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Thread: Report on Recommendations for increasing the safety of small GA airplanes

  1. #1
    JimRice85's Avatar
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    Report on Recommendations for increasing the safety of small GA airplanes

    This could finally be the time when owner performed maintenance for older aircraft becomes reality. It is good to hear "less burdensome and costly" in a recommendation in reference to the FAA.

    From page 53 of document linked below.

    "6.4 PRIMARY NON‐COMMERCIAL CATEGORY
    The Primary Non‐Commercial Category is intended for the private owner to operate their aircraft in a substantially less burdensome and costly manner by reducing the level of FAA maintenance and alteration requirements to a level appropriate for a privately owned vehicle.
    Recommendation: The FAA create a Primary Non‐Commercial Category under 14 CFR part 21.
    The Primary Non‐Commercial Category is intended for the private owner to operate their aircraft in a substantially less burdensome and costly manner by reducing the level of FAA maintenance and alteration requirements to a level appropriate for a privately owned vehicle."

    Aircraft would be dual category. Owner maintained for non-commercial and A&P/IA for commercial. An A&P inspection for annual inspection would be required. Very closely following E-AB rules.

    http://www.faa.gov/regulations_policies/rulemaking/committees/documents/media/Part.23.Reorganization.ARC.FINAL.Report.pdf
    Jim Rice
    Wolf River Airport (54M)
    Collierville, TN
    1946 Globe GC-1B Swift N3368K
    1946 Piper J-3C Cub N7155H

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    Does the doc state how a non-commercially maintained aircraft could be moved back into the commercial category? There are lots of airplanes where the owner might want to operate in the commercial category. Example - If you or I as Swift owners wanted to use our airplane to check out a prospective Swift buyer or new Swift owner and accept compensation. Today if we do that, the only aircraft record the FAA cares about is that within the last 100 hrs our airplane has undergone an annual or 100 hr inspection. Another example is if I own a C-182 and a skydiving operation is interested in purchasing my airplane? If I have switched the airplane maintenance into the non-commercial track, how do I get if back to the commercial track?

    Hopefully the transition is not onerous or lots of owners might not take the risk. Most of us will eventually sell our airplanes.

    And it will be interesting how the insurance companies set premiums for airplanes in the proposed category.

    Best of luck,

    Wes
    N78PS

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    Sounds like a very slippery slope with no way back. Resale value would no doubt take a big hit. The proposal does not state how or even if an aircraft could be returned to 'commercial' status. Question also regarding modifications. Would current requirements remain or would E-AB rules apply.

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    Quote Originally Posted by WLIU View Post
    Does the doc state how a non-commercially maintained aircraft could be moved back into the commercial category?
    Yes.

    Quote Originally Posted by Dave Stadt View Post
    Sounds like a very slippery slope with no way back. Resale value would no doubt take a big hit. The proposal does not state how or even if an aircraft could be returned to 'commercial' status.
    Doesn't sound like you read the document very closely. This proposal is basically the same as the Canadian Owner Maintenance category, except with the provision that the plane can be returned to Normal Category (unlike the Canadian version). From the document:
    Conversion Back to Normal Category

    1. Aircraft operated in the Non‐Commercial type certification class would be dual certificated in both the Normal and Non‐Commercial categories, as is commonplace for Restricted Category aircraft.
    2. Aircraft in the Non‐Commercial TC category can be operated in the Standard Category, provided the aircraft meets it type design data including compliance with all ADs, removal of all Non‐PMA/TSO parts and replacement with certified units and the removal of all non‐certified alterations.
    3. The conversion can be accomplished by an Inspection Authority (IA) mechanic with a complete and thorough annual inspection and logbook audit. Upon successful completion, the aircraft could be operated under its Standard Airworthiness Certificate. The procedure is very common with Restricted Category aircraft and proven to be safe and successful.


    So basically, to return it to a normal category certificate, all non-PMA'd and non-TSO'd parts have to be removed, and a regular inspection by an IA to insure the plane is in compliance with all applicable ADs, etc. will bring it back to a normal category plane that can be used for commercial activities again.

    Quote Originally Posted by Dave Stadt View Post
    Question also regarding modifications. Would current requirements remain or would E-AB rules apply.
    According to the document:
    Privileges

    1. Aircraft in this category can be maintained by the owner with a repairperson’s certificate, similar to currently established procedures for LSA aircraft repairpersons.
    2. Replacement or alteration parts should be appropriate for aircraft use; however, such parts need not be PMA/TSO authorized.
    3. Owners can alter their own aircraft without the requirement for FAA approved data; however, some alterations may require “phase 1” flight testing similar to Experimental Amateur Built (EAB) requirements.


    I think this is a great idea, and would love to see it happen. If it did, I would be one of the first to sign up.
    Last edited by FloridaJohn; 10-14-2013 at 12:30 PM.

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    Yep I missed that. Went back and reread and noticed annual inspections would be required by an A&P not an IA. Don't see much savings there. So other than being able to self install non PMA/TSO parts what is the real world difference? Flying a Cessna 120 why would I want to go this route?

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    Quote Originally Posted by Dave Stadt View Post
    Yep I missed that. Went back and reread and noticed annual inspections would be required by an A&P not an IA. Don't see much savings there. So other than being able to self install non PMA/TSO parts what is the real world difference? Flying a Cessna 120 why would I want to go this route?
    There are a lot more A&Ps then there are IAs, so it should give you more options for the inspections. More options usually results in lower prices, so that may be a benefit.

    The main benefit, as I see it, is that you can do all the maintenance yourself, including signing off the work. So you can install new avionics, replace your mags, make repairs, etc. on your own instead of paying someone to do it for you. An added bonus is that you would get access to all the newer, less expensive avionics that the experimental folks have been enjoying for years.

    Doing your own maintenance and using lower cost components sounds like a really easy way to lower the cost of owning a certified airplane.

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    I will offer the suggestion that you will not really be able to use less expensive components and have an A&P sign off your annual inspection. The mechanics that I work with have regular horror stories of redo-ing work that an uneducated owner did with Radio Shack wire or the wrong hardware. A conscientious mechanic who values their certificate is going to insist that Cessna's be repaired with Cessna parts and hardware and parts that meets the current definitions of aircraft grade. That's the booby trap. At the annual inspection, any work that is not as good as your mechanic would have done, will get re-done at your expense. And that is completely understandable since no mechanic wants to sign off work that was done to a lower standard than he or she would have done, and then get called because you crashed.

    What that means in practical terms is that today you can do all of the things that have been listed in the previous post so long as you know your mechanic, work under his or her supervision, to the mechanic's standards, and probably using whatever tools you do not own but he or she does. I have done all of the tasks listed in the previous post and my mechanics provide guidance, quality control, and the apprpriate log book entries after I fork over some $$ and maybe beer. So I gain nothing with the implementation of this proposal. Your hands and my hands can already do all of these tasks so long as we have a good relationship with our local mechanics and respect their role, their accumulated knowledge, and the value they bring to working on your and my airplanes.

    Now if I put LSA avionics in, my ship's resale value takes a hit because a prospective buyer may have to take it all out and put in certified avionics for what they want to do. So I will suggest that most folks will stick with the more expensive stuff.

    It is good to see a proposal, but it would be even better to see a proposal that does not suffer the fate of the Recreational Pilot Certificate where the number of folks who thought it was worth earning one is vanishingly small.

    Best of luck,

    Wes
    N78PS
    Last edited by WLIU; 10-14-2013 at 05:14 PM.

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    That is my take also Wes and to recertify is akin to giving an IA a signed blank check. I would not blame an IA as they will have no idea what they will be dealing with. If it was me I would not put my ticket on the line unless I knew the person and their quality of work.

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    Well, there are modifications and then there are modifications.

    I suspect that a mechanic may wave off on doing the annual for a Champ with a VW engine on it, but let's think a bit smaller.

    Let's say one's compass needs replacing. It came with Ye Olde whiskey compass, and the owner wants to put in a vertical card compass. First, if it's taken out of commercial status one doesn't have to worry about whether or not it's legal to change the type or any paperwork for exceptions. And one doesn't need a TSO'd compass.

    The price difference between a TSO'd and non-TSO'd vertical card compass is over a hundred dollars.

    I won't even approach the matter of clocks on panels. TSO'd clocks must have pure gold back plates; they dang sure aren't accurate enough to warrant the prices they demand.

    Does anyone think a mechanic will refuse to do an annual because the compass isn't a TSO'd model?

    And while it bodes well for a pilot owner to pay attention to AD's, in the experimental world they're optional, being given that the owner has a responsibility to ensure his aircraft is safe. The pilot can defer implementing an AD if they choose to and still keep flying.
    The opinions and statements of this poster are largely based on facts and portray a possible version of the actual events.

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    Quote Originally Posted by WLIU View Post
    I will offer the suggestion that you will not really be able to use less expensive components and have an A&P sign off your annual inspection. The mechanics that I work with have regular horror stories of redo-ing work that an uneducated owner did with Radio Shack wire or the wrong hardware. A conscientious mechanic who values their certificate is going to insist that Cessna's be repaired with Cessna parts and hardware and parts that meets the current definitions of aircraft grade. That's the booby trap. At the annual inspection, any work that is not as good as your mechanic would have done, will get re-done at your expense. And that is completely understandable since no mechanic wants to sign off work that was done to a lower standard than he or she would have done, and then get called because you crashed.
    Yes, of course. I agree with your basic premise. However, how is this different than what an owner of a currently E-AB plane that they did not build has to go through? If you own an E-AB plane without a repairman's certificate, you are subject to the scrutiny of an A&P at least once a year. It seems to be working just fine in the experimental world, so why not in a non-commercial setting for a certified plane?

    Quote Originally Posted by WLIU View Post
    What that means in practical terms is that today you can do all of the things that have been listed in the previous post so long as you know your mechanic, work under his or her supervision, to the mechanic's standards, and probably using whatever tools you do not own but he or she does. I have done all of the tasks listed in the previous post and my mechanics provide guidance, quality control, and the appropriate log book entries after I fork over some $$ and maybe beer. So I gain nothing with the implementation of this proposal. Your hands and my hands can already do all of these tasks so long as we have a good relationship with our local mechanics and respect their role, their accumulated knowledge, and the value they bring to working on your and my airplanes.
    Yes, of course, and I do that as well. Nearly all the work on my plane has been done by myself, and then inspected and signed off by an A&P. However, if I am already doing all the work, and it is clearly acceptable up to aviation standards (because it is passing the A&P's inspection), then why do I need to "fork over some $$ and maybe beer" to someone else? Surely you can see this as an immediate reduction in expenses?

    Quote Originally Posted by WLIU View Post
    Now if I put LSA avionics in, my ship's resale value takes a hit because a prospective buyer may have to take it all out and put in certified avionics for what they want to do. So I will suggest that most folks will stick with the more expensive stuff.
    I disagree here. Your premise is that a plane is more valuable with certified avionics than with non-certified avionics. Granted, a G1000 panel in my plane would be more desirable than a Dynon panel, but I don't know anyone that would prefer the traditional six-pack panel over a Dynon panel. The new-plane market sees this as well, since nearly all new planes come with glass panels. If there was a market for steam gauges, the manufacturers would be offering it as an option. Since the majority of the planes that would fall under this proposal are older planes, I think ones with a modern, glass panel will fetch more than ones with an original panel.

    I also think you are overstating the commercial value of this class of planes. The vast majority of these planes have never been used in a commercial setting, or are no longer used for commercial activities. They are personal planes used for personal reasons. The main commercial use for this class of planes is flight instruction, and those planes will have to remain stock. All others are for personal use and the owner should be allowed to do what they want (within reason, of course).

    But the beauty of this proposal is that it is voluntary, and any plane can be returned to commercial service merely by removing any non-certified parts. So, if you think your plane is more valuable in stock condition, then don't move your plane into the new category. I have read time and time again how the biggest barrier to entry in aviation is the cost. Here is a concrete proposal on how to reduce those costs, and somehow it is being perceived as a bad thing?

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