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Thread: Pilot and air frame logging question.

  1. #11

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    I carry hull insurance and as most folks know, the rates go down at something like 250, 500, 1000 PIC hours, if you have an instrument rating, etc.

    If all you carry is liability insurance, and/or your total time and/or time in type is a 4 or 5 digit number there aren't any more price breaks you can get.

    But every log tells a story. Perhaps when I am old and can no longer get out of my rocking chair someone can read me my pilot log and remind me that I was young once and bold...

    Best of luck,

    Wes

  2. #12

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    Quote Originally Posted by Marc Zeitlin View Post
    +But there IS a requirement for logging maintenance, although there are some who will argue with this (and have). 14 CFR Part 91.417:

    https://www.law.cornell.edu/cfr/text/14/91.417
    Since you cast out your crankbait, I'll bite:

    In order for this "requirement" to work, one has to take the mutually inclusive language of the cited FAR and apply it carte blanche. Unless specifically stated, one can not dissect a reg and apply only the parts of one's choosing while ignoring the remainder. It's most unusual this practice would be applicable to this one specific regulation without being noted anywhere. Perfectly understandable why one may be skeptical of such a "requirement"

    there is no exemption from this requirement anywhere for EAB aircraft that anyone who believes it doesn't apply has ever been able to point me to. I've had informal discussions with the FAA's corporate legal department and they support this position (although they have not issued an official letter on the subject, so until they do, this is just my opinion).
    Touché! Nor is there any evidence to conclusively support the opinion that EAB are bound by this reg. Not aware the FAA has a corporate legal department but being a branch of the US Gov. they do have an office of chief counsel that serves as the legal dept. From that office or any regional branch thereof, no chief counsel or deputy chief counsel opinion, no interpretive ruling. In addition, no record of enforcement action and/or civil case law finding fault for not logging EAB aircraft maintenance. EAB have been around a long time, you'd think something would have come up by now.

    And log 100% of any maintenance you do on the plane
    As a matter of practice, good advice. Heck, I record all the maintenance I do on my truck - if nothing else for data collection! But it's not required.

  3. #13

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    So we're in the realm of the dreaded "best practices."

    I'm about as far from OCD one can get without wearing my pants on backwards, but I actually put in a column of my log book just for my Nieuport.

    Oh, and I wound up with a perfect 90 hours of total time as a pilot this last weekend.
    The opinions and statements of this poster are largely based on facts and portray a possible version of the actual events.

  4. #14

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    Thumbs Up

    Quote Originally Posted by Frank Giger View Post
    Oh, and I wound up with a perfect 90 hours of total time as a pilot this last weekend.


    !!! 100 hrs is a milestone after which you'll find things like crosswind landings just click into place. Also worthy of a party celebration! Preemptive congrats now!

  5. #15

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    Any more it seems like I need some wind, including a bit of a crosswind, to get a decent landing.
    The opinions and statements of this poster are largely based on facts and portray a possible version of the actual events.

  6. #16

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    Quote Originally Posted by martymayes View Post
    In order for this "requirement" to work, one has to take the mutually inclusive language of the cited FAR and apply it carte blanche. Unless specifically stated, one can not dissect a reg and apply only the parts of one's choosing while ignoring the remainder. It's most unusual this practice would be applicable to this one specific regulation without being noted anywhere. Perfectly understandable why one may be skeptical of such a "requirement"
    I'm not sure what you're saying here. 91.417 says maintenance has to be logged. EAB aircraft are subject to part 91. There's a specific FAR that says EAB aircraft are NOT subject to part 43. There is no such thing about any of part 91, unless your specific OL's say so (and I've never seen any that do).

    So I don't know what you're getting at here...

    Quote Originally Posted by martymayes View Post
    Touché! Nor is there any evidence to conclusively support the opinion that EAB are bound by this reg.
    The evidence is that they're bound by every other paragraph of part 91 that they fit the requirements of (not more than 12,500 lb., etc.). Without a part 43 type exemption, we're not exempt. Otherwise, why wouldn't you also claim exemption from part 91.155 (weather minimums for VFR) since no place says we're specifically bound by them. EAB aircraft are aircraft, and 91.417 says "aircraft", not "Type Certificated Aircraft".

    Quote Originally Posted by martymayes View Post
    Not aware the FAA has a corporate legal department but being a branch of the US Gov. they do have an office of chief counsel that serves as the legal dept.
    Yeah, that's what I meant..

    Quote Originally Posted by martymayes View Post
    From that office or any regional branch thereof, no chief counsel or deputy chief counsel opinion, no interpretive ruling. In addition, no record of enforcement action and/or civil case law finding fault for not logging EAB aircraft maintenance. EAB have been around a long time, you'd think something would have come up by now.
    I get that the chief counsel hasn't issued an opinion, which is why I said this is only MY opinion. But they did unofficially state this position to me on the phone. Would you like me to write them a letter and get an official opinion? I'd be happy to do so...

    I agree that there's no record of enforcement (but as far as I can tell, the FAA hardly enforces any regs with respect to EAB aircraft, or most aircraft, whatever they SAY you should be doing). We're discussing the rules here, not the enforcement thereof. 91.209(b) says that if you've got anti-collision lights on your plane, they have to be on unless you determine it's safer to turn them off (formation? inside a cloud?). You ever heard of anyone getting a ticket for violating that rule? Me neither, but it's still a rule, even if no one's enforcing it.

    Quote Originally Posted by martymayes View Post
    As a matter of practice, good advice. Heck, I record all the maintenance I do on my truck - if nothing else for data collection! But it's not required.
    On the truck, no. On the airplane, obviously we disagree about the regs.

  7. #17

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    Most of the routine maintenance records can be discarded after one year (91.417 (b)(1).
    Most owners do not discard these records.

  8. #18

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    Quote Originally Posted by Bill Berson View Post
    Most of the routine maintenance records can be discarded after one year (91.417 (b)(1).
    True.
    Quote Originally Posted by Bill Berson View Post
    Most owners do not discard these records.
    Assuming they created them in the first place :-). About 1/2 of my customers keep all the records they should. Some barely have the CI signoffs :-).

  9. #19

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    Quote Originally Posted by Marc Zeitlin View Post
    I'm not sure what you're saying here. 91.417 says maintenance has to be logged. EAB aircraft are subject to part 91. There's a specific FAR that says EAB aircraft are NOT subject to part 43. There is no such thing about any of part 91, unless your specific OL's say so (and I've never seen any that do).

    So I don't know what you're getting at here...
    The reg has specific requirements for logging maintenance. Lets break it down:

    The records must include -

    (i) A description (or reference to data acceptable to the Administrator) of the work performed; and

    (ii) The date of completion of the work performed; and

    (iii) The signature, and certificate number of the person approving the aircraft for return to service.



    Items (i), (ii), and (iii) are mutually inclusive so a certificate number is mandatory for .417 compliance. What if the maintainer has no certificate, ergo, no certificate number?

  10. #20

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    Quote Originally Posted by martymayes View Post
    The reg has specific requirements for logging maintenance. Lets break it down: ...
    Items (i), (ii), and (iii) are mutually inclusive so a certificate number is mandatory for .417 compliance. What if the maintainer has no certificate, ergo, no certificate number?
    If they have one, put it in. If they don't, leave it out. I understand what you're saying - that you sometimes cannot comply, intrinsically, with ALL of the listed requirements. But that doesn't imply (to me) that if you can't comply with all of them, you're exempt from all of them. You comply with the ones that are possible to comply with given the rules of EAB aircraft, which allow your mom's dog to do the maintenance on the plane (and she probably doesn't have an FAA certificate # to list [the mom or the dog]).

    That's how I interpret it. Like I said, others (and obviously you) interpret it differently.

    I'm sure I'll be loved forever if I ask the FAA's Chief Counsel's Office for an official ruling on the matter with respect to EAB aircraft, so we can settle this as proper litigants, and not just clowns yakking at each other on the interwebs :-).

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