Primarily for general aviation discussion, but other aviation topics are also welcome.
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By GrahamB
FLYER Club Member  FLYER Club Member
#1650805
I'm completely confused by the current situation regarding what is and isn't a 'Commercial' operation on an EASA type.

My ELA1 aircraft aircraft has an engine with 1000 hours since zero-timing (2000 hr TBO), but it is 13 years since that took place. It is on an SDMP, as has been required for the best part of a year. I understand that initially only ELA1 non-training operations were required to move to the SDMP, but that is now or soon will be the case for any ELA1 and ELA2 including those used for training.

1) Can it be hired out for self fly private use?
2) Can it be hired for training within an ATO (not ab-initio, but IR(R) training, say)?

Please no discussions on wisdom or otherwise of renting out aircraft, I'm just trying to establish the facts in this ever-changing world.
#1650808
Join the club.
I thought this was all supposed to be sorted out with Part M Light which was due to be published years ago. I thought that would allow flying schools to operate with engines that were maintained on condition and therefore gives us a better definition of what they mean as "commercial".
Look at the page on the CAA for SDMP and it tells you the answers.
By LysanderV8
FLYER Club Member  FLYER Club Member
#1650842
My understanding is that the aircraft cannot be used for hire or reward if the engine is on condition. That applies to individual hire or to rental via an ATO.

We have an aircraft ,with an engine on condition, which is owned by a company and flown by the shareholders. It cannot be flown by anyone other than a shareholder.
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By Dodo
FLYER Club Member  FLYER Club Member
#1650980
I am in the same position (EASA CofA a/c. Engine 1600 hrs but 17 years since new) and I am afraid that the advice given by Lysander V8 seems to in line with what I have been told. ie. It is not acceptable to operate an engine like this in a flying school environment. (Now I may be wrong and would be very happy to be corrected as it would make my aircraft rather more valuable).
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By GrahamB
FLYER Club Member  FLYER Club Member
#1651163
Thanks for your opinions. A bit more digging reveals:

Issue 1 - SDMP. It would seem that at the moment, the CAA regard ATOs, RTF, and DTOs as 'commercial' and thus an SDMP is not acceptable - it would be under Part M Light, but as yet there is no date for that reaching the statutes. The ways round that would seem to be either to go back to a LAMP or convert the SDMP to an 'approved' MP. The former seems ludicrously simple, as I still have the previous Blue Book!

Issue 2 - 12 year engine life. Under AMC 20 Amendment 10 - it would seem that there is scope for extensions, but the requirement would have to be declared in the MP, which I assume means the LAMP option above would be out, so an approved MP would be required.

Anyone been through the approved MP route? It doesn't sound like an attractive option, and I have an aversion to scrutiny by a regulator - and given the state that the CAA seem to be in it would probably take months if not years.
#1651366
@GrahamB you asked "1) Can it be hired out for self fly private use? "

The answer is yes if each of the hirers has a beneficial interest in the aircraft, i.e. a share with some value. Look at this on the CAA website. You no longer have to have equal shares and there is no limit on the number of shareholders within reason. You would be a Trustee. If you are an AOPA member use the Ask AOPA form for any more advice.
#1651648
I believe the sticking point is that the CAA interpret flight training as a commercial operation. Although other EASA states dont.

So countries like Sweden allow aircraft that are on condition to be used for flight training.

I just think the whole lot is a bit of a mess and doesn't strike me as easy to understand.