SR22 operating costs (and is the 10-year BRS re-pack mandatory under EASA)

So just out of curiosity, since I have no skin in the game… I am completely lost trying to follow this alphabet soup of organisations, rules, regulations…
Suppose I have an SR-22 on F-reg, and the chute is out of date. Can I legally fly it or not?

No. You cannot legally fly it with expired CAPS.

And same for G-reg?

Same. No.

I know that for N-reg I can’t.

Correct.

And I’m surprised that the rules would allow any other interpretation for any other reg, given that the type approval comes from the FAA.

Your surprise is warranted, as no such rules exist.

Snoopy wrote:

You cannot legally fly it with expired CAPS

According to EASA TCDS, you can

• CAPS is not mandated in N-reg by instructions, letters and bultin….it’s a requirement in FAA via TCDS (see ELOS for spins)
• CAPS is not mandated in G-reg or F-reg via TCDS, every kid who went to school can read TCDS and make their own mind

I did a read of EASA TCDS, CAPS is not there and in CS23, parachute is optional, that’s it: “nothing less, nothing more”, if you think they should put CAPS in CS23, go ahead and let them know

Now for manufacturer instructions for continued airworthiness (ICA), where on earth did you read that they are legally binding for SR22 in EASA land? can you show any legal reference? I have no dog in this fight (own and fly N-reg), however, you are doing huge disservice to GA claiming that whil disregarding changes in Part-ML, Part21, ELA, DOA…there was some simplification of certification, airworthiness and maintenance of light aircraft without lot of type holder obligations and privileges

For annual maintenance, you probably have a very valid point, finding Part145/M that signoff annual for SR22 without CAPS is impossible, the same applies for missing light bulbs (not required for Day-VFR). They usually confuse SR22 (fall under NCO, ELA, ML…) with TBM and CJ4

…out alphabet-souped again.

TCDS = type certificate? If so then there is only one, the one issued by the FAA. You can’t go round deciding that bits don’t apply based on the country of registration of the aircraft, unless it has its own country-specific type certificate, which nothing ever does.

johnh wrote:

TCDS = type certificate? If so then there is only one, the one issued by the FAA

Type Certificate (Data Sheet) which usually match AFM/POH limitations, there are two actually,

There is one for FAA, see ELOS page: CAPS is required for Cirrus spin !

https://drs.faa.gov/browse/excelExternalWindow/DRSDOCID192641915020231018140404.0001

There is one for EASA, well UK/EU did spin the heck out of Cirrus in 2006 !

https://www.easa.europa.eu/en/downloads/7512/en

johnh wrote:

You can’t go round deciding that bits don’t apply based on the country of registration of the aircraft, unless it has its own country-specific type certificate, which nothing ever does.

You have to read type certificate and supplementary type certificates,

• STC FAA but not EASA or STC EASA but not FAA
• Certified EASA but not certified FAA (e.g. DR400)
• Can fly IFR in EASA but not in FAA (e.g. Extra)
• Can’t fly without CAPS in FAA but can in EASA (e.g. SR22)
• Can fly UL91 under CS-STAN but for FAA it needs FAA STC
• Can fly NVFR N-reg but not F-reg

This create lot of frictions: some pilots believe limitations in FAA TCDS or limitations from manufacturer (ICA, MM, MEL)…do affect G-reg SR22? AFAIK, only FAA AD for SR2x will get automatically transposed as EASA AD (FAA being the state of manufacturer for Cirrus Aircraft)

For certification, I have not seen yet anything that state that manufacturer instruction, data, limitations…that are not in EASA TCDS do affect F-reg SR22

For maintenance, ask your maintenance !

Ibra wrote:

According to EASA TCDS, you can

Are you serious or trolling?

Your logic is flawed. You imply that because something is not mentioned in the TCDS, it doesn’t apply at all for the aircraft.
Example: Just because in the TCDS it says nowhere that a valid inspection and ARC is required doesn’t mean you can legally fly without.

Please refrain from stating that it is fine and legal to fly an SR2x without CAPS. It is not. The airworthiness limitation section (ALS) of the DAH (Cirrus) AMM (instructions for continued airworthiness) clearly states that CAPS must be serviceable. Without it, the aircraft is not airworthy.

Snoopy wrote:

Please refrain from stating that it is fine and legal to fly an SR2x without CAPS. It is not. The airworthiness limitation section (ALS) of the DAH (Cirrus) AMM (instructions for continued airworthiness) clearly states that CAPS must be serviceable. Without it, the aircraft is not airworthy.

You have not mentioned how manufacturer instructions are legally binding, yet you keep getting back trolling with this?

Ok, let me give you a hint, how about a screenshot of Part21 (the red that got removed is not mine). Are you saying, they should put these back for CAPS? For G-reg, I am not following that much, however, no such thing as mandatory manufacturer instruction under CAA,

We are talking about sub-2000kg here not TBM and Jets

johnh wrote:

So just out of curiosity, since I have no skin in the game… I am completely lost trying to follow this alphabet soup of organisations, rules, regulations…

EASA (the EU FAA equivalent) publishes easy access rules for maintenance (Part-ML for aircraft <2730kg) and operation (Part-NCO).

Your TB20 if used

• privately by yourself
• chartered out/for hire
• in a flying club (“club” for members, incl. club run DTO/ATO)
• in a commercial DTO/ATO (“open to the public”)
  is operated acc. Part-NCO and maintained acc. Part-ML.

If you want to do commercial air transport (CAT) with it, you need to operate acc. Part-CAT and mantain acc. Part-M. A 0,01% chance of this happening :)

If your TB20 is EASA registered, you must abide, for operations and airworthiness the the limitations listed in the

• EASA TCDS Type Cert Data Sheet (for this being an “EASA Product”)
• AFM/POH Limitations
• ICA (instructions for cont. airworthiness, = Daher Socata TB20 Aircraft Maintenance Manual, Chapter 4) published airworthiness Limitations.
• Similar limitations to the above if they were historically published under different terminology.

So
EASA = FAA
Part-NCO = Part 91
Part-ML = maintenance for Part 91 (incl. 141, …)

Part-ML rules applies for NCO flying with “non commercial other than complex” airplanes up to 2730kg.

Part-ML rules → more info here

EASA complex = twin turbine, 1 or more turbofan, multi pilot, 19 seats etc… (Cirrus SF50)
A TB20 is not a complex aircraft under EASA.

FAA complex = prop and gear (TB20, Piper Arrow…)
A TB20 is a complex aircraft under FAA.

Ibra wrote:

Instructions required by the certification specifications, such as the maintenance manual, the
MMEL, etc., are usually prepared
the type investigation process to comply with the certification requirements. These documents are covered by the type investigation process. The generation and publication of ir nation or instructions alated to continued airworthiness,
including updates to the abe:
mentioned ICA and MMEL and to any related design activity,
are handled according to the sa
principles as any type design, change design or repair desiga
activity/documentation if no separa
precess as per GM. 21.A.265(h) is defined. The
DOH should state how documents une
obligation are issued and distributed to the aircraft

Ibra wrote:

owner and to other interested parties. Using the change/repair proces:
be the simplest
way for small companies to de this: The approval of minor revisions to the AFM and its supplements should contain the following statement: ‘The technical content of this decument is approved under the authority of the DOA, ref.: EASA.21). XXXX). Such a change is treated as a change to the type certificate, as the AFM
is formally a part of the type certificate, and it is consequently classified on the basis of the
applicationofthemethoddefinedinresponsetoAMEEbANo21021.4.239(al,andidentified as being related to a miner design change. Administrative revisions to the AFM are alse expected to be classified as ’minor The following revisions to the AFM are defined as ’miner’
fevisters:
1. editorial revisions or corrections to the AFM;
2.
changes to parts of the AFM that are not required te be approved by EAS,

What does this have to do with anything?

Snoopy wrote:

The airworthiness limitation section (ALS)

I think you should refrain from referring to mandatory ALS by manufacturers (this stuff is only mentioned in CS25 aircraft like B737, see CS 25.1529, Appendix H25.4)

• You only need to comply with TCDS and AD limitations (and nothing else)
• You only comply with self declared maintenance program (you don’t have an approved maintenance program)