last few years and in particular at the workshop in Cologne last October.
In phase 1 of our work we have tackled, inter alia, the question of approved maintenance programmes. In a nutshell the forthcoming NPA (hopefully next month) will propose owner/operator 'self-approved' standardised minimum maintenance programmes for each category of aircraft (i.e. aeroplanes, sailplanes, balloons. Helicopters left to phase II work) within the ELA 1 definition - up to 1200 kg MTOM, and used non commercially. The reason for this boundary so far is simply the phased approach we've adopted to considering all the complex issues, using a 'bottom-up' approach. The NPA will provide the standard templates, to which can be added anything a particular type of an aircraft requires and not covered by the standard template. These templates will be an alternative to adopting the manufacturer's maintenance programmes where they exist, and the choice will be with the owner / operator. Individual MMPs using the template, will not require approval by the CAA, under our proposals.
But also, we have discussed the question of interpretation by NAAs etc of what is mandatory and what is not for maintenance purposes. Clarification will appear in the NPA, and essentially a mandatory requirement has to be in the form of, e.g. an AD or life limit for a part.
That will be great - hope it takes less than 15 years to filter down to the surveyors working in the field
Good for the <1,200 crowd. Small step in the right direction for everyone else. The 10 years on seatbelts are a life limit, the 5 years on magnetos and 6 years for prop overhaul and 12 years on engines are all life limits. Unless it allows inspection-and-repair-as-neccessary (IRAN) at these life limits, the EASA regulation will remain detrimental to safety. Many parts have significant infant mortality (many who has ever replaced a vac pump or an alternator can attest to this, and engines fail a lot more in the first 100 or so hours after new or overhaul).
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