**Executive Summary**
This document proposes amendments to CAR Section 8 Series S Part I, which outlines the requirements for Extended Diversion Time Operations (EDTO) for Commercial Air Transport. The amendments detail maintenance program requirements, propulsion system reliability, and continuous airworthiness maintenance. The updated text is shown with deleted text marked with strikethrough and new or amended text highlighted in grey.
**Key Points / Main Content**
* **Eligibility for EDTO:**
* Airframe/engine combinations must be certified to Airworthiness Standards by FAA (FAR25), EASA (CS25), or other regulatory authority acceptable to DGCA.
* **Maintenance Program:**
* Ensure titles and numbers of airworthiness modifications made to qualify aeroplane systems for EDTO are provided to DGCA.
* Submit changes to maintenance and training procedures related to EDTO to DGCA before adoption.
* Develop and implement a reliability monitoring and reporting program before approval and continuously after.
* Implement required modifications and inspections that affect propulsion system reliability promptly.
* Establish procedures to prevent dispatch for EDTO after engine shutdown or EDTO significant system failure until the cause is identified and corrected.
* Establish a procedure to maintain airborne equipment at the required performance and reliability level.
* Establish a procedure to minimize scheduled or unscheduled maintenance on more than one parallel or similar EDTO significant system during the same maintenance visit.
* Establish a procedure (placard/marking) to indicate to maintenance and flight crew EDTO status.
* **Propulsion System Reliability:**
* Establish firm criteria for action when adverse trends in propulsion system conditions are detected.
* When the propulsion system IFSD rate exceeds specified limits, accomplish immediate evaluation and forward report to DGCA.
* Compile necessary data on propulsion system reliability, including:
* List of engine shutdown events.
* Unscheduled engine removal rate and summary.
* Total engine hours and cycles.
* Mean time between failures of propulsion system components.
* IFSD rate based on 6 and 12 months rolling averages.
* Any other relevant data.
* **Continuous Airworthiness Maintenance Programme (CAMP):**
* Develop and comply with an EDTO continuous airworthiness maintenance programme, approved by DGCA and endorsed in Operator's operations specifications.
* Include an EDTO manual for use by personnel involved in EDTO.
* Develop a pre-departure service check tailored to the operator's specific operation.
* Appropriately trained and EDTO qualified maintenance person must accomplish and certify EDTO specific tasks. Before an EDTO flight, a EDTO pre-departure service check (PDSC) Signatory Person shall certify by signature, that the EDTO PDSC has been completed.
* **Limitations on dual maintenance:**
* Except in specific instances, scheduled or unscheduled dual maintenance on similar EDTO Significant Systems is prohibited during the same maintenance visit.
* **Verification programme:**
* Develop and maintain a programme for the resolution of discrepancies to ensure the effectiveness of maintenance actions taken on EDTO Significant Systems.
* **Task identification:**
* Identify all EDTO-specific tasks and have them accomplished and certified by a trained AME.
* **Centralized maintenance control procedures:**
* Have a centralized entity responsible for monitoring of the EDTO maintenance activities.
* **Parts control program:**
* Develop an EDTO parts control program to ensure the proper identification of parts used to maintain the configuration of aeroplanes used in EDTO.
* **Reliability program:**
* Have an EDTO reliability program to report specific events to the regional/sub-regional office within 72 hours.
* **Propulsion system monitoring:**
* If the IFSD rate exceeds specified values, the operator must do a comprehensive review of its operations.
* **Engine condition monitoring:**
* Have an engine condition monitoring program to detect deterioration at an early stage and to allow for corrective action before safe operation is affected.
* **Oil-consumption monitoring:**
* Have an engine oil consumption monitoring program to ensure that there is enough oil to complete each EDTO flight.
* **APU in-flight start program:**
* Develop and maintain a programme acceptable to DGCA for cold soak in-flight start-and-run reliability.
* **Maintenance training:**
* Develop a maintenance training program that provides training adequate to support EDTO, including EDTO specific training.
* **Configuration, maintenance, and procedures (CMP) document:**
* Use a system that ensures compliance with the applicable FAA/EASA-approved CMP document.
* **Procedural changes:**
* Each substantial change to the maintenance or training procedures must be submitted to DGCA for review.
**Impact Analysis**
**Aircraft Operators conducting EDTO**
* **Impact:** Operators are affected by the new and amended requirements for eligibility, maintenance programs, propulsion system reliability, continuous airworthiness, dual maintenance limitations, verification program, task identification, maintenance control procedures, parts control, reliability program, engine monitoring, oil consumption, APU start program, training, and procedural changes.
* **Action Required:** Operators must update their existing maintenance programs, procedures, training, and documentation to comply with the new requirements and obtain DGCA approval.
**Maintenance Personnel**
* **Impact:** Maintenance personnel are impacted by the new EDTO specific training, the need to identify and certify EDTO specific tasks, the enhanced oversight for dual maintenance, and the requirement to complete and certify the EDTO pre-departure service check.
* **Action Required:** Maintenance personnel must undergo EDTO specific training, adhere to strict protocols for EDTO maintenance tasks, and accurately document all work performed.
**DGCA (Regulatory Authority)**
* **Impact:** DGCA will be responsible for reviewing and approving operator's revised EDTO maintenance programs and procedures, monitoring compliance, and providing feedback and oversight.
* **Action Required:** DGCA must update its review procedures and provide guidance to operators on complying with the new requirements.
Key Entities Referenced
CAR Section 8 Series S Part I: Establishes requirements for Extended Diversion Time Operations (EDTO) for Commercial Air Transport and is the primary subject of this document.
DGCA: The regulatory authority to which changes, reports, and programmes related to EDTO must be submitted and approved.
EDTO: Extended Diversion Time Operations; the central concept and subject of the policy.
FAA (FAR25): One of the Airworthiness Standards of Transport Category aeroplanes.
EASA (CS25): One of the Airworthiness Standards of Transport Category aeroplanes.
CAR Section 8 Series S Part I – Requirements for Extended Diversion Time Operations
(EDTO) for Commercial Air Transport is proposed to be amended. The proposed amendments
are shown in subsequent effected paragraphs.
The text of the amendment is arranged to show deleted text, new or amended text as shown
below:
(a) deleted text is marked with strikethrough;
(b) new or amended text is highlighted in grey.2.2 To be eligible for EDTO, the specified airframe/engine combination should have
been certificated to the Airworthiness Standards of Transport Category
aeroplanes by FAA (FAR25) of USA or EASA (CS25) or by any other regulatory
authority acceptable to DGCA.
5.1.2 Maintenance programme
Each operator’s maintenance programme shall ensure that:
(a) the titles and numbers of all airworthiness modifications, additions and
changes which were made to qualify aeroplane systems for extended
diversion time operations are provided to DGCA;
(b) any changes to maintenance and training procedures, practices or
limitations established in the qualification for extended diversion time
operations are submitted to DGCA before such changes are adopted;
(c) a reliability monitoring and reporting programme is developed and
implemented prior to approval and continued after approval;
(d) prompt implementation of required modifications and inspections which
could affect propulsion system reliability is undertaken;
(e) procedures are established which prevent an aeroplane from being
dispatched for an extended diversion time operation after engine shutdown
or EDTO significant system failure on a previous flight until the cause of
such failure has been positively identified and the necessary corrective
action is completed. Confirmation that such corrective action has been
effective may, in some cases, require the successful completion of a
subsequent flight prior to dispatch on an extended diversion time operation;
(f) a procedure is established to ensure that the airborne equipment will
continue to be maintained at the level of performance and reliability required
for extended diversion time operations; and
(g) a procedure is established to minimize scheduled or unscheduled
maintenance during the same maintenance visit on more than one parallel
or similar EDTO significant system. Minimization can be accomplished by
staggering of maintenance tasks, performing and/or supervising
maintenance by a different technician, or verifying maintenance correction
actions prior to the airplane entering an EDTO threshold.
(h) a procedure (through cockpit placard/external marking) is established to
indicate to maintenance and flight crew EDTO status of the aeroplane.
Note.— The maintenance considerations applicable to extended diversion
time operations are provided in the Airworthiness Manual (Doc 9760).
5.1.3 Propulsion system reliability
The operator should establish firm criteria as to what action has to be taken
when adverse trend in propulsion system conditions are detected. When the
propulsion system IFSD (computed on 12 month rolling average) exceeds
0.05/1000 engine hours for a 120 minute operation or exceeds 0.02/1000
engine hours for a 180 minutes operation, an immediate evaluation should be
accomplished and a report on problems identified and corrective action taken
must be forwarded to DGCA to consider additional corrective action oroperational restriction. Further the operator should compile necessary data on
propulsion system reliability which should include;
(a) A list of all engine shutdown events both on ground and in flight (excluding
normal training events) for all causes including flame out.
(b) Unscheduled engine removal rate and summary
(c) Total engine hours and cycles.
(d) Mean time between failures of propulsion system components that affect
reliability.
(e) IFSD rate based on 6 and 12 months rolling average.
(f) Any other relevant data.
5.1.2 Continuous Airworthiness maintenance programme (CAMP)
In order to conduct an EDTO flight, the Operator shall develop and comply with
the EDTO continuous airworthiness maintenance programme, as approved by DGCA
and endorsed in Operator’s operations specifications, for each aeroplane-engine
combination used in EDTO. The Operator shall develop the EDTO CAMP by
supplementing the manufacturer's maintenance program or the CAMP currently
approved for the Operator. The EDTO CAMP shall include the following elements:
(a) EDTO manual. The Operator shall have an EDTO manual for the use by each
person involved in EDTO.
(1) The manual shall -
(i) List each EDTO significant system (Refer para 5.1.3),
(ii) Refer to or include all of the EDTO maintenance elements in this section,
(iii) Refer to or include all supportive programs and procedures,
(iv) Refer to or include all duties and responsibilities, and
(v) Clearly state where referenced material is located in the Air Operator’s
document system.
(b) EDTO pre-departure service check. The Operator shall develop a pre-
departure check tailored to their specific operation.
(1) The Operator shall complete the pre-departure service check immediately
before each EDTO flight.
(2) At a minimum, this check must -
(i) Verify the condition of all EDTO Significant Systems;(ii) Verify the overall status of the aeroplane by reviewing applicable maintenance
records; and
(iii) Include an interior and exterior inspection to include a determination of engine
and APU oil levels and consumption rates.
(3) An appropriately trained maintenance person, who is EDTO qualified, shall
accomplish and certify by signature EDTO specific tasks. Before an EDTO flight
may commence, an EDTO pre-departure service check (PDSC) Signatory Person,
who has been authorized by the Operator, shall certify by signature, that the EDTO
PDSC has been completed.
(4) For the purposes of this paragraph (b) only, the following definitions apply:
(i) EDTO qualified person: A person is EDTO qualified when that person
satisfactorily completes the operator's EDTO training programme and is
authorized by the Operator.
(ii) EDTO PDSC Signatory Person: A person is an EDTO PDSC Signatory Person
when that person is EDTO qualified and that person:
(A) When certifying the completion of the EDTO PDSC:
(1) Works for an operator authorized to engage in Scheduled/ Non-Scheduled
operation or works for a CAR 145 organisation; and
(2) Holds an AME licence with airframe and powerplant ratings.
(B) When certifying the completion of the EDTO PDSC for an aircraft of an
Indian Air Operator outside India, the person shall have the requisite experience
or training to return aircraft to service on behalf of an EDTO maintenance entity.
(iii) EDTO maintenance entity: An entity authorized to perform EDTO
maintenance and complete EDTO PDSC and that entity is:
(A) a Scheduled/ non-Scheduled Air Operator;
(B) an approved/ accepted CAR 145 Organisation; or
(C) a maintenance organisation approved by local regulatory authority (in case
a CAR 145 approved/ accepted organisation is not available at the location).
Note: When the maintenance is sub-contracted, the operator must ensure that;
(i) The maintenance personnel of the sub-contractor involved are
qualified for EDTO.
(ii) All airworthiness flight dispatch procedures and additional
maintenance requirements as identified in the Operator’s CAME is
complied with.(c) Limitations on dual maintenance.
(1) Except as specified in paragraph (c)(2), the Operator may not perform
scheduled or unscheduled dual maintenance during the same maintenance visit
on the same or a substantially similar EDTO Significant System listed in the EDTO
Manual, if the improper maintenance could result in the failure of an EDTO
Significant System.
(2) In the event dual maintenance as defined in paragraph (c)(1) of this para cannot
be avoided, the Operator may perform maintenance provided:
(i) The maintenance action on each affected EDTO Significant System is
performed by a different AME, or
(ii) The maintenance action on each affected EDTO Significant System is
performed by the same AME under the direct supervision of a second qualified
individual; and
(iii) For either paragraph (c)(2)(i) or (ii) of this para, a qualified individual conducts
a ground verification test and any in-flight verification test required under the
program developed pursuant to paragraph (d) of this para.
(d) Verification programme. The Operator shall develop and maintain a
programme for the resolution of discrepancies that will ensure the effectiveness of
maintenance actions taken on EDTO Significant Systems. The verification program
must identify potential problems and verify satisfactory corrective action. The
verification program must include ground verification and in-flight verification policy
and procedures. The Operator shall establish procedures to indicate clearly who is
going to initiate the verification action and what action is necessary. The verification
action may be performed on an EDTO revenue flight provided the verification action
is documented as satisfactorily completed upon reaching the EDTO Entry Point.
(e) Task identification. The Operator shall identify all EDTO-specific tasks. An
appropriately trained AME who is EDTO qualified must accomplish and certify by
signature that the EDTO-specific task has been completed.
(f) Centralized maintenance control procedures. The operator conducting EDTO
(regardless of the size of its EDTO fleet) shall have a centralized entity responsible
for monitoring of the EDTO maintenance activities. The Operator shall develop and
clearly define in its EDTO manual specific procedures, duties, and responsibilities for
involvement of their centralized maintenance control personnel in their EDTO
operation.
(g) Parts control program. The Operator shall develop an EDTO parts control
program to ensure the proper identification of parts used to maintain the configuration
of aeroplanes used in EDTO. The programme must include rocedures to verify that
the parts installed on EDTO aeroplanes during part borrowing or pooling arrangementas well as those parts used after repair or overhaul maintain the required EDTO
configuration.
(h) Reliability program. The Operator shall have an EDTO reliability program. This
programme must be event-oriented and include procedures to report the events listed
below, as follows:
(1) The Operator shall report the following events within 72 hours of the occurrence
to the concerned regional/sub-regional office:
(i) IFSDs, except planned IFSDs performed for flight training.
(ii) Diversions and turnbacks for failures, malfunctions, or defects associated
with any aeroplane or engine system.
(iii) Uncommanded power or thrust changes or surges.
(iv) Inability to control the engine or obtain desired power or thrust.
(v) Inadvertent fuel loss or unavailability, or uncorrectable fuel imbalance in flight.
(vi) Failures, malfunctions or defects associated with EDTO Significant Systems.
(vii) Any event that would jeopardize the safe flight and landing of the airplane on
an EDTO flight.
(2) The Operator shall investigate the cause of each event listed in para (h)(1)
above and submit findings and a description of corrective action to the concerned
regional/ sub-regional office. The report must include the information specified in
CAR Section 2 Series C Part I (Appendix II). The corrective action must be
acceptable to the concerned regional/ sub-regional office.
(i) Propulsion system monitoring.
(1) If the IFSD rate (computed on a 12-month rolling average) for an engine
installed as part of an aeroplane-engine combination exceeds the following values,
the Operator shall do a comprehensive review of its operations to identify any
common cause effects and systemic errors. The IFSD rate must be computed
using all engines of that type in the Operator’s entire fleet of aeroplanes approved
for EDTO.
(i) A rate of 0.05 per 1,000 engine hours for EDTO up to and including 120
minutes.
(ii) A rate of 0.02 per 1,000 engine hours for EDTO beyond 120-minutes up to
and including 180 minutes.(2) In case the above rates are exceeded, the Operator shall carry out an
immediate evaluation and submit a report to concerned regional/sub-regional office
on problems identified and corrective action taken to consider additional corrective
action or operational restriction. Further the operator should compile necessary
data on propulsion system reliability which should include;
(f) A list of all engine shutdown events both on ground and in flight (excluding
normal training events) for all causes including flame out.
(g) Unscheduled engine removal rate and summary
(h) Total engine hours and cycles.
(i) Mean time between failures of propulsion system components that affect
reliability.
(j) IFSD rate based on 6 and 12 months rolling average.
(k) Any other relevant data.
(j) Engine condition monitoring.
(1) The Operator shall have an engine condition monitoring program to detect
deterioration at an early stage and to allow for corrective action before safe
operation is affected.
(2) This program must describe the parameters to be monitored, the method of
data collection, the method of analyzing data, and the process for taking corrective
action.
(3) The program must ensure that engine-limit margins are maintained so that a
prolonged engine-inoperative diversion may be conducted at approved power
levels and in all expected environmental conditions without exceeding approved
engine limits. This includes approved limits for items such as rotor speeds and
exhaust gas temperatures.
(k) Oil-consumption monitoring. The Operator shall have an engine oil
consumption monitoring program to ensure that there is enough oil to complete each
EDTO flight. APU oil consumption must be included if an APU is required for EDTO.
The operator's oil consumption limit may not exceed the manufacturer's
recommendation. Monitoring must be continuous and include oil added at each
EDTO departure point. The programmme must compare the amount of oil added at
each EDTO departure point with the running average consumption to identify sudden
increases.
(l) APU in-flight start program. If the aeroplane type certificate requires an APU
but does not require the APU to run during the EDTO portion of the flight, the
Operator must develop and maintain a programme acceptable to DGCA for cold
soak in-flight start-and-run reliability.
(m) Maintenance training. For each aeroplane-engine combination, the Operator
shall develop a maintenance training program that provides training adequate to
support EDTO. It must include EDTO specific training for all persons involved inEDTO maintenance that focuses on the special nature of EDTO. This training must
be in addition to the operator's maintenance training program used to qualify
individuals to perform work on specific aeroplanes and engines.
(n) Configuration, maintenance, and procedures (CMP) document. If an
aeroplane-engine combination has a CMP document, the Operator must use a
system that ensures compliance with the applicable FAA/EASA-approved CMP
document.
(o) Procedural changes. Each substantial change to the maintenance or training
procedures that were used to qualify the Operator for EDTO, must be submitted to
DGCA for review. The Operator cannot implement a change until the concerned
regional/ sub-regional office notifies the Operator that the same is approved/ accepted.
5.1.4 5.1.3 EDTO significant systems