Continental diesel engines can run 'on condition'
Whilst not really 'new' this change, which is particularly notable for private owners who may fall well short of 2,100 flight hours over 12 years, appears not to be widely known or understood, hence this notice.
Because Part 21 aircraft, of which the Robin CDI is an example, are no longer subject to GR24 of CAP747, which mandated engine time before replacement (TBR), under a self declared maintenance program (SDMP), or CAO approved AMP with justification in the case of flying school aircraft, Continental diesel engines fitted to Robin aircraft are no longer limited to a 12 year TBR and can continue to be run 'on condition' up to, and possibly even beyond, their 2,100 hour service life. Owners of Robin CDI aircraft may, therefore, wish to discuss with their maintenance workshop having their aeroplanes transferred onto a SDMP or CAO approved AMP at the aircraft's next 100 hour / 12 month check.
Whilst Continental has stipulated engine life in service bulletin (SB) TAE 125-0001, SBs are not mandatory, although they should be considered in the formulation of an AMP. GR24 of CAP747 disallowed running 'on condition' for several engine types, including Continental diesels, whilst allowing it for avgas engines in private use, because the affected engine types, at the time, had "yet to demonstrate acceptable reliability when operating at the manufacturers' recommended overhaul period." When Part M Light (Part-ML) under Regulation (EU) 2019/1383 came into force on 24 March 2020, however, GR24 no longer applied to EASA aircraft types, paving the way for the Continental diesel engines to be run 'on condition.'
A private owner can, therefore, use a SDMP and show that SB TAE 125-0001 is not being adopted with no further justification needed. A flying school aircraft needs to be on a CAO approved AMP and so it is at the discretion of the CAO as they do need to make a justification / safety case as to why they are not following the design approval holder's instructions for continued airworthiness (ICA). Sending oil samples for analysis is commonly used for the purpose.
The SB remains, it is just no longer being adopted under Part-ML, so when supplying parts for an engine over TBR, Continental Diesel will require a waiver signed by the aircraft owner.
Because Part 21 aircraft, of which the Robin CDI is an example, are no longer subject to GR24 of CAP747, which mandated engine time before replacement (TBR), under a self declared maintenance program (SDMP), or CAO approved AMP with justification in the case of flying school aircraft, Continental diesel engines fitted to Robin aircraft are no longer limited to a 12 year TBR and can continue to be run 'on condition' up to, and possibly even beyond, their 2,100 hour service life. Owners of Robin CDI aircraft may, therefore, wish to discuss with their maintenance workshop having their aeroplanes transferred onto a SDMP or CAO approved AMP at the aircraft's next 100 hour / 12 month check.
Whilst Continental has stipulated engine life in service bulletin (SB) TAE 125-0001, SBs are not mandatory, although they should be considered in the formulation of an AMP. GR24 of CAP747 disallowed running 'on condition' for several engine types, including Continental diesels, whilst allowing it for avgas engines in private use, because the affected engine types, at the time, had "yet to demonstrate acceptable reliability when operating at the manufacturers' recommended overhaul period." When Part M Light (Part-ML) under Regulation (EU) 2019/1383 came into force on 24 March 2020, however, GR24 no longer applied to EASA aircraft types, paving the way for the Continental diesel engines to be run 'on condition.'
A private owner can, therefore, use a SDMP and show that SB TAE 125-0001 is not being adopted with no further justification needed. A flying school aircraft needs to be on a CAO approved AMP and so it is at the discretion of the CAO as they do need to make a justification / safety case as to why they are not following the design approval holder's instructions for continued airworthiness (ICA). Sending oil samples for analysis is commonly used for the purpose.
The SB remains, it is just no longer being adopted under Part-ML, so when supplying parts for an engine over TBR, Continental Diesel will require a waiver signed by the aircraft owner.
