Chances for owner-perfomed condition inspections for C172s, Cherokees, Beech Sundowners etc Under Mosaic Program In the near future?

[pfarber]

Somebody above already said this privilege could be limited at the beginning to certain certified airplanes I.e. by AS , weight, # of seats, and only its owner will do the inspection job etc, and more complicated harder -to -comply ADs for instance, left to the IA?

This is an obvious can of worms that shouldn't be opened. What is complicated? What is harder? What about light GA AC that use unconventional construction (Grumman AA's immediately come to mind). Also Pt 65 states that an MX cannot sign off work unless they have previously done it (lol the most unenforced FAR in the entire book).

If you want to do your own MX then buy/build an E/AB L-L. Don't muddy the waters with carve outs... the FAA is far to conservative and completely uninterested in it.

 

[DJTorrente]

Good. Unfortunately, more often than not, people who rally for an owner-based maintenance privilege do not perform any prevent mx on their aircraft now. So it makes one wonder, if they want more ability, why don't they do what they can now.

Maybe because the cost of buying tools necessary to do what on the Apdx. A "Mother May I" list is a total loss if I still have to pay an A&P for things not so blessed.

I eagerly look forward to the Federal Automobile Administration applying the same stringent requirements, and the inevitable effect of such on adoption & usage.

 

[pfarber]

I don't see why, for a limited owner maintenance certificate, they couldn't do the same in 3 months with a similar commitment.

I've seen, nay had to correct, certificated AnPs doing work that had little to no idea what they were doing. One didn't know how a V-band clamp worked. The other had to be instructed on the proper use of a sight glass. Even simple fasteners have tripped up new AnPs. To cut the educational time to less than a year is not something I support.

I'll say it, and many, many of my co-workers can say the same thing: A class of 25+ students start a 147 program... maybe 5 actually make it. When I was at ERAU we would lose 1 or 2 people a month... and that's at a school MILES above a CC or private 147 school.

You need that time to weed out the dumb dumbs.

 

[Cesarmx]

If you want to do your own MX then buy/build an E/AB L-L. Don't muddy the waters with carve outs... the FAA is far too conservative and completely uninterested in it..

Bell206 already stated:
“Might make for an interesting grassroots project for the PoA membership to advance the idea to the appropriate people?”……..He may be right……..The next question is : Who might be the appropriate people? AOPA, FAA public affairs (if there is such an office), other Pilot/Aircraft /associations or Institutions ?

 

[pfarber]

Maybe because the cost of buying tools necessary to do what on the Apdx. A

Other than some very specialized engine/sheetmetal/electrical tools a $50 HF tool kit will get you 80% of all MX tasks. Safety wire pliers will amost double your tool costs ($80 for a millibar clone) and the all important knipex is another $50.

Heck on airliners I rarely use more than 1/4in socket set, knipex and a flathead. Unless were talking engines... then I need 1 3/8s or 1in for ignitors or filters.

Torque wrenches can cost some some money, but you don't need $1000 Snap on Digital. You can also calibrate them yourself. Nonthing in Pt 43 says you need NIST calibration certs.

 

[pfarber]

Bell206 already stated:
“Might make for an interesting grassroots project for the PoA membership to advance the idea to the appropriate people?”……..He may be right……..The next question is : Who might be the appropriate people? AOPA, FAA public affairs (if there is such an office), other Pilot Institutions ?

Preventative MX covers a lot.

I don't see a problem that needs a solution. If you want to MX a certified AC get the certification. If you don't want the cert (and the liability of it) then E/AB or LSA.

Hand picking people for what? The FAA is completely uninterested and rewriting FARs is a legal maze.

 

[Bell206]

I've seen, nay had to correct, certificated AnPs doing work that had little to no idea what they were doing.

And? The certificate does not make the person, the person makes the certificate. Or do you simply think a person with a CRS repairman is not as smart as an A&P with an IA? Dumb people do dumb stuff regardless of what certificate they have in their pocket. I don't see where that is relevant to creating another certificate level to preform maintenance for those who want it.

Maybe because the cost of buying tools necessary to do what on the Apdx. A "Mother May I" list is a total loss if I still have to pay an A&P for things not so blessed.

Ha. Too much. Sums up my point perfectly.

 

[bradg33]

Dumb people do dumb stuff regardless of what certificate they have in their pocket.

Bingo. There are a ton of "unlicensed' owners already working on their airplanes, whether legal or not, that likely do a better job than A&Ps (especially those who own/maintain more unique airplanes). And there are also a ton of A&Ps and aircraft owners/pilots who I wouldn't trust to put oil in my airplane.

But if you read between the lines, a LOT of the folks banging the drum for expanded owner-maintenance really just want to do LESS maintenance or do it outside the scope of approved parts or procedures. Or they are folks that don't actually know WTF they are doing and don't really understand what they are asking for (nor do they understand how much some of the specialty and other tools they will need cost).

The ones I refer to at the top, who own and largely maintain their own airplanes w/o an A&P certificate but do so in the same (or better) manner and quality as an A&P, tend to keep their mouths shut and don't make any noise at all.

 

[Bell206]

a LOT of the folks banging the drum for expanded owner-maintenance really just want to do LESS maintenance or do it outside the scope of approved parts or procedures

I think in context, less than 50% of TC'd aircraft owners want to perform mx on their aircraft. Maybe even less now. And of those who do, I've found a clear majority will benefit from any increase in their mx privileges vs most being in the category you list. Maybe its just my location that I see a difference or maybe if was the years I offered owner assist services. Will there be folks that want to play the system? Sure and there here now.

 

[kyleb]

I think in context, less than 50% of TC'd aircraft owners want to perform mx on their aircraft. Maybe even less now. And of those who do, I've found a clear majority will benefit from any increase in their mx privileges vs most being in the category you list. Maybe its just my location that I see a difference or maybe if was the years I offered owner assist services. Will there be folks that want to play the system? Sure and there here now.

Let's say you're working with a mechanically competent owner. You've taught him/her to clean/gap plugs, change tires/tubes, lubricate pulleys, clean/grease bearings, open and close inspection panels, etc. You let that owner do everything s/he can and you walk up to an "opened up" C-172 or Cherokee. How long does it take you to do the inspection itself? Compression test, visual and functional inspection of the required bits, perform an AD/SB check, and make an entry into the logbook? Maybe 25% of the time it would take if you performed the entire annual yourself?

My point is owners can save a ton on labor if they do the allowable things themselves and let the IA perform the inspection. And we don't need new reg's for that to happen...

 

[Bell206]

My point is owners can save a ton on labor if they do the allowable things themselves and let the IA perform the inspection. And we don't need new reg's for that to happen...

And this is exactly what we did with my owner-assist customers. However, the gap between willing or available mechanics and willing owners has been increasing ever since then and in the past 5-10 years its been accelerating. So while that concept does work as you state, the opportunities for it to happen is decreasing in a number of areas. And it will only get worse in the next 5-7 years as a large portion of the active A&Ps retire. So what other options are there for those owners who want to do that, but do not have a willing mechanic to participate? And its closer to 60% savings with a fully engaged owner.

 

[Cesarmx]

And this is exactly what we did with my owner-assist customers. However, the gap between willing or available mechanics and willing owners has been increasing ever since then and in the past 5-10 years its been accelerating. So while that concept does work as you state, the opportunities for it to happen is decreasing in a number of areas. And it will only get worse in the next 5-7 years as a large portion of the active A&Ps retire. So what other options are there for those owners who want to do that, but do not have a willing mechanic to participate? And its closer to 60% savings with a fully engaged owner.

True! It is hard to find willing and Abailable APs and IAs to do the job nowadays, and only it is getting harder even when the owner has a long established relationship with them, it is just reality!

My airport has not had a based AP for the last 12 years! We all 42 tenants have to find someone off field willing to come for unscheduled or AOG situations - and in most cases we have To wait for weeks-or to fly to them for annuals because they simply are too busy.

Even nearby airports who have mechanics in the field are hard to find for unscheduled maintenance at the owners convenience and have to wait weeks to fix the issues. In one case a friend had one of his mixture cables stuck in the cut off position in his Baron, the field mechanic who knows him for years and the one doing his annuals too told him it will be two months for him to get to it even after offering the AP his assistance!

In another case a pilot friend got stranded at an off base airport with a mechanical issue and no mechanic in the field, called several airports nearby at less than 30 miles away and no mechanic was willing to drive to assist him….. drove back home and his mechanic got free after several weeks and drove 150 miles - at a hefty premium- to evaluate and fix the issue! And the stories go on and on………
Because of high demand for APs they can charge the owner whatever they please if you want their service. That’s reality! “So what other options are there for the owners?”………..

 

[pfarber]

My airport has not had a based AP for the last 12 years! We all 42 tenants have to find someone off field willing to come for unscheduled or AOG situations - and in most cases we have To wait for weeks-or to fly to them for annuals because they simply are too busy.

I started another thread about low GA pay. These one man band AnPs are not the answer. You need a crew of at least two people to be productive and really make money.... and most of all: CHARGE A PROFITABLE RATE.

As for airports without AnPs. I was asked if I wanted to start a shop on a local field. They wanted an AnP/IA and after a brief conversation i quickly realized that it would be a losing endeavor. First there were only a few thousand operations per year (ie its not that busy) and most of the hangars were storage. I would also not get a discount for a hangar and lastly due to the weather (NE) about 1/3rd of the year would be dead.

What might have worked is a discount for the hangar, kick out all the winnibego's and add at least 10-15 more hangars. But that's not how local airport authorities work.

 

[Cesarmx]

I started another thread about low GA pay. These one man band AnPs are not the answer. You need a crew of at least two people to be productive and really make money.... and most of all: CHARGE A PROFITABLE RATE.

As for airports without AnPs. I was asked if I wanted to start a shop on a local field. They wanted an AnP/IA and after a brief conversation i quickly realized that it would be a losing endeavor. First there were only a few thousand operations per year (ie its not that busy) and most of the hangars were storage. I would also not get a discount for a hangar and lastly due to the weather (NE) about 1/3rd of the year would be dead.

What might have worked is a discount for the hangar, kick out all the winnibego's and add at least 10-15 more hangars. But that's not how local airport authorities work.

Same story at my airport, low operations a year , even with 30 or so active airplanes, some APs have approached management but when they talk to the city authorities they stay away………..the winnebagos, seadoos, antique cars , sail boats, RVs etc have been run away!

 

[Cesarmx]

Bell206
Can I email you?

 

[Ed Haywood]

A second approach could be to expand the knowledge requirements and privelages of an LSRM to those aircraft but restrict the certificate by aircraft model, gross weight, or some similar fashion.

I love this idea. Use the same restrictions as Basic Med. Or the new MOSAIC aircraft criteria.

In the meantime, the FAA should do more to encourage and facilitate owner PM. They could start by amending Part 43 Appendix A to incorporate the Coleal Memo interpretation, and by releasing an AC which provides additional guidance and decision tools for owners to use to determine where their limits are.

I firmly believe an aircraft with a high degree of owner maintenance will be safer than one where the owner is terrified to tighten a screw without A&P supervision.

If the FAA is concerned about untrained owners working on their planes, the smart solution is to provide some kind of regulatory incentive to getting training. Now that the LSRM framework exists, adding some sort of GA owner privilege would greatly increase the participation rate for that course.

 

[Bell206]

In the meantime, the FAA should do more to encourage and facilitate owner PM.

Unfortunately, that is not in the job description nor within their budget. As to the Coleal LOI, it was directed at pilot performed mx on a Transport category aircraft. And while it provided supporting definitions to how preventive mx should be looked at, just as major repairs and alterations are via those similar listings, it does not directly translate to a regulatory change. So what it does say is the 31 prevent mx items are considered categories and when combined with review of the Part 1 definition of prevent mx, you can expand on those specific categories but not add new categories.

So like in the major alteration listing in Appdx A it states "fuselage", however, once you apply the Part 1 definition to it, its only certain things that apply. If all that makes sense. Regardless, I and others think a higher level of owner mx participation could be possible with the right approach. However, I think before any public effort toward that goal, time needs to be given to the new Part 22 and its subsequent new model offerings to see how the market reacts. How the private recreational market reacts to that over the next 2-3 years will give an idea if new owners mx level will be possible.

 

[Ed Haywood]

And while it provided supporting definitions to how preventive mx should be looked at, just as major repairs and alterations are via those similar listings, it does not directly translate to a regulatory change. So what it does say is the 31 prevent mx items are considered categories and when combined with review of the Part 1 definition of prevent mx, you can expand on those specific categories but not add new categories.

I disagree with you on that. A pilot or owner reading part 43, Appendix A, paragraph (c) could easily conclude by the plain language of the reg that any task not included in the list is not PM:

"Preventive maintenance is limited to the following work"​

​

AC 43-12A reiterates that restrictive interpretation:

If a task or maintenance function does not appear in the list, it is not preventive maintenance.​

The lawyer who wrote Coleal had a rare attack of bureaucratic common sense, and concluded that an all inclusive list would be impossible, so the task list must be examples:

the lists are better viewed as examples of the tasks in each category-they cannot be considered all inclusive. ​

OK, cool, problem solved. But owners and pilots should not have to stumble on an obscure 17 year old legal opinion to understand the core meaning of regulatory guidance that directly affects them. The regulation is ambiguously written, and either the reg or the AC should be reworded to clarify the meaning.

Note the Coleal lawyer agrees, since he also wrote:

It is our understanding that Flight Standards' Aircraft Maintenance Division is planning to clarify this issue in a future revision to the AC. ​

Interesting that this never happened. My speculation is that some old hands in the FAA were unhappy with the lawyer's opinion, and a bureaucratic stalemate exists. Having worked in a federal agency, it is easy to prevent change. Just gum up the internal staffing process with revisions and concerns so it never makes it to the top, unless someone powerful demands progress.

 

[Bell206]

I disagree with you on that. A pilot or owner reading part 43, Appendix A, paragraph (c) could easily conclude by the plain language of the reg that any task not included in the list is not PM:

Let me try from a different angle. One, the Coleal LOI has zero applicability to Part 91 ops. So if one day you get checked and you pull out that LOI as your reference for performing prevent mx, you lose. On the flip side, you follow all rules and guidance verbatim so by your note above you take Appdx A(c) and AC43-12 as gospel. But let's say you're an engaged owner who prefers to dig deep and learn all they can on how the regulations and guidance docs can work for you to navigate aircraft ownership and you run across the Coleal LOI.

While you are close with your first blue quote above you forgot the more important part of that sentence: "As with the other paragraphs of Appendix A (i.e., on major repairs and major alterations), the lists are better viewed as examples of the tasks in each category-(they cannot be considered all inclusive.) The "all inclusive" part is a bit of a stretch here given there no other guidance to support it, however, with the added underline part referencing the major repair and alterations, there is other guidance that does support the "examples of tasks in each category" comment.

For example, say your aft position light is inop, but 43 A(c)16 only states troubleshoot of landing light circuit. However, if you apply the Part 1 definition along with the Coleal statement above, could troubleshooting and repairing the position light circuit be considered another "example of that landing light category?" Is it a slam dunk. No. But it now puts the burden on the ASI to determine it isn't. And if you want further support research the guidance into how major repairs and alterations are determined using the same method. There is a lot more leeway in the rules and guidance than people realize. But how far down that rabbit hole you want to go is strictly where you draw your risk/reward line.

 

[Cesarmx]

I have no problem with some of the repairman cert ideas being floated -- as long as it's just you flying the thing you're maintaining. It's your butt, go ham. Try to miss the schools and orphans please, and stay out of my insurance pool. I can't support any sort of shortcuts that allow you to carry unwitting passengers around based on your mastery of youtube or LLMs. I've seen too much.

There is nothing wrong using you tube to consult to enhance your knowledge on certain subjects, I have even seen APs and IAs consulting YouTube , the web in general when unsure…………

 

[pfarber]

the smart solution is to provide some kind of regulatory incentive to getting training

The FAA is lazy and generally uninterested in GA reform. The FAAs idea of safety is fining airlines $15,000 if a single fire extinguisher is out of the green band. Yet when the parts supply is flooded with garbage parts, the FAA acts like Voldemort has returned... don't speak of it and hope it goes away:

Counterfeit Components Ground Airlines

American Airlines, Delta, and Southwest Airlines are among the companies experiencing pain due to counterfeit parts entering the supply chain.

connectorsupplier.com

Its not a money issue. Raise the registration fee from $5 to say $100 and now you have a couple million to fund a Pt 91 MX reform package to update PM and remove ambiguity from Pt 43. There should be no regulations that include the words 'such as'. Even the FAA working group from the 2000s tried to solidify the definition of major repair/alteration and reading it shows that almost none of them were happy with the use of 'such as' when trying to define an act of maintenance/repair.

The FAA could boost GA with one minor change: AnPs can perform 100 hour inspections, which are identical to annuals. Allow AnPs to perform annuals and now the bottleneck of IAs is gone and wait times for owners is reduced. IAs would still be needed for 337s etc, but there is nothing in the IA training regarding annuals that an AnP doesn't already know.

Also the correct answer is: get an AnP certificate. Many schools offer 12 month courses. The Pt 147 FAR Appendix C used to state that you needed 1900 hours of class time. That no longer exists. As long as you can test to the Maintenace ACS standard you are good to go. Most schools use the semester/trimester system and limit school time to 6-7 hours a day and that's a huge waste of time. A school that offers 10 hour days, 6 days a week could accelerate training to a few months. That would match a regular airline work schedule and get you on yoru way to a $40/hr job well inside a year, if you can pass the tests.

In all honesty there was so much 'dead time' in the old 1900 hour system that sitting around watching King vidoes was most of my powerplant class.

 

[Bell206]

Its not a money issue. Raise the registration fee from $5 to say $100 and now you have a couple million to fund a Pt 91 MX reform package to update PM and remove ambiguity from Pt 43.

So, if its not a money issue, then why raise the fees?