Turning Certificated Acft into "Experimental"

[TedK]

Last December, the Small Aircraft Revtalization Act directed the FAA to implement the recommendations of the Part 23 ARC study. In addition to trying to fix Part 23 to make it easier to design, certified and produce new aircraft (<19,000 lbs), the study also made the extraordinary recommendation to permit an owner to convert their Certificated Aircraft to essentially an Experimental aircraft. This would create what is called the Primary NonCommercial Aircraft.

PNC (pink?) aircraft would have to be at least 20 years old, up to date on AD compliance, in annual but could then converted to the PNC catagory. At that point, the PNC aircraft (PNCA) could no longer carry persons for hire or rental,but the owner could effectively treat it as an Experimental-Amateur Built aircraft, making Mods as the owner saw fit.

Also, PNCA Owners could get a Repairmans certificate allowing them to perform maintenance.

Also, the ARC Study includes a provision where the pickle could be turned back into a cucumber. PNCA could be returned to Certificated status by removal of the Modifications.
See Section 3.3.5 (page39) and Appendix G4 of the study at
http://www.faa.gov/regulations_polic...NAL.Report.pdf

There are a lot of other good items like easier Field Approvals for Certificated aircraft, improvements for owner performed preventative maintenance and lower barriers to making avionics for Certificated aircraft.

Thoughts?

We need to get smart on this ARC study so that we are prepared for the NRPM.

[Todd copeland]

This is an intriguing proposal. I liked it from the start. Unfortunately the FAA will likely never agree to it. The agency is so slow to make changes and it can only see risk when it does make changes. Makes it unlikely unfortunately.

[TedK]

This is an intriguing proposal. I liked it from the start. Unfortunately the FAA will likely never agree to it. The agency is so slow to make changes and it can only see risk when it does make changes. Makes it unlikely unfortunately.

SARA is the Law now and it directs the FAA to issue final rules by 15 Dec 2015. FAA will have a hard time backing away from this since it is Legislatively demanded.

Vintage should be all over this like white on rice working with EAA Advocacy to make sure we get the Regs right.

This is has the potential to be a god send to personal flyers and EAA (and us) needs to drive this over the goal line.

[Todd copeland]

SARA is the Law now and it directs the FAA to issue final rules by 15 Dec 2015. FAA will have a hard time backing away from this since it is Legislatively demanded.

Vintage should be all over this like white on rice working with EAA Advocacy to make sure we get the Regs right.

This is has the potential to be a god send to personal flyers and EAA (and us) needs to drive this over the goal line.

I didn't realize that! That is fantastic, now combine it with the current legislation to eliminate the third class medical and we have a chance at some revival within GA.

[TedK]

I didn't realize that! That is fantastic, now combine it with the current legislation to eliminate the third class medical and we have a chance at some revival within GA.

Yeah, now that it is Law, the ball falls back into our court to respond to the Notice of Proposed Rulemaking (NRPM). When the NRPM comes out, the FAA will post the proposed new Regs, that will be our last chance to comment and get them changed if they aren't what we want.

Our best chance of getting what we want is for EAA (and AOPA) to hear what WE want BEFORE the NPRM comes out so they can craft the language for our desired proposed Regs.

So what can we do now? Read the ARC Study. Comment on the forums on what you like, what you don't like, and what you want changed. The public discourse here will help EAA determine where the membership (us) stand, and what they consider gotta have, nice to have and don't care.

The squeaky wheels get the grease here. And the more wheels all demanding the same grease make it hard for FAA to ignore. Your voice, our voices, count.

Read, think, comment!

[jam0552@msn.com]

This rule would have tremendous potential for me. I'm trying to license my 1940 Funk with an 85HP Continental instead of Lycoming O-145 or Ford Model B engines. The FAA has not yet told me if I'm able to sign off the aircraft logs as a minor modification, or if I'm going to need a one-time STC or a Field Approval. Under this rule I could just license it experimental and sign it off myself. I had also contemplated getting rid of the battery, starter and generator, and with the weight savings license it as alight sport under 1320 lb. I hope this rule comes to pass...
-Joel Marketello

[Puertoricoflyer]

The only issue I have with this recommendation is that the PNCA owner can get a "repairmans certificate allowing them to perform maintenance".
I feel the PNCA owner should not need a "repairmans certificate" to do maintenance. The requirement should be the same as the Experimental world where anyone can do "maintenance" but requires an annual "condition" inspection" by an A&P (IA not required) when the owner did not build the aircraft. In other words, treat the PNCA the same as an experimental aircraft except that the PNCA could be returned to Certificated status by removal of the Modifications.
Overall, I think this is a great idea and very long overdue.

[raytoews]

In Canada it is called the Owner Maintenance category has been in place for about 15 yrs and the sky hasn't fallen yet.
It has made aircraft ownership affordable and enjoyable for me.

Ray

[raytoews]

Part of the COPA guide to OM.

Under the O-M Category, Aircraft Pilot/Owners are
Eligible To:

 maintain an airplane
 conduct and sign for the annual inspection
 refurbish all or part of an airplane
 overhaul all or part of an airplane
 install certified and uncertified parts
 install or replace any instruments or avionics
 modify an airplane within certain limits
 rebuild an airplane that is out of service
COPA Guide to the Owner Maintenance Category
5
 sign the maintenance release.

NOTE: The pilot/owner pilot can do any work on an airplane or hire someone (such as
an AME, amateur-builder or anyone else) to do the work for the owner/pilot. Either an
AME or the pilot/owner can then sign the maintenance release.

Changing the Rules

The following CARs were some of those that were affected by the creation of this
category and outline some of the privileges and benefits:

 CAR 507.10 The pilot/owner of an O-M Category aircraft no longer has to have
inspections performed or supervised by an AME.

 CAR 571.06 The pilot/owner can sign the maintenance release for a major repair or
overhaul on an O-M aircraft and only needs to show that the repair conforms to the
requirements of “acceptable data”.

Sources of “acceptable data” include, but are not limited to:

 Drawings and methods recommended by the manufacturer of the aircraft,
component, or appliance

 STC documents for that type or other types of aircraft

 Transport Canada advisory documents;

 FAA Advisory Circular 43.13-1B Acceptable Methods, Techniques & Practices-
Aircraft Inspection and Repair, and FAA Advisory Circular 43.13-2A Acceptable
Methods, Techniques, and Practices - Aircraft Alterations

 UK CAA Civil Aircraft Inspection Procedures (CAIP),

 JAA Advisory Circulars, (ACJ) and

 Publications issued by recognized authorities on the subject matter
concerned.

 Pilot/Owners may devise their own data, which need not be approved, but
must be subject to an appropriate level of review or analysis, or be shown
to comply with recognized industry standards, or commonly accepted
practice.

NOTE: Changes that affect the structural strength, performance, power plant
operation, or flight characteristics of an aircraft must be reported to the
Minister before further flight of the aircraft; such changes may require re-
COPA Guide to the Owner Maintenance Category
6
evaluation to confirm that the aircraft continues to comply with the applicable
standards.

NOTE: The Minister of Transport is the final authority for determining the
acceptability of data.

 CAR 571.10 and CAR 571.11 The owner of an O-M aircraft, who is a pilot, can sign
all the maintenance releases for the aircraft using the following wording: "The
described maintenance has been performed in accordance with the applicable
airworthiness requirements."

 CAR 571.07 The pilot/owner can install new and used certified and uncertified parts
on an O-M aircraft.

 STD 507.06(13)(a) The pilot/owner of an O-M aircraft may apply for a Special
Certificate of Airworthiness – Owner-Maintenance without having to have available
an approved Aircraft Flight Manual or approved operating limitations.

 STD 571.13 Aircraft in the O-M category are excluded from the requirement that
only those parts specified in the type design of the aeronautical product are eligible
for installation on that product.

 CAR 605.84 Pilot/owners of aircraft operated under a Special Certificate of
Airworthiness – Owner-Maintenance are not compelled to comply with
Airworthiness Directives or to operate in accordance with airworthiness limitations
applicable to the type design for the aircraft although they may voluntarily do so.

 CAR 605.92 Pilot/owners of aircraft operated under a Special Certificate of
Airworthiness – Owner-Maintenance are allowed to keep the required technical
record reports in the Journey Log rather than keeping one or more technical record

[Todd copeland]

Ok this is great! I'm dumbfounded that I didn't know about this. Why isn't the EAA more vocal about it? We need a link to the law as it reads, and someone to give the membership actionable direction for it just like the proposed elimination of the third class medical. These recent moves in congress is shocking given the regulation happy government we have had in recent years but I love it. Let's help continue the momentum.