Primary Category

[cliffy]

On 1/27/2020 at 6:08 AM, 1964-M20E said:

(i) Is unpowered; is an airplane powered by a single, naturally aspirated engine with a 61-knot or less Vso stall speed as determined under part 23 of this chapter; or is a rotorcraft with a 6-pound per square foot main rotor disc loading limitation, under sea level standard day conditions;

I wonder about our CAR-3 certification instead of Part 23

[Flybeech21]

https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_21-37.pdf

 

This is a rather old advisory circular on the issue...

[carusoam]

That’s a lot of legaleeaze to find out you would still need to be rated as a mechanic to do the mechanic’s job...

Got anything from this century?

Unfortunately, it looks like you may have been given some odd advice...?
 

The document seems to outline writing a new Type Certificate for a plane...  I was unable to determine if you could trade in the one you have to obtain a different one...

I’m not qualified to give an opinion on the proposal, but the part I cut and pasted below keeps me from being any too interested in following along...

“The 12-month annual inspection required by§ 91.409(a) is required for primary category aircraft that have been issued an airworthiness certificate under§ 21.184. In addition, the 100-hour inspection required by§ 91.409(b) is required if the aircraft is used for rental or flight instruction. Pilot-owners that do not also hold airframe and powerplant mechanic ratings and/or inspection authorizations are not authorized to perform the inspections.“

 

Are you seeing something different and interesting?

What is this category trying to do that is different than the known categories?

It looks like it proposes special rules for four seat planes, under a certain weight limit...

But the rules don’t seem to be similar to the experimental rules for the builder...

PP thought only, out on a limb with no Legal training... 

Best regards,

-a-

[cferr59]

Guess you still would need to do an annual just like a normal category aircraft.  However, would would gain additional maintenance ability if you got the training specified in 21.163.  Is that training even available for a Mooney?  I've never seen it...  Also, it seems like a Mooney might not really be a "simple design" considering it is specifically a "complex" aircraft.

 

[1964-M20E]

It looks like it s doable for our aircraft but I'm not sure how much is gained.  There are some additional maintenance  items that can be done by the pilot owner above our current preventive maintenance.  It does say the owner pilot cannot change radios if wiring is involved.

It really does not say anything about making changes such as electronic ignition or other major changes that do not already have an STC associated with them.

A question for those who have an experimental aircraft.  If you wanted to do what is classified as a major change for certificated aircraft do you have to file a form 337 with the FAA when you do it or just log book entry?  I would think just log book entry.

 

 

 

 

[Flybeech21]

So I just verified with the local FSDO that I can indeed cross over to the primary category with the Mooney M20E through the STC process.  I intend to do it and I'll keep you guys informed of how the process goes.  

[carusoam]

Let us know early if things are looking as expected...

It may take years to come across any road blocks... unless you call a branch of the FAA to ask ‘goofy’ questions...

Sounds like visiting the FSDO often with goofy questions up front would test the waters pretty quickly...

Does an STC exist already for this? Or are you writing one yourself?

PP thoughts only, no familiarity with the primary category...

Best regards,

-a-

[Flybeech21]

On 1/29/2020 at 4:19 AM, cliffy said:

I wonder about our CAR-3 certification instead of Part 23

I mentioned this on the phone call to the local FSDO AMI that I am going to be working with on this.  He said it does not matter.

So, I see why people don't do it now.  The STC process is very intimidating.  

 

[tigers2007]

I just read through AC 21-37 and I found a significant contradiction.

"The notice proposed to permit pilot-owners of primary category aircraft to do certain maintenance procedures, including inspections, on their own aircraft after receiving the appropriate training. The notice also proposed to permit the conversion of aircraft that are within the primary category engine and weight limits from standard category to primary category."

Then I see:

"Pilot-owners that do not also hold airframe and powerplant mechanic ratings and/or inspection authorizations are not authorized to perform the inspections."

?????  Granted, the jargon regarding the pilot-owner performing the inspection was in the Background section that discussed the proposed application.

Apparently there is a training requirement:

"Only a properly qualified pilot-owner may perform the additional preventive maintenance items listed in the preventive maintenance program. To be properly qualified, a pilot-owner must successfully complete an FAA-approved course given by either an FAA-approved aviation maintenance technician school, by the holder of the production certificate for the pilot-owner's aircraft, or by another entity approved by the Administrator."

So getting your A&P might be a stipulation?

One page one, they do note:

"While these guidelines are not mandatory, they are derived from extensive Federal Aviation Administration (FAA) and industry experience in determining compliance with the pertinent regulations."

The AC is only 13 pages. Maybe one of our Doctors of Jurisprudence can do a cursory review and opine?

[tigers2007]

After doing some perusing, the Primary Category discussion has been raging for a long time. Apparently at least one person started up a 24-hour training program to coincide with the FAA's advice. https://web.archive.org/web/20041129112111/http://www.topcatschool.com/  (It is apparently defunct).

Allegedly, attending the TOPCAT course would allow you to get an STC on yourself. Sounds weird but apparently it would allow the owner to work on certain aircraft they own. The TOPCAT STC's apparently were only for the C150/152 and the C172. The course sounds it had oddities including the attendee to actually fly their aircraft TO the training location in Dallas TX and then they would perform actual work on their own aircraft such as R&R the starter etc. Apparently the STC's had a defined list of allowable activities similar to what is listed in the AC (replacing the vacuum pump, installing quick drains, etc.)

This is very akin to the Light Sport Repairman training. I am attending a 16-hour LS Repairman class next weekend in Louisville, KY. It will allow me to perform the annual inspection on any E-LSA I own (anyone can perform maintenance on an Experimental). Also, any S-LSA can be converted to E-LSA with the approval of a DAR.

[Flybeech21]

2 hours ago, tigers2007 said:

I just read through AC 21-37 and I found a significant contradiction.

"The notice proposed to permit pilot-owners of primary category aircraft to do certain maintenance procedures, including inspections, on their own aircraft after receiving the appropriate training. The notice also proposed to permit the conversion of aircraft that are within the primary category engine and weight limits from standard category to primary category."

Then I see:

"Pilot-owners that do not also hold airframe and powerplant mechanic ratings and/or inspection authorizations are not authorized to perform the inspections."

?????  Granted, the jargon regarding the pilot-owner performing the inspection was in the Background section that discussed the proposed application.

Apparently there is a training requirement:

"Only a properly qualified pilot-owner may perform the additional preventive maintenance items listed in the preventive maintenance program. To be properly qualified, a pilot-owner must successfully complete an FAA-approved course given by either an FAA-approved aviation maintenance technician school, by the holder of the production certificate for the pilot-owner's aircraft, or by another entity approved by the Administrator."

So getting your A&P might be a stipulation?

One page one, they do note:

"While these guidelines are not mandatory, they are derived from extensive Federal Aviation Administration (FAA) and industry experience in determining compliance with the pertinent regulations."

The AC is only 13 pages. Maybe one of our Doctors of Jurisprudence can do a cursory review and opine?

From what I read, the A&P certificate is required if you plan on using the airplane for instruction/rental.  At least for the required inspections.

[cferr59]

On 2/16/2020 at 11:53 AM, tigers2007 said:

After doing some perusing, the Primary Category discussion has been raging for a long time. Apparently at least one person started up a 24-hour training program to coincide with the FAA's advice. https://web.archive.org/web/20041129112111/http://www.topcatschool.com/  (It is apparently defunct).

Allegedly, attending the TOPCAT course would allow you to get an STC on yourself. Sounds weird but apparently it would allow the owner to work on certain aircraft they own. The TOPCAT STC's apparently were only for the C150/152 and the C172. The course sounds it had oddities including the attendee to actually fly their aircraft TO the training location in Dallas TX and then they would perform actual work on their own aircraft such as R&R the starter etc. Apparently the STC's had a defined list of allowable activities similar to what is listed in the AC (replacing the vacuum pump, installing quick drains, etc.)

This is very akin to the Light Sport Repairman training. I am attending a 16-hour LS Repairman class next weekend in Louisville, KY. It will allow me to perform the annual inspection on any E-LSA I own (anyone can perform maintenance on an Experimental). Also, any S-LSA can be converted to E-LSA with the approval of a DAR.

I found a post on the Cessna 152 forum with a quote from the owner of TopCat.  It is from 2006 so it sounds like the project may not have been revived, but it might be worth reaching out to Rick.  Maybe he could be convinced to hold a course for Mooney owners...

https://www.cessna150152.com/forum/ubbthreads.php/topics/38447/5.html

Thanks for your email. Please allow me to tell you a short story. Several months ago the hangar that I used at Hicks Airfield was sold, and the new owner and I couldn?t work out a good agreement for TOPCAT School?s continued use of the facility. At about the same time Tarrant County College (TCC) asked me to work on a National Science Foundation (NSF) project that they were the lead college on. TCC is the community college that serves Fort Worth, Texas and the surrounding area. TCC has an A&P program that is 36 years old and is, according to the FAA, the highest rated A&P program in the state. The NSF project was to be known as the National Center for Aircraft Technician Training (NCATT). It was a great opportunity and I agreed to work on the project. I became the project?s ?Business Liaison?, the project?s ?Grant Writer? and ?Coordinator of Special Projects, Aeronautical Technology Department?. The proposal that I submitted to NSF was selected and funded by the NSF. I then became, and am, the ?National Director of Accreditation and Certification? for NCATT. As you might suspect, I?ve been busy. If you?re interested take a look at the NCATT website at www.ncatt.org [ncatt.org], it?s a continuing work in progress.

Back to what both of us are interested in, TOPCAT School. I?ve never abandon the project. Having had a long association with TCC (from 1980 to the present) I suspected that I might be able to work out an agreement with TCC through which the TOPCAT School Program could come back into existence. I'm in the process of developing that partnership agreement now. When the details are worked out I'll be able to use the classrooms, laboratory and equipment (training aids) that we use in the college?s A&P program. It will be the same equipment that we train A&P mechanics on. It will make the TOPCAT School program a lot better, and we won't have to worry about breaking "real" airplanes in the training process. It also means that owners won?t have to fly their airplanes from all over the country. It also means that the program should cost several hundred dollars less. The down side is it will cover only the owner training. The owner will still have to contact their local FAA office to convert their airplane to the ?Primary Category?, but with the training completed, ?Certificate of Competency? issued and signed-off, and the STC and instructions from the Fort Worth FAA FSDO to the owner?s FAA FSDO providing instructions on that process in hand, the owner will be in good shape.

 

[Flybeech21]

This was the FAA's first attempt to offer relief to certificated aircraft operators prior to LSA.  That is why the training program is there.  

I am an A&P/IA and this avenue is perfect for mechanic/Owners.

Edited March 1, 2020 by Flybeech21

[Flybeech21]

On 1/29/2020 at 4:19 AM, cliffy said:

I wonder about our CAR-3 certification instead of Part 23

Of the two instances I know that this process has happened, both were CAR-3 airplanes.

[Flybeech21]

A little update on how things are going.

A friend of mine is in the final stages of getting another one of his airplanes placed in the Primary Category.  He has one already.

The ACO he is dealing with told him: "we don't do that anymore" and basically refused to do the Primary category cert.  He insisted that the process exists in Federal Regulations and that they can't decide to not do it.  After some back and forth, they agreed to do it and are now finalizing.

So, yes this is a viable option.  It was the FAA's first attempt to ease financial burden for general aviation.  It didn't take off because of the training requirement for owners to do preventive maintenance that exceeds what is defined in part 43.  

 

 

 

[cliffy]

This still leaves the Training Requirements for the pilot/owner and the Annual Inspection by a certified A&P in place.

The only real advantage I can see is the expanded Preventive Maintenance section allowed to be done by the TRAINED owner/pilot.

Or an I missing something here?  

[Flybeech21]

24 minutes ago, cliffy said:

This still leaves the Training Requirements for the pilot/owner and the Annual Inspection by a certified A&P in place.

The only real advantage I can see is the expanded Preventive Maintenance section allowed to be done by the TRAINED owner/pilot.

Or an I missing something here?  

Correct.  But your Mods no longer need an STC.  Non-Certified Avionics and instruments are a go.  EDM-350 vs. certified GEMs are a good comparison.  I personally am doing it for avionics purposes.  

My next question is going to be insurance.  I haven't asked them what they think about this yet.

[cliffy]

OK I'm willing to learn-  where do you find that electronics is anything different than that required under Normal category?

I've read the AC and only see where radios can be changed IF wiring changes are not needed. 

[Flybeech21]

11 hours ago, cliffy said:

OK I'm willing to learn-  where do you find that electronics is anything different than that required under Normal category?

I've read the AC and only see where radios can be changed IF wiring changes are not needed. 

You are reading the preventive maintenance section.  The airworthiness standards/limitations that will be followed are submitted by the owner and reviewed by the FAA via the STC process.   There will be an excerpt in my standards giving me relief from TSO'd Avionics and allowing non-certified radio equipment.    

[Raptor05121]

Why isnt this a bigger thing? You should document your process and submit to AOPA/EAA/etc to get put in magazines

[steingar]

This is a disaster in the making.  One thing I like about myself, I suck at wrenching and I know it.  I also know  LOT of guys who suck just as badly as I do but think they're Odin's gift to mechanics.  Guys like that are going to wreck airplanes, and either die in them or kill the pilots who purchase them.  Mark my words, this is going to end in blood.

[gsxrpilot]

57 minutes ago, steingar said:

This is a disaster in the making.  One thing I like about myself, I suck at wrenching and I know it.  I also know  LOT of guys who suck just as badly as I do but think they're Odin's gift to mechanics.  Guys like that are going to wreck airplanes, and either die in them or kill the pilots who purchase them.  Mark my words, this is going to end in blood.

This has been going on for many years in the Experimental world and hasn't be a problem. 

[Ragsf15e]

I think it’s a disaster as well, but not for the same reason... taking a 50+ year old certified airplane and changing its category, maintenance practices, and equipment certification begs an insurance, regulatory and maintenance disaster for the current owner, future owners and/or both. 

In the end, this is going to cost you or someone else more $$ to fix than it would cost to just use certified parts and do work yourself under A&P supervision.

[cliffy]

We kinda opened a can of worms here for me. I'll admit I'm old and crotchety I've been at this business of flying for 55+ years and I've seen a lot of my friends die in airplanes so excuse me if I try to "educate" a few with words.  "Its NOT personal, Its just business" as the Mafia used to say in my day>

Primary Category may be a golden opportunity to salvage our old airframes and make things SAFER than they would be otherwise. Think about it- advances in electronics to make things safer moves at light speed while the FAA revision of decades old regulations moves at a glacial pace in comparison.   Good safe proven equipment is available at a  reasonable price for our airplanes if we could use it but the draconian regulations prevent it'

We now fly 50+ year old airplanes. How many of us drive 50+ year old cars ?  Time marches on. Where are we going to be in another 20  or 30 years at this pace? Still sitting with KX-170 radios and vacuum gyros in 75 year old airplanes? We will if things don't change and change relativity quickly.

(Look at the industry as a whole. We have  new Certified airplanes,  Sport airplanes, Ultralights, Experimentals and more and we have our OLD LEGACY airplanes. Where's the money going? NOT to our segment is it? Other than the newly built airplanes our segment is in a stalemate with a constantly diminishing supply of old airframes,  forced to remain with old radios or install new stuff well in excess of the value of our airplanes. We're basically an orphan industry. )

Maintenance will remain relatively the same as it always was in terms of quality because part of the process to convert to Primary and to expand what the owner/pilot is allowed to do on the maintenance side requires professional training in the areas sought BEFORE the owner/pilot can perform those items. AND, the ANNUAL INSPECTION still has to be done by a certified A&P.   

Now (and here's MY big issue) think back even to this last month or two on this site to how many times we have seen questions asked about "how do I change my oil",  how do I get the sump screen out". how do I jack my airplane", "I want to pull out my landing gear and disassemble it and paint it", "how do I do this or that", "how do I change my vacuum pump"? and more. It goes on and on with questions on how to do maintenance asked by what appears to be less then knowledgeable or trained owners which begs the question are they legal with respect to be doing what they are asking us to tell them how to do? 

BTW, do WE as licensed A&Ps have any legal  exposure when we tell someone that we are NOT monitoring how to do some maintenance procedure that requires an A&P to sign off?

Anyone with a modicum of maintenance history can figure out most of this stuff even if they are not a licensed A&P (not legal but they could figure it out as it ain't exactly rocket science in the mechanical world.)  How safe is this? Please tell me!  I try to be "gentle" with my responses here but there is a limit. I have seen (as many of the working A&Ps here have seen) things done to airplanes by well meaning owners that just defy common sense.   

Now a few do mention that they are having their A&P look over their shoulders but not many even venture there. 

At least with the training required by the Primary Category some of the "preventive" maintenance expanded will be done properly. 

Now to the other side of the equation- electronics. We have BIG leaps and bounds in electronics that would salvage our OLD OLD airframes if we could use it. The airframe itself can be kept up to standards very easily by good maintenance but we can't do much about 50 year old radios if they won't let us.  If Primary category will allow the use of the same types of electronics as we allow in Experimental aviation then I'm all for it. I even postulated years ago right here that there is no sane reason why we can't have a "Maintained by Certified Mechanics" airframe and "Experimental " world electronics. It defies common sense that one world is safe with it and the other is not. Experimental airplanes are not falling out of the sky because of non-certified electronics!!!!!!!!!!!

Think maybe of how much more good maintenance could be done on the airframe if the owners didn't have to shave every last penny just to get a reliable panel? 

As to the resale of Primary Airplanes? I don't think in the long run it will have much effect, The airframe is still maintained by "Certified" means and standards and only the instrument package is less than FAA certified and as almost all of the legacy airplanes don't do heavy IFR or charter it may be of a moot point.  AND how much old radio stuff is actually working in the panels its mounted in? 

I'm following this thread closely to see if it comes to fruition for as to the way most of us fly our airplanes, it would be a big improvement. . 

 

[Hank]

47 minutes ago, cliffy said:

Now a few do mention that they are having their A&P look over their shoulders but not many even venture there. 

At least with the training required by the Primary Category some of the "preventive" maintenance expanded will be done properly.

I've had licensed, current IAs do things to my Mooney that defy description!

• one genius replaced my control rod ends after I asked him not to because he didn't have travel boards, and I didn't like his "method" of measuring carefully before removing the old ones . . . My follow-up visit to an MSC to fix things found the elevator only gave 15º Up, while it went off-scale in Down. It's supposed to be 20º ± 3º in both directions.
• A freshly-certified IA couldn't figure out how to crank my plane  , because just turning the key didn't do it, and he'd never seen one that needed to be pushed. Didn't  read the placard on the panel at the keyhole, didn't bother looking at my checklist on the passenger seat, didn't think to look for the Owners Manual that is required to be in the plane when I flew it to him. Instead he spent a half-hour "figuring it out." He coulda called me . . . 
• Then there's the genius who adjusted my nose gear doors, because he didn't like how they closed. Never thought to jack the plane up and raise the gear. The MSC said that i was lucky the gear extended for my landing there, as it was binding on the door. I thought A&Ps weren't supposed to do work that they had not done before?

My whoel problem with the Primary category is that it still requires me to either go to A&P school or log a couple thousand hours working under supervision before I can do anything beyond the current owner-approved maintenance. That's a burden that few owners with jobs will ever be able to meet . . . . .