I'm wondering if a private pilot could do this in light of the Coleal letter re. preventative maintenance (page 2).
"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
.... " (emphasis added), in view of the broader definition of preventive maintenance in
section 1.1, we believe that such limitation'is not controlling. Similarly, for the same
reason, we also believe that the following sentence in Advisory Circular 43-12A,
Preventive Maintenance (which was referenced in Mr. Hernandez's letter), is overly
restrictive. That sentence, found in Paragraph 3(b)(1), states: "If a task or maintenance
function 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 allinclusive.
There are, no doubt, many "simple or minor preservation operations [tasks]"
and many "replacement[ s] 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."