Turning Certificated Acft into "Experimental"

[TedK]

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

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

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

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

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

Thoughts?

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

[Todd copeland]

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

[TedK]

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

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

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

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

[Todd copeland]

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

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

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

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

[TedK]

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

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

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

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

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

Read, think, comment!

[jam0552@msn.com]

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

[Puertoricoflyer]

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

[raytoews]

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

Ray

[raytoews]

Part of the COPA guide to OM.

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

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

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

Changing the Rules

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

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

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

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

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

 STC documents for that type or other types of aircraft

 Transport Canada advisory documents;

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

 UK CAA Civil Aircraft Inspection Procedures (CAIP),

 JAA Advisory Circulars, (ACJ) and

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

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

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

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

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

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

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

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

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

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

[Todd copeland]

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

[TedK]

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

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

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

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




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

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

Administrator of the Federal Aviation Administration shall issue a

final rule--

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

airplanes by reorganizing the certification requirements for such

airplanes under part 23 to streamline the approval of safety

advancements; and

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

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

subsection are based on the recommendations of the Part 23

Reorganization Aviation Rulemaking Committee



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

[Mike Berg]

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

[raytoews]

Get the alphabets on this hard.

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

Or so we are hoping.

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

Ray

[TedK]

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

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

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

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

[TedK]

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

Primary Non-Commercial Category Recommendations

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

Privileges
· Aircraft in this category can be maintained by the owner with a repairmans certificate. Similar to currently established procedures for LSA aircraft repairman. (see draft regulation 65.108)
· Replacement or Alteration Parts should be appropriate for aircraft use, however need not be PMA / TSO authorized. (see draft regulation 21.24)
· Owners can alter their own aircraft without the requirement for FAA Approved data (however, some alterations may require “phase 1” flight testing similar to Experimental AB requirements) (see draft regulation 91.328)

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

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

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

[raytoews]

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

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

Ray

[Mike Berg]

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

[rwanttaja]

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

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

Ray

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

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

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

Ron Wanttaja

[raytoews]

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

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

[TedK]

Http://www.macsblog.com/2014/03/could-your-airplane-be-a-pnc/

[Bill Berson]

20 years or older? Why? It should apply to all personal aircraft including new manufacture or this industry is doomed.

[WLIU]

The 20 years or older cutoff is likely due to liability for the manufacturers. Here in the US the legal profession has gotten a lot of money out of aircraft manufacturers. Burt Rutan stopped selling Eze plans due to the lawyers.

But I have to say that aircraft maintenance and annual inspections, at least in the US do not have to be expensive. My annuals go well because I always bring my IA a perfectly working airplane, or an airplane where I already know what to fix. In between annuals I find any issues that pop up, pull out the parts book, the service manual(s), and AC43.13 and fix it. I give my mechanic a couple of $$ to look at it, maybe tell me what to do, and make the log book entry. Surprises are expensive so I spend quality time with my machine and my mechanic and the bills are relatively low. I LIKE having the second set of eyes looking at my work since even though I have been at this for many years, I have a non-aviation day job and my mechanic looks at broken airplanes all day. Sometimes he has a better idea, some days I do. In the US, anyone's hands can do the work so long as they have a good working relationship with a certificated mechanic who will provide consultation, supervision where needed, and make the log book entry. Its really not that hard or expensive if you are willing to find a mechanic that will work with you and you respect and pay for their advice. My experience is the the longer we have worked together, the less mechanic time I have to buy. But I buy all I am asked to.

Certificated airplanes don't have to be expensive to maintain.

Best of luck,

Wes
N78PS

[martymayes]

Http://www.macsblog.com/2014/03/could-your-airplane-be-a-pnc/

"This is different from the annual inspection required for standard category airplanes. An annual is intended to confirm that the airplane conforms in every respect to its type certificate. The condition inspection confirms only that the airplane is airworthy."

lol..... Gee Mac, what exactly is the definition of "airworthy?"

[Mike Berg]

Wes, Except as I posted above. There is or will be a shortage of mechanics that know tube and fabric, wooden wings type aircraft......Champs, Chiefs, J-3, Taylorcraft, etc. I doubt if it's even taught in A & P school any more (it may be touched upon but I'd be willing to bet that's about it). Another set of eyes is fine but it doesn't have to be a IA or A & P. Sloppy work can be done by the owner but in 30+ years of aircraft ownership I've also seen sloppy work by aircraft mechanics, too. Just like I'm not going to take the aircraft up unless I'm 'fit to fly' physically I'm not going to take the aircraft up if it's not 'fit to fly'.

[Bill Berson]

Wes, yes, the 20 years number might be based on liability. But why should the FAA make rules on that basis?
On the other hand, I think if an owner takes over the airworthiness choices, that might relieve the original manufacturer of the liability burden. The government can decree that. (Not likely, but possible :rollseyes:)

At least give the manufacturer the option to offer these perks that now go only to Kitplanes.
This 20 years cutoff surely has no basis related to safety.

[1600vw]

"This is different from the annual inspection required for standard category airplanes. An annual is intended to confirm that the airplane conforms in every respect to its type certificate. The condition inspection confirms only that the airplane is airworthy."

lol..... Gee Mac, what exactly is the definition of "airworthy?"

Marty with all do respect, a condition inspection does NOT state an experimental is airworthy. It states an experimental is in a condition for safe operation. Airworthy is reserved for certified airplanes. Nothing about an experimental airplane is airworthy.

Tony

[martymayes]

Marty with all do respect, a condition inspection does NOT state an experimental is airworthy. It states an experimental is in a condition for safe operation. Airworthy is reserved for certified airplanes. Nothing about an experimental airplane is airworthy.

Tony

Tony, click on the link. The quoted statement is from Mac's blog, not me.

[1600vw]

Tony, click on the link. The quoted statement is from Mac's blog, not me.

Yes I see now.

I do not mean to piss in anyone's Wheaties. But Why not take this group of airplanes and just make them experimental for what is being proposed is an experimental type of certificate but with Certified type of regulations or rules.

Also by reading this I see the author does not understand the difference in the type certificates between a Certified airplane and a experimental airplane or the wording there of between the two.

Tony

[WLIU]

"Also by reading this I see the author does not understand the difference in the type certificates between a Certified airplane and a experimental airplane or the wording there of between the two."

Considering the source, I do not know why you would be surprised.

20 years - welcome to the committee process. A committee process brings in the views of each self-interested parties. Since builders of certificated airplanes get a voice, they propose a number that will appeal to the antique classic folks, but also push back their own liability horizon. Please understand that moving from a system of bureaucrats making rules to a committee system is not better, just different. We can push for a better result, but that is not guaranteed.

Now the FAA, being chartered to keep airplanes from falling out of the sky on the heads of the general public, is NOT going to change the rules so that anyone can work on their airplane without oversight. It is completely unrealistic to expect that each airplane will no longer have to pass the scrutiny of an FAA certificated individual on an annual basis. It you have had any contact with the FAA at all you should realize that the FAA will not waive that.

As to the coming shortage of mechanics that know old airplanes, you can influence that. If you make friends with your local small shop, take your steel tube and fabric airplane there, they will see that you are good business. They will WANT their staff to come up to speed on those arts since it will be a money maker for them. They are not in this for charity, its their livelihood and if no one wants to pay them for those skills, they will abandon them. Its a death spiral if we do not bring them that business. If I had a maintenance business and I saw one group of potential customers telling me that I do too much maintenance, am too concerned about making a ship "airworthy", and continually tell me that charge too much, as I try to pay for the mortgage, heat, and tools, and I had another group of potential customers who wanted their airplanes to be 100% reliable, wanted every part 100% airworthy, and was willing to pay for that, I would go with group #2.

As I have noted previously, I work with my mechanics to take care of every issue as soon as I see it. I understand that my mechanic has a mortgage and aspires to have a decent 401K retirement plan, that he does not set his supplier's parts prices, and that we will show our work to the FAA on a regular basis (I do 337 Field Approvals on my aircraft), and that I will be the first one to the scene of the crash if we do not get it right. Plus the mechanics I know are good guys, good to talk to over a beer, and every one of them could make more money working at the Toyota dealer. Mechanics work on airplanes because of a genetic defect that makes them feel good when they see another airplane fixed and back in the air, rather than another Ford roll out of the service bay. I personally believe that while every owner should become as knowledgeable and skilled at working on the innards of their ship as possible, this recurring theme of "we don't need no steenkin' mechanics!" is part of the death march of recreational aviation.

Just my view.

Wes
N78PS

[martymayes]

Also by reading this I see the author does not understand the difference in the type certificates between a Certified airplane and a experimental airplane or the wording there of between the two.

Precisely my point and no offense taken.

[1600vw]

I use an A&P when I need to. For my Condition inspection. If I need something worked on and have no idea what I am doing who do you think I look up, My A&P. But just because he has bills to pay do not expect me to pay those bills from working on my little eab. I will not pay your mortgage or your 401K just because times are tight, but I wll give you a fair amount to help.

If you believe the way the rules are written everyone is in danger then petition to have the rules changed. But just because those with an Experimental do what is written in the regs does not make them a danger to others. It states right in the regs, anyone can work on a experimental without any sign off from anyone. If you do not like it petition to have these regs changed.

As for major changes a experimental plays by a different set of rules then those certified, again if you do not like it, start a petition to change it, but be ready for a fight.

Tony

[TedK]

Yes I see now.

I do not mean to piss in anyone's Wheaties. But Why not take this group of airplanes and just make them experimental for what is being proposed is an experimental type of certificate but with Certified type of regulations or rules.

Also by reading this I see the author does not understand the difference in the type certificates between a Certified airplane and a experimental airplane or the wording there of between the two.

Tony

Tony - in essence, these recommendations accomplish what you suggest with one significant difference that I think is an asset.

E-AB airplanes will always be Experimentals. No way to be born an Experimental but die aCertificated

The PNC proposal, let's you be born a Certificated airplane, play as an E-AB, then if you want, perhaps for better resale value, she'd the Mods and become a Certificated airplane again.

[1600vw]

TedK:
If you take a certified part and install it on an experimental you can not put this part back on a certified airplane not without a complete tear down and inspection. Lets say you have a certified engine and you stick it on an experimental. You can not then take this engine off the experimental and reinstall it back onto a certified airplane not without a complete tear down and inspection. Because of this I doubt this will ever pass what you are hoping for.

Tony

[TedK]

TedK:
If you take a certified part and install it on an experimental you can not put this part back on a certified airplane not without a complete tear down and inspection. Lets say you have a certified engine and you stick it on an experimental. You can not then take this engine off the experimental and reinstall it back onto a certified airplane not without a complete tear down and inspection. Because of this I doubt this will ever pass what you are hoping for.

Tony

Tony - the report drew a parallel between the Restricted category and the Standard category and noted that airplanes go back and forth all the time between those tow categories. Yes, and while the "Pickle Rule" (once you're a pickle you can never again be a cucumber) has been in effect for E-AB, there are other Experimental categories like R&D that I understand let you return to Standard after a compliance check.

The magic of breaking the pickle rule will be the compliance check. You have to keep your airplane safe and airworthy, you don't have to do ADs until you want to be Standard again.

But, and this is the beauty of semantics, your PNC will not be an experimental, so experimental rules don't apply. You can treat it sort of like an E-AB, but it won't be an E-AB but a PNC.

[1600vw]

The magic of breaking the pickle rule will be the compliance check. You have to keep your airplane safe and airworthy, you don't have to do ADs until you want to be Standard again.

But, and this is the beauty of semantics, your PNC will not be an experimental, so experimental rules don't apply. You can treat it sort of like an E-AB, but it won't be an E-AB but a PNC.


Thing about an experimental. The owner needs to keep it in safe operation. Nothing about an Experimental is airworthy.

Tony

[martymayes]

It's great they have included a pathway back to normal category in the proposal, however, the practicality of following that path won't be known for some time. While some planes do move from normal - restricted - normal without too much hassle, those planes are maintained IAW with Part 43 using authorized maintenance personnel regardless of category. Anyway, if insurance companies decided this PNC stuff is to risky to insure, it won't fly very far.

[WLIU]

"too risky to insure"

Most of us have families and mortgages and savings and insurance is not optional. I recently asked my wife about what age life insurance is no longer needed. Her answer was "you aren't old enough."

The number of insurance companies that cover aircraft with any type of airworthiness certificate that has a title that begins with the word "Experimental" is significantly smaller than the list of companies that cover the rest of the GA fleet. And the rates are different. You can find coverage. Each owner has to decide if what they can buy matches what they need.

Even if the US gets some sort of owner maintained category, how the insurance companies approach that market will have a big influence. I will hazard a guess looking around that the population of individuals who take advantage of this change will not be huge and the age demographic will be older. The young pilots seem to like flying behind the TV tubes in nice clean rental airplanes. The builder population is significantly graying. This trend does not suggest lower insurance rates.

Have to see what happens. But the FAA moves slowly and often reluctantly. Just because Congress gives the FAA a push does not mean the output matches what was wished for. The staff at Independence avenue can produce 1000 pages of documentation on how what the FAA produces is the best match for what Congress asked for.

As an aside, when I walked by the lobby at 800 Independence Ave, I saw that they still have a rag-wing Piper hanging in the lobby. But I understand that you might be able to count on your fingers the number of residents of that building who could actually fly it. Such is the state of the FAA.

Best of luck,

Wes
N78PS

[TedK]

Marty and Wes- Yep. FAA could give us everything in the ARC Recommendations and the Insurance companies could decide it's too risky. But look at CAMO, LSA and E-AB today. They are getting sufficiently affordable policies. The risk must be seen as manageable and profitable otherwise the Insurance companies wouldn't be underwriting them.

The report harps on the fact that the increases in safety that could be gained will greatly offset any risks.

[Mike Berg]

I don't know if insurance would be a big factor if I turned my plane from 'certified' into the 'experimental' category. I'm near 75 years old, fly a tail dragger Champ type plane (L16A) under light sport (no third class medical), something over 1000 hours and my insurance dropped by $30 this year. Seems like a personal (claim) record would be more of a factor than if I were maintaining my own plane. I have mine valued at $30,000 although I probably have a bit more than that in it and my insurance cost dropped from $688 to $658 for full coverage including hull. I know several that have fairly high value aircraft and have 'experimental' stickers in them and the insurance costs are quite reasonable considering they are valued over $100,000.

[raytoews]

My Cheetah is insured with EAA insurance, no change when I went OM.

Insurance companies and lawyers don't run the world, Smith and Wesson do.

Ray

[raytoews]

OOOPS my redneck just showed.

Ray

[WLIU]

That is encouraging to hear, but my understanding is that the Canadian insurance market is quite different than the US insurance market. Not sure you are comparing apples to apples.

Best of luck,

Wes
N78PS

[TedK]

That is encouraging to hear, but my understanding is that the Canadian insurance market is quite different than the US insurance market. Not sure you are comparing apples to apples.

Best of luck,

Wes
N78PS

Perhaps a Canadian Apple is different than a US Apple. :-) But they are similar.

In addition to CAMO, we have E-AB and LSA doing OM today with US insurance. But your point is well taken, even if the govt gives us the latitude, the insurance market will be a major factor. If PNC turns out to be unsafe, the Insurance market will dry up and we will be begging for that IA to restore the original AW certificate. The FAA won't need to undo its regulation.

Market Based regulation....I feel the unseen hand....

[S3flyer]

A valid comparison might be taken from those who went from S-LSA TO E-LSA. I know about half a dozen folks who have gone this route with no change in insurance.

[BTBFlyboy]

As many of those commenting here are comparing this proposal to the Canadian Owner Maintenance (OM) category, I wonder how many have bothered checking out the total number of Canadian OM aircraft (since that programs inception in 2000) ?? Well here's the link, http://wwwapps2.tc.gc.ca/Saf-Sec-Sur/2/ccarcs/aspscripts/en/monthsumairbycatresult.asp . As can be seen, only 612 (as of Feb 2014) aircraft have been moved into the OM category since that programs inception in 2000. For comparison Canada currently has 4072 homebuilt aircraft registered. Ergo, it doesn't look as if the Canadian OM has been an overwhelming success (similar to the US Recreational Pilot category of which their are less than 500) !! So how again is supporting the addition of a whole new section of FAR's/regulations (which we all know will not reduce cost) for a very, very small percentage of US aircraft owners going to help/save private aviation ??

[scott f]

“PNC” pink airplanes…. Terrible acronym!! What we were actually going for when we were writing this was “ANV” Antique – Non Commercial – Vintage. (Some of you history buffs might also recognize ANV from another group of patriots trying to defeat an invading and conquering army - kind of poetic justice and that’s why I picked it) Naturally I like ANV better, but call it PNC or whatever, what is in a name anyway.


So where to start….
The whole idea of the ANV category was to allow an owner of any non-turbine powered Part 23 airplane to be operated as if it were an experimental so long as it was not being used commercially. Now, as common sense as that may sound to all of us, imagine trying to sell this to an aviation rulemaking committee – oh and BTW, you need to get a nearly unanimous vote for it from more than 90 representatives on the committee.

So, what was needed was an angle here. We came up with was that we would not invent anything new, everything proposed in the ANV category was a rule already in use today with a proven safety record. Obviously maintenance came from Experimental AB, the conversion back and forth to standard category from restricted category, the repairman’s certificate from LSA. Last but not least the hated requirement for the aircraft to be 20 years old, originally this was compared to antique plates on a car (thus the A in ANV) but a few of you already guessed correctly the real reason.

The idea of the above is that we could take real world safety data from the categories mentioned above along with the Canadian owners MX class and prove statistically that the incorporation of ANV would not cause a safety problem. In this way we met both the ARCs requirements of cost savings for owners and proven safe operations. Plus it made it really hard for the FAA to argue what we were proposing was a safety risk as they would have to admit that the current regulations were unsafe.

To prove this though, we had to spell out EXACTLY how this was to be done, by what regulations, by what FAA Orders, instructions for how to have a repairman’s class and even instructions to the inspectors on how to accomplish this. All of these are included in the ARC recommendation. (Mac seems to have missed all this when he said that the ARC had not figured out how to implement these concepts and that it may be limited to 4 seats.. oh well…I think he only read the first few pages) I have attached a copy of the ARC recommendation, don’t let it scare you, it’s only 26 pages)

In the end of we did get the nearly unanimous vote (only one guy from Cessna voted no) (well technically a guy from EASA voted no too, but he did not seem to realize that he was not allowed to vote anyway)

So where are we today… sadly the same place we were a year ago. Unfortunately SARA was craftily amended to not cover any recommendation made by the ARC save for the Industry Standards rec. (which changes Part 23 into LSA, but don’t get me started on that stupidity) I have also been told that the FAA vehemently opposes any deregulation of this type and considers the ANV category a closed issue. The person that told me this (who actually is in favor of it) suggested that the only way to implement the ANV will be through legislation.

So if we want this, it is going to have to come through congress. I think one possible and viable course of action would be to tack it onto the Pilots Protection act currently making the rounds. Less face it, if we are going to deregulate the pilots, we may as well deregulate the airplanes. Pragmatically speaking, if a congressman or senator was going to vote yes on ending third class medicals, do you really think adding in a new primary category that no one understands but pilots is going to scare them off?

In the end this will have to be a grass roots effort. If you want this or something like it, you guys are going to have to fight for it.

Oh, to protect myself -- I have to say everything I have said here is in my strictly my opinion in my role as NATCA representative to the PART 23 ARC.

[scott f]

BTB

The problem with the Canadian category is once it goes in, it basically can never come out again. In fact you even have to stamp all the rotables on the airplane as OM so they never again enter into the parts pool for certified airplanes. This hugely devalues the airframe (like sticking a Cessna into experimental). You are also forbidden to fly the aircraft into the US or sell it to a US owner. In short, move it over and you have created the proverbial white elephant.

We actually were briefed by the guy who started Canadian OM, courtesy of AEA, during the ARC development of the ANV category. We attempted to fix some of the issues that made the Canadian system less popular than it could have been.

But remember ANV is VOLUNTARY. Unlike most ARC proposals, there is nothing in this that forces people to do anything.

[scott f]

Moving to Experimental Exhibition.

This is a good idea except... the problem is that if an aircraft originally held airworthiness certificate in the Standard Category, it must still me maintained per part 43 and part 21. (this can be found in FAA order 8900.1) Thus, you still need an A&P to sign off your MX, IA to do your annuals and PMA parts for all areas of your plane that are not experimental. Now, in all honesty we could probably come up with a program that fixes the parts issue, but what is really needed here was a straight forward way to allow all this stuff in a new category.

[Matt Gonitzke]

Moving to Experimental Exhibition.

This is a good idea except... the problem is that if an aircraft originally held airworthiness certificate in the Standard Category, it must still me maintained per part 43 and part 21. (this can be found in FAA order 8900.1) Thus, you still need an A&P to sign off your MX, IA to do your annuals and PMA parts for all areas of your plane that are not experimental. Now, in all honesty we could probably come up with a program that fixes the parts issue, but what is really needed here was a straight forward way to allow all this stuff in a new category.

That is not necessarily true. It depends on how the operating limitations are written. I have seen quite a few gliders in the experimental exhibition category that require only a condition inspection performed by a normal A&P. Your mileage may vary...

[TedK]

ScottF - Thank you for the background!

I have to do a fair bit of "working the hill" in my day job and asked some of my Lobbyist colleagues how best to proceed here. They reviewed the Bills and legislative history and were unanimous in their opinions and recommended strategy. To paraphrase the spaghetti sauce commercial, "Prego -Its in there". They all cautioned me not to give any public credence to the FAA's arguments.

Politically, we can sabotage ourselves by wringing our hands and giving the impression that the FAA might be justified in not putting it in the NPRM.

Our attitude should be that the ARC and its recommendations are legitimate. Congress recognized that and SARA is for ALL of the recommendations.

We need to prepare to have the Chairman of the House Aviation Subcommittee write a diplomatic letter to FAA politely pointing out that SARA is for all of the recommendations. That will mean political shoe leather getting the whole of the committee onboard.

But your background info on the voting rules strengthens our case.

But most importantly, we must believe and act like we are going to get PNC. We have to act like anything less than PNC is theft.

EAA, when are you going to start scheduling those PNC Repairman classes?

[BTBFlyboy]

Scott F, Thanks for the heads up as to what actually happened within the ARC. I do find it a bit curious as to why the National Ar Traffic Controllers Association (NATCA) was involved in an ARC concerning Airworthiness Standards (Part 23) ?? Be that as it may, the approach used per your statement; "So, what was needed was an angle here. We came up with was that we would not invent anything new, everything proposed in the ANV category was a rule already in use today with a proven safety record. Obviously maintenance came from Experimental AB, the conversion back and forth to standard category from restricted category, the repairman’s certificate from LSA." while novel, is akin to the old axiom about; A camel is what you get when you design a horse by committee !!

Any way a question or two. Wouldn't deregulating aircraft carrying a Standard Airworthiness certificate take a whole new section of the FAR's to accommodate and administrate? Will companies (Cessna, Beech and Piper for example) still holding many ATC's of PNC eligible aircraft, support those conversions with approved data such as drawings etc ? If not, how will the PNC owner assure airworthiness as approved data, not acceptable data, must be used when attempting issuance of a standard airworthiness certificate? Ergo, how can that conversion back to Standard Airworthiness be accomplished without a conformity inspection to it's ATC ?

All that (and more) being said, if you, TedK and other supporters believe it's pertinent expending so much of what little political capital private aviation has, on an idea that has proven elsewhere to be of little success (1.7 % of all aircraft in Canada are in the OM category), I wish you well in your efforts.

[tspear]

Scott F, Thanks for the heads up as to what actually happened within the ARC. I do find it a bit curious as to why the National Ar Traffic Controllers Association (NATCA) was involved in an ARC concerning Airworthiness Standards (Part 23) ?? Be that as it may, the approach used per your statement; "So, what was needed was an angle here. We came up with was that we would not invent anything new, everything proposed in the ANV category was a rule already in use today with a proven safety record. Obviously maintenance came from Experimental AB, the conversion back and forth to standard category from restricted category, the repairman’s certificate from LSA." while novel, is akin to the old axiom about; A camel is what you get when you design a horse by committee !!

Any way a question or two. Wouldn't deregulating aircraft carrying a Standard Airworthiness certificate take a whole new section of the FAR's to accommodate and administrate? Will companies (Cessna, Beech and Piper for example) still holding many ATC's of PNC eligible aircraft, support those conversions with approved data such as drawings etc ? If not, how will the PNC owner assure airworthiness as approved data, not acceptable data, must be used when attempting issuance of a standard airworthiness certificate? Ergo, how can that conversion back to Standard Airworthiness be accomplished without a conformity inspection to it's ATC ?

All that (and more) being said, if you, TedK and other supporters believe it's pertinent expending so much of what little political capital private aviation has, on an idea that has proven elsewhere to be of little success (1.7 % of all aircraft in Canada are in the OM category), I wish you well in your efforts.

If I had any political capital besides writing and calling my congressional representatives, I would think this might be the way to lower the cost of GA to the point it survives. Just think of the number of planes for sale now which are approaching salvage value. Within a few years more and more of the fleet will end up in the dust bin of history. For many aspiring pilots these planes and this category can be the metaphorical salvation to ownership and flight.

Tim

[martymayes]

I have seen quite a few gliders in the experimental exhibition category that require only a condition inspection performed by a normal A&P. Your mileage may vary...

did they ever hold a standard airworthiness certificate?

[scott f]

BTB, here is my best Sunday morning shot at answering your questions.


I do find it a bit curious as to why the National Ar Traffic Controllers Association (NATCA) was involved in an ARC concerning Airworthiness Standards (Part 23) ??

NATCA is the union the represents the Certification Aerospace Engineers for the FAA.


while novel, is akin to the old axiom about; A camel is what you get when you design a horse by committee !!

Think of it this way… I accept certain operating limitations for my experimental airplane and in exchange for that I get many privileges in terms of owner maintenance, use of non PMA but airworthy parts, flexibility in addressing ADs etc. Now if a person with a certified airplane accepts those same limitations, shouldn’t he get the same privileges? My Friend, how would it be in the least bit fair to deny them the same opportunities I get? The ANV Rec is simply an attempt to make things fair and create a level playing field.

I am sorry that you feel that this is such a white elephant. But again, this was designed as a voluntary program, so if you hate it – don’t do it. But if your neighbor likes it, why try and prevent them from having the same privileges you do? Part of the problem with general aviation is that there is not enough flexibility; we are constantly requiring people to do things that may or may not fit their particular situation or needs.


Any way a question or two. Wouldn't deregulating aircraft carrying a Standard Airworthiness certificate take a whole new section of the FAR's to accommodate and administrate?

Not a new section, but several new and revised regulations and a host of changed orders. See the ANV rec a few posts up for a list of these and recommended language.


Will companies (Cessna, Beech and Piper for example) still holding many ATC's of PNC eligible aircraft, support those conversions with approved data such as drawings etc ? If not, how will the PNC owner assure airworthiness as approved data, not acceptable data, must be used when attempting issuance of a standard airworthiness certificate?

I believe that they will. However, not being the great carnack I can not say for sure J



Ergo, how can that conversion back to Standard Airworthiness be accomplished without a conformity inspection to it's ATC ?

Yes, the ANV rec does not require a full or formal conformity for conversion back, just an annual and log book audit Excerpt from page two of ANV rec below, also the draft regulation and order references are included.


Conversion Back to Standard Category
· Aircraft operated under a Primary Non Commercial Airworthiness Certificate would be dual certificated in both the Normal and Non Commercial categories, as is common place for Restricted Category aircraft. (see draft regulation 21.184)
·  Aircraft in the Primary Non-Commercial category can be operated in the Standard category, provided the aircraft meets 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-certifiedalterations (see draft 21.24, draft Order 8130.2)
·  The conversion can be accomplished by an IA mechanic with a complete and thorough annual inspection and log book audit. Upon successful completion the aircraft could be operated under it’s Standard Airworthiness Certificate. The Procedure is very common with Restricted Category aircraft and has proven both safe and successful. (see draft Order 8130.2)






All that (and more) being said, if you, TedK and other supporters believe it's pertinent expending so much of what little political capital private aviation has, on an idea that has proven elsewhere to be of little success (1.7 % of all aircraft in Canada are in the OM category), I wish you well in your efforts.

Dude, part of the problem is General Aviation apparently has no political capitol. I wish we did but the FAA constantly runs over us and our organizations. I wish our organizations would start acting more like the NRA then the cowering victims of bullying.


All of the above is strictly my opinion in my role as NATCA representative to the PART 23 ARC.

[TedK]

When you look at the membership in the ARC, it doesn't look to be a cast of revolutionaries...at least not given their employers. There are very few organizations participating in the ARC that would stand to benefit by the creation of PNC. So, perhaps their motives in creating PNC were pure, if counterintuitive.

[scott f]

That is not necessarily true. It depends on how the operating limitations are written. I have seen quite a few gliders in the experimental exhibition category that require only a condition inspection performed by a normal A&P. Your mileage may vary...

I hear you Matt. In fact when we first started this Rec we wrote it as a new type of experimental certificate rather than a new category. However, we quickly abandoned that and went with the new ANV category for fear operating limitations "creep." The FAA controls experimental through operating limitations and these do not require public comment to change. My fear here was that even if were were successful, the FAA would simply change the operating limitations and kick us back to square one - heck they have been doing that to the warbird owners for the last few years.

The advantage of the new category is we wrote the limits into the FARs (like LSA) therefore it takes the regulatory process to change them. It effectively sets them in stone.

So, now with your gliders.. there are a few possibilities of how they got these;
1. Most probably, the ops limits predate the requirement of ex standard aircraft still being maintained per part 43.
2. Someone screwed up when writing them - this is god awfull common
3. Possibly they never held a standard certificate.

One way or the other, if you know someone that has op limits like that, tell them to play their cards close to the vest!

[scott f]

ScottF - Thank you for the background!

I have to do a fair bit of "working the hill" in my day job and asked some of my Lobbyist colleagues how best to proceed here. They reviewed the Bills and legislative history and were unanimous in their opinions and recommended strategy. To paraphrase the spaghetti sauce commercial, "Prego -Its in there". They all cautioned me not to give any public credence to the FAA's arguments.

Politically, we can sabotage ourselves by wringing our hands and giving the impression that the FAA might be justified in not putting it in the NPRM.

Our attitude should be that the ARC and its recommendations are legitimate. Congress recognized that and SARA is for ALL of the recommendations.

We need to prepare to have the Chairman of the House Aviation Subcommittee write a diplomatic letter to FAA politely pointing out that SARA is for all of the recommendations. That will mean political shoe leather getting the whole of the committee onboard.

But your background info on the voting rules strengthens our case.

But most importantly, we must believe and act like we are going to get PNC. We have to act like anything less than PNC is theft.

EAA, when are you going to start scheduling those PNC Repairman classes?


Ted

The operative word that was inserted into SARA is "certification" - the argument is going to be that the putting an airplane into ANV is not certifying it, just like when we put an aircraft into experimental. But obviously the intent of SARA was all the recs, not just the industry standard portion.

But.. I like your thinking. That is certainly a easier and more logical first step then what I suggested. Have you called Sean to start the ball rolling on this?

All of the above is strictly my opinion in my role as NATCA representative to the PART 23 ARC.

[TedK]

From SARA (I've taken the liberty of placing and annotating the language in SARA that supports PNC)

2. Congress makes the following finds: ...
(8) General aviation safety can be improved by modernizing and revamping the regulations relating to small airplanes to clear the path for technology adoption and cost-effective means to retrofit the existing fleet with new safety technologies.


3.
Safety and regulatory improvements for general aviation

...

(b)
Objectives described
The objectives described in this subsection are based on the recommendations of the Part 23 Reorganization Aviation Rulemaking Committee: (TK's note: this doesn’t say “some of the recommendations”)

[BTBFlyboy]

Scott f

NATCA is the union the represents the Certification Aerospace Engineers for the FAA.
I did not know that but now that I do it makes sense. Thanks for clearing that up.

I am sorry that you feel that this is such a white elephant. But again, this was designed as a voluntary program, so if you hate it – don’t do it
Apparently you missed where I stated; "I wish you well in your efforts"

[scott f]

I have been getting tons of emails on this since Mac devoted one of his Blogs to the ANV recommendation.I am doing my best to keep up, but there has been a lot! (Mac called it PNC, but whats in a name anyway)

So let me try and paraphrase what the Part 23 Aviation Rulemaking Committee recommended (and thereby get ahead on some of the emails). The Part 23 ARC came up with something we called the ANV category recommendation.(ANV is for Antique – Non Commercial- Vintage)

Without belaboring all the details, this is how the ANV recommendation is described in the ARC report:

The Primary Non-Commercial Category is intended for the private owner to operate his or her aircraft in a substantially less burdensome and costly manner by reducing the level of compliance to FAA maintenance and alteration requirements to a level more appropriate for a privately owned vehicle.
Owners of standard category aircraft that are more than twenty years old could elect to redesignate their aircraft as“Non Commercial” use. This would enable owners to maintain their aircraft in a manner similar to a Light Sport or amateur built aircraft. This would include owner maintenance privileges (once a FAA accepted class is passed) and use of non PMA / TSO parts. Aircraft would be subject to a yearly “condition inspection” by an A&P mechanic which certifies the aircraft is in a condition for safe operation, identical to the requirements for Amateur Built Experimental Aircraft.

So in a nutshell the ANV boils down to is that if the owner of a standard category aircraft is willing to accept the same operating limits as an Amateur Built Experimental (EAB) , then he/she should also be allowed the same privileges. (i.e. parts,alterations, owner MX etc)

It really is about fairness – we don’t limit those privileges to the builder of an EAB, the 2nd,3rd, 4th etc owners get the same (save for a repairman’s certificate). So, if a 2nd owner of any EAB can get this, why can’t the owner of a standard category aircraft do the same?

For you detail oriented types, I have attached the entire text of the rec. for your reading pleasure. It is only 26 pages – but most of the detail is in the first 3.

It appears that alot o f people are intrigued by the prospect. This is going to take a lot of work and time to advance this concept, so please post and let people know what you think of the idea. If we are ever going to see something like this it is going to take a grassroots effort – so even if you never posted (maybe like me you hate social media!) please take the time to do so. If you want it – you need to let people know or it ain’t gonna happen.

(to be clear the above is strictly my opinion in my role as NATCA representative to the PART 23 ARC).

[Mike Berg]

So why don't we have something like this for the older 'classic' type aircraft like Champs, J-4, Taylorcrafts, etc. I can tell you the Rotex engine is a lot more complex than a A65/C85/0200. Inspection for these older aircraft is not that complex either .http://eaa.org/news/2014/2014-04-02_repairman-lsa-inspection-course-slated-after-airventure.asp

[1600vw]

So why don't we have something like this for the older 'classic' type aircraft like Champs, J-4, Taylorcrafts, etc. I can tell you the Rotex engine is a lot more complex than a A65/C85/0200. Inspection for these older aircraft is not that complex either .http://eaa.org/news/2014/2014-04-02_repairman-lsa-inspection-course-slated-after-airventure.asp


Rotex engines are not more complex then something like an a-65 or something. Less moving parts in a rotex engine unless you start counting every needle bearing then the part count goes up. The thing about two strokes, the smallest air leak will ruin a two stroke because of running it lean. Nothing complex about a two stroke. No valves or cam or a lot of other things like mags, impulse couplers, and a host of other things in a 4 stroke. A 4 stroke is way more compex then a two stroke. It just takes a lot less to kill a two stroke engine, a 4 stroke shrugs it off or just shakes it off and keeps on purring.

Tony

[Matt Gonitzke]

I think he's referring to the Rotax 4-strokes, the 912 and 914, which are definitely more complicated than the small 4-cyl. Continentals.

[1600vw]

I think he's referring to the Rotax 4-strokes, the 912 and 914, which are definitely more complicated than the small 4-cyl. Continentals.

When someone says Rotax I think two strokes. I have no idea why. But you are so correct. The 912, 914 are some very complicated engines. I do like them but one reason I would prefer an a-65,75,85 over a 912. The cost of running a 912,914 compared to a 65-85 is so high per hr. I would never own a 912,914. Its so much easier to find someone who knows how to work on a continental compared to a rotax 4 stroke. So the cons out weigh the pros when it comes to owning a rotax 4 stroke, for me anyway.

But this is another story, back to regular programing....

Tony

[scott f]

So why don't we have something like this for the older 'classic' type aircraft like Champs, J-4, Taylorcrafts, etc. I can tell you the Rotex engine is a lot more complex than a A65/C85/0200. Inspection for these older aircraft is not that complex either .http://eaa.org/news/2014/2014-04-02_repairman-lsa-inspection-course-slated-after-airventure.asp

Hi Mike

That is what we are trying to do here. The ANV rec would apply to the all the airplanes you listed and would allow you to do all your MX (except for the annual) by taking a class similar to the LSA mechanic class.

[Mike Berg]

I was speaking of the 912/914 Rotex. I have a friend who owns a RV12 and that is a fairly complex aircraft.....airframe and engine. On the other hand, Champ, Chiefs, Taylorcrafts, "J series Pipers" with the A65/C85/0200A etc. are very simple. I've rebuilt three Champs and am presently rebuilding a Chief. I simply don't understand why I need a A&P to do the yearly condition inspection when I likely have a lot more experience with tube and fabric and wooden spars. At my age I don't have a problem putting the plane into the experimental category as it's probably the last one I'll own anyway. Let me take a course and let me sign it off. After all...I own it. Maybe if it was a Bonanza or Baron it might be different.

[1600vw]

I was speaking of the 912/914 Rotex. I have a friend who owns a RV12 and that is a fairly complex aircraft.....airframe and engine. On the other hand, Champ, Chiefs, Taylorcrafts, "J series Pipers" with the A65/C85/0200A etc. are very simple. I've rebuilt three Champs and am presently rebuilding a Chief. I simply don't understand why I need a A&P to do the yearly condition inspection when I likely have a lot more experience with tube and fabric and wooden spars. At my age I don't have a problem putting the plane into the experimental category as it's probably the last one I'll own anyway. Let me take a course and let me sign it off. After all...I own it. Maybe if it was a Bonanza or Baron it might be different.

:thumbsup:

[scott f]

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

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

Ray

Ray

This is same as the experimental yearly condition inspection i.e. inspected per the scope and detail of 43 appendix d and found to be in condition for safe operation.

The only unique additions to the logbook requirements is the need for the owner to document all alterations that are not FAA approved, the status of all ADs and a list of all non-approved parts installed. This is obviously to facilitate the conversion back to normal category should the owner choose to do so.

scott

[Paul@Flightline.tv]

I like Ted K, work the Hill in my day job (or is it moonlight as I am a pilot who lobbies for my union). I hope I can help shed some light on where to work on this issue.

As Ted K and Scott F have pointed out the FAA is not pleased with the findings of this ARC and are giving hints they aren't going to move on this ANV proposal. Forums are great for banter and venting but not really great at finding solutions and directing actions. Let's see if we can direct the energy of the keyboard in front of you to move this proposal forward.

We all need to find out where our alphabet groups are on this. If EAA and AOPA make this a priority it can start moving forward. Mac's column was great but does the Governmental Affairs team have any idea this is a priority and that the members want a legislative solution to this problem? You need to write, email, and call your organizations and ask where they are and what they are doing regarding this proposal legislatively? If the answer is nothing; ask them to draft legislation as it is a priority to you to have the ARC's findings enacted.

We have intent in the SARA and existing legislation but it needs to be refined to drive this outcome. That is a very good place to start and we are miles ahead with this in place. EAA or AOPA lobbyists should be able to find a sympathetic ear on the Hill. My guess is Sam Graves (R-MO) would be a good fit and is a huge supporter of GA. Collin Peterson (D-MN) is another likely supporter (Bonanza owner). If their offices can introduce the legislation it will then get kicked to the House Aviation sub-committee. Graves is there so he can speak to it and the Chair LoBiondo is a GA backer also (400 Cessna guy I think). If it gets through committee it then goes to the floor for a vote and on to the Senate.

The Senate is a bit of a chocolate mess (insert your political views and frustrations here) and finding sympathetic offices to run with this might be tough. I would look to the Small Aircraft Revitalization leadership for this. Your alphabet guys should get this and will drive it along.

EAA and AOPA have good people on the Hill, I just wish there were more of them. I think both groups spend too much time and effort being a bank and a insurance company and not enough on legislative affairs, but that is my opinion as a long standing member of both groups. What they need is grassroots support and active and involved members that can call and write in support of the work they do. I am making a call to both tomorrow and asking where they are on this issue as I am an owner of an aircraft that would take advantage of this program. I hope you do the same.

EAA Governmental Affairs (govt@eaa.org)

AOPA Regulatory Policy 800/872-2672

[scott f]

Paul

Well said - like anything else, if people want this they are going to have to make it known. Has anyone contacted EAA / AOPA yet and willing to share the conversation?

[TedK]

Paul

Well said - like anything else, if people want this they are going to have to make it known. Has anyone contacted EAA / AOPA yet and willing to share the conversation?

I spoke with EAA yesterday. They indicated that they are certainly for the ANV/PNC portion of the ARC Recommendations but have not yet crystallized their engagement strategy.

IMO there are several issues at play and the various organizations are trying to figure out how to spend their political capital.

i think GAMA is after the Part 23 changes. EAA and AOPA appear focused on the DL Medical. Unless we make a strong demand for ANV/PNC it may be lost in the churn.

i doubt AOPA will expend much effort on ANV/PNC. I think the effort needs to come from EAA and the AEA.

BOTTOM LINE: contact EAA ADVOCACY at govt@eaa.org or tel:920-426-6522 (tel:920-426-6522). Let's demand a forum on this at Airventure.

[scott f]

Interesting article on AVWEB that talks about ANV proposal. The podcast has more discussion than the article and Greg Bowles from GAMA had some nice things to say about it. Thanks Greg!

http://www.avweb.com/avwebflash/news/GAMA-Panthera-C4-Benefit-from-Reg-Revision221866-1.html

[Planeguy]

Howdy all,


Late to the party as usual... I have been following this PNC with much interest. I am quite disheartened to hear that the FAA is not interested in helping to sustain GA. After all when GA fails they will loose many jobs.


I was quite invigorated when I initially read the ARC. The verbiage that the author used was in my opinion revolutionary. It would seem that the proposed regulatory changes would be relatively easy to enact. It's the shift in attitude however that may prove difficult.


As the owner and restorer of a vintage twin I find that the PNC (or ANV) would be a great way to revitalize a dwindling type. I have high hopes for its implementation.


Admittedly, I have had some huge swings from glee to total dismay with the varying news I'm getting. I have spoken with several inspectors I know in the KC area. They all claim to have made contribution to the ARC in some form or fashion over the last several years. Though none of them are working on implementation currently they all agree that the PNC is part of the ARC and not a stand alone addition. They also state that it would be uncommon for part of an ARC to be excluded.


Scott, do you (or anyone else for that matter) have specific information indicating that the PNC is being excluded from enactment? I know that we tend to vilify the FAA and doubt there intentions but, is there solid proof or are we operating on doubt alone here?


If my interpretation is correct then the FAA is required by law to implement the entire ARC with no exceptions.




Pg

[scott f]

Pg

You are not late PG, I hope (and somewhat fear) this is just the beginning here.


See TedK's post above, it is the best advice on how to proceed that I have seen and I am sure that EAA government advocacy will be happy to answer all your questions.