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

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  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
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  2. #2

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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

  3. #3

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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.

  4. #4

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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.

  5. #5

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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?

  6. #6

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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.

  7. #7
    jjhoneck's Avatar
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    Is anyone holding their breath?

    After two decades of waiting, I finally gave up and bought an RV-8.

  8. #8

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    The final ruling will probably be a watered down version of the proposal. Buying an RV-8 or any other E-AB makes much sense if that is the route one wants to go. I just do not see that the proposal is going to save much money in the long run. If one has the ability you can work with an A&P/IA and pretty much do what is being proposed and maintain certification. On the other hand, we have all seen certified aircraft that have 'passed' annual but should not be allowed out of the hangar much less in the air. What would make sense is if changes to improve safety of certified aircraft would be streamlined without having to go through the onerous STC process.

  9. #9
    Mike Berg's Avatar
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    Having rebuilt/recovered several light tube and fabric certified planes I am fortunate to have a IA that will work with me. However he happens to be about 60 miles away so it gets to the point where there is a certain amount of waiting for him to make the trip to inspect my work. One would say "why not get your A & P" but there's no local school and I have no desire at my age (+70) to learn about jet and turbine engines, controllable props or heavy electronics ,etc. As a diesel mechanic with over 50 years of experience including 30+ years teaching the subject I've worked on equipment a lot more complex that a 7AC Champ or J-3 Cub. It would seem to me that common sense should take over and offer a path for those of us who only want to maintain older light duty aircraft. Taking my Champ, Taylorcraft or J-3 to the 'big shop up the road' only means they're going to be learning about tube and fabric aircraft on my dollar ($$$$) and I feel much more confident of doing the work myself anyway. I doubt A & P schools even teach tube and fabric anymore. Plus, let's say I've had a couple of bad experiences with annuals by 'certified mechanics'. My suggestion would be that a course (and examination) be offered to those of us who want to maintain our light duty aircraft. Probably not going to happen in the amount of flying time I have left but it's a nice thought.
    If God had intended man to fly He would have given us more money!

  10. #10
    Matt Gonitzke's Avatar
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    Quote Originally Posted by Mike Berg View Post
    I doubt A & P schools even teach tube and fabric anymore.
    It's still part of the curriculum and probably will be forever. There's still material about radial engines covered, too...

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