I have a specific question regarding aircraft, engine, and component times.
As defined in 14 CFR Part 1 Time in service, with respect to maintenance time records, means the time from the moment an aircraft leaves the surface of the earth until it touches it at the next point of landing.
As defined by Rotax in their Line Maintenance Manual for Rotax® Engine Type 912 Series (http://www.flyrotax.com/portaldata/5/dokus/d05562.pdf) p.43 (05-10-00 page 3)
As you can see there is considerable difference between the two definitions of time. The question has arisen regarding maintaining the aircraft in accordance with Part 135 standards. The question regarding times has come up, because an agency wants clarification of which definition of time is appropriate.
The three scenarios that come to mind are:
1. Use the definition included in Title 14 CFR Part 1 for all maintenance.
2. Use the definition included in Title 14 CFR Part 1 for airframe maintenance for aircraft equipped with a Rotax engine and Rotax definition of time for the engine and engine accessories.
3. Use the Rotax definition of time for the aircraft and engine for aircraft equipped with a Rotax engine.
I’d appreciate any thoughts on this matter, especially considering that the intent regarding Part 135 is to insure an adequate level of safety and oversight.