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

Attached a copy (.pdf) and screenshot of the Cirrus SR series EASA Cirrus Type Certificate Data Sheet clearly stating “including airworthiness limitations”.

TCDS_EASA_IM_A_007_Issue_17_pdf

always learning
LO__, Austria

Sorry, I gave up: you are right, you brilliantly proved us that any service instruction from Cirrus Aircraft is mandatory for F-reg or G-reg SR22 according to the way how you managed to read an EASA Type Certificate !

Now time to pull your wallet that would be anything from chute repack to expired light bulb

Last Edited by Ibra at 20 Jun 15:20
Paris/Essex, France/UK, United Kingdom

I have no horse in this race, but a very interesting discussion
If I understand correctly the SR22 certification, in terms of spin recovery under EASA was different to FAA,
Q: does the MM reflect the difference?

On a wider subject: can a manufacturer under EASA regs back door limitations via entries in MM?

Poland

This is all way above my head. In general I’m all for as littlre regulation as possible, but surely if the manufacturer says – and the country in which the aircraft has itys primary certification says in the type approval – that a parachute (or an inflatable Simon’s Cat sitting on the glareshield, or whatever) is required for airworthisness, how can some other authority come along and say, “not ‘ere it ain’t, mate”?

How about countries which are neither FAA or EASA (I understand there are a few)? Can I take my SR22 to Australia and fly it VH-reg without either a chute or a vertical stab, since the Australian non-document doesn’t say anything about either?

(By the way my TB20 is N-reg, although since the original certification is French, I guess it’s still subject to some level of EASA regulation).

LFMD, France

Part-NCO = Part 91

This is an aside but the above is not true especially when you get the details like this where N-reg / Part 91 has big advantages. This will be true for an SR22, TB20, etc and has a big impact on costs IF properly utilised.

Whether your maint company will agree is a different matter and is totally off topic; we’ve had plenty of threads on commercial explotation of the “aviation paperwork route”; one company owner who did the whole Socata MM said to me “I am in business to make money, not run Part 91”. And the topic here (SR22) will be almost always company maintained.

This is partly why almost nobody on N is moving to EASA-reg. The only cases I know of have been where the pilot got pushed into the FAA Special Issuance medical route which

  • suffers from few FAA AMEs in Europe willing to be bothered with the extra work
  • is more fussy in certain areas like certain cancers

or where he was selling the plane due to packing it all in (in Europe, an EASA-reg SR22 fetches a higher price nowadays than an N-reg one).

can a manufacturer under EASA regs back door limitations via entries in MM?

If you are referring to the FAA policy of blocking “purely commercially explotative” Limitations entries, then Yes; EASA has no equivalent policy.

By the way my TB20 is N-reg, although since the original certification is French, I guess it’s still subject to some level of EASA regulation

Only if you are using a maintenance company which wants to maximise revenue. Under Part 91, there is no original (DGAC) influence other than what Socata+DGAC managed to pack into Limitations, and the FAA accepted.

that would be anything from chute repack to expired light bulb

Are light bulbs in the SR22 Limitations section?

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

Are light bulbs in the SR22 Limitations section?

There is a service instruction on light bulbs from Cirrus, the TC makes it mandatory (if I read TCDS like Snoopy suggested)

RV14 wrote:

On a wider subject: can a manufacturer under EASA regs back door limitations via entries in MM?

Not for light aircraft (sub-2000kg, ML, ELA, NCO, SDMP), the changes need to go into original TCDS or imposed via AD
Your maintenance shop may have different opinion when aircraft comes to annual
In meantime, feel free to fly !

Last Edited by Ibra at 20 Jun 16:40
Paris/Essex, France/UK, United Kingdom

Peter wrote:

This is an aside but the above is not true

You misunderstand. My post was meant as an explanation to John for FAA vs EASA, in other words what the EASA equivalent of Part 91 operation is… NCO.

always learning
LO__, Austria

@Ibra,

again:

Under EASA (Part-ML, NCO) it is mandatory to follow

TCDS Limitations
AFM (POH) Limitations
AMM Airworthiness Limitations
ADs

CAPS is a limitation.

The lightbulb you quote is not in the airworthiness limitations section of the AMM. As such it is not a limitation and not mandatory. Also any kind of TBO Service Bulletins, Service Instructions etc.. are no mandatory (Part-ML/NCO/private owner).

I think at this point it is better to agree to disagree. You are convinced a Cirrus SR2x can be flown without CAPS. I am convinced it cannot. The end.

Last Edited by Snoopy at 20 Jun 17:10
always learning
LO__, Austria

Snoopy wrote:

Also any kind of TBO Service Bulletins, Service Instructions etc.. are no mandatory (Part-ML/NCO/private owner).

You said TCDS makes these mandatory under ‘Operating & Service Instruction
You can’t cherry pick on CAPS vs Bulbs, either you take the whole pack? or leave all of it?

AFM, ICA, AMM, MMEL…limitations are only legally binding when they are listed as limitations in the certification (TCDS and STC), see Part21 – SubpartJ

Most of manufacturer instructions are about product liability, it’s between your and manufacturer: if Cirrus, says in AFM limitation your need CAPS (or can’t lean), you can fly without CAPS (or lean) at own risk, it may invalidate your warranty or product insurance, however, the EASA will not come after you, they only care about limitations in TCDS (aka Chap2 of AFM !)

For maintenance, my opinion and yours are worth nothing when some pilot receive their book of work invoice for SR22 annual from Part145 shop at the end of the year, they will tell him if they want his CAPS re-packed in pink, then when it comes to payday, they will pull his wallet…

Last Edited by Ibra at 20 Jun 17:00
Paris/Essex, France/UK, United Kingdom

Ibra wrote:

You said TCDS makes these mandatory under ‘Operating & Service Instruction’

I meant the actual Service Instructions by the manufacturer are not mandatory (e.g. Service Bulletin, Service Information etc..) and not a TITLE containing the same words in the TCDS (which obviously means something completely different).

Again, obviously, the words “Operating and Service Instructions” as contained in the TCDS, listing the

  • AFM
  • AMM AWL

mean something different and mandatory as opposed to e.g. this which is voluntary (unless it is an AD):

@Ibra I am curious, why do you believe the Cirrus SR2x can be flown without CAPS legally? Can you elaborate your thought process?

Last Edited by Snoopy at 20 Jun 17:19
always learning
LO__, Austria
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