This does not fall within allowed owner maintenance.
Nope you can’t. Napa doesn’t sell FAA PMA and this is not something that falls under Part 43 App. A.
As simple as that repair is, it doesn't fall under the preventive maintenance a pilot owner is allowed to do.
Is it included under preventative maintenance, no.
I disagree. In my oft-ignored but never humble opinion, this fits
perfectly within the realm of preventive maintenance that can be performed by the owner. Let's dig into things a bit.
FAA legal (the Coleal interpreation,
https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2009/Coleal-Bombardier Learjet_2009_Legal_Interpretation.pdf ) has stated:
And, preventive maintenance is defined to
mean "simp le or minor preservation operations and the replacement of small standard
parts not involving complex assembly operations." Id. Preventive maintenance, in
general, includes tasks that are less complex than those deemed to be maintenance, and
requires less sophistication in terms of the knowledge, skill, and tools required.
Many preventive maintenance tasks are listed in 14 C.F.R. part 43, appendix A,
paragraph (c ). The paragraph sets forth in 32 numbered subparagraphs items the FAA
has determined to be preventive maintenance. Even though the introductory text of
subparagraph ( c) states that "[p ]reventive maintenance is limited to the following work
2
... ." (emphasis added), in view of the broader definition of preventive maintenance in
section l. l , we believe that such limitation is not controlling. Similarly, for the same
reason, we also believe that the following sentence in Advisory Circular 43-l2A,
Preventive Maintenance (which was referenced in Mr . Hernandez' s letter), is overly
restrictive. That sentence, found in Paragraph 3(b)(l), states: " If a task or maintenance
functi on does not appear in the list, it is not preventive maintenance." 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. There are, no doubt, many "simple or minor preservation operations [tasks]"
and many "replacement of small standard parts not involving complex assembly
operations" performed daily, especially on small general aviation aircraft, that the agency
would consider to be preventive maintenance, though they are not included in the 32
listed items.
So, according to the FAA legal department, the list of tasks in Appendix A, paragraph (c) is no more a complete list than are the lists of things considered major repairs or major alterations. Rather,
it is the definition given in 14 CFR 1.1 that tells us what preventive maintenance really is, and the list in Appendix A is illustrative rather than binding.
Now then, 14 CFR 1.1 specifically says that preventive maintenance "means simple or minor preservation operations and
the replacement of small standard parts not involving complex assembly operations." The crimp-on connector shown is certainly a "small standard part" and crimping on a new one is about as simple an operation as I can imagine; certainly it does not involve a complex assembly operation.
If we look to the Appendix A paragraph (c) list of examples to better inform our decision, we see that item 16 gives an example of repairs to wiring: "Trouble shooting and repairing broken circuits in landing light wiring circuits." Clearly, this example tells us that simple wiring repair jobs fit the PM definition.
I don't see any problem at all with the OP doing this repair himself as owner preventive maintenance and logging it as such.
