AAC No 3/2013

Date 06-12-2013

GOVERNMENT OF INDIA
CIVIL AVIATION DEPARTMENT
AIRWORTHINESS
DIRECTOR GENERAL OF CIVIL AVIATION ADVISORY CIRCULAR

Subject: EDTO Airworthiness Approval

1. INTRODUCTION :- Purpose and Scope

1.1 CAR Section 8 Series S Part I requires the operator to seek DGCA approval
prior to operating their aircraft for EDTO Operation. This circular should be
read in conjunction with the above CAR.

1.2 This circular details the approval process required to be followed by each
operator seeking Initial and subsequent airworthiness approvals to
undertake EDTO operation.

1.3 The Airworthiness approval requires the operator to comply with the additional
continuing airworthiness requirements related to EDTO operation as detailed
in this circular. Compliance Checklist to demonstrate the compliance of
Airworthiness requirements for special operation approval is available in
chapter 24 of Airworthiness procedure manual which is available on dgca
website i.e, www.dgca.nic.in.

1.4 The specified airframe/engine combination, to be eligible for EDTO must

have been certificated to the airworthiness standards of Transport Category
aeroplanes Federal Aviation Regulation (FAR) Part 25, the European Aviation
Safety Agency (EASA) CS25 or the equivalent.

2. Application

2.1 Any operator applying for EDTO approval ( Airworthiness aspect ) should
submit a request, with the required supporting data, to the DGCA at least 3
months prior to the proposed start of EDTO with the specific airframe/engine
combination.

2.2 Application for approval for EDTO operations shall be submitted to the
Regional/ Sub-Regional offices where the aircraft is based along with para
wise compliance of the CAR related to the operation. The supporting
documents confirming compliance with requirements of CAR and the EDTO
1
 Compliance Check attached with Chapter 24 B of APM ( Available on dgca
webside i.e, www.dgca.nic.in) shall also be enclosed by the concerned
operator seeking approval. The checklist should clearly show the compliance
and the location of the compliance in the column 1.. Verification remarks
column to be used by DGCA officer. The operator should further furnish
details of the procedure/instructions and methodology for continued
capability to adhere to conditions laid down at the time of grant of approval
in a separate EDTO Manual their by personnel involved in EDTO. Any
amendment to the EDTO manual requires DGCA approval.

3. Operator EDTO process elements

3.1 The operator seeking EDTO Airworthiness Approval should also
demonstrate to the DGCA that it has established an EDTO process
that includes the following EDTO elements:

i) Airframe/engine combination and engine compliance to EDTO/ EDTO

Type Design Build Standard (CMP); Evidence that the type design of
the aeroplane is approved for extended range operation is normally
reflected by a statement in the Aircraft Flight Manual (AFM) and Type
Certificate Data Sheet (TCDS) or Supplemental Type certificate (STC),

ii) Engineering Modifications - The operator must provide to DGCA all

titles and numbers of all modifications, additions, and changes which
were made in order to substantiate the incorporation of the CMP
standard in the aeroplanes used in EDTO.

iii) Compliance with the continuing airworthiness requirements as defined

in Para, 4 which should include EDTO:

a. Occurrence reporting
b. Maintenance Programme;
c. Reliability Programme;
d. Oil Consumption Monitoring Programme;
e. Engine Condition Monitoring and Reporting system;
f. Propulsion system monitoring programme;
g. EDTO parts control programme;
h. Plan for resolution of aeroplane discrepancies.
i. Aircraft performance monitoring programme

iv) The operator should establish a programme that results in a high

degree of confidence that the propulsion system reliability appropriate
to the EDTO diversion time would be maintained;

v) Initial and recurrent training and qualification programmes in place for

all EDTO related personnel.

2
3.2 Control Process (centralised control process)

3.2.1 Procedures, and a centralised control process, must be established

which would preclude an aeroplane being released for EDTO after
propulsion system shut down, or EDTO significant system failure on a
previous flight, or significant adverse trends in system performance,
without appropriate corrective action having been taken.
Confirmation of such action as being appropriate may, in some cases,
require the successful completion of one or more non-revenue or non-
EDTO revenue flights (as appropriate) prior to being released on an
EDTO. As an alternative the first 60 minutes of an EDTO flight can be
used as a verification flight.

3.2.2 The operator conducting EDTO (regardless of the size of its EDTO
fleet) must have a centralized entity responsible for monitoring of the
EDTO maintenance activities. The certificate holder must develop and
clearly define in its EDTO maintenance document specific
procedures, duties, and responsibilities for involvement of their
centralized maintenance control personnel in their EDTO operation.

3.3 Customised MEL and DDPG

3.3.1 Approved copy of customised MEL and DDPG shall be submitted to

DGCA along the application.

4. CONTINUING AIRWORTHINESS CONSIDERATIONS

4.1 The continuing airworthiness management organisations (CAMO) managing
the aircraft for which an EDTO operational approval is sought, ensure that
additional requirements for maintenance and monitoring are to be complied
with in addition to the applicable continuing airworthiness requirements of
CAR-M. They specifically affect:

a. Occurrence reporting;
b. Aircraft maintenance programme and reliability programme;
c. EDTO Manual / Continuing airworthiness management
exposition;
d. Competence of continuing airworthiness and maintenance
personnel.

4.2. OCURRENCE REPORTING

In addition to the items generally required to be reported in accordance with
requirements , the following items concerning EDTO should be included:

a. in-flight shutdowns;
b. diversion or turn-back;
c. un-commanded power changes or surges;
d. inability to control the engine or obtain desired power; and
e. failures or malfunctions of EDTO significant systems having a
detrimental effect to EDTO flight.
3
 Note: status messages, transient failures, intermittent indication of failure,
messages tested satisfactorily on ground not duplicating the failure should
only be reported after an assessment by the operator that an unacceptable
trend has occurred on the system
The report should identify as applicable the following:

a. aircraft identification;
b. engine, propeller or APU identification (make and serial number);
c. total time, cycles and time since last shop visit;
d. for systems, time since overhaul or last inspection of the defective
unit;
e. phase of flight; and
f. corrective action.

4. 3. EDTO MAINTENANCE PROGRAMME

4.3.1. The maintenance programme should contain the standards, guidance
and directions necessary to support the intended operations. Maintenance
personnel involved, including maintenance sub-contractors’ personnel,
should be made aware of the special nature of extended diversion time
operation (EDTO) and have the qualifications, authorisation, knowledge,
skill and ability to accomplish the requirements of the programme. The
quality of maintenance and reliability programmes can have an
appreciable effect on the reliability of the propulsion system and the EDTO
Significant Systems. The proposed maintenance and reliability
programme’s ability to maintain an acceptable level of safety for the
propulsion system and the EDTO Significant Systems of the particular
airframe/engine combination. is assessed and approved by DGCA The
maintenance programme should also include tasks to maintain the
integrity of cargo compartment and pressurisation features, including
baggage hold liners, door seals and drain valve condition. Processes
should be implemented to monitor the effectiveness of the maintenance
programme in this regard

4.3.2. Any changes to the maintenance and training procedures, practices or

limitations established in the qualification for EDTO must be submitted to
the DGCA for approval .
4.3.3 The maintenance programme should be reviewed and supplemented as
necessary to ensure that it adequately provides for the continued
airworthiness for the aircraft being considered for EDTO: .

• The operator must identify all tasks that need to be completed and
certified as complete by EDTO- qualified maintenance personnel The
intent is to have EDTO- trained maintenance personnel accomplish
these tasks because they are related to EDTO.

• EDTO related procedures, such as maintenance of EDTO significant

4
 system items should be clearly defined in the system of maintenance.

• Logbooks should be reviewed and documented, as appropriate, to

ensure proper Minimum Equipment List (MEL) procedures, deferred
items and maintenance checks, and that system verification procedures
have been properly performed.

4.3.4. Scheduled Maintenance of Multiple Identical Systems (Dual

Maintenance )

The operator must establish procedures that minimize scheduling dual

maintenance actions to multiple similar elements in any EDTO significant
system during the same routine or non- routine maintenance visit. In order
to manage this requirement, the certificate holder must develop a list of
fleet- specific EDTO significant systems and include them in their EDTO
Manual. The certificate holder should include a clear definition of what
constitutes dual maintenance in their EDTO maintenance document. In the
event that the certificate holder performs dual maintenance, their
procedures must ensure the verification of positive corrective action prior
to entry into EDTO airspace. The procedures must ensure that such
maintenance actions are performed by a different qualified technician, or if
performed by the same technician, then he or she must be under the direct
supervision of a second qualified individual. In either case, a qualified
individual must conduct a ground verification test and ensure that any
in-flight test that is required by the certificate holder be done as well An
operator may choose to conduct a functional check flight after a heavy
maintenance visit to address dual maintenance actions in addition to first
performing ground verification action. While planning schedule
maintenance following shall be kept in mind:-

• The operator should identify specific maintenance activities that are to

be carried out to multiple identical systems on a planned basis.
• If the maintenance activities identified above are carried out, a
subsequent EDTO verification flight is not required if the operator has
identified the activity and has a procedure in place which provides an
equivalent level of safety.
• Where the disturbance to multiple identical systems is unavoidable
during a scheduled check, the maintenance personnel carrying out the
maintenance task must not repeat that task on an identical system, on
the same aeroplane during that check.
• If a disturbance occurs which is otherwise unavoidable during a
scheduled check, separate maintenance personnel must carry out the
respective system’s maintenance tasks with an independent physical
check completed and signed for by an authorised person.
• Any maintenance task which disturbs multiple identical elements of
EDTO significant systems should be identified as such on the operator’s
work forms and instructions.
• Upon completion of maintenance, complete and adequate testing
5
 should be carried out in accordance with the aeroplane maintenance
manual/s and modification instructions.

• An EDTO verification flight should be carried out where ground testing

cannot provide positive assurance of serviceability.
• After the disturbance of a component which, if it was to leak, could
cause loss of system fluid (oil, fuel, hydraulic or air) a high power engine
ground run is required to check system integrity.
.

4.3.5 PRE-DEPARTURE SERVICE CHECK

4.3.5.1 An EDTO service check should be developed to verify that the status of
the aeroplane and certain critical items are acceptable. This check
should be accomplished and signed off by an authorised and qualified
person prior to an EDTO flight. A member of the flight crew may also
perform these checks, if appropriately trained and authorised.

4.3.6 Unscheduled maintenance

• When unscheduled maintenance is carried out which disturbs identical

elements of EDTO significant systems the system should be tested after
rectification in accordance with the aeroplane maintenance manual
procedures to provide positive assurance of serviceability.

• An EDTO verification flight should be carried out where ground testing cannot
provide positive assurance of serviceability.

• Maintenance action must be taken to isolate faults that are intermittent in

nature and if the fault cannot be positively corrected an EDTO verification
flight should be carried out.

4.4 Reliability Programme :

4.4.1 An EDTO reliability programme should be developed or the existing

reliability programme supplemented. This programme must be designed
to achieve early identification and prevention of EDTO related problems as
the primary goal. The programme should be event-orientated and
incorporate reporting procedures for significant events detrimental to EDTO
flights. This information should be readily available for use by the operator
and DGCA to help establish that the reliability level is adequate, and to
assess the operator's competence and capability to safely continue EDTO.
DGCA must be notified within 72 hours of events reportable through this
programme.

In addition to the items required to be reported by regulation, the following

items must-be included:
6
 • In-flight shutdowns;
• Diversion or turnback;
• Uncommented power changes or surges; and
• Inability to control the engine or obtain desired power; and problems with
EDTO significant systems.
Any other event detrimental to EDTO

The report must identify the following:

• Aeroplane identification;
• Engine identification (make and serial number);
• Total time, cycles and time since last maintenance inspection;
• For systems, time since overhaul or last inspection of the defective
unit;
• Phase of flight; and
• Corrective action
4.5 ASSESSMENT OF PROPULSION SYSTEMS RELIABILITY

4.5.1 The operator’s assessment of propulsion systems reliability for the EDTO fleet
should be made available to the DGCA (with the supporting data) on at
least a monthly basis, to ensure that the approved maintenance programme
continues to maintain a level of reliability necessary for EDTO operations.
4.5.2 The assessment should include, as a minimum, engine hours flown in the
period, in-flight shutdown rate for all causes and engine removal rate, both
on a 12-months moving average basis. Where the combined EDTO fleet is
part of a larger fleet of the same aircraft/engine combination, data from the
total fleet will be acceptable.

4.5.3 Any adverse sustained trend to propulsion systems would require an

immediate evaluation to be accomplished by the operator in consultation
with the DGCA. The evaluation may result in corrective action or operational
restrictions being applied.

4.5.4. A high engine in-flight shutdown rate for a small fleet may be due to the limited
number of engine operating hours and may not be indicative for an
unacceptable trend. The underlying causes for such an increase in the rate
will have to be reviewed on a case-by-case basis in order to identify the root
cause of events so that the appropriate corrective action is implemented.

4.5.6 If an operator has an unacceptable engine in-flight shutdown rate caused by

maintenance or operational practices, then the appropriated corrective
actions should be taken.

4.6 OIL CONSUMPTION PROGRAMME

4.6.1. The operator should implement an EDTO oil consumption monitoring
programme. The operator's oil consumption programme should reflect the
manufacturer's recommendations. The programme should contain procedures
to monitor and respond to oil consumption trends. It should consider the
7
 amount of oil added at each departing station with reference to the running
average consumption, i.e. the monitoring must be continuous up to, and
including, oil added at each departure station. If oil analysis is recommended to
the type of engine installed, it should be included in the programme. If the
auxiliary power unit (APU) is required for EDTO operation, it should be added
to the oil consumption programme.

4.7 APU IN-FLIGHT START PROGRAMME

4.7.1 Where an APU is required for EDTO and the aircraft is not operated with this
APU running prior to the EDTO entry point, the operator should initially
implement a cold soak in-flight starting programme to verify that start
reliability at cruise altitude is above 95%. Once the APU in-flight start
reliability is proven, the APU in-flight start monitoring programme may be
alleviated. The APU in-flight start monitoring programme should be
acceptable to the competent authority.
4..7.2 The Maintenance procedures should include the verification of in-flight start
reliability following maintenance of the APU and APU components, as
defined by the OEM, where start reliability at altitude may have been
affected.
.
4.8. ENGINE CONDITION MONITORING PROGRAMME
4.8.1 The engine condition monitoring programme should ensure that a one-
engine-inoperative diversion may be conducted without exceeding approved
engine limits (e.g. rotor speeds, exhaust gas temperature) at all approved
power levels and expected environmental conditions. Engine limits
established in the monitoring programme should account for the effects of
additional engine loading demands (e.g. anti-icing, electrical, etc.), which
may be required during the one-engine-inoperative flight phase associated
with the diversion.

4.8.2 The engine condition monitoring programme should describe the parameters
to be monitored, method of data collection and corrective action process.
The programme should reflect manufacturer’s instructions and industry
practice. This monitoring will be used to detect deterioration at an early stage
to allow for corrective action before safe operation of the aircraft is affected.

4.9 Aircraft Performance Monitoring:

4.9. The continued airworthiness Program mentioned should cover Aircraft

Performance Monitoring to assess any degradation in the aircraft
performance. This monitoring programme should form part of EDTO manual

4.10. VERIFICATION PROGRAMME

4.10.1 The operator should develop a verification programme to ensure that the
corrective action required to be accomplished following an engine shutdown,
any EDTO significant system failure or adverse trends or any event which
8
 require a verification flight or other verification action are established. A clear
description of who must initiate verification actions and the section or group
responsible for the determination of what action is necessary should be
identified in this verification programme. EDTO significant systems or
conditions requiring verification actions should be described in the EDTO
Manual / Continuing Airworthiness Management Exposition (CAME). The
CAMO may request the support of (S)TC holder to identify when these actions
are necessary. Nevertheless the CAMO may propose alternative operational
procedures to ensure system integrity. This may be based on system
monitoring in the period of flight prior to entering an EDTO area.

4.10.2 The operator must have ground and in-flight verification flight procedures
described in their supplemental maintenance program for events involving
propulsion system shutdown, engine or major engine module change, primary
system failure, and for certain adverse trends or prescribed events.

• Written procedures exist to ensure that the flight crew receives a full briefing
prior to dispatch concerning the event and/or the maintenance performed.

• Appropriate maintenance personnel should convey to the flight crew the

specific observations and/or actions required of them during the verification
portion of the flight, as well as the method used to properly record the
satisfactory completion of that verification flight.

• All flight crew observations and/or actions must be complete prior to entering
the EDTO portion of the flight.

• Documentation of pass/fail. Communications with the dispatch or flight

following center and maintenance control, and an appropriate logbook entry
must be completed in accordance with the certificate holder’s EDTO
maintenance document.

4.11 EDTO PARTS CONTROL

4.11.1 The operator must develop a parts control programme with support from the
manufacturer, that ensures the proper parts and configuration are
maintained for EDTO. The programme includes verification that parts placed
on an EDTO aeroplane during parts borrowing or pooling arrangements, as
well as those parts used after repair or overhaul, maintain the necessary
EDTO configuration for that aeroplane.

4.12 EDTO MANUAL

4.12.1. The operator should develop a manual for use by personnel involved in
EDTO. All EDTO maintenance requirements and procedures should be
identified in this manual as well as the specific duties, number and identity of
qualified and authorised personnel, responsibilities, processes and
procedures assigned to the various Maintenance & Engineering
departments. Samples of the forms and reports should be included.

4.12.2 The EDTO Manual can be a chapter in the operator’s existing Continuing
9
 Airworthiness Management Exposition or it can be produced as a separate
document. In either case, the EDTO Manual should provide complete details
on each topic or can reference other documentation where the information is
located. For example, the EDTO Pre-departure Service Check (PDSC) can
be listed in the EDTO Manual or the EDTO Manual can reference the
operator’s PDSC task card or other manual where the check is defined. The
format of the EDTO Manual, as well as identification number should be
consistent with the operator’s documentation system. Document handling
should be in accordance with the operator’s current policies relative to
revision and distribution.

4.12.3 Contents of Manual

The CAMO should specify the procedures necessary to ensure the
continuing airworthiness of the aircraft particularly related to EDTO
operations. It should address the following subjects as applicable:
a. General description of EDTO procedures
b. EDTO maintenance programme development and amendment

c. EDTO reliability programme procedures

(1) Engine/APU oil consumption monitoring
(2) Engine/APU Oil analysis
(3) Engine conditioning monitoring
(4) APU in-flight start programme
(5) Verification programme after maintenance
(6) Failures, malfunctions and defect reporting
(7) Propulsion System Monitoring/Reporting
(8) Aircraft Performance Monitoring
(8) EDTO significant systems reliability

d. Parts and configuration control programme

e. Maintenance procedures that include procedures to preclude identical
errors being applied to multiple similar elements in any EDTO significant
system

f. Interface procedures with the EDTO maintenance contractor, including the

operator EDTO procedures that involve the maintenance organisation and
the specific requirements of the contract

g. Procedures to establish and control the competence of the personnel

involved in the continuing airworthiness and maintenance of the EDTO
fleet.

4.12.4 Training Programme

Proposed Training Programme for personnel involved in the Continuing
Airworthiness and Maintenance of the EDTO Fleet should contain initial
and recurrent training for as follows:
1. INTRODUCTION TO EDTO REGULATIONS AND CIRCULARS
a. Contents of CAR
10
 b. EDTO Type Design Approval – a brief synopsis

2. EDTO OPERATIONS APPROVAL

a. Maximum approved diversion times and time-limited systems
capability
b. Operator’s Approved Diversion Time
c. EDTO Area and Routes
d. EDTO MEL

3. EDTO CONTINUING AIRWORTHINESS CONSIDERATIONS

a. EDTO significant systems

b. CMP and EDTO aircraft maintenance programme
c. EDTO pre-departure service check
d. EDTO reliability programme procedures
e. Engine/ APU oil consumption monitoring
f. Engine/APU Oil analysis
g.Engine conditioning monitoring
h. APU in-flight start programme
j. Verification programme after maintenance
k. Failures, malfunctions and defect reporting
l. Propulsion System Monitoring/Reporting
m. EDTO significant systems reliability
n. Parts and configuration control programme
o. CAMO additional procedures for EDTO
p. Interface procedures between CAR 145 organisation and
CAMO

4.12.5 COMPETENCE OF CONTINUING AIRWORTHINESS AND

MAINTENANCE PERSONNEL
4.12.5.1 The CAMO organisation should ensure that the personnel involved in the
continuing airworthiness management of the aircraft have knowledge of the
EDTO procedures of the operator.
4.12.5.2 The CAMO should ensure that maintenance personnel that are involved in
EDTO maintenance tasks:
a) Have completed an EDTO training programme reflecting the relevant
EDTO procedures of the operator, and,
b) Have satisfactorily performed EDTO tasks under supervision, within
the framework of the CAR-145 approved procedures for Personnel
Authorisation.
5 Approval for EDTO
5.1 After satisfactory demonstration with the CAR requirements, Contents of
EDTO Manual, Aircraft eligibility etc. the request of operator along with
approved manual and a copy of completed checklist shall be forwarded by
the Regional office to the DGCA, Hqrs (Airworthiness Directorate ) for
further action. Initial Operations Approval for EDTO shall be issued by the
11
 DGCA Hqrs. indicating Airframe engine combination and tail no of aircraft,
after satisfactory scrutiny both by Airworthiness offices. Approval for
additional aircraft shall be granted by regional office. Procedure to be
followed by Airworthiness Office for processing the request of operator is
described in chapter 24 B of Airworthiness procedure manual.

6. CONTINUING SURVEILLANCE
6.1 The fleet-average IFSD rate for the specified airframe/engine combination shall
be monitored by the operator. The DGCA should also monitor all aspects of
the EDTO that it has authorised to ensure that the levels of reliability achieved
in EDTO remain at the satisfactory levels. and that the operation continues to
be conducted safely. In the event that an acceptable level of reliability is not
maintained, if significant adverse trends exist, or if significant deficiencies are
detected in the type design or the conduct of the EDTO operation, then the
appropriate Competent Authority should initiate a special evaluation, impose
operational restrictions if necessary, and stipulate corrective action for the
operator to adopt in order to resolve the problems in a timely manner. The
Regional office should alert the DGCA Hqrs when a special evaluation is
initiated and make provisions for their participation.
6.2 Daily Monitoring. In addition to the normally internal audit and surveillance
each operator is required to have daily monitoring of their EDTO program in
place as part of the daily oversight. Daily fleet performance, event reports,
adverse trends, and pilot reports shall be monitored and in case of
event/occurrences, the same shall be reported to DGCA.

Sd/-
( Charan Dass )
Jt Director General of Civil Aviation
For Director General of Civil Aviation

12