Cheapest engine overhaul or used engine? (TCM IO-360-D) - Czech CAA demands a Form 1 for an already installed engine, and registry transfers

@Jelen

Why do you think those national CAAs of EU member countries, which you listed, can decide how they do things themselves?

This stuff is all EU law, and unless there are derogations in place, it is to be done the same way all over the EU.

To clear some questions, engine is not the original one. It has been removed from D-ECQE prior to sale. It was (is) a project plane. Anyway D-ECQE was meanwhile sold to Russia and all logs are gone now, and never can be reachable again. I believe it was original engine in D-ECQE.

OK; I suspect the Czech CAA thinks the engine was extracted from a plane which was

• unairworthy at the time, and
• transferred without paperwork being regenerated

Both of these are a “red rag to the European bull”. The 1st one is basically bogus… why can’t you remove a door handle from a plane which was force-landed, or had its CofA expire? It’s bollocks! But it has produced an extremely lucrative business in stripping down old jets and flogging off the parts, with an EASA-1, for silly money. A lot of Socata parts sold by them today come from reclaimed parts.

I am not saying this because I am Czech but prob99 the Czech CAA is fairly smart – or at least tries hard to cover their ar*se. Many years ago I asked them re a transfer of my N-reg TB20 to the OK-reg (for a complicated reason to do with some proposed EASA regs). They emailed me back a huge long email, with all kinds of interesting stuff like being quite specific that the UK IMC Rating could not be used in an OK-reg (which may or may not have been legally true; the UK has no such restriction and why would CZ pass such a stupid law?) and they said that no other TB20 was on the OK-reg (which was definitely untrue) so the process would be “very complicated” and they sent me about 50 pages of documents on what I would need to do… I didn’t bother

This thread is worth a read. There are some posts there which I would regard as disingenuous (the European maintenance business doesn’t like practices which reduce revenue, obviously) but the general drift is fairly clear.

I think that every single NAA can tighten up the rules. They can’t loose them up, but can be more strict

It’s more or less the opposite. But if they depart too far, Brussels can take action. But only against a bigger target, so e.g. Ireland can do stuff which Germany would not get away with. France would be somewhere between the two

Snoopy wrote:

Why do you think those national CAAs of EU member countries, which you listed, can decide how they do things themselves?

This stuff is all EU law, and unless there are derogations in place, it is to be done the same way all over the EU.

In theory yes – in reality the law is a collection of words printed on a piece of paper and it is fully in the responsibility of the local CAA to construe these words and to act accordingly. Even given the same words different CAAs could have different interpretations. And as the EASA (in contrast to popular belief) is not a superordinate agency to the local CAAs there is no direct way that EASA can enforce that a CAA acts according to their interpretation.

Therefore if someone beliefs that the local CAA is not acting within the limits of the EU regulation, he pull the CAA first in front of the local courts or finally in front of EuGH. This is, however, time and resource consuming and therefore is rarely worth the effort for private individuals.
The only other way is that EASA tries to persuade the Commission that it takes action against the member state (the EASA itself has no lever to do it) and then again have that taken in front of the EuGH.

I don’t know, I think that every single NAA can tighten up the rules. They can’t loose them up, but can be more strict.

No. That’s called gold plating and it’s precisely what isn’t allowed.

In theory yes – in reality the law is a collection of words printed on a piece of paper and it is fully in the responsibility of the local CAA to construe these words and to act accordingly. Even given the same words different CAAs could have different interpretations. And as the EASA (in contrast to popular belief) is not a superordinate agency to the local CAAs there is no direct way that EASA can enforce that a CAA acts according to their interpretation. Therefore if someone beliefs that the local CAA is not acting within the limits of the EU regulation, he pull the CAA first in front of the local courts or finally in front of EuGH. This is, however, time and resource consuming and therefore is rarely worth the effort for private individuals.
The only other way is that EASA tries to persuade the Commission that it takes action against the member state (the EASA itself has no lever to do it) and then again have that taken in front of the EuGH.

As you say, in theory. Practically the NAAs clarify the IR and AMC with EASA and things are very much more streamlined than this thread makes them out to be.