Primarily for general aviation discussion, but other aviation topics are also welcome.
#1795999
Having just spent 2 hours trawling through the ANO 2016 I still can't find the definition of "Commercial Operations" as applicable to EASA aircraft. Does anyone by chance have a direct link that would help?
I need to properly understand how and which parts of GR24 would apply to me at this time, I'm sure things will change when we leave EASA but for the time being.....................

Many thanks for any assistance.
#1796017
Seemingly not;
GR no 24 para 1(d) reads;

"Following the introduction of Part M Light (Part-ML) under Regulation (EU) 2019/1383 which became applicable on 24 March 2020 this GR does not apply to EASA aircraft types."

My issue is still whether or not renting out my (EASA) aircraft costitutes "Commercial Ops" or not, and whether I can apply an extension beyond TBO to my AMP
#1796030
Personal view - purely on the definition of “commercial”, self fly hire alone does not count.

I am not sure what the CAA view is on this though and I’m not familiar enough with Part-ML to know what the implications of being commercial or not are.
#1796078
My issue is still whether or not renting out my (EASA) aircraft costitutes "Commercial Ops" or not, and whether I can apply an extension beyond TBO to my AMP

Why not just write to the Authority and ask for clarification? If they write back saying “no problem” then you’re bulletproof.

The Mo Salah case should make everyone tread very carefully indeed.
#1796097
Gas Guzzler wrote:Seemingly not;
GR no 24 para 1(d) reads;

"Following the introduction of Part M Light (Part-ML) under Regulation (EU) 2019/1383 which became applicable on 24 March 2020 this GR does not apply to EASA aircraft types."

My issue is still whether or not renting out my (EASA) aircraft constitutes "Commercial Ops" or not, and whether I can apply an extension beyond TBO to my AMP


It was never intended that rental would come under commercial operations. The definition includes "which is performed under a contract between an operator and a customer". If the operator is the same person as the customer, there is no such contract, even if there is a contract between the owner and the operator/customer.

Under Part-ML, the AMP is declared by the owner or approved by a CAO/CAMO, the latter being the only option for commercial operations and "commercial" training organisations. There is no mechanism for an NAA to set out a generic requirement like GR24. The recommendations of the manufacturer with respect to engine overhaul are not mandatory.
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#1796107
Thanks all for your input, having now trawled through the EASA document on Part-ML I am now happy to continue on the basis that a risk based assessment is being adopted to ensure engine integrity. I did also ask AOPA and their take on it is the same, happy days! and thanks again.
#1796193
It was never intended that flying instruction would come under commercial operations and that's certainly what EASA stated.

However the CAA state that flying instruction is a commercial operation and because of this aircraft engines used by flying schools cannot be operated on extension.

Now as GR24 extension no longer applies to EASA aircraft flying schools can no longer obtain 20% extension to TBO.

It's a mess.
#1796202
I've had it confirmed by AOPA this evening that my renting to other pilots is pemissible under Part M lite. The full details can be found here https://www.easa.europa.eu/sites/default/files/dfu/Easy_Access_Rules_for_Continuing_Airworthiness-June_2020.pdf if you want to trawl though it. Or use the PDF search facility. From what I can see schools can use this too.
#1796354
It was never intended that flying instruction would come under commercial operations and that's certainly what EASA stated.

However the CAA state that flying instruction is a commercial operation and because of this aircraft engines used by flying schools cannot be operated on extension.


That's not correct. Flying instruction is not a "commercial operation" as such. The complication is that Part-ML puts a "commercial" ATO/DTO in the same category as a commercial operation in that the owner cannot self declare an AMP: it must be approved by a CAMO/CAO. But the CAMO/CAO can use the same principles as the owner would have used to develop the AMP. If they want to do something different from the manufacturer's recommendations, they need to record a justification. I would have thought that the successful application of GR24 is justification enough!

The requirement for a CAMO/CAO for "commercial ATO/DTOs" was snuck in by the member states at EASA Committee (at which EASA itself is a mere observer) without consultation with the GA community. It caused a serious row, but it is now law.

ML.A.201
(e) For aircraft operated by commercial Approved Training Organisations (‘ATO’) and commercial Declared Training Organisations (‘DTO’) referred to in Article10a of Regulation (EU) No 1178/2011 or not operated in accordance with Annex VII to Regulation (EU) No 965/2012 (Part-NCO) or operated in accordance with Subpart-ADD of Annex II (Part-BOP) to Regulation (EU) 2018/395 or Subpart-DEC of Annex II (Part-SAO) to Regulation (EU) 2018/19761, the operator shall:
(1) be approved as a CAMO or as a CAO for the management of the continuing airworthiness of its aircraft in accordance with Annex Vc (Part-CAMO), Subpart G of Annex I (Part-M) or Annex Vd (Part-CAO), or contract such an organisation using the contract set out in Appendix I to this Annex;

ML.A.302(c)
The AMP:

(8) when approved by the CAMO or CAO, shall be signed by this organisation, which shall retain records with the justification for any deviation introduced to the DAH’s recommendations;
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