When does the time start for a 100hr requirement?

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KyleT

Pre-takeoff checklist
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New (old) plane goes online for rental and instruction duties. Has about 50hrs flown solely by the owner since the last annual. When is the 100hr inspection due? I can't find anything in the reg answering this question. 91.409 is what we fall under but that doesn't help decide when to do the inspection just that it is required. I and the owner lean towards starting the clock at the last annual. Others have said it starts when the first student/instructor takes the aircraft.

I need a source either way, anyone have experience? Or resources?


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Tach time from the last annual or 100hr.
 
§91.409 Inspections.
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(a) Except as provided in paragraph (c) of this section, no person may operate an aircraft unless, within the preceding 12 calendar months, it has had—
(1) An annual inspection in accordance with part 43 of this chapter and has been approved for return to service by a person authorized by §43.7 of this chapter; or
(2) An inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter.
No inspection performed under paragraph (b) of this section may be substituted for any inspection required by this paragraph unless it is performed by a person authorized to perform annual inspections and is entered as an “annual” inspection in the required maintenance records.

(b) Except as provided in paragraph (c) of this section, no person may operate an aircraft carrying any person (other than a crewmember) for hire, and no person may give flight instruction for hire in an aircraft which that person provides, unless within the preceding 100 hours of time in service the aircraft has received an annual or 100-hour inspection and been approved for return to service in accordance with part 43 of this chapter or has received an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. The 100-hour limitation may be exceeded by not more than 10 hours while en route to reach a place where the inspection can be done. The excess time used to reach a place where the inspection can be done must be included in computing the next 100 hours of time in service.
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If it has been 100 hours or more since either an annual or a 100 hour, you cannot give instruction in it for hire or fly it for hire. For instance if you had an annual done and then you fly it for 100 hours privately before putting it on the line, it would need a 100 hour inspection before the first for hire flight as it has not had an inspection within the preceding 100 hours.
 
James331 said:
Tach time from the last annual or 100hr.
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The time may also be by the Hobs, Clock on the instrument panel, Hour Glass or Tach, whatever you use to clock the 100hr just the requirement to comply with the 100hr inspection.
 
But you're crazy if you're not using tach :)
 
I agree. But the "time in service" was the argument used against me. Seems like I'm going to hold to my understanding of the Reg. Thanks for the reassurance.

We use tach time.


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Not all aircraft have a recording tachometer or electrical system no Hobs, so you have to use something else.
 
KyleT said:
New (old) plane goes online for rental and instruction duties. Has about 50hrs flown solely by the owner since the last annual. When is the 100hr inspection due? I can't find anything in the reg answering this question. 91.409 is what we fall under but that doesn't help decide when to do the inspection just that it is required. I and the owner lean towards starting the clock at the last annual. Others have said it starts when the first student/instructor takes the aircraft.

I need a source either way, anyone have experience? Or resources?
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I want to make sure I understand. Is this an airplane that has not been available for instruction until now? If that's the case, the reg is very straightforward in looking backward. As @SkyDog58 pointed out the reg talks about "the preceding 100 hours of time in service." You look back for that annual or 100 hour inspection. If it's been less than 100 hours, you are good; if not, you're not.
KyleT said:
But the "time in service" was the argument used against me
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What was that argument? Were they saying "time in service" refers to the time being used for instruction rather than all the time the aircraft has been in flight, as FAR 1.1 tells us?
 
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Exactly. Some people have interesting interpretations.


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KyleT said:
Exactly. Some people have interesting interpretations.


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Then I guess you have your FAR reference in 1.1. ;)

You can also find multiple FAA orders, publications, etc that use it that way, most of which tell us total "time in service" is the total flight time the airplane or a part has had since it was manufactured (or in the case of engines, rebuilt).
 
brien23 said:
Not all aircraft have a recording tachometer or electrical system no Hobs, so you have to use something else.
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If you're using them for flight instruction, it'd be foolish to not install both a tech and a Hobbs, if you're interested in really utilizing the plane for training.
 
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