Pilot and air frame logging question.

[Frank Giger]

Yesterday was a unique window in the weather we've been having, and I took full advantage of it, making several hour and half hour flights during the day, all of it "local."

Others saw the same thing, so the normally deserted airport had a bunch of folks driving up, pulling open hangars and exposing their aircraft to sunlight. Heck, at one point there were four aircraft on the taxiway at the same time waiting on a fifth to land!

I kept track of each flight, including having my trusty tablet recording data for CloudAhoy.

At the end of the day I just put them all together by writing how many flights, how many landings, total duration of all the flights, and a smiley face in both the pilot's log and the air frame log.

Now, then, I'm not too worry about the Sky Cops coming to get me over this, but it does beg to question whether this is actually in the regs or not.

[DaleB]

I don't think you're actually required to log any of that, are you?

[Frank Giger]

Actually, since I'm in test phase, yep. Otherwise, how can I sign off when I've accomplished the forty?

But to be honest, I'm kind of in the dark on logging to begin with, so I just log everything.

[rwanttaja]

There's no requirement to log anything...except to comply with specific regulatory requirements. Examples:

- Currency requirement (3 TO/Landings in 90 days). Doesn't apply to you, since the requirement is for carrying passengers.

- Time required for a given rating. If you were going for a commercial license, for example, you need a logbook to show that you have the required minimum hours.

- Airframe/Engine hours to comply with ADs or other required services. Most doesn't apply to you, but like you said, there's the need to document the 40-hour test period.


Ron Wanttaja

[Frank Giger]

Pretty enlightening.

I like having a log of my flying time, to be honest. I can look back and see the comments I left (and I tend to be pithy or happy), and the memory of the flight is instantly triggered.

And having a track of all the maintenance is nice - every bit of work done on the air frame and engine is in there, so I can go back to see what I've done and need to keep an eye on.

Frank "Please, please, won't some FAA man ramp check me!" Giger

[Marc Zeitlin]

And having a track of all the maintenance is nice - every bit of work done on the air frame and engine is in there, so I can go back to see what I've done and need to keep an eye on.Logging aircraft flying time and logging maintenance are two different things. As Ron W. states, there's no requirement to log flights. I've seen a zillion EAB aircraft with no indication of flights - only a signoff at 40.3 hours that the Phase I test period was complete, blah, blah, blah. That's the only legal requirement, per the OL's. Is it good to keep a record of what you actually did on each flight, if for no other reason than that the guy you sell the plane to in 15 years will have some sense of security that you actually tested the damn thing and didn't just fly around in circles for 40 hours at mid-weight and mid-CG? Sure. And it's nice to look back on, because YOU won't remember it all, either.

But there IS a requirement for logging maintenance, although there are some who will argue with this (and have). 14 CFR Part 91.417:

https://www.law.cornell.edu/cfr/text/14/91.417

speaks to this issue, and although EAB aircraft are not subject to Part 43 requirements, they most certainly are subject to part 91 requirements, and there is no exemption from this requirement anywhere for EAB aircraft that anyone who believes it doesn't apply has ever been able to point me to. I've had informal discussions with the FAA's corporate legal department and they support this position (although they have not issued an official letter on the subject, so until they do, this is just my opinion).

So, log whatever you want for both yourself and for the airplane - totally up to you. Log what you ate for lunch while changing the oil, too, if you like. The only thing you HAVE to log for yourself is what Ron W. said.

And log 100% of any maintenance you do on the plane.

My $0.02.

[rwanttaja]

Agree wholeheartedly with Marc about logging what's done to the airplane. It's especially important when, like me, you purchased a homebuilt rather than building it. Once a year, I need to have an A&P examine the airplane for the Condition/Conditional/Giger inspection. If I did work that WASN'T logged, they might suspect I'm trying to hide something or am sloppy. So in goes everything.

Pilot log? Pish. Every two years, I make an entry (adding up time from a rough log I keep at the airport) noting my total time. CFI for the BFR wants to know.

Ron Wanttaja

[L16 Pilot]

Also, insurance companies usually want total time, time in type, last 90 days, etc. Anyway I pretty much log all my time.

[WLIU]

As noted above, there are different reasons for logging time. Since I carry insurance on my Pitts I need to tell the insurance company how many hours I flew each year. Helps with rates. And as a Pitts driver, I keep track of take-offs and landings. Some folks attach some weight to having logged over 1000 Pitts landings without scratching the airplane. And the FAA and CFI's attach some importance to whether you have done 3 in 90.

The airplanes that I fly generally have recording tachometers that track time. We use those for scheduling maintenance. Since oil changes are the most basic and important maintenance that is done to most airplanes, when I look at a new airplane's logs I look for those entries as an indication that the owner cared about maintenance. My eyes can look at the airframe and tell whether its been bent and/or repaired correctly.

Some aerobatic guys log spins as that is another number that some folks attach weight to. I have to confess that I gave that up once it got into three digits.

Logs tell a story. You can make each story as detailed or as vague as you like depending on what you want to accomplish.

Best of luck,

Wes

[rwanttaja]

My last two insurance renewals, they didn't ask any questions other than "Do you want to renew?" Of course, I just have liability.

I keep a "rough log" at the airport, and list every flight and the significant aspects (temperatures if extreme, fly-in attended, people seen, etc.). It's just a three-ring binder. It's what I use to tally my flight hours when I have to. My official personal logbook is at home. Somewhere. I transfer data to it from the rough log for BFRs and if an insuror ever asks.

Ron Wanttaja

[WLIU]

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

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

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

Best of luck,

Wes

[martymayes]

+But there IS a requirement for logging maintenance, although there are some who will argue with this (and have). 14 CFR Part 91.417:

https://www.law.cornell.edu/cfr/text/14/91.417

Since you cast out your crankbait, I'll bite: :)

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


there is no exemption from this requirement anywhere for EAB aircraft that anyone who believes it doesn't apply has ever been able to point me to. I've had informal discussions with the FAA's corporate legal department and they support this position (although they have not issued an official letter on the subject, so until they do, this is just my opinion).

Touché! Nor is there any evidence to conclusively support the opinion that EAB are bound by this reg. Not aware the FAA has a corporate legal department but being a branch of the US Gov. they do have an office of chief counsel that serves as the legal dept. From that office or any regional branch thereof, no chief counsel or deputy chief counsel opinion, no interpretive ruling. In addition, no record of enforcement action and/or civil case law finding fault for not logging EAB aircraft maintenance. EAB have been around a long time, you'd think something would have come up by now.


And log 100% of any maintenance you do on the plane

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

[Frank Giger]

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

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

Oh, and I wound up with a perfect 90 hours of total time as a pilot this last weekend. ;)

[martymayes]

Oh, and I wound up with a perfect 90 hours of total time as a pilot this last weekend. ;)



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

[Frank Giger]

Any more it seems like I need some wind, including a bit of a crosswind, to get a decent landing. :)

[Marc Zeitlin]

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

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


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


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


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

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


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

[Bill Berson]

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

[Marc Zeitlin]

Most of the routine maintenance records can be discarded after one year (91.417 (b)(1).True.

Most owners do not discard these records.Assuming they created them in the first place :-). About 1/2 of my customers keep all the records they should. Some barely have the CI signoffs :-).

[martymayes]

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

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

The reg has specific requirements for logging maintenance. Lets break it down:

The records must include -

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

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

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


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

[Marc Zeitlin]

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

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

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

[martymayes]

If they have one, put it in. If they don't, leave it out. I understand what you're saying - that you sometimes cannot comply, intrinsically, with ALL of the listed requirements. But that doesn't imply (to me) that if you can't comply with all of them, you're exempt from all of them.

"exempt" and "not in compliance" do not have the same meaning. Omitting a regulatory requirement would be "not in compliance"

I doubt the FAA intended a rule to be applicable if by default it can force one to be "not in compliance"


You comply with the ones that are possible to comply with given the rules of EAB aircraft, which allow your mom's dog to do the maintenance on the plane (and she probably doesn't have an FAA certificate # to list [the mom or the dog]).

Mom's dog would not be able to comply with any of the mutually inclusive requirements. So in that example, we just completely ignore sections (i), (ii), and (iii) and leave the log blank! Got it!! The dog does all my EAB maintenance! That's why there are no entries!

I've seen Chief Counsel Opinions result in unintended consequences, not in a good way. Sometimes it's best to let sleeping dogs lie. Not aware of a single violation being handed out over EAB maintenance records.

[FlyingRon]

I was kind of lacadasical about my logbook until I had the aircraft accident. Between the FAA and the insurance adjusters, I needed to total up my hours (both on the plane and me) and even provide the "last page" of the respective log books. Amusingly, while I had logged flights, I'd not computed "totals" since i went for my instrument rating over ten years ago.

Amusingly, when I totalled it up, I found I had just over 1000 hours. I backed up and found the flight that I busted 1000 on. It was flying with Snowbird 11 at Oshkosh.

[martymayes]

Insurance companies can get persnickety over logbooks, especially when a large loss payout is forthcoming. Nonetheless, I’ve seen them pay for a homebuilt loss despite having sketchy logs. They really only cared about the ‘conditional’ inspection. ;)

[Frank Giger]

Marty, don't get a ruling; this isn't broke, and so doesn't need fixing. But it would be helpful to get guidance.

Much like the guidance on best practices in building, which take the standards and regulations on Certified aircraft construction, I think we can apply the same with a large part of the logging.

We know, for example, that Condition Inspections are to be placed in the air frame logbook, with the precise magic words provided for us. I think that all the maintenance required to get it to that point needing to be logged sort of flows from that. Certainly it was relevant to include the wing spars and landing gear leg I replaced - as well as replacing the crankshaft and propellor on the engine - after I flipped my little Bebe into the air frame and engine logs.

I'll admit that not all maintenance goes into it, as a lot of it is super minor. Replacing tapes on the wires past the swags or a tire tube isn't worth the ink to write it down, IMHO.

I log flights into my air frame logbook because I've seen a lot of old logbooks from way back that had the same. I was just curious to see if A) other people did that (not many) and B) it's required (I'm getting that flights aren't).

I do think this would be a good article for Sport Aviation, that's for sure.

On insurance, as a low time Sport Pilot with an experimental still in test phase, the companies I asked quotes for were....interesting in their responses. One never, ever responded; I guess they thought it was a prank. Another would only give me quotes with hull and passenger insurance included, though I only asked for liability, and it was not encouraging; however, I did feel like I was sixteen all over again, but with Lamborghini instead of a '70 International Scout.

[FlyingRon]

We know, for example, that Condition Inspections are to be placed in the air frame logbook,
I know nothing of the sort. There's no requirement for a "logbook" let alone one separate for the airframe versus the engine or any other part. The requirement is just for it to be recorded in the "aircraft maintenance records." An airframe logbook is just a convenience for the owner.

[Bill Berson]

It's customary to log each flight for a glider because it doesn't have a tach hour meter. Airplanes with recording tach hour meters usually only log the total at each annual or condition inspection.
Now motorgliders accrue both engine time and glider time. My experience is most Motorglider owners don't log aircraft time.

[martymayes]

Marty, don't get a ruling; this isn't broke, and so doesn't need fixing. But it would be helpful to get guidance..

Guidance is how we got here! lol
I don’t plan to poke any dragons. Don’t care who is right, more concerned with what’s right.
EAB maint is essentially an unregulated activity. If authorized persons, content, form and disposition of records was regulated it would be included in the OL, along with the appropriate guidance like that for condition inspection.

[WLIU]

For a different perspective, in Canada, each aircraft has a technical log in which maintenance is recorded, and a journey log in which all flight time and the names of the pilot and passengers are recorded. My Pitts S-2A spent 25 years of its life in Canadian registration. The logs that came with my S-2A are an interesting read.

This is one area where the US rules are more permissive.

Best of luck,

Wes

[Frank Giger]

Ah, Marty, as an old soldier I'm more interesting in what's best rather than what's "right" when it comes to regulations and their application. :)

For example, the builder's log is pretty much whatever the builder makes it. It's just to show the FAA man that one is builder and that some sort of standard was held. It can be broad descriptions of text only, such as "built wings."

I took a piece of advice from my EAA brothers when they said to use it as more than just a document in ways that are probably well beyond what they meant. My dead simple straightforward tube and gusset held together with pop rivets fabric covered scale just-over-ultralight aircraft has a good three inches of builder's log with pictures and loads of text detailing how I did stuff, why I did it the way I did, and the problems I had trying it a different way.

It proved to be a godsend when I had to do extensive repairs, though. More than once I was staring at a bit of the wing I was putting back together and thought "what the heck?" and dug into the log to where I did that task and went "aha! So that's how I did it!"

Granted I came to aviation from a place of near total ignorance (I became a pilot because I wanted to build my own airplane, and built my airplane because I wanted to be a pilot - circular logic is my friend!), so I naturally bought the EAA Air Frame, Engine, and Prop logbooks and put stuff in them that I thought was relevant. Not really sure about that Propeller book - it seems unnecessary for a simple wooden prop, to be honest. But I bought one because, hey, they sell them and I have a propeller.