Report on Recommendations for increasing the safety of small GA airplanes

[JimRice85]

This could finally be the time when owner performed maintenance for older aircraft becomes reality. It is good to hear "less burdensome and costly" in a recommendation in reference to the FAA.

From page 53 of document linked below.

"6.4 PRIMARY NON‐COMMERCIAL CATEGORY
The Primary Non‐Commercial Category is intended for the private owner to operate their aircraft in a substantially less burdensome and costly manner by reducing the level of FAA maintenance and alteration requirements to a level appropriate for a privately owned vehicle.
Recommendation: The FAA create a Primary Non‐Commercial Category under 14 CFR part 21.
The Primary Non‐Commercial Category is intended for the private owner to operate their aircraft in a substantially less burdensome and costly manner by reducing the level of FAA maintenance and alteration requirements to a level appropriate for a privately owned vehicle."

Aircraft would be dual category. Owner maintained for non-commercial and A&P/IA for commercial. An A&P inspection for annual inspection would be required. Very closely following E-AB rules.

http://www.faa.gov/regulations_policies/rulemaking/committees/documents/media/Part.23.Reorganization.ARC.FINAL.Report.pdf (http://www.j3-cub.com/forum/redirect-to/?redirect=http%3A%2F%2Fwww.faa.gov%2Fregulations_p olicies%2Frulemaking%2Fcommittees%2Fdocuments%2Fme dia%2FPart.23.Reorganization.ARC.FINAL.Report.pdf)

[WLIU]

Does the doc state how a non-commercially maintained aircraft could be moved back into the commercial category? There are lots of airplanes where the owner might want to operate in the commercial category. Example - If you or I as Swift owners wanted to use our airplane to check out a prospective Swift buyer or new Swift owner and accept compensation. Today if we do that, the only aircraft record the FAA cares about is that within the last 100 hrs our airplane has undergone an annual or 100 hr inspection. Another example is if I own a C-182 and a skydiving operation is interested in purchasing my airplane? If I have switched the airplane maintenance into the non-commercial track, how do I get if back to the commercial track?

Hopefully the transition is not onerous or lots of owners might not take the risk. Most of us will eventually sell our airplanes.

And it will be interesting how the insurance companies set premiums for airplanes in the proposed category.

Best of luck,

Wes
N78PS

[Dave Stadt]

Sounds like a very slippery slope with no way back. Resale value would no doubt take a big hit. The proposal does not state how or even if an aircraft could be returned to 'commercial' status. Question also regarding modifications. Would current requirements remain or would E-AB rules apply.

[FloridaJohn]

Does the doc state how a non-commercially maintained aircraft could be moved back into the commercial category?
Yes.


Sounds like a very slippery slope with no way back. Resale value would no doubt take a big hit. The proposal does not state how or even if an aircraft could be returned to 'commercial' status.
Doesn't sound like you read the document very closely. This proposal is basically the same as the Canadian Owner Maintenance category, except with the provision that the plane can be returned to Normal Category (unlike the Canadian version). From the document:

Conversion Back to Normal Category



Aircraft operated in the Non‐Commercial type certification class would be dual certificated in both the Normal and Non‐Commercial categories, as is commonplace for Restricted Category aircraft.
Aircraft in the Non‐Commercial TC category can be operated in the Standard Category, provided the aircraft meets it type design data including compliance with all ADs, removal of all Non‐PMA/TSO parts and replacement with certified units and the removal of all non‐certified alterations.
The conversion can be accomplished by an Inspection Authority (IA) mechanic with a complete and thorough annual inspection and logbook audit. Upon successful completion, the aircraft could be operated under its Standard Airworthiness Certificate. The procedure is very common with Restricted Category aircraft and proven to be safe and successful.


So basically, to return it to a normal category certificate, all non-PMA'd and non-TSO'd parts have to be removed, and a regular inspection by an IA to insure the plane is in compliance with all applicable ADs, etc. will bring it back to a normal category plane that can be used for commercial activities again.


Question also regarding modifications. Would current requirements remain or would E-AB rules apply.
According to the document:

Privileges



Aircraft in this category can be maintained by the owner with a repairperson’s certificate, similar to currently established procedures for LSA aircraft repairpersons.
Replacement or alteration parts should be appropriate for aircraft use; however, such parts need not be PMA/TSO authorized.
Owners can alter their own aircraft without the requirement for FAA approved data; however, some alterations may require “phase 1” flight testing similar to Experimental Amateur Built (EAB) requirements.


I think this is a great idea, and would love to see it happen. If it did, I would be one of the first to sign up.

[Dave Stadt]

Yep I missed that. Went back and reread and noticed annual inspections would be required by an A&P not an IA. Don't see much savings there. So other than being able to self install non PMA/TSO parts what is the real world difference? Flying a Cessna 120 why would I want to go this route?

[FloridaJohn]

Yep I missed that. Went back and reread and noticed annual inspections would be required by an A&P not an IA. Don't see much savings there. So other than being able to self install non PMA/TSO parts what is the real world difference? Flying a Cessna 120 why would I want to go this route?
There are a lot more A&Ps then there are IAs, so it should give you more options for the inspections. More options usually results in lower prices, so that may be a benefit.

The main benefit, as I see it, is that you can do all the maintenance yourself, including signing off the work. So you can install new avionics, replace your mags, make repairs, etc. on your own instead of paying someone to do it for you. An added bonus is that you would get access to all the newer, less expensive avionics that the experimental folks have been enjoying for years.

Doing your own maintenance and using lower cost components sounds like a really easy way to lower the cost of owning a certified airplane.

[WLIU]

I will offer the suggestion that you will not really be able to use less expensive components and have an A&P sign off your annual inspection. The mechanics that I work with have regular horror stories of redo-ing work that an uneducated owner did with Radio Shack wire or the wrong hardware. A conscientious mechanic who values their certificate is going to insist that Cessna's be repaired with Cessna parts and hardware and parts that meets the current definitions of aircraft grade. That's the booby trap. At the annual inspection, any work that is not as good as your mechanic would have done, will get re-done at your expense. And that is completely understandable since no mechanic wants to sign off work that was done to a lower standard than he or she would have done, and then get called because you crashed.

What that means in practical terms is that today you can do all of the things that have been listed in the previous post so long as you know your mechanic, work under his or her supervision, to the mechanic's standards, and probably using whatever tools you do not own but he or she does. I have done all of the tasks listed in the previous post and my mechanics provide guidance, quality control, and the apprpriate log book entries after I fork over some $$ and maybe beer. So I gain nothing with the implementation of this proposal. Your hands and my hands can already do all of these tasks so long as we have a good relationship with our local mechanics and respect their role, their accumulated knowledge, and the value they bring to working on your and my airplanes.

Now if I put LSA avionics in, my ship's resale value takes a hit because a prospective buyer may have to take it all out and put in certified avionics for what they want to do. So I will suggest that most folks will stick with the more expensive stuff.

It is good to see a proposal, but it would be even better to see a proposal that does not suffer the fate of the Recreational Pilot Certificate where the number of folks who thought it was worth earning one is vanishingly small.

Best of luck,

Wes
N78PS

[Dave Stadt]

That is my take also Wes and to recertify is akin to giving an IA a signed blank check. I would not blame an IA as they will have no idea what they will be dealing with. If it was me I would not put my ticket on the line unless I knew the person and their quality of work.

[Frank Giger]

Well, there are modifications and then there are modifications.

I suspect that a mechanic may wave off on doing the annual for a Champ with a VW engine on it, but let's think a bit smaller.

Let's say one's compass needs replacing. It came with Ye Olde whiskey compass, and the owner wants to put in a vertical card compass. First, if it's taken out of commercial status one doesn't have to worry about whether or not it's legal to change the type or any paperwork for exceptions. And one doesn't need a TSO'd compass.

The price difference between a TSO'd and non-TSO'd vertical card compass is over a hundred dollars.

I won't even approach the matter of clocks on panels. TSO'd clocks must have pure gold back plates; they dang sure aren't accurate enough to warrant the prices they demand.

Does anyone think a mechanic will refuse to do an annual because the compass isn't a TSO'd model?

And while it bodes well for a pilot owner to pay attention to AD's, in the experimental world they're optional, being given that the owner has a responsibility to ensure his aircraft is safe. The pilot can defer implementing an AD if they choose to and still keep flying.

[FloridaJohn]

I will offer the suggestion that you will not really be able to use less expensive components and have an A&P sign off your annual inspection. The mechanics that I work with have regular horror stories of redo-ing work that an uneducated owner did with Radio Shack wire or the wrong hardware. A conscientious mechanic who values their certificate is going to insist that Cessna's be repaired with Cessna parts and hardware and parts that meets the current definitions of aircraft grade. That's the booby trap. At the annual inspection, any work that is not as good as your mechanic would have done, will get re-done at your expense. And that is completely understandable since no mechanic wants to sign off work that was done to a lower standard than he or she would have done, and then get called because you crashed.
Yes, of course. I agree with your basic premise. However, how is this different than what an owner of a currently E-AB plane that they did not build has to go through? If you own an E-AB plane without a repairman's certificate, you are subject to the scrutiny of an A&P at least once a year. It seems to be working just fine in the experimental world, so why not in a non-commercial setting for a certified plane?


What that means in practical terms is that today you can do all of the things that have been listed in the previous post so long as you know your mechanic, work under his or her supervision, to the mechanic's standards, and probably using whatever tools you do not own but he or she does. I have done all of the tasks listed in the previous post and my mechanics provide guidance, quality control, and the appropriate log book entries after I fork over some $$ and maybe beer. So I gain nothing with the implementation of this proposal. Your hands and my hands can already do all of these tasks so long as we have a good relationship with our local mechanics and respect their role, their accumulated knowledge, and the value they bring to working on your and my airplanes.
Yes, of course, and I do that as well. Nearly all the work on my plane has been done by myself, and then inspected and signed off by an A&P. However, if I am already doing all the work, and it is clearly acceptable up to aviation standards (because it is passing the A&P's inspection), then why do I need to "fork over some $$ and maybe beer" to someone else? Surely you can see this as an immediate reduction in expenses?


Now if I put LSA avionics in, my ship's resale value takes a hit because a prospective buyer may have to take it all out and put in certified avionics for what they want to do. So I will suggest that most folks will stick with the more expensive stuff.
I disagree here. Your premise is that a plane is more valuable with certified avionics than with non-certified avionics. Granted, a G1000 panel in my plane would be more desirable than a Dynon panel, but I don't know anyone that would prefer the traditional six-pack panel over a Dynon panel. The new-plane market sees this as well, since nearly all new planes come with glass panels. If there was a market for steam gauges, the manufacturers would be offering it as an option. Since the majority of the planes that would fall under this proposal are older planes, I think ones with a modern, glass panel will fetch more than ones with an original panel.

I also think you are overstating the commercial value of this class of planes. The vast majority of these planes have never been used in a commercial setting, or are no longer used for commercial activities. They are personal planes used for personal reasons. The main commercial use for this class of planes is flight instruction, and those planes will have to remain stock. All others are for personal use and the owner should be allowed to do what they want (within reason, of course).

But the beauty of this proposal is that it is voluntary, and any plane can be returned to commercial service merely by removing any non-certified parts. So, if you think your plane is more valuable in stock condition, then don't move your plane into the new category. I have read time and time again how the biggest barrier to entry in aviation is the cost. Here is a concrete proposal on how to reduce those costs, and somehow it is being perceived as a bad thing?

[jjhoneck]

Is anyone holding their breath?

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

[Dave Stadt]

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

[Mike Berg]

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

[FloridaJohn]

Is anyone holding their breath?
Not really, but it is nice to dream. :)

[Victor Bravo]

I would like to add my opinion that an owner-maintenance category or status is a great idea for SOME owners, and a terrible idea for others.

I happen to have been around long enough, and learned enough, and studied under the right people... to have a fairly good idea of what I can and cannot do safely. I hold two STC approvals and one PMA. I'm also VERY cognizant and vigilant of my limitations, of which there are a lot.

But there are a lot of pilots and owners who do not know which end of a screwdriver to pick up. There are a lot of people who would substitute a $3 automotive spark plug for a certified one, by trying to re-tap a cylinder head for the different thread, or use JB weld to compensate for the difference in thread.

There are some really good and experienced pilots who simply should not be working on airplanes. I'm not sure how this "owner maintenance" situation would keep them safe in between annual inspections.

Please remember that in this age of anti-aviation media, TSA, and lawyers crawling out of the toilet...every time someone makes an emergency landing on a road, or lands in someone's back yard... could be the END of our ability to fly freely in this country.

[Matt Gonitzke]

I doubt A & P schools even teach tube and fabric anymore.

It's still part of the curriculum and probably will be forever. There's still material about radial engines covered, too...

[martymayes]

I doubt A & P schools even teach tube and fabric anymore
It's still part of the curriculum and probably will be forever. There's still material about radial engines covered, too...True but for the last 30+ yrs it's been Level 1 in part 147 which means knowledge of general principles but no practical application and no development of manipulative skill. IOW's, the "teaching" can be an instructor pointing to a picture saying "Some planes use fabric covering, this is what it looks like, any questions?" Essentially the same for radial engines. You can graduate from A&P School without ever touching fabric or a radial engine. As it should be, those are now specialized skills.

[Trackwelder]

I learned to fly in an Ercoupe that had been converted to an 85 hp engine, this engine had the wrong oil tank and the wrong carburetor, but the IA and A&P who had been signing it off for years never caught it, for the person who is going to buy one plane and keep it for life resale isn't a big deal and I trust my work on an airplane than the work that those mechanics did.

[Richard Warner]

For all of you not wanting this change, nobody is twisting your arm requiring you to put your airplane in the non-commercial category. I am an A&P with I.A. The "annual inspection" that would be required, I presume, would be a condition inspection much like is done on amateur built aircraft. I have done these as an A&P. It would take a change in the regulations to allow an A&P to do a real annual inspection versus an annual condition inspection where the aircraft must meet its original type certificate or have been properly altered and only an IA or the FAA can do that. You still couldn't put a VW engine in a Champ like someone suggested because that would require FAA approval just like it would if, say a Wag-Aero Cuby Continental 65 engine was in the plane when its airworthiness certtificate was issued and the builder put a VW engine in it a year or two later. More than likely, the FAA would require the builder to go through a test period again. I think this proposal to change the regulation is a great idea. It might even make an airplane in that new category more easily sold if there is someone out there looking to have a plane he could legally do his own maintenance on. I'm afraid though that this will be met by the FAA just like the "No 3rd Class Medical" proposal was met. They aren't about to give up any control on us in my opinion.

[raytoews]

Best thing ever happened to aviation in Canada.
I own a Grumman Cheetah and have been having a ball installing Efis, autopilot, different exhaust, electronic mags, etc, etc,. Much improved airplane.
It can be put back with basically the same conditions in Canada, remove non certified parts and get it signed off by an overhaul mechanic but why would I even consider putting it back.
Wayyy better this way.
Resale value, who knows, who cares!

Ray

[raytoews]

http://wwwapps2.tc.gc.ca/Saf-Sec-Sur/2/ccarcs/aspscripts/en/current.asp

Seems like at least 500 owners in Canada thought it was a good idea, a wide variety of aircraft.

Ray