Turning Certificated Acft into "Experimental"

[TedK]

Ok this is great! (...) We need a link to the law as it reads, (snip)

The entire text of of SARA, Public Law 113-53 is at:

http://beta.congress.gov/113/plaws/p...-113publ53.htm

The text of SARA isn't terribly long (by congressional norms) but IMO the below is the operative text that says to implement the study (those as my words). The text says:

SEC. 3. SAFETY AND REGULATORY IMPROVEMENTS FOR GENERAL AVIATION.

(a) In General.--Not later than December 15, 2015, the

Administrator of the Federal Aviation Administration shall issue a

final rule--

(1) to advance the safety and continued development of small

airplanes by reorganizing the certification requirements for such

airplanes under part 23 to streamline the approval of safety

advancements; and

(2) that meets the objectives described in subsection (b).

(b) Objectives Described.--The objectives described in this

subsection are based on the recommendations of the Part 23

Reorganization Aviation Rulemaking Committee

The recommendations of the Part 23 ARC are in the link on the first post. The ARC Study report is 346 pages long but most of it deals with its main charter of modernizing the design, certification and production of GA aircraft. But within that tome are some real presents for us existing owners.

[Mike Berg]

To me this is long overdue. As one who flies older "Champ" type aircraft I find it will get more and more difficult to find a IA who has experience with tube/fabric and wooden spar type aircraft. In the past dozen or so years I've rebuilt and recovered three tube and fabric aircraft under the supervision of my IA but one wonders who to go to once he retires. I feel much better about doing the inspection and signing the aircraft off myself rather than having a 20 year old graduate doing the inspection. Most A & p schools don't even teach fabric anymore and I doubt they know anything about wooden spars. As far as the engine goes I'd guess my Honda motorcycle engine is much more complicated and checking cylinder leakage (compression to some) and engine timing is not brain surgery. I would argue that it's necessary to follow the AD directives and any service letters that become necessary and obviously it's necessary to use aircraft quality nut/bolts, etc.

[raytoews]

Get the alphabets on this hard.

This has had a greater impact on my cost and enjoyment of flying then a medical exemption, not that I am opposed to the medical exemption.
I contacted COPA, our equivalent of AOPA and asked about medical exemption in Canada and the response was if it happens in the US it will likely have to happen in Canada as a pilot with a medical exemption would not be allowed into Canada.

Or so we are hoping.

On the other hand, it is not a bad thing to be forced to go to a doctor every couple of years and have him put his finger where the sun don't shine!
The fear is if the doctor finds something he is obligated to rat you out to the govt, that is just wrong in so many ways, not the least being doctor patient confidentially.
Some years ago I had an EKG done by a sloppy technician and thankfully the doctor noticed and suggested I get a "premed" done in another country.
I would be more inclined to remove the rat provision for recreational pilots from the rules and let the pilot and the doctor make the decision. I
IMHO

Ray

[TedK]

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.

In reading the Study, it appears that the reason for the Repairmans certificate was that unlike E-AB where the builder proves he has the skills to maintain an airplane by building one, the Study decided to use the LSA model, which means you can maintain your airplane after taking a short course to get RC. Owners with an RC can do their own PM or Return to Service Maintenence.

Yearly Condition inspections require only an A&P (wo IA), and restoration to Normal category requires a regular Annual signed by an IA.

IMO the RC is a minor barrier and I would certainly want that training before I was turned loose with tools on my airplane. I suspect a lot of that training is Administrative...where to find the right Regs, Procedures, etc, and how to properly document what you are doing. Not necessarily obvious, even to the most seasoned watcher of Tooltime.

[TedK]

This is page 311 of the Study Recommendation summarizing the recommended changes to create the PNC category.

Primary Non-Commercial Category Recommendations

Applicability
· The owner of a fixed wing, non turbine powered Part 23 aircraft or Part 23 glider, 20 years or older, may elect to redesignate his or her aircraft as a Primary Non-Commercial. (see draft regulations 21.24 and 21.184)

Privileges
· Aircraft in this category can be maintained by the owner with a repairmans certificate. Similar to currently established procedures for LSA aircraft repairman. (see draft regulation 65.108)
· Replacement or Alteration Parts should be appropriate for aircraft use, however need not be PMA / TSO authorized. (see draft regulation 21.24)
· 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 AB requirements) (see draft regulation 91.328)

Limitations
· Primary Non Commercial Category Aircraft are required to observe the FAA Approved Aircraft Flight Manual Operational Limitations and or required placard limitations established for the Standard Category (see draft regulation 91.328)
· Aircraft can not be used to carry persons for hire, this includes aircraft rental, but allows an owner to receive flight instruction in their own aircraft (see draft regulation 91.328)
· Airworthiness Directives are applicable as currently allowed for Experimental Amateur Built aircraft
Aircraft Owners must maintain a list in the aircraft logbook off ALL applicable ADs and their compliance status. This list would be used to highlight the owners awareness of the ADs existence and document their choice of compliance. This list would be used to facilitate the conversion of the aircraft back to the normal category. (draft regulation 21.24)
· Aircraft owners must maintain a list in the aircraft logbook of ALL alterations performed that are not FAA approved and ALL non PMAed / TSO parts installed. This list would be used to facilitate the conversion of the aircraft back to the normal category. (see draft regulation 21.24)
· Incomplete or Fraudulent Maintenance log book entries result in revocation of the aircraft’s standard airworthiness certificate (see draft Order 8130.2)

Requirements
· Before original conversion, the aircraft must have a current annual inspection – all applicable ADs must be complied with current annual inspection. (see draft regulation 21.24)
· Airplane owners must either add the prefix of “NC” to the aircraft registration number or affix a “Non-Commercial” placard readily visible to all passengers. (see draft regulation 45.22)
· The aircraft must have a yearly condition inspection by an A&P Mechanic certifying that the aircraft is “in condition for safe operation.” (see draft regulations 91.328)
· Upon transfer of aircraft ownership, the Non-Commercial Airworthiness Certificate must be reissued in the new owner’s name (see draft regulation 21.184)

Conversion Back to Normal Category
· Aircraft Operating under a Primary Non Commercial Airworthiness Certificate would be dual certificated in both the Normal and Non Commercial categories, as is common place for Restricted Category aircraft. (see draft regulation 21.184)
· Aircraft in the Primary Non-Commercial category can be operated in the Standard category, provided the aircraft meets its type design data including compliance with all ADs, removal of all Non PMA / TSO Parts and replacement with certified units and removal of all non-certified alterations (see draft 21.24, draft Order 8130.2)
· The conversion can be accomplished by an IA mechanic with a complete and thorough annual inspection and log book audit. Upon successful completion the aircraft could be operated under it’s Standard Airworthiness Certificate. The Procedure is very common with Restricted Category aircraft and has proven both safe and successful. (see draft Order 8130.2)
Pg 311

[raytoews]

The aircraft must have a yearly condition inspection by an A&P Mechanic certifying that the aircraft is “in condition for safe operation.” (see draft regulations 91.328)

What does this look like? I understand homebuilt and LSA aircraft need this as well??

Ray

[Mike Berg]

I would agree with most of this other than the need of having a A & P (instead of a IA) doing a yearly condition inspection. To me this defeats the whole purpose of the proposal. I would rather do the inspection (and sign it off) myself than have a A & P who is not familiar with tube and fabric, wooden spars aircraft. Is he or she going to know how or where to look for spar cracks, rusted tubing, fabric condition, etc? This is even getting to be a problem with current IA's who have limited knowledge of older aircraft. A better proposal would be to have a required short course and test on older aircraft condition inspection. The 'graduate' would then be 'certified' to inspect and sign off his personal aircraft or something like the LSA or builder as I understand it. I taught courses in heavy truck maintenance at a community college for many years and certified folks for air brakes, air conditioning, annual vehicle inspection and it worked just fine. I also tested and 'certified' those who had experience but needed certification in various areas. This is done all the time by various manufacturers. Just my two cents worth. The overregulation is what drives people into the home built field.

[rwanttaja]

The aircraft must have a yearly condition inspection by an A&P Mechanic certifying that the aircraft is “in condition for safe operation.” (see draft regulations 91.328)

What does this look like? I understand homebuilt and LSA aircraft need this as well??

Ray

The Operating Limitation of my Fly Baby state that the aircraft must be inspected "...in accordance with the scope and detail of Appendix D, Part 43, and to be in a condition for safe operation."

Appendix D is the "Scope and Detail of Items to be included in Annual and 100-hour inspections."

The way I understand it, the main difference between "old" and "new", as far as the annuals are concerned, is that the person doing the inspection does not have to verify that the aircraft still meets its original type certificate. This why an IA will not be necessary; just like a homebuilt only needs an ordinary A&P (or repairman certificate). So you can install a non-TSO'd bit of gear, as long as the A&P at the next inspection considers the installation to be non-detrimental to safe operation.

Ron Wanttaja

[raytoews]

If you need an A&P to sign off your aircraft you have gained nothing.
My understanding is a repairmans certificate is a few weekends of classe's and a test??

What started me down this path was an experience we had. A couple of us bought an old Aeronca Champ and when annual was due we took it to a local AME who only knew about iron. He looked at it and said the spar was cracked, we said thanks we'll go elsewhere. He immediately phoned Transport Canada and ratted us out. Made lots of headache for us. There was nothing wrong with the airplane. I'm not a licensed mechanic but I am more than a pilot with a screwdriver. I have worked in the industry but 30 yrs. ago an apprentice couldn't make enough to support a family.
Since then I have had numerous occasion after my aircraft was inspected I had to go back and redo work.
Now nobody touches my airplane. I fix it, I fly it, I trust it.
If you don't want to fit into that category, buy a spam can and get taken to the cleaners.

[TedK]

Http://www.macsblog.com/2014/03/coul...lane-be-a-pnc/