New Idea from the Feds on "experimental" parts

[cliffy]

I saw a short commentary (I think it was on the AOPA website and at OSH) about the Feds talking about something new for "legacy" airplanes called a "Special Airworthiness Certificate" to allow the installation of what are now unapproved parts (avionics)?  One would turn in their current airworthiness certificate in exchange for this one. It would allow as noted what are now unapproved parts and maybe allow the owners to do the maintenance much like experimental aircraft owners do now. Maybe a special repairman's certificate (just speculating on that one). 

Limitations, as mentioned, might be nothing outside of the USA, no Canada or Mexico but I feel that might not be a restriction in the future, 

I can't find where I saw it but I'll keep looking. As I said, I think it was one one of my AOPA emails like the weekly update or something.  

[N9405V]

This would be great, but I wouldn’t hold my breath. This idea makes too much good sense for a federal agency to adopt it.


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[steingar]

I think they have had such a system in Canada for some time.

[0TreeLemur]

Seems infinitely sensible, given that parts availability for our our "legacy" aircraft is becoming limited by dwindling demand...   Keeping a relic "certified" in the same category as a new aircraft seems unlikely.   I might hope they pull it off.   At least until I understand what the reaction of the insurance industry might be to such a change...   If it goes the wrong way, it might mean that "certified" parts become unavailable such aircraft in this new category.

[bob865]

I was under the impression that you could already exchange a certified airworthiness certificate for an experimental.  What would be the benefit for what sounds like an "in between" certificate?

[jetdriven]

That’s not true. You can get an experimental for air show exhibition are for testing and modification for an STC but usually this requires you to return it back to a normal category of airworthiness after a period of time. You can’t just stick experimental on it and go on though

[Yetti]

16 minutes ago, jetdriven said:

That’s not true. You can get an experimental for air show exhibition are for testing and modification for an STC but usually this requires you to return it back to a normal category of airworthiness after a period of time. You can’t just stick experimental on it and go on though

And while experimental they take away passenger carrying and such.   Just depends.

It would only help somewhat in the electronics since there are other regs ADSB that set the standard.   But then it might narrow the gap of all the experimental planes with experimental ADSB sets that are not available for certified planes.

[bradp]

Can you not currently fly EA-B to Canada/Mexico?  What would be the reasoning for this restriction.  

[Niko182]

1 minute ago, bradp said:

Can you not currently fly EA-B to Canada/Mexico?  What would be the reasoning for this restriction.  

Im pretty sure you can fly into both in an experimental.

[bradp]

Just now, Niko182 said:

Im pretty sure you can fly into both in an experimental.

Right which would make a restriction on “legacy aircraft” arbitrary.   

[Guest]

From the COPA site concerning Owner Maintenance category.

https://copanational.org/en/owner-maintenance/

[DMM]

EAA had a write-up summarizing the FAA administrator's remarks about the Modernization of Special Airworthiness Certificates (MOSAIC) Rulemaking Package. Nothing written in stone yet but article included the following tidbit:    "Finally, Elwell announced a very exciting prospect for the legacy fleet.  For older aircraft not being used for commercial purposes, owners will be able to exchange the standard airworthiness certificate for a special airworthiness certificate — similar to certificates held by experimental aircraft. "That means the owner will be able to install lower-cost, safety-enhancing equipment — the kind that is widely available for the experimental market — without an STC or 337."

[NJMac]

EAA had a write-up summarizing the FAA administrator's remarks about the Modernization of Special Airworthiness Certificates (MOSAIC) Rulemaking Package. Nothing written in stone yet but article included the following tidbit:    "Finally, Elwell announced a very exciting prospect for the legacy fleet.  For older aircraft not being used for commercial purposes, owners will be able to exchange the standard airworthiness certificate for a special airworthiness certificate — similar to certificates held by experimental aircraft. "That means the owner will be able to install lower-cost, safety-enhancing equipment — the kind that is widely available for the experimental market — without an STC or 337."

The insurance is a consideration but provided that has no factor, I would do it

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[Hank]

1 hour ago, DMM said:

EAA had a write-up summarizing the FAA administrator's remarks about the Modernization of Special Airworthiness Certificates (MOSAIC) Rulemaking Package. Nothing written in stone yet but article included the following tidbit:    "Finally, Elwell announced a very exciting prospect for the legacy fleet.  For older aircraft not being used for commercial purposes, owners will be able to exchange the standard airworthiness certificate for a special airworthiness certificate — similar to certificates held by experimental aircraft. "That means the owner will be able to install lower-cost, safety-enhancing equipment — the kind that is widely available for the experimental market — without an STC or 337."

That's what they said during the Part 23 rewrite before they dropped the idea.

[RobertGary1]

Just being able to do routine maintenance on your plane without spending 2 years studying jet engines, pressurization systems and deicing would be great. 

I’ve long advocated for a private a&p program not for hire with restricted authorization ( ie change a mag but not overhaul an engine)  

Also saves a couple grand on every Garmin panel toy. I guess that means it won’t happen. 

-Robert 

[Sandman993]

42 minutes ago, RobertGary1 said:

Just being able to do routine maintenance on your plane without spending 2 years studying jet engines, pressurization systems and deicing would be great. 

I’ve long advocated for a private a&p program not for hire with restricted authorization ( ie change a mag but not overhaul an engine)  

Also saves a couple grand on every Garmin panel toy. I guess that means it won’t happen. 

-Robert 

Typically, if you have to ask... the answer is NO

[Sandman993]

There was a kid that had parents that worked for the faa... he was 15 before he figured out his name wasn’t “No”.

[Tom]

Indeed this was previously designated as the Primary Non-Commercial (PNC) initiative that was to be part of the Part 23 re-write, though PNC wasn't incorporated (~2017).  Googling the PNC subject can find previous discussions on what it entails.

Incidentally I was on the phone with AOPA earlier today regarding the complete evaporation of independent A&P/IAs on my field caused by onerous insurance requirements from the city.  This 'insurance requirement lack of maintenance providers' issue is a huge problem in several areas around the country yet I've seen nothing from AOPA whatsoever on the subject.  And of course AOPA has long been in bed with the insurance people to make ends meet.

It's known that PNC will come out sooner or later easing the burden a little bit in the maintenance provider department (with owners allowed to do certain maintenance and use whatever parts/mods), but the little-guy commercial operators who have to turn to the palatial FBOs for maintenance are getting screwed out of existence.  Otherwise probably not a good time in history to invest heavily in STCs that PNC aircraft can do without the STC.  FWIW.

[Austintatious]

I don't know if this is a great idea or a horrible one.

Insurance wise, there is no telling.  I think they like to use every excuse they can muster to increase rates.  For their perspective there is absolutely no reason the rates should go down! "Ohh now you are putting non certified stuff in those things!  that is less safe!"

What would that do to value?  Looking at the used kit/home built market I really cant imagine.  I suspect that aircraft that have been kept to the same certified standard would be worth more on the used market and those who had gone down the road of non certified will likely be less.

I for one, would have HATED to been shopping for a Mooney in an environment like that.  It would have cut the options down as there is just no way I would be purchasing one that I know the owner had been doing unsupervised work on.   I OWN an experimental as well and I have seen what that results in!  Every single one that fell into this new category I would be looking at as a project.  A project of fixing all the mistakes and shortcuts the Previous owner did himself.

 

Here is what I dont get.  Why dont they require the same standard for the AIR FRAME and simply allow non certified instrumentation?  I mean if the non standard Instrumentation is good enough to fly IFR in a 200+ knot home built over all of the "general public".... then why is it not OK to do the same in a Certified air frame with proper mechanics looking after it?

[Tom]

16 minutes ago, Austintatious said:

Here is what I dont get.  Why dont they require the same standard for the AIR FRAME and simply allow non certified instrumentation?  I mean if the non standard Instrumentation is good enough to fly IFR in a 200+ knot home built over all of the "general public".... then why is it not OK to do the same in a Certified air frame with proper mechanics looking after it?

The above point made a lot of sense 10 years ago.  Now, with Dynon, the G5, and the STC'd experimental autopilots coming on the scene, there's practically no difference between an experimental panel and a certified panel (sure STC fee, but overall small in the larger scheme of things).  The big difference is who can/can't do the install.  If certified, you have to cough of $10-15k minimum for labor and wait months, no matter how much elbow grease you have.

A few weeks ago I paid $475 for 3 bushings (for a non-Mooney).  These parts would be <$10 from an auto parts store, will cost <$30 when PNC goes live.  I for one don't need help with panel options...I need help with all the nitnoid parts that have no business being "certified" in the first place.

[1964-M20E]

I think this would be great idea for people like me who are willing an able to turn wrenches.  I would do it in a heartbeat any loss of value on a 67 F model would be negligible.  One thing I would probably do pretty quickly is put E-mags on my plane.  Then evaluate the direction I want to go with my panel.

Keep in mind just because one would put a plane in this proposed new category doesn't mean you can't continue to put "certified" gadgets in the plane but it would allow you to install them yourself if so skilled and inclined to do it.

Yes you still want to do things to the FAA standards using aviation grade materials but allowing the owner to do more on his own would be good.

I would suggest that many owners who are confident in their skills already employ hangar fairies for many tasks.

Yes there would be some repercussions for flight schools and other commercial operators.  One large  (with 5 to 6 planes) local commercial operator here has his own mechanics on the payroll so IAs are not an issue for them. 

Finally, a shortage of certified mechanics under the current system is something I do worry about.  When the current mechanic on the filed decides to leave his tools in the toolbox and I am unable to find another willing to come to my hangar and I am forced to go elsewhere for an annual inspection the plane will arrive cleaned, greased, oil changed, plugs cleaned and gaped, engine washed, gear pre-loads checked and pre-inspected by me.  I already do this under my owner operator privileges anyway and knowing what is going on before dropping the plane off I know I should only be getting a bill for the annual inspection alone.

 

[McMooney]

keeping the 20k I've paid in labor in the last year would more than makeup for any loss in value of the aircraft

[cliffy]

3 hours ago, Austintatious said:

 

Here is what I dont get.  Why dont they require the same standard for the AIR FRAME and simply allow non certified instrumentation?  I mean if the non standard Instrumentation is good enough to fly IFR in a 200+ knot home built over all of the "general public".... then why is it not OK to do the same in a Certified air frame with proper mechanics looking after it?

I said exactly this years ago here. It makes sense. Airframe and engine certified and the rest open to discussion. 

[Hank]

6 hours ago, cliffy said:

I said exactly this years ago here. It makes sense. Airframe and engine certified and the rest open to discussion. 

They did! But to the Feds, our pitot tube & ASI are part of the airframe, and the OilT probe & gage is part of the engine . . . .

[steingar]

If they change the rules, it won' last long.  Perhaps there are folks who are willing and able, but there are plenty more who are willing, semi-able and convinced of their own expertise.  Aircraft will fall out of the sky.  Happens in the experimental world as it is, airplanes crashing because of builder mistakes. First time one hits the wrong thing on the ground (feel free to use the  more morbid parts of your imagination), gig's up.  Won't even matter if the aircraft was working perfectly, "it was maintained by an amateur, that's why it crashed!". Pilot could have been drunk and run out of gas, won't matter.