New small airplane laws may allow owner Owner Maintenance!!!

[beechboyA36]

Long time reader, never posted before. I saw this on another message board – after reading it I am really excited and had to post it! I attached the file to this post, hopefully it works.

Evidently there is an FAA group rewriting the small aircraft laws. Looks like there has been a proposal made to allow people to maintain their own airplanes. The jist of it is that if you have an airplane that could be considered “noncommercial use” you could treat just as if it were a homebuilt.

The cost savings on this would be HUGE!!!!

I am not sure who made this suggestion, but it seems to go right along with the medical idea EAA is working. If this is EAA, I really applaud them – between the medical issues and this someone is finally working to make things better in the GA world. Great Job EAA!!!!!!!!!! (or whomever is doing this!!!)

[David Darnell]

Not entirely sure that it's a good idea- have seen too many pilots whose mechanical knowledge is (in generous terms) extremely limited at best

[scott f]

I like it alot. It is well written and well thought out - and it gives people the freedom to choose which direction they want to go.

[WLIU]

In terms of laws and regulation, there is quite a gap between what makes good regulation and what is a good idea. I will suggest that we should err on the side of less regulation rather than more. EAA is a great umbrella for folks to learn the info and the skills to work up to a high standard. If you have not noticed, folks who bring poor attitude and poor skills to aviation are not deterred by the current regulations in any field of endevour, not just aviation. Since most of us try to do better, increased regulation only makes it harder on the 90% who try to do a good job since it generally only translates into more paperwork and labor hours doing that paperwork. That is what is killing recreational aviation today. Easier to own a boat.

The gotcha will be how an airplane that has been owner maintained can be brought back from that status. Many airplanes can be used for flight training and other commercial purposes today. Will taking the airplane into owner maintained status lower its $$ value for resale? That might deter a lot of Cessna/Piper/Mooney owners right there.

Guess we will stay tuned.

Wes
N78PS

[Bill Berson]

I can't open that attachment for some reason (Mac ?).
Can you provide a web link if possible?
thanks
Bill

[steveinindy]

Welcome to ideas that have both great and lousy aspects to them. In other words, it depends upon which pilots decide to take which route.

[beechboyA36]

I tried to repost the file - Being new here I am not sure if I am doing it right. Unfortunately I can;t point you to a webpage because this actually came off a Beech mail list I am on.

It does talk about returning to normal category. I am not sure about all the terminolgy but here is a cut paste from it:


Conversion back to Normal Category
 Aircraft operated in the Non Commercial (TC) class would be dual certificated in both the standard and noncommercial classes, as is common place for Restricted Category aircraft.
 Aircraft in the Non-Commercial (TC) category can be operated in the Standard category, provided the aircraftreasonably meets it type design data including compliance with all ADs, removal of all Non PMA / TSO parts andreplacement with certified units and the removal of all non-certified alterations
 The conversion can be accomplished by an IA mechanic with a complete and thorough annual inspection and logbook 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.


Not sure what the heck a restricted category airplane is - but looks like this would be just an annual and catching up with ADs.

[Neil]

I am seeing where this could be a huge benefit to owners that are capable of maintaining their own aircraft. The down side is I know owners that think they are capable but have no business with tools of any kind. For those, the time between condition inspections could prove hazardous.

Don't think there is a regulation that defines capability of an owner but at least with AB there is a learning curve during the build.

[MickYoumans]

I would still have an AP mechanic do my work, but it sure would be nice to have the option to use the less expensive non-certified parts. It would also be neat to be able to retrofit my Cherokee with a Dynon SkyView system, but under current regulations it is not allowed.

[Bill Berson]

Thanks Beechboy, that second attachment try doesn't work either. Might be something in my computer only if others are able to read it, my message says "file damaged".

I can read it somewhere else. No hurry.

[martymayes]

I think someone's April fools day joke slipped out early...



BeechboyA36......where did you see this, exactly?

[scott f]

I have seen it too Marty.. can;t say where for various reasons, but I can assure you it is 100 percent serious. One of those things though, if people want something like this - then they need to voice their opinion loudly.

But I have to ask too - Beechboy, where exactly did you get this?

[turtle]

Some really asinine thinking in that document. Especially considering the FAA came unglued when Canadian O-M aircraft, which have more restrictive rules than proposed, tried to fly in the US. I really can't believe someone would let this drivel out to the public. It looks like it was written by someone who couldn't be bothered to build, but just wanted to mod his Cessna and have even less restrictions. Instead of a well thought out plan with sound reasoning, it reads like a bunch of rednecks who want to hot rod their planes and pull the wool over the public's eyes.

One nugget of stupidity:
"Owners can “opt out” of Airworthiness Directives at their discretion."

One can argue all day about whether a switch from Napa is better than a 80 year old used replacement, but to let someone "opt out" of say, a critical wing attachment AD is ludicrous. This site is a prime example of people that would spend a few grand on an auto pilot, but use the cheapest fuel line money can buy to save a few pennies. Do we really need some cheap owners flying clapped out, fatigued Tomahawks with no AD's done over our houses because they think it's their god given right?

Which is followed by:
The name “non-commercial” was chosen deliberately to accomplish several goals
1. It does not carry the same connotation or public stigma as “Experimental” – the general public does not have
the same fear of ‘non- commercial” aircraft flying over their neighborhoods as they do experimental aircraft.
2. It would make it far more difficult for municipalities to ban Experimental AB aircraft – with this change of designation they would have to ban all Non Commercial aircraft. This would be considerable harder if not impossible because the new name does not invoke the same level of public reaction.
3. This same concept carries over to Non-Commercial (TC) aircraft – there is very little public fear to leverage to require unwarranted operational restrictions.

It SHOULD carry the same or worse stigma as Experimental. When you allow someone to fly an aircraft with a known safety issue that warranted an AD, you are saying that the defect wasn't serious in the first place, or that you condone unsafe aircraft flying over neighborhoods. If the public can get riled up over lead in avgas, they can get riled up over unsafe aircraft flying overhead. Using the Non-Commercial moniker unfairly stigmatizes private owners that want no part of that category. If a municipality wanted to ban experimentals due to safety, with the new category wording they would just ban ALL small planes.

This proposal needs to die. Quickly.

[martymayes]

I have seen it too Marty.. can;t say where for various reasons, but I can assure you it is 100 percent serious. One of those things though, if people want something like this - then they need to voice their opinion loudly.


Well, if it's a proposal to the ARC, has it been proposed yet? It is going to be proposed on April 1? The Part 23 ARC will be reviewing part 23 and supposed to make recommendations by Feb. of 2013. Have they discussed/debated the proposal yet? Does it fit in with the commitee's direction? Okay, say it makes it to the NPRM stage. The FAA will have to open a comment period. I'll certainly be sure to comment in support of such rule changes but it needs major, major clean up work. I think it's a long, very long shot in the dark.

[Tom Downey]

Thanks Beechboy, that second attachment try doesn't work either. Might be something in my computer only if others are able to read it, my message says "file damaged".

I can read it somewhere else. No hurry.

Bill on a iMAC it goes to your down loads files. in the upper right corner of the screen there is a small box with an arrow in it, click there and look for a file that says "Proposal to ARC" click that and it should open.

[Tom Downey]

IMHO changing the aircraft's airworthiness certificate to a "PRIMARY " aircraft would suit the purpose better. Trained pilot/owners could then return their aircraft to service with out supervision.

READ CFR 21.24 // and change this para to read a sensible number
(1) The aircraft—
(i) Is unpowered; is an airplane powered by a single, naturally aspirated engine with a 61-knot or less Vsostall speed as defined in §23.49; or is a rotorcraft with a 6-pound per square foot main rotor disc loading limitation, under sea level standard day conditions;

[martymayes]

There is a guy in Fort Worth who has an STC for C-150/2 aircraft changing them to primary category aircraft. I seem to recall he was intending to seek primary category STCs for a number of aircraft but the project apparently stalled during the base to final turn.

[Tom Downey]

There is a guy in Fort Worth who has an STC for C-150/2 aircraft changing them to primary category aircraft. I seem to recall he was intending to seek primary category STCs for a number of aircraft but the project apparently stalled during the base to final turn.

Why would it require an STC?

[martymayes]

Why would it require an STC? Maybe the FAA made him pursue an STC for the type alteration? I dunno. At any rate, can't argue with the success of his "FAA approved" methodology.

[rawheels]

Sorry in advance for such a long post...

I have often thought that it would be nice if there was a way to convert older aircraft to an experimental category (or at least to an experimental category with more freedom than research, exhibition, or racing). I think this is a good way to get the discussion going, but I think there are some major flaws in this proposal.
1. I don't think that "non-commercial" is the right term, and the FAA and aircraft manufacturer's lawyers aren't going to allow it for liability reasons. Experimental is the right word, but we need to keep on supporting the EAA and their local chapters as they continue to help the public understand that it isn't a bad word.
2. If you stick with the current proposal, I think that all AD's are going to have to be complied with. Not mitigating the risk is just idiotic. I do think that there is going to be a point where it is going to be difficult to determine which AD's need to be applied to a highly modified aircraft.
3. I don't think you are going to have a path back to a standard category aircraft under this proposal. The reason that research planes have that ability is because the item/change that has made the aircraft non-compliant is specifically recorded by a certified mechanic and they are supposed to be actively trying to get the aircraft back into a certified status. Without any training (and personal risk of losing license/livelihood/etc), there is no way that a pilot/owner is going to make sure that all maintenance/mods are recorded. And, there is no IA in their right mind that would sign off that they have checked an aircraft and determined that every single component of an aircraft has been returned to a certified status on a plane that has had free-reign for any amount of time.
4. You're going to have to get aircraft manufacturer's to buy into this somehow. If their name is going to still be on the aircraft, they are going to have to battle the widow in court. My guess is that at minimum you are going to have to completely obliterate their name from the aircraft (again, making it hard to ever return to standard category).
5. Then you'll have the FAA hot button issue of counterfeit parts. If you open up a market for a whole bunch of people who want to build faux-Cessna parts for these new experimentals, how will it be controlled so that they don't "accidently" get marked with the original part number and get sold as the real-deal? Or, if the plane is disassembled in the future, how will someone know that the "Piper wing" that is for sale was internally modified one time with a non-certified part, and is structurally not safe for use on a damaged Cherokee. There may be some risk of this currently, but the 51% rule mitigates some of that risk.
6. In addition, there may be some unforeseen backlash to all of this, as we've had a rare gem in the aviation world that companies like Cessna have still produced parts for 60+ year old aircraft. Who is to say that they don't use this to force all aircraft over 10 years old to go to the experimental class to avoid liability? That would make flight training and new aircraft ownership even harder to obtain for a low cost.
7. Don't expect a lot of A&P's to come running to get your business. There is limited risk in signing off an aircraft that has the records to indicate that it has been kept in accordance with the manufacturer's specifications. At least with Ex-AB, someone's name is listed as a manufacturer.

I think you really have two options to get close to what you want:
A. If you want the owner-maintenance portion; Propose a new experimental category that allows less than 51% amateur building. You'd have to obliterate all original manufacturer's markings, and then apply for a new registration under the new Experimental - Amateur Assembled (or whatever) category. (Big hurdles and impacts to consider with this one, not to mention it still doesn't provide an answer to some of the issues listed above).
B. If you just want to be able to upgrade items without STC's and testing; Alter the proposal to eliminate the owner maintenance portion and open up the Experimental - Research & Development category for people who aren't actively trying to return the aircraft to a completely certified state. You'd simply allow the certified mechanic to maintain a list of non-TSO/certified parts that are currently installed in the plane within the log-books. And, like present day, you may find a mechanic that knows/trusts you, and would allow you to perform some of the work yourself.

[Joe LaMantia]

I'm with Steve on this one! I have done only very basic maintenance that is allowed under the current rules, and am comfortable with oil changes, replacing a battery or light bulb and I've assisted an A&P doing an annual by removing inspection plates and the cowling and cleaning spark plugs. I would not be comfortable using anything but a screw driver on an airplane. It would be nice to be able to take advantage of some new non-STC'd avionics and save some $. If this comes to pass on wonder how the courts will treat "owner" maintained aircraft in accident lawsuits? Be careful what you wish for on this issue!

Joe
:cool:

[Shari]

I think the idea has a lot of merit. It would allow people to maintain their aircraft in the manner they chose and in which they are comfortable, each person has there own level of risk and risk management. I do not agree that just because something is experimental it is not "safe". A walk around the local airport has many examples of certified aircraft, Cessnas and Pipers and the like that are in less than ideal condition, are they safer just because they are "certified". I have seen experimental aircraft being built and maintained with incredible workmanship and skill. I am willing to bet most pilots will still have their local mechanic do most of the work, but now you have the opportunity to use non-std parts especially avionics. The proposal may not be perfect but I think it has many good points that are worthy of discussion.

[Tom Downey]

First issue for Airworthiness of any aircraft?

[Joe LaMantia]

Shari,

I agree, this does have a lot of positives and I hope it goes through, I think my cautions echo Steve's concerns that it could have some down side if people don't use good judgement in trying to save a buck. Aviation is loaded with the need for good judgement and the penalty for a misstep can be bad news for those involved.

Joe
:cool:

[steveinindy]

My take on it is why remove the need for a certified mechanic if the primary selling point for the average pilot is to allow use of non-certified parts? I mean to me, certain things really don't "need" to be certified (glass cockpits with steam gauges to back them up as an example).

[RV8505]

I am split, I know A&P mechanics I wouldn't let change my oil and homebulders that could rebuild the space shuttle and visa versa.. I guess then it comes down to liability. Doesn't Canda have some rules regarding owner maintenance? Maybe someone from up North could give some insight!

[Kurt Flunkn]

Very interesting proposal. Let's look at the pros and cons:

PROS:
Reduced MX costs
Increased availability of (non-certified) replacement parts
Easy to incorporate technology upgrades (like glass cockpits)
Will increase importance of type clubs
Non-commercial status may have potential to shield user fees
Ability to return to standard category

CONS
Untrained MX by owners who probably don't own manuals
Increased insurance costs - at least initially
Certified shops and A&Ps may decline to perform MX

If you step back and look at this objectively, this is similar to the current state for experimental aircraft. This is an idea definitely worth exploring more!

[martymayes]

Very interesting proposal.
If you step back and look at this objectively,
This is an idea definitely worth exploring more!


Agree. When you step back and look at the big picture, the purpose of the proposal is to bolster the shrinking lightplane/pilot population. Make airplanes more affordable with relaxed 'maintainability' rules. Sounds good on the surface, but:

Will a new a/c classification accomplish that? Wasn't primary category and LSA supposed to do that?

Since O-M became reality in Canada, their plane and pilot population has apparently continued to shrink. I don't know how many total aircraft are registered in Canada but the unofficial information I found says ~700-800 O-M airplanes. Less than 100 switching over every year. I'm thinking that's not a very large slice of the pie. How many US owners will jump over to O-M with it's pro's and con's? 1 for every 10? 1:100? 1:1000? Is that going to make a difference? Under the present system airplanes orphaned since WWII can still be maintained on a reasonable budget. We have a good system in place, much better than Canada's.

I think there's some real serious issues facing aviation. This one doesn't rank very high on the scale. But press on, I'm listening.

[Bill Greenwood]

As the saying goes, "the devil is in the details", and I haven't read this proposal, never even heard of it before now.
But I sure have my doubts. It sounds like a chance for someone who has an airplane to skip maintenance or take shortcuts just because it is in experimental or homebuilt category.
Let's say I have an Lyc IO-360 in my Mooney 201, as I did for 10 years, and due to problems reported by I As at annuals and over the years there is an AD issued on the ignition, or fuel injection. I would and should follow this in the Mooney. Now if you have the same engine in your homebuilt experimental category Pitts, or whatever world beater you have, is the engine and it's need for safety any different? Can you ignore it, or get some good parts at Target that might fit in? Maybe get your neighbor who rides a Harley to listen to your engine and say, "she seems go to go to me"?
Obviously there may be few places where there may be room for some savings, but I don't like to take too many chances with safety, and leave too many things to doubt.

I am probably missing something in the translation, am I ?

And it seems that the person who is most likely to shortcut safe maintenance is the same one who will take too many other chances.
If there is some lower level of safety that is going to be allowed, then perhaps the plane need some designation on it that tells any passenger that he is riding in something that is "amateur maintained" or similar.
Experimentals have to have a placard that says that now, but this would be something more.

[Bill Greenwood]

As for resale value, most of the people that I know who have expensive planes, try to get top maintenance. Bargain basement and warbird don't go well together. If you are buying a T-6 or P-51 or similar, the price will reflect not only what the plane looks like, but who and how it has been repaired or rebuilt.

And if there is an accident, the opposing lawyer would likely love to go into court and tell a jury of average folks like housewives that the reason behind the fire in the panel was unaproved instruments , or the engine stoppage was because that the maintenance was done by a person who did not have a & p or I A training.

[beechboyA36]

Bill

No expert here, but many of the things you listed it covers, such a placard requirement to warn passengers. You should read it, you might actually like it. How often do we see an FAA proposal that actually REDUCES regulations? I think this is a blessing no matter what form it is!


I guess what I like about it the most is that it allows choices. If you want to stay standard category, you can. If you want to maintain it yourself, you can. If you want to go back and forth - you can.

As it says in the text, this approach has proven safe for experimetal airplanes now for like 50 years. While would it not be safe then for a factory airplane? Or are we saying here that experimentals are dangerous and the practice should be stopped?

My own feelings, as little as they count for, is that I want GA to grow again. This is one approach that MAY make things better. There must be a reason that experimetal aircraft are the only sector that is growing, so copying that stuff over to factory airplanes may make an impact. Most of all though, I want flexibility - this gives me and other like me that without forcing other owners to do anything.

On another note I showed this at my Chapter meeting. Many of the homebuilders loved it also because they said it removed the operating limitations from experimentals.

[scott f]

I agree with the Beechboy

Bill, as you said most people you know would continue to get top notch maintenance - that’s Great. But it is also a perfect example of why this approach would work. Most warbirds are experimentals and can be worked on by the owners requiring only a yearly A&P condition inspection. (unless of course they are limited category like the airplanes you cite) These are Safe - So most warbirds already have this privilege and people are still getting top notch MX. I think this actually is an example for this type of approach.

If an owner is willing to accept the same operating limitations as an experimental, then it is certianly both logical and fair that they can have the same maintenance program.

Plus like the Beechboy said - are we really arguing against a proposal that vastly reduces regulations?

Bill, on a side note - as a warbird guy I am SURE you know everything going on with operating limitations. There is some interesting stuff in this thing you might like about that too.

[steveinindy]

How often do we see an FAA proposal that actually REDUCES regulations? I think this is a blessing no matter what form it is!

You might look at the so-called "law of unintended consequences". Such a move might, directly or indirectly, lead to more regulation if sufficient numbers of people start doing their own maintenance and having operational problems (read as: "crashes") as a result. That old joke about "No one ever went broke underestimating the intelligence of their fellow man" is a good one to apply to situations. You don't write regulations for the smartest pilot or the pilot/builder who has all the skills necessary to fix any mechanical issue. You write them for the one you wouldn't fly with or the one that if they touched a plane you wouldn't reposition it on the apron let alone take off in it.

The road to hell is paved with the best of intentions and the easiest person to hang is the one who asks you to hand them the rope.....


Plus like the Beechboy said - are we really arguing against a proposal

No, just remembering that you never take a regulation or operational measure at face value. What seems like a good idea at the time often in hindsight seems like one of those "What the hell were they thinking?" scenario.


that vastly reduces regulations?

So you perceive it...most likely because you wish it to be so. Don't let a confirmation bias allow you to think without hard and fast operational proof that a government agency is going to do something to reduce it's hold on it's respective "turf".

[Dana]

Doesn't the existing Primary category allow for an increased amount of owner maintenance? AFAIK there's only one aircraft model (Quicksilver GT-500) ever certificated in that category, but it's possible to convert a normal or utility category registration to primary and get the benefits (and, yes, restrictions). I was thinking of doing that with my Taylorcraft, but as I recall there was no way to revert back to standard registration, which could have affected resale value.

Seems analogous to the procedure for converting an existing SLSA to ELSA, after which anybody can work on it.

[martymayes]

Doesn't the existing Primary category allow for an increased amount of owner maintenance? AFAIK there's only one aircraft model (Quicksilver GT-500) ever certificated in that category,

Yes, with proper training. From Rev. Jim memory, I think RANs has/had a model certificated in the primary category, so there should be at least 2. Primary category was a complete flop and part of the reason was there wasn't any interest despite the number of people who claim they want an aircraft they can maintain themselves.


but it's possible to convert a normal or utility category registration to primary and get the benefits (and, yes, restrictions). I was thinking of doing that with my Taylorcraft, but as I recall there was no way to revert back to standard registration, which could have affected resale value.

If you do it with the STC process I would think you could convert it back to standard registration unless the FAA requires some language otherwise. Guess we could ask an STC holder about that.

The proposal seems to seek the freedom to convert back and forth but I'm not holding my breath on that one. They tried the same thing in Canada with the O-M category but the final rule intentionally makes it very difficult (re: completely impractical) to convert back to standard. In fact the guidance specifically says if there is any chance that an owner might want to convert back to normal, they should not seek O-M classification.

[Frank Giger]

I guess I'm missing a lot about what is required to be done by an A&P/IA and what can be done by the owner - or maybe I'm just involved with the wrong sorts of aircraft?

Looking at a Champ, there's gobs of stuff the owner can do himself and save a bunch of money, from recovering the aircraft (follow the STC and get a sign-off) to repacking the gear bearings right down to the mundane stuff of changing the oil.

Heck, one can restore a factory built aircraft from the dataplate up by one's self if it's all documented and inspected properly, as our vintage folks can attest.

Engine overhauls are beyond most people's skills nowadays (tools and machines notwithstanding) as is airframe repair, so that wouldn't really change anything.

OTOH, if one wants to seriously modify the design and function of an aircraft the option exists for almost carte blanch path to owner/operators, where one gets Repairman Authority from spinner to rudder. It's called homebuilding. Want to convert from gas to electric powerplants? Go ahead! Put in the paperwork and return it to test flight status. Want to change out the instruments by type and layout? No paperwork required other than annotation in the aircraft logs.

And this, btw, is why Experimental isn't a bad or onerous label in the least bit.

[steveinindy]

And this, btw, is why Experimental isn't a bad or onerous label in the least bit.

Because then I can't use that 32% of my larger design's MTOW that's fuel to serve as a tanker above the holding pattern at Oshkosh. *Vincent Price laugh*

[rawheels]

there's gobs of stuff the owner can do himself and save a bunch of money, from recovering the aircraft (follow the STC and get a sign-off) to repacking the gear bearings right down to the mundane stuff of changing the oil.

There are a lot of maintenance items that pilots can perform, but you need to be aware of which items you can do on your own (a lot more than you think) and which require oversight by an A&P; Recovering an aircraft is definitely a supervison item. Here is a old article, but still very useful one, describing the different tasks that can be performed: http://www.watsonvillepilots.org/articles/DIYmaint.htm

[Dana]

...there's gobs of stuff the owner can do himself and save a bunch of money, from recovering the aircraft (follow the STC and get a sign-off) to repacking the gear bearings right down to the mundane stuff of changing the oil.

Heck, one can restore a factory built aircraft from the dataplate up by one's self if it's all documented and inspected properly, as our vintage folks can attest...

Yes, but none of that (except for repacking wheel bearings) is legal owner maintenance, as it all has to be signed off by an A&P. You can do any work on any airplane if you have an A&P willing to sign it off, which is not what we're talking about here.

Years ago, the engine in my T-Craft lost a valve seat. The shop at the field where I was stuck had a deal, the owner could do the work (in my case removing the jug, taking it elsewhere for repair, and putting it all back together again), in their shop, with their tools, under their supervision, and the A&P would sign it off, for half of their standard hourly rate. I took advantage of it... realizing afterwards that it cost me just as much since it no doubt took me twice as long to complete the job as the experienced A&P would have... but it was worth it as I learned a lot in the process.

[aosunaiv]

Hello everyone, new guy here. The file was an interesting read, but I have to agree with the folks that believe the ability to blow off an AD is a bad thing. Additionally, I think most of us know it, but it wasn't stated here that the reason that EAB builders have expanded maintenance privileges, is because they BUILT the airplane. If they didn't build the airplane, then they'd have to seek competent technical personnel to perform anything other than minor maintenance, unless they received additional training. Finally, how many times have we read about non A&P personnel performing unauthorized maintenance, that cost them their lives? Thanks for listening.

BTW, I know there are sub-par A&Ps out there, as well.

[Bill Berson]

Welcome to the forum AOS. Unfortunately your comment is not correct. Any person can perform maintenance on any experimental homebuilt aircraft because FAR 43 excludes experimental homebuilts.

You probably meant to say that only the builder can qualify for the limited repairman certificate to do the annual condition inspection. Only the condition inspection requires an A&P(or repairman). The maintenance, including major repairs or alterations can be performed by anyone.

In my experience, there doesn't seem to be much of a problem with owners performing preventive maintenance items listed under FAR 43 App A. on certified aircraft (where FAR 43 does apply). But FAR 43.3 does require that the owner or operator have a pilot certificate. I think this requirement for a pilot certificate insures some competency in the view of the FAA, because all pilots have to pass a written test which includes some limited questions about maintenance, engines etc.

I support this proposal to allow owner maintenance.

[martymayes]

I support a proposal for owner maintenance. Unless it's pretty simplistic, a final rule is not likely to have much resemblence to it's proposed version.

[aosunaiv]

Welcome to the forum AOS. Unfortunately your comment is not correct.

Good afternoon, Bill. Thanks for the corrective assist. I agree with the intent of the document, but still have to disagree with making ADs optional. Have a good one.

[Ylinen]

I think this proposal is just the type that needs to be seriously considered. Small GA is dying. The FAA has built up an oversight program for small GA that is akin to what they do with Airliners. No other form of personal transportation is so regulated and expensive. In my opinion; non-Commercial GA should be regulated just like personal boating. The Tort system for non-commercial GA should be overhauled. No Widow should be able to sue any OEM or vendor. If her husband did not have adequate insurance for her; then that is between them. No lawyer should get rich taking the $ out of an OEM. Only if there was proven negligence should there be any recourse.

This proposal bring some common sense back to small GA. Add to this that the medical requirement for small GA should be the same as for personal autos or boats.

The one thing that could be done is to provide for a common group insurance program similar to flood insurance run the government that if any non-commercial GA aircraft injuries or kills someone on the ground or damages their property; the would be fairly compensated. The vast majority of small GA non-commercial accidents do not harm any public.

Small GA can not continue with aircraft costing over $500K. We are being regulated out of existence which is what the FAA and airlines want.

I hope the Part 23 ARC considers this type of major proposal changes.

[Richard Warner]

I had no problem opening the file. I wonder how the FAA is going to take to something like this one? Hope it goes through.

[Ylinen]

Hello everyone, new guy here. The file was an interesting read, but I have to agree with the folks that believe the ability to blow off an AD is a bad thing. Additionally, I think most of us know it, but it wasn't stated here that the reason that EAB builders have expanded maintenance privileges, is because they BUILT the airplane. If they didn't build the airplane, then they'd have to seek competent technical personnel to perform anything other than minor maintenance, unless they received additional training. Finally, how many times have we read about non A&P personnel performing unauthorized maintenance, that cost them their lives? Thanks for listening.

BTW, I know there are sub-par A&Ps out there, as well.

The NTSB database does not support your claim. There are far more MIF (Maintenance induced Failures) by A&Ps then for AB aircraft maintained by owner after the 40 hour phase 1. Owner maintenance has not produced a higher accident rate. And just to be fair; the majority of accidents are pilot errors not aircraft failures. Also; there are really very few accidents each year on the total and very few due to maintenance. So do we really need all the regulation and cost to manage a very small incident? What we need are bold changes to Small GA so that it can grow and start to get some economies of scale.

[Bill Berson]

Can anyone else open the file with a Mac?
The file was made with PC. If anyone else with a mac can open, perhaps my Mac is out dated (5 years old with Adobe Reader 5).

[steveinindy]

There are far more MIF (Maintenance induced Failures) by A&Ps then for AB aircraft maintained by owner after the 40 hour phase 1.

I'm not saying you are off the mark, but I would like to point out that you have to be careful saying "Well, there are more of X than Y in the NTSB database and that means...." because, in this case, there a lot more planes getting maintained by A&Ps than by non-A&Ps.


What we need are bold changes to Small GA so that it can grow and start to get some economies of scale.

I agree with the caveat that one must not be so bold as to forget that just because we have an endpoint in mind that we must not do anything that might hurt what we have now, let alone the chances of obtaining that goal. In other words, "bold changes" when it comes to a hobby that depends on level-headed and well thought out approaches to keep from killing the people engaging in it may not be the best approach.


And just to be fair; the majority of accidents are pilot errors not aircraft failures.

Just to be fair, the average investigation for a small plane crash- especially a homebuilt- is not nearly as thorough as it should or could be. It's not horrible, but I have a feeling that if one really went digging we would probably find more crashes where one of the contributing factors was a mechanical failure (very few crashes are truly due to a single mechanical failure; even crashes where the engine goes out, most of them that kill people involve pilot error leading to a stall or something similar that compounds the problem) especially in the first 100 hours or so of flight than a lot of us would like to admit.

[aosunaiv]

Not disagreeing with the concept. We need to demonstrate due diligence and consideration in any implementation. I could care less if a pilot removes him or herself from the gene pool, due to technical incompetence, with respect to aircraft maintenance. I just hope someone isn't with him or her. However, I am concerned for the safety of the non-aviation personnel, on the ground, that their aircraft may come down upon due to the fact that we fly over populated areas. I get the feeling this may be the FAA point of view, as well. Too many people seem to forget that ours is an unforgiving hobby/sport/what-have-you and that most lessons are written in blood.

[aosunaiv]

With 2 Macs, an iPhone and an iPad. What type of Mac, OS version, and browser are you using?

I'm typing this on a mid 2005 iBook with a 1.42GHz G4 PPC processor. :cool:

[steveinindy]

I could care less if a pilot removes him or herself from the gene pool, due to technical incompetence, with respect to aircraft maintenance. I just hope someone isn't with him or her.

The problem is not so much the loss of life, but the press coverage thereof.


However, I am concerned for the safety of the non-aviation personnel, on the ground, that their aircraft may come down upon due to the fact that we fly over populated areas.

The risk to a person on the ground, not involved in aviation activities are about as slim as your chances of being killed by lightning while having a winning lottery ticket in your pocket.

[martymayes]

The risk to a person on the ground, not involved in aviation activities are about as slim as your chances of being killed by lightning while having a winning lottery ticket in your pocket.

Guess nobody ever explained the odds to this guy.......:rollseyes:.



Plane Hits, Kills Man on South Carolina Beach

Read more: http://www.foxnews.com/story/0,2933,589402,00.html#ixzz1qd57Kfc5

[aosunaiv]

The problem is not so much the loss of life, but the press coverage thereof.

The risk to a person on the ground, not involved in aviation activities are about as slim as your chances of being killed by lightning while having a winning lottery ticket in your pocket.

In answer to the first part...HUH??? WTF???

In answer to the second part... Your opinion is noted.

[aosunaiv]

Or these school kids...

At Least 13 Die in [Light] Plane Crash....

http://www.nytimes.com/2011/12/11/world/asia/at-least-13-killed-in-plane-crash-in-the-philippines.html

[martymayes]

I'm thinking pilots, aircraft owners and wannabes will be their own worst enemy if this proposal were to be seriously debated and considered.

[Bill Berson]

With 2 Macs, an iPhone and an iPad. What type of Mac, OS version, and browser are you using?

I'm typing this on a mid 2005 iBook with a 1.42GHz G4 PPC processor. :cool:

We have a 2007 iMac 5.1 desktop with Tiger 10.4 OS, and Safari browser (version 4.1.3).
This problem happened once before, but only once.

[steveinindy]

In answer to the first part...HUH??? WTF???

OK....I'll remember to type slower and try to refrain from using words with more than four syllables. The problem is that if we have people killed in crashes, it makes the news and people get worked up about it (the NIMBY morons). When people get a hair up their butts, they call their local politicians. When they call their politicians, the politicians take it out on the FAA who in turn takes it out on us. Reduce the number of deaths, reduce the amount of press coverage and you reduce the political pressure that is most often the trigger for oppressive regulation.


Or these school kids...

Welcome to how you have odds: something has to occur (or have at least the theoretical ability to occur) to have an odds ratio above zero. The odds of being killed by a crashing plane when you're not on board it are pretty small which is what I was trying to point out. It's something ridiculously small. If ten people a year are killed in the US by crashing aircraft (which I think is probably well above the actual number) and there are 311 million people in the US (let's assume everyone has equal exposure to the risk, which they don't), that gives you an one-year odds ratio of 1:31.1 million. Assuming a 76 year life expectancy, that gives you a roughly 1 in 400,000 chance. That's 1/5th the risk of being struck by lightning or about the same as the odds of being killed by a meteor or asteroid impact.

My point was that the bigger concern should be for the folks on board the airplanes who have a much larger risk of serious injury. Now, if you'll excuse me, I'm going to go back to watching the FedEx jets as they pass over my apartment. ;)

[aosunaiv]

Good evening, steveinindy,

Okay...I'll type in douche-speak.

The WTF was not in reference to the likelihood that CNN types would report any mishaps in an overblown manner. That's a given, these days. Additionally, it wasn't in reference to the fact that folks tend to remember, often incorrectly, dramatic events. Yes, Steve, other folks have endured psych classes as well.

The WTF was in reference to what seemed to be an utter lack of regard for anyone that is not you, or that would inconvenience you. Lost lives matter.

Your refusal to acknowledge any other view, as demonstrated by the refusal to acknowledge the simple fact that 13, non-aviation related, people died when the light plane impacted a school, in the article provided, when combined with the attempted use of semi-statistical bullying in defense of your view serves as a fine example of confirmation bias. Yes, Steve, other folks have endured stats, physics, thermo, diffy qs, and many other university courses, as well.

Remember, it's okay to be very intelligent, and very learned, but to speak plainly.

Enjoy the FedEx hardware show. Remember not to stare into the sun, and to lower your head if it rains.

__________________________________________________ __________________________________________________ ______________________

To the Moderator, and the rest of the group. I'm sorry, that this has become a rude exchange. But some folks really should take themselves less seriously. I'll disengage at this point and endure whatever is sent my way. I'll understand being barred. Have a good night.

[aosunaiv]

We have a 2007 iMac 5.1 desktop with Tiger 10.4 OS, and Safari browser (version 4.1.3).
This problem happened once before, but only once.

I performed a quick check on your system specs. If your machine is a Core 2 Duo, 2.16 Ghz, 1GB RAM, iMac, then you can easily upgrade your OS to Snow Leopard OS X 10.6. Which is available for about thirty bucks at the online Apple store. It will allow you to run the latest Safari, and provide added security. I recommend you stay away from OS X 10.7, as it'll slow your machine to a crawl.

Let me know what else I can do.

[steveinindy]

The WTF was in reference to what seemed to be an utter lack of regard for anyone that is not you, or that would inconvenience you. Lost lives matter.

Woah, woah....back the aggression train up there, you're completely taking what I said the wrong way.

As someone who keeps a roof over his head by trying to keep people from dying in plane crashes (I do aviation safety research for a living), I agree wholeheartedly that lives do matter. You seem to miss the point that in the big scheme of things, 700 or so lives a year in GA crashes doesn't mean a lot to those of us who haven't counted friends or loved ones in that group. In other words, it's not a huge deal to anyone outside not directly connected to the GA community because the numbers are so small until we get a bunch of non-pilots riled up. The way we make that number better for us and worse for our critics is by pushing the number of fatal crashes down so that we give our enemies less ammunition to use against us.

In GA crashes alone, I've lost NINE friends including the first person who ever took me for a ride in a small plane. If you fact in the the friends I've lost in medical helicopter crashes, I'm getting close to two dozen. I don't do the work I do because of the fact that I think I'm better than anyone or because I hate people who inconvenience or annoy me. Quite frankly, I spend my professional life trying to give those people (and everyone else) the best chance possible to go home from their flights- GA, commercial, HEMS, etc- to their families and friends because I don't care how much someone annoys me, no one deserves to die in a crash. I don't want anyone else to standby a grave and long to spend time with their friend again.


Your refusal to acknowledge any other view, as demonstrated by the refusal to acknowledge the simple fact that 13, non-aviation related, people died when the light plane impacted a school, in the article provided, when combined with the attempted use of semi-statistical bullying in defense of your view serves as a fine example of confirmation bias.

I'm not bullying anyone. I'm pointing out that the odds of the average person has far bigger things to worry about than a plane landing on them. Nothing more, nothing less. OK? Yes, people do die from being struck by crashing planes but so few as to make it a freak event (if it broke 500 people in an average year worldwide, I'd be rather surprised). Is it sad a handful of folks died? Yes. Does it prove that there's a significant risk, nope. That was my point with all the statistics I mentioned.

BTW, I'll have you know this very same "bullying" got me a thank you e-mail from the president of the AOPA several years ago when I helped derail a "not in my backyard because those planes crash here all the time and are going to kill one of us" article after a crash. I spend a fair amount of time talking to reporters and here's the amazing thing. If you give them the actual facts and statistics, most of them (unless they work for USA Today) tend to be really, really willing to listen. The problem is that most of us treat them like the enemy, don't want to teach them and so they have to go off of rumor and supposition because if we don't want to talk, we must have something to hide tends to be the attitude.

Trust me, I'm not looking down on anyone. I may get irritated (and plus, I'm still recovering from surgery earlier this month so I'm kind of crabby because of the pain and stuff; I do apologize for being condescending earlier) but once you get to know me, you'll realize that my heart is in the right place even if, at times, I tend to put my foot in my mouth because I don't word things the best.

If you're coming to Oshkosh this year, I'll buy you lunch as a way of making up for the miscommunication. You'll find I don't take myself that seriously at all.

[Frank Giger]

Between the beers I owe people and the lunches Steve is going to give away the concessions at Airventure are going to have a banner year!

Concurring that the tone needs to come down a bit, a few notes:

1) Steve is right - statistically, the odds of being struck by an airplane while on the ground are so tiny as to not warrant a person's concerns. The person struck on the beach was unfortunate and a freak accident. The light plane that struck a school was in the Phillipines; I am not convinced that the safety standards are the same there as they are in the USA.

To the guy that gets struck by lightning the odds are 1:1 at the precise moment he is hit; however, that doesn't mean it's a major concern we should be worried about. Indeed, the guy struck by lightning has the same chance of being struck again as he did before - basically none.

There's a lesson in our human grounding rod, though, that we can use. Prudent care in situations where the improbable becomes the unlikely has huge rewards. Experimental aircraft, for example, aren't supposed to be flown over populated areas (which apparently is defined on whether or not one hits a house or not); in an engine-out, the pilot should take care on where he puts it down taking the odds of people on the ground into account.

This is the golf course problem. A par five fairway can make for a fine emergency field, but there's the potential for hitting a guy that has just laid up from the woods. Does one reduce the risk to the pilot and passengers and increase the odds for striking a person, or put the odds of a guy that might be on the fairway above those around him and put it into some trees?*

2) The media always fluffs up airplane crashes because they've been trained for something spectactular when it happens. Plane crash = commercial flight with hundreds of people involved. That it's a Cub that put down into a pasture and killed a cow (without loss of human life) makes no never mind - the headline is worth gold....the reader may be disappointed to find out how minor it was, but the point is that he read it to the media.

Add in the "how did that get there" people who buy houses next to local airports and then are shocked to find out that suddenly there are airplanes flying near them and that they make noise to try and remedy the problem in an inverse fashion and it's an unfortunate circus.

3) Guys and gals that build airplanes are in the main much better prepared to maintain their aircraft than those who simply write a check for them. The analogy is folks who customize (or even build) cars and motorcycles. They don't take their rides into the dealership for an oil change or to change a spark plug.

Just because something is permitted doesn't mean it's prudent, and that's the hesitation to the notion of absolving an owner of supervised or professional only maintenance. There is already a lot of flexibility in maintaining a spam can, if one exercises it (and yes, it may mean firing the local A&P for someone else).

* Note the stress on people. To hell with "saving" the aircraft - it was never alive to begin with.

[steveinindy]

Between the beers I owe people and the lunches Steve is going to give away the concessions at Airventure are going to have a banner year!

I'm half tempted to just put together a dinner for everyone one night. I figure if everyone chips in, I can grill the heck out of whatever people want to bring. Then again, I also kicked around the idea of renting a golf car and then riding around with a bucket of ice cold bottles of water and a donation jug. Figure that's one way to raise a little money for my research (which I'm turning into an NPO if the government ever gets off their butt and processes the paperwork) and also help keep people from collapsing.


This is the golf course problem. A par five fairway can make for a fine emergency field, but there's the potential for hitting a guy that has just laid up from the woods. Does one reduce the risk to the pilot and passengers and increase the odds for striking a person, or put the odds of a guy that might be on the fairway above those around him and put it into some trees?*

This is why I've always joked that aircraft should be fitted with horns like cars. Preferably one that plays "Dixie". That'll get people's attention as we're coming in for a landing that should be freeze framed and then narrated by Waylon Jennings. ;)


That it's a Cub that put down into a pasture and killed a cow (without loss of human life) makes no never mind - the headline is worth gold....the reader may be disappointed to find out how minor it was, but the point is that he read it to the media.

I actually have a journal article under review at the moment that makes mention of a cow walking out in front of an aircraft. One of the comments from the reviewers was that he shot coffee out of his nose at the visual. I think he is a city boy who doesn't realize that hitting a cow is just about as bad as hitting a tree (and a lot messier with that prop up front).


The analogy is folks who customize (or even build) cars and motorcycles. They don't take their rides into the dealership for an oil change or to change a spark plug.

Hang around RUBs (rich urban bikers) and you'd be surprised. These are the same guys who have their biked trucked into Sturgis. I mention this only because my uncle happens to be one. During my time in healthcare, I saw surgeons who were less thorough about cleaning under their nails than Tom is. He's so OCD about cleanliness that you couldn't pull a needle out of his butt with a tractor. I can't see him doing any maintenance on the Harley he owns. LOL

[Dana]

I suspect that relaxing the rules on owner maintenance will either have zero effect on safety, or it might even improve it.

For the vast majority of aircraft, it will have no effect at all. Even today, where an owner can legally change the oil, plugs, pack wheel bearings, etc., very few actually do it themselves... just as only a small percentage of automobile owners change their own oil, and even fewer do anything more involved.

Of those airplane owners that are so inclined, they fall into one of three groups:

1. The technically competent guy who's capable of performing just about any repair even though he doesn't have an A&P certificate, and who is competent enough to know his limitations, if any, and get help when necessary.

2. The guy who isn't competent enough to do much more than change his own oil, but has a competent (but non A&P) friend willing to assist when necessary.

3. The guy who isn't competent to do any work, but tries anyway because now he's allowed to, and does a poor job.

Of these three, only the third type is any increased danger. The first is probably doing his own maintenance anyway. The first and second are likely to perform needed maintenance sooner under the relaxed rules, rather than waiting to have it done during the annual inspection, or not at all. Some of the third group will screw up (and a [I]very few of those put others in danger), while others in that group will try to do something, get in over their heads, and hire an A&P to fix their mistakes.

Another thing to consider is that the people likely to actually do their own maintenance are owners of older aircraft that many modern trained A&P's aren't comfortable or even competent working on anyway. In many cases the owner knows far more about his aircraft than most any A&P.

In the end, I doubt the change will result in much more owner maintenance being done. What it will do is result in that maintenance being properly logged (and then checked more carefully by an IA during the annual). Net result: Increased safety.

[aosunaiv]

Good morning, steveinindy,

I apologize. I'll try not to firewall the throttle in our future exchanges.

I'm Al, BTW, good to meet you. If you're ever down here for Sun 'n Fun, lunch is on me.

[Bill Berson]

Very good post Dana.

I still have not been able to read the proposal yet. But if it contained some training for the owner, to achieve an Equivalent Level of Safety (ELOS)*, then the FAA might approve this.


* see the recent EAA blog about ELOS: http://macsblog.com/2012/03/third-class-medical-and-faa-elos/

[rwanttaja]

Very good post Dana.

I still have not been able to read the proposal yet....

Bill, I did a text conversion of the proposal and attached it, in two parts. Two parts because text files are limited to 20k....

Ron Wanttaja

[aosunaiv]

Very good post Dana.

I still have not been able to read the proposal yet. But if it contained some training for the owner, to achieve an Equivalent Level of Safety (ELOS)*, then the FAA might approve this.


* see the recent EAA blog about ELOS: http://macsblog.com/2012/03/third-class-medical-and-faa-elos/


Good afternoon, Bill,

This PDF should do the trick.

1770

[rwanttaja]

The NTSB database does not support your claim. There are far more MIF (Maintenance induced Failures) by A&Ps then for AB aircraft maintained by owner after the 40 hour phase 1.
Sorry, don't agree with this. I compared homebuilt accidents with a "control group" of Cessna 172/210s, and got practically the same rate of maintenance-induced accidents. For aircraft with more than 40 hours, the rate is actually a bit higher. This is probably due to similar accidents in the 0-40 hour period being assessed as builder error rather than maintenance error.

Still, it's a good sign...I hadn't expected homebuilts to come out so close. And as others have mentioned, this is an extremely small portion of the total accidents (4-5%).

Ron Wanttaja

[Bill Berson]

Thanks Ron and aos, I was able to read both. It appears others are downloading the file as well.

My comment after reading is this:

Finding an A&P willing to perform a condition inspection and logbook signature with the associated risk, might be difficult.
It would be better if the owner could do the condition inspection as well, perhaps with some additional training. This way the owner assumes the risk. It would be very hard for a mechanic to assume this risk, insurance could be maybe 5K-10K or impossible to get.

It should be possible to maintain a non-commercial aircraft without involving any other person, in my opinion.

Bill Berson
A&P I.A. (but not signing any logbooks, other than my own, at this time, for liability reasons)

[Joe LaMantia]

WOW!

This thread really took-off with full Afterburner on Military Power! I wasn't planning on going to OSH this year but with all the free food and drinks being offered I may just take another look at my summer schedule.
I did manage to download the file on my IMac running OS 10.5/Leopard with no problems. The give and take here has been excellent and entertaining as well. I don't think I can actually add anything to this discussion, all the pro's and con's are right here and should make the FAA's job easy.

Best to All,

Joe
;)

[aosunaiv]

The problem is not so much the loss of life, but the press coverage thereof. The risk to a person on the ground, not involved in aviation activities are about as slim as your chances of being killed by lightning while having a winning lottery ticket in your pocket.

Hey Steve, I swear that this isn't to start anything, but I saw this and had to chuckle. You can't make this stuff up!


"Kansas man struck by lightning hours after buying lottery tickets"


http://www.orlandosentinel.com/sns-rt-us-usa-lottery-lightningbre82u0fk-20120331,0,5387804.story?obref=obnetwork


BTW, He wasn't carrying a winning ticket.

[steveinindy]

I apologize. I'll try not to firewall the throttle in our future exchanges.

I'm Al, BTW, good to meet you.

No worries. You'll learn that I've got pretty thick skin on most things and given that I spend a lot of my time trying to teach people that long held beliefs in the GA pilot community about crash survivability are incorrect, what you said to me is actually fairly polite. At least you didn't spit at me like a couple of guys (friends of the pilot) did when I was helping a medical examiner look over a crashed experimental up in Michigan. After they realized why we were taking photos, notes and measurements, they mellowed out and I ended up having lunch with them.


If you're ever down here for Sun 'n Fun, lunch is on me.

That sounds like a plan. I am hoping to attend next year. I've never been down for it. If you ever find yourself in the Indy area, you're also always welcome to meet up with my fiancee and I.


Hey Steve, I swear that this isn't to start anything, but I saw this and had to chuckle. You can't make this stuff up!


"Kansas man struck by lightning hours after buying lottery tickets"


http://www.orlandosentinel.com/sns-r...bref=obnetwork (http://www.orlandosentinel.com/sns-rt-us-usa-lottery-lightningbre82u0fk-20120331,0,5387804.story?obref=obnetwork)


BTW, He wasn't carrying a winning ticket.

LMAO. It's nice to know you have a well-developed sense of humor. I'll have to pass that one along to one of my previous research mentors (I got my start in research looking at lightning induced morbidity and mortality).

[beechboyA36]

Well, I guess this got people talking! (some maybe even talking too much) Dana's post was great - my feelings on this exactly.

I am really excited to see how things go on this, although I bet it is going to take some work to get this passed. Is there anyone in the EAA we can contact to see if we can help? Somewhere on the EAA website I remember seeing a list of the people that are on the commitee to rewrite the laws. I wonder if it would help to contact some of them directly to show our support. Anyone know anyone to ask?

[Kurt Flunkn]

I am really excited to see how things go on this, although I bet it is going to take some work to get this passed. Is there anyone in the EAA we can contact to see if we can help?

I'm curious to see what someone like maintenance expert Mike Busch thinks about this proposal. From a grass roots level would this be something best pushed from the chapter level? If so, would this fall under VP of chapters, Jeff Skiles? Would AOPA support this proposal? This might make a good forum topic for this summer at Oshkosh. Then the big question is how to get a sponsor at the FAA to write an NPRM. Anyone know how to create an NPRM?

[WLIU]

It is important to understand that the FAA is not influenced by the number of comments, but rather by information offered to support the assertion that rules that allow an owner to sign off maintenance will provide an equivalent level of safety to the current rules (what J Mac M writes as "ELOS"). So organizing your EAA chapter to write letters will not really accelerate consideration or increase the likelihood of changes to the rules.

What might be a very interesting and constructive thing to do is to contact the companies who make the parts in your favorite airplane, and ask what training, online, books, classroom, etc., they will make available to you when, not if, owner maintenance becomes part of the FARs. I suggest that because the availability of "approved data" and training will be a part of the FAA's final rulemaking and pressuring the industry to support it now will have a much greater effect than writing "I vote in favor" letters to the FAA.

I will note that your hands can already do all of the work so long as you have a mechanic who will supervise and sign off the paperwork. So the rulemaking issue is really establishing that you can do the work and sign the logbook for more than the list of owner tasks currently in Part 43. I will suggest that the rulemaking will not endorse parts or work that does not meet today's standards for airworthiness. And bringing an airplane back from owner maintained to standard might involve either removing a bunch of stuff that you added, or going through the Field Approval process. Caution is advised.

Best of luck,

Wes
N78PS

[martymayes]

I'm curious to see what someone like maintenance expert Mike Busch thinks about this proposal. From a grass roots level would this be something best pushed from the chapter level? If so, would this fall under VP of chapters, Jeff Skiles? Would AOPA support this proposal? This might make a good forum topic for this summer at Oshkosh. Then the big question is how to get a sponsor at the FAA to write an NPRM. Anyone know how to create an NPRM?

With regard to the FARs, FAA legal writes NPRM's. Any US citizen can petition the FAA for a rule change, the how-to is spelled out in Part 11 of Title 14. It's still not clear if the proposal in the pdf. has been submitted anywhere. It may just be someone's manifesto as it's somewhat incomplete as an FAA petition in current form. It says 'proposal to the small aircraft ARC' but I have yet to find any kind of confirmation. Is the ARC reviewing the proposal? Does anyone know? I'd like to climb on board and offer support but I'm still at the station waiting for the train to show up.

Afther thinking about it, the toughest sell will likely be at the Transportation Secretary's office. It would be nice to get Huerta's opinon on such a rule proposal so after he is confirmed as Administrator and makes a public apperance at a general aviation event (like AirVenture), someone need to corner him with the question. Get a feel for what your up against.

[WLIU]

And all of that is why we are members of EAA. The folks from OSH carry a lot more weight when they speak with all of us behind them rather than one of us speaking as an individual. Keep paying your dues and recruit all of your friends.

Best of luck,

Wes
N78PS

[LarryS]

Where did this "proposal" come from?? I see no signatures or source or origin?

[martymayes]

I have been asking this question myself. I got this from a Beech email list I subscribe to - doing a little asking around over the last couple of days, it appears that the writers are people on the rule group and they were floating a draft version around for comments and someone forwarded it to the mail list - that is how it wound up being mailed around. I don't want to post the guys email that originally sent it, but he is on the list of the members of the group from this eaa posting;

http://www.eaa.org/news/2011/2011-11-17_part23.asp


Because of that, I think that there must be some level of seriousness to it. My big thing is, I want to do something to help support this, but am not sure how to start.


I think the owner maintenance proposal is nothing but wishful thinking at this point......

[scott f]

I think the owner maintenance proposal is nothing but wishful thinking at this point......

It may be Marty. But my thoughts are more like WLIU's. "Tilting a windmill or two" is what I expect from the organizations I belong to. Maybe it does not get through, but I would sure rather see an attempt at something made than to have people not try for fear of failing.

Beechboy - you said you were not sure how to start with this. Well, you already have. Express your opinion, get the word out. Maybe what was posted is not the perfect solution or presented in a form that the FAA expects - But if people can do it in Canada, then we should be able to do it here. Heck, we are like supposed to be land of the free right?

Somewhere, somehow we as a community have allowed the proverbial regulatory heat to be slowly turned up over time - it now seems in many ways that it is more about control than about safety. No matter what the historical reasons for it, I think most of us would agree that general aviation has been regulated to death. Something or maybe multiple things need to be done to "bend the curve" the other way if we want to avoid what has happened to general aviation in Europe.

Wishfull thinking... maybe Marty... but sign me up for that line thinkin. Although, I guess I could just register my airplane in Canada.. Land of the free ay :)

[martymayes]

It may be Marty. But my thoughts are more like WLIU's. "Tilting a windmill or two" is what I expect from the organizations I belong to. Maybe it does not get through, but I would sure rather see an attempt at something made than to have people not try for fear of failing.


Scott, what is EAA's opinion on owner maintenance? Is EAA working on an owner maintenance proposal? Folks that want owner maintenance rules should stand around and wait for EAA to make such a proposal? Good luck, that's not the way to get things done.

[scott f]

Scott, what is EAA's opinion on owner maintenance? Is EAA working on an owner maintenance proposal? Folks that want owner maintenance rules should stand around and wait for EAA to make such a proposal? Good luck, that's not the way to get things done.

Marty, my wording must have been a bit clumsy as the above was not my intended meaning at all. I am simply agreeing with WLIU that it is always beneficial to have a group behind any such endeavor. As for how EAA stands on this, well I know about as much as you do on that subject.

All I know for sure at this point is that while there maybe bugs in what was presented in the pdf, I am in very much in favor of the concept. There is absolutely no reason in my mind that if one can have an owner mx class in Canada, that we should not do it here. I know that the FAA allowed owner maintenance under the primary category, so this is not new to the FAA. To top it off though, I see no safety related reason why owners of factory airplanes should not be able to operate under the same rules as homebuilts if they are willing to accept the same restrictions -that is just equal and fair treatment under the law.

Marty, I guess the question I would ask is if you don’t think people should wait for the EAA on this, what do you think they should do?

[martymayes]

I guess the question I would ask is if you don’t think people should wait for the EAA on this, what do you think they should do?

I guess step one is finding out if EAA has any interest in the subject. I don't know where they stand. My point was that those content to wait for EAA or any alphabet club to take the inititive might be waiting a long time. Too bad we don't have any background on whoever authored the .pdf. Perhaps one could find out what the motivation is/was and find out if this has actually been proposed to the FAA or ARC. Sure, it's not perfect but gotta start somewhere.


I am in very much in favor of the concept. There is absolutely no reason in my mind that if one can have an owner mx class in Canada, that we should not do it here. I know that the FAA allowed owner maintenance under the primary category, so this is not new to the FAA. To top it off though, I see no safety related reason why owners of factory airplanes should not be able to operate under the same rules as homebuilts if they are willing to accept the same restrictions -that is just equal and fair treatment under the law.

I'll support an owner maintenance proposal as well but as an A&P, not much benefit for me. Some issues I see off the bat are: Yes, Canada has owner maintenance but the FAA doesn't recognize Canada's "owner maintained category" and does not allow those aircraft to operate in the US. I know EAA has tried to get the restrictions relaxed with no luck. Need progressive culture change at Independence Ave. and that's a tough order with the sitting Transportation Secretary. There's more involved than just doing it because it's permitted for other airplane categories.


.

[WLIU]

Guys,

You might be missing the big point. EAA is a volunteer organization. Talking about this stuff on an internet forum creates no progress but sending an e-mail to Rod Hightower and asking how you might volunteer energy and time might create a small bit of progress. Maybe more. Step up, ask the movers and shakers questions, and volunteer to do what needs to be done.

My perspective is one of a guy who was persuaded to be an EAA/IAC chapter president for five and one half years. I am the benificiary of guys who stepped up before me. I think that I left the chapter in better shape than I found it, but I can affirmatively say that I did something. I invite you to get your hands involved also.

As for who submitted the proposal that is being discussed, that info should be part of the public record. You might have to dig a little deeper.

And almost all of my maintenance is owner done. I buy A&P and IA time to look over my shoulder, take advantage of their experience, do the work to their satisfaction, and get their logbook signoff. Another set of eyes is always good, I learn from their experience, and it adds to the social element of aviation. You can to it too - today, with the current FARs. Get dirty. Its half the fun.

Best of luck,

Wes
N89PS

[Frank Giger]

One of the saleability points missing in the proposal (unless I misse it) is defining which GA aircraft would be included.

It might get more traction if the option were tied to aircraft that fall within the Recreational Pilot category - single 180 hp engines, non-retractable gear, etc.

The mindset of the people making the rule is of the safety of people on the ground more than in the air - they're worried about what a poorly maintained aircraft will damage when it crashes.

[beechboyA36]

Frank

There is a spot talks about that, if memory serves they say any Part 23 airplane that is not carrying people for hire.

On the subject of A&Ps losing money over this, speaking as an A&P / IA I think I actually will gain by this. Most of my customers will not be doing the type of maintenance I actually make money on. They may try to do some of the petty stuff that I can't charge the time it takes anyway, but the heavy billable stuff will still be brought in - the difference being is that I won't be required to sign it off as an A&P anymore, the owner will sign it - just the unloading of both liability and FAA issues will far outweigh the moderate discount I give them for not signing it. Plus I won't be stuck buying expensive parts which eat into what I can charge for labor.

I really am hoping this or something like it goes through.

[steveinindy]

The mindset of the people making the rule is of the safety of people on the ground more than in the air - they're worried about what a poorly maintained aircraft will damage when it crashes.

Actually, you'd be quite surprised insofar as that attitude is not all that prevalent at the FAA since the vast majority of folks realize that a light aircraft hitting the ground is not prone to causing large numbers of casualties except in a very narrow set of circumstances. The concern is more towards preventing any mortality associated with crashes.

[Kurt Flunkn]

Frank

- the difference being is that I won't be required to sign it off as an A&P anymore, the owner will sign it - just the unloading of both liability and FAA issues will far outweigh the moderate discount I give them for not signing it. Plus I won't be stuck buying expensive parts which eat into what I can charge for labor.


I agree with Beechboy. I'm also an A&P but not an IA and do not perform work for other people due to the liability issues. Since the owner would be doing the sign off, I would be much more likely to assist other owners. Currently I tell people to just take their airplane to XYZ maintenance shop and remind them that mechanical things never fix themselves.

The second part is the "expensive parts" issue. After reading the proposal it is apparent that under the proposed "non-commercial" category, the requirement for PMA'd parts goes away. This opens the door for the use of parts from the experimental market, which are generally much less expensive. This also means leveraging technology for spiral upgrades becomes a far easier task due to less government regulation. If this proposal becomes reality, the first thing I would do is develop installation kits for Dynon glass cockpit displays in Cessna 100 series and the Piper PA-28 series aircraft.

[beechboyA36]

Where is the EAA on this? Have they been looking at? Are they all on vacation?

We have been talking about this for the better part of 3 weeks, have like 80 posts - do we need to start personally attacking each other or use naughty words to get our moderator to at least chime in?? lol

[steveinindy]

Where is the EAA on this? Have they been looking at? Are they all on vacation?

We have been talking about this for the better part of 3 weeks, have like 80 posts - do we need to start personally attacking each other or use naughty words to get our moderator to at least chime in?? lol

As someone pointed out: where did this come from? I don't recall seeing an answer on that.

[beechboyA36]

As someone pointed out: where did this come from? I don't recall seeing an answer on that.

I answered it a couple of times Steve - in fact it's on the first page of this thread.

[steveinindy]

All I see on the first page is a vague comment about "a group within the FAA" that's rewriting the small airplane regulations.


Evidently there is an FAA group rewriting the small aircraft laws.

Which group specifically?

Then you make a comment that sounds like you don't know who is behind it:


Great Job EAA!!!!!!!!!! (or whomever is doing this!!!)

You also claim to have just randomly found it on a message board:

I saw this on another message board – after reading it I am really excited and had to post it! I attached the file to this post, hopefully it works.

Which one?

....or was it a mailing list?

Being new here I am not sure if I am doing it right. Unfortunately I can;t point you to a webpage because this actually came off a Beech mail list I am on

Better yet, how did you learn of this before any of the major alphabet organizations did?

I call BS on this until we're given some actual information and not just the runaround by someone whose story seems to shift considerably each time he "answers" the question.

[scott f]

Wow Steve - you sure know how to make friends. You seem to insult people all across these boards - maybe you should find a new hobby where being nice to people is not required.

That being said, I don't think that the Beechboy knows where this came from beyond the message board he got it from. However, owner MX was a subject on the agenda at the last ARC meeting. EAA and AOPA government relations, NATCA and whole host of type clubs are aware of it and discussing it. Whether or not they are in favor of it, I will let them speak for themselves.

Now Steve - go take a Dale Carnegie class... Beechboy I sent you a private message, please contact me.

[steveinindy]

You seem to insult people all across these boards -

You call it insulting people. I call it being honest and not blowing smoke just to avoid ruffling feathers. The problem is that with the lack of tone of voice inherent in internet forums what is said one way (bluntly) comes across as a totally separate one when it's said in person or on the phone.


maybe you should find a new hobby where being nice to people is not required.

Last time I checked aviation didn't require being all sunshine and rainbows to people either. I mean there are a lot of very successful people in the ranks of aviation who make me seem like Mahatma Gandhi.


Now Steve - go take a Dale Carnegie class.

I call it like I see it. There's no stipulation that I have to kiss the butt of everyone I cross paths with. If you seriously think I've got an attitude problem beyond just a low tolerance for indecisiveness and possible BS coupled with a means of communication that makes it difficult at times to interpret intent, then I guess you've got a problem and well....no offense but deal with it until July and we can sort it out over a beer or something. I'll be bringing a couple of cases since I think I've offered a bottle to just about everyone on here at one time or another. There are a lot of folks on this forum that I originally thought were abrasive or prickly (Hi Frank!) until I got a chance to talk to them.


I don't think that the Beechboy knows where this came from beyond the message board he got it from.

Well, then he needed to say that. When he gives conflicting stories about something that no one seemed quite sure of who wrote the "proposal" we were presented with, it makes it seem as though the source (in this case "Beechboy") may be feeding us a line. Even if he had just said "Well, I found it over on AOPA forums/PoA/Purple Board/etc...." it would have been much simpler and reliable than a vague non-committal answer that appeared to change several times.

That said, if that came across as excessively harsh, my apologies. My point was just to get to the bottom of where this came from and to point out that Beech hadn't really answered my question like he thought he had. That said, now that the origins/implications of the document have been ascertained, Beech, my apologies for being so freaking harsh. Sometimes that "in G-d we trust, everyone else bring ****ing data" mantra that I've had drilled into my head during my tenure in research tends to get the better of me.

[Kurt Flunkn]

Everyone else,

Based on the style and format this is likely a draft from a rules making committee. This may have come from industry, one of the alphabet groups, or FAA. There is no way to tell for sure. The call to action is to 1). read the proposal. 2). if you are an owner / operator of a certified aircraft and you believe this proposal to be beneficial lend your support.

Thank-you.

[Hal Bryan]

REMINDER: No personal attacks guys (the previous post has been trimmed.)

[LostUpNorth]

A&P still has to annual it though.

[flyingriki]

Not entirely sure that it's a good idea- have seen too many pilots whose mechanical knowledge is (in generous terms) extremely limited at best

Having seen some of the lousy work done in shops by A&Ps I'd hate to think everyone relies on them as gospel.......

[RV8505]

I am skeptical as the goverment rarely does anything without a long term hidden agenda.