CS-STAN Iss. 04 CS-SC202c

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Michael Orf • 14 October 2022
in community General Aviation
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USE OF AVIATION GASOLINE (AVGAS) UL 91:

Hello EASA world, regarding CS-SC202c I do have a question for the experts:

in 3. of CS-SC202s it is defined how the conditions for Avgas UL91 are met.

So the issue:

Diamond DA40-180 with Lycoming IO-360 M1-A.

There is a SI (Service Instruction) from Lycoming: SI1070 dated 08-APR-2020, saying that the IO-360 M1-A is capable and officially released to use Avgas UL91 as fuel. BUT in the same SI under "CAUTION: Airframe approval necessary"

The TCH (DAI Canada, NOT EASA) does not have a STC using Avgas UL91 on the AC.

So, my question to the experts:

Is it possible with implementing CS-SC202c to officially overrule necessary TCH statement?

There are about 300 DA40-180 A/C in Europe and all of them will be grounded in the near future due to the fact that Avgas 100LL will not be available soon.

Looking forward to hear from the experts! 

Take care and always happy landings!

 

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Comments (7)

Jannes Neumann
Jannes Neumann • 1 year ago

First of all, we are talking about aircraft registered in an EU Member State only (for N-reg or Canada-reg you need to look at US respectively CAN requirements).

The use of an alternative fuel needs to be approved for both, the engine and the airframe (fuel system).
In this case the use of UL91 is EASA approved for the engine, since the Lycoming SI1070AB has been approved by EASA. This is visible in point 8. of the EASA TCDS.IM.E.032 where this Service Instruction 1070 is referenced.

With regard to the airframe, CS-SC 202c can be embodied to a given aeroplane as long as the use of UL91 is not explicitly excluded by TC-holder data (pls. refer to CS STAN.30). Please follow the entire instructions of the SC 202c that requires among others to establish an Aircraft Flight Manual Supplement.

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Michael Orf • 1 year ago

Hello Jannes,
many thanks for your thoughts on this issue. If I get it correct: the
CS-STAN "regulation" is able to relax/dismiss the airframe approval?
My issue is, that the engine is certified for using AVGAS UL91, but in the SI from Lycoming the sentence "Caution: Airframe approval necessary" is stated.
The (Non-EU) TCH is not interested in stating any approval, since they want to sell their STC, which will be available in the next comming years.
At the end, the question is, if CS-STAN is able to certify/state the usage of UL91 without dedicated airframe approval?
Release of the CS-SC202c is another topic, Part-ML with pilot-owner release...
And you are correct: we are talking about an EASA reg. aircraft, of course :-)
Stay healthy!

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Lars-Henrik Eriksson • 1 year ago

Michael, as I wrote above the whole point of this Standard Change is to act as the airframe approval. If a separate approval issued by the TCH was required, then there would not be any point of having the SC, would there?

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Torben Matzen • 1 year ago

A supplementary question... in case UL91 is not available but UL94 is, could this somehow be covered by CS-SC202 in the future?. Currently I have the information from AOPA-DMU Denmark, that CS-SC202 does NOT include UL94. Both UL91 and UL94 are however following the ASTM-D7547 specification, so my guess is that UL94 did not exist when CS-SC202 was published, and I hope that UL94 could be included in the future.

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