[Deans894]

Hi,

Im looking to potentially purchase a LSA aircraft which is on an EASA Permit to fly and i am concerned about a couple of things. The aircraft is 1 of 2 in the UK and there was only 37 built. The company has gone bankrupt and having spoken with the aircraft designer there is no spare parts so all parts would need to be manufactured by myself. As far as I have spoken with the LAA to see if i could get the aircraft moved onto the LAA as orphaned aircraft but im told thats not possible. Could i have your thoughts on this please. I was hoping not to name the aircraft type if at all possible. Thanks

EASA have responded with the following:
Thank you for contacting EASA. I am the PCM for this aircraft and I can confirm there are 4 serial numbers under EASA flight conditions for Permit to Fly and these approvals are unlimited in time, they are permanent flight conditions restricted to non-commercial operations. The owner is responsible. We have not identified any safety issue as of today.

The maintenance regime and replacement parts are stated in the Form 18b for each aircraft, please find attached the template of Form 18b we have used for these approvals in the UK. As you can see in the Form:

• Maintenance to be done in accordance with Part M
• New spare parts are not required to have an EASA Form 1 but proper documentation shall be available. The owner is responsible for accepting the part, more guidance in this Certification Memorandum whose scope is extended to ALL NEW PARTS by the Form 18b: https://www.easa.europa.eu/system/files ... A_PUBL.pdf

The main difference with a normal Certificate of Airworthiness is that these airplanes are not certified, they have not showed compliance with a set of certification specifications, they have showed they are capable of safe flight and landing. The legal difference is also important, the manufacturer are not responsible for the design or continued airworthiness. If there are safety problems or accidents the owners will need to find a solution or the fleet could be grounded in the worst case.

Regarding the possibilities to cancel the EASA flight conditions and move the aircraft to Annex II (experimental aircraft, homebuilts …) under the responsibility of the UK-CAA, you should contact them for agreement as it is the Member State’s decision weather to accept an aircraft in Annex II. I copy my colleagues Shanine Rockhill and Steve Standing from the UK-CAA, please contact them for more information.

[joe-fbs]

I've done two non-permanent EASA PtF for new designs and the team tha do it are good to work with. Reading that response above you are dealing with the same people and they are being very positive and helpful. I can also say from experience that the two UK CAA people named above are also excellent. In summary it seems to me that you'll be fine. If you want to discuss details then please feel free to PM me.

[Deans894]

Hi Rob, That's great to know. The way i understand that email is that if a part needs replacing id have to manufacture it myself and then get it signed off. But will they definitely accept it and would an engineering company be happy to sign it off? The aircraft is in excellent condition and i'm really interested but concerned about some of these issues.

[joe-fbs]

I've scan read the CM and I think you are making things more difficult than it says but I need time to study it properly.

BTW the contact name at the bottom of the CM had not been at EASA for about three years, he's my immediate boss at HAV!

[joe-fbs]

What follows should be treated with all the caution of any other opinion posted on-line. I don’t know enough about your case to be certain that my thoughts below are valid. Key points about / from the document:

1. It is guidance not law
2. The preamble says that it was expected to be superseded by a rule-making task. That needs checking.
3. The responsibility for choices lies with the owner not the maintenance person, the manufacturer, EASA or the local aviation authority. If you are not competent in design engineering then you might want to take advice from someone is. (I use competent here in its normal usage not the EASA usage).
4. Advice: get as much documentation as you can from the current owner and whoever currently has access to the former manufacturer’s records. You particularly need if at all practical, the AFM, AMM and IPC. Any other design information you can get will be useful. All this is to get you as much information as possible about what processes, parts and materials were used and where they were sourced.
5. Part M has been eased a lot for ELA since the memo was written, even for certified aircraft never mind one on a permit.
6. When UK CAA issued our EASA permits (EASA issues the Flight Conditions, the local authority issues the permit), part of the CAA application form was to specify the maintenance regime so if the system is the same for non-expiring permits you have some flexibility there.
7. You need to study the Form 18 very carefully then complete it very carefully. To get to the Form 18b you need to download form 37

https://www.easa.europa.eu/document-lib ... -downloads

8. There are probably people out there more familiar with this type of thing than I am, my experience is in rather different cases but might help a bit.

Good luck.

[User72]

I would give this aircraft a wide berth as I suspect it will be costly from the start. You must establish a close working relationship with the person who will sign off the aeroplane. That person will have to be specifically approved for that aircraft type by CAA, at an annual fee of between £200 & £700 (which you will have to pay). With no factory support any minor ding will become a major headache. Few maintenance organisations (who most of the people who might be approved by CAA will work for) will want to know you - your aeroplane will just be too difficult. Although you (or your maintained) may be permitted to make parts - and I'm not sure that is how the CAA will look on it - what data will you go manufacture the parts? How will you persuade the person signing off the aeroplane that the part you have made is airworthy? Once you are fed up with the aeroplane what will the resale value be? I would find a different type.

[Deans894]

Ill have a rethink! Thanks for all your help