Average Annual Cost?

[Pinecone]

As I understand it, to do the Mooney 100 hour/annual checklist it takes about a total for 30 - 35 shop hours.  So if you are getting an annual for $1500, are they doing all that should be done?

Of course, owner assisted, even with simply the inspection panels remove and replace, can cut the cost.

[Skates97]

3 hours ago, MikeOH said:

@Skates97

$650 for the inspection!!  WOW!!  I've always done 'turn-key' annuals but now that I'm retired that price looks mighty attractive!

How many days/hours do you spend on 'owner assist' time?

I usually spend a Saturday plus a couple nights after work prior to the inspection so that everything is opened. lubed, etc. before he comes to inspect. After the inspection it depends on what if anything he wants done. Typically after the inspection it will be another night or two after work plus a Saturday. Probably somewhere around 40 hours of my time once all is said and done.

For me it's not about saving the money on the annual. I could pay to have everything done, (see my comment in another thread about the revocation of my CB Club Membership Card ) but I enjoy working on the plane and I also feel better knowing exactly what was done and how it was done.

[MikeOH]

59 minutes ago, PT20J said:

In our world, there is a shortage of A&Ps and most larger shops hire unlicensed mechanics to "work under supervision" while obtaining the experience necessary to get their certificate. You can bet that each unlicensed mechanic does not have a licensed one shadowing every move they make. This will get fixed. It's an unintended consequence of trying to stop a dumb idea.

BINGO!  I believe that was the conclusion reached in the Mike Bush video...and this should get fixed as it was likely an FAA lawyer with no practical experience issuing an unintended overreach.  I'm just concerned with what is going to happen in the mean time...apparently it took the FAA 26 months to respond to the initial FSDO inquiry with this memorandum!  Sure hope it doesn't take that long to fix this!

[MikeOH]

29 minutes ago, Pinecone said:

As I understand it, to do the Mooney 100 hour/annual checklist it takes about a total for 30 - 35 shop hours.  So if you are getting an annual for $1500, are they doing all that should be done?

Of course, owner assisted, even with simply the inspection panels remove and replace, can cut the cost.

Pretty sure that number is dependent upon which Mooney model.

Top Gun, whom I trust, charged 21.5 hours for my 1970 'F' model.

However, your point is well taken; I'd be suspicious of $1500 for a non-owner assist situation!

[N201MKTurbo]

I know the capabilities of everyone I work with. I will not assign them any tasks they are not competent to do. I always inspect the results of their work. The FAA doesn't have the manpower to watch me watching someone else work. The chance of the FAA discovering that you don't have your eyeballs on somebody are about as close to zero as your chance of winning the Power Ball.

[Hank]

The full Mooney Annual / 100 Hr checklist is generally 20-24 hours labor. No idea what the difference is for turbo or long body models.

The owner assist tasks that I used to do were

• remove inspection panels and cowl 
• Clean, gap and test spark plugs
• Grease landing gear
• Replaced inspection panels and cowl

Whether I did anything else depended on what else needed doing and how everything came along. Doing the little maintenance tasks let the IA handle all of the Inspection tasks. We replaced nose tire and tube together, which is different from auto work and more dangerous; I'm competent to do this myself now if needed. 

More importantly, I was there to look at things and monitor year-to-year changes, make decisions about fix this now or later, etc.

I miss it . . . . But my new IA doesn't allow it. Been with him for the last four annuals.

[N204TA]

Dugosh started doing flat-rate annuals a couple of years ago.  Current prices range between $2,080 and $2,890, depending on the model.  The price includes everything but parts, oil, and additional repairs.  

[MikeOH]

2 hours ago, N201MKTurbo said:

I know the capabilities of everyone I work with. I will not assign them any tasks they are not competent to do. I always inspect the results of their work. The FAA doesn't have the manpower to watch me watching someone else work. The chance of the FAA discovering that you don't have your eyeballs on somebody are about as close to zero as your chance of winning the Power Ball.

Well, sure; you're an independent A&P/IA, correct?  I suspect you are right in not having a thing to worry about.

However, a staffed shop may have to take a more conservative view and that's what I'm concerned with since I use shops!  All it is going to take is some over zealous FSDO guy, say the one in Arkansas that asked this question, to give some shop owner grief when he walks in and sees a non-certificated guy wrenching on someone's plane WITHOUT an A&P in sight!  Word will get around pretty damn fast if that happens before this gets resolved.

This may turn out to be a nothing burger, but a rogue FSDO inspector that chooses to wave this memorandum around may not be as remote as you seem to believe.  Yeah, IMHO.

[jetdriven]

2 hours ago, MikeOH said:

BINGO!  I believe that was the conclusion reached in the Mike Bush video...and this should get fixed as it was likely an FAA lawyer with no practical experience issuing an unintended overreach.  I'm just concerned with what is going to happen in the mean time...apparently it took the FAA 26 months to respond to the initial FSDO inquiry with this memorandum!  Sure hope it doesn't take that long to fix this!

You don't have to have a mechanic standing over the guy's shoulder, but you need to have a licensed mechanic be readily available, in person, to consult. It's the same thing with owner supervision, if you had a mechanic standing over your shoulder watching you do each task it wouldn't save any money. It depends on the skill and the aptitude of the non-licensed person and his relationship with the supervising mechanic.  Each situation is different.

[MikeOH]

8 minutes ago, jetdriven said:

You don't have to have a mechanic standing over the guy's shoulder, but you need to have a licensed mechanic be readily available, in person, to consult. It's the same thing with owner supervision, if you had a mechanic standing over your shoulder watching you do each task it wouldn't save any money. It depends on the skill and the aptitude of the non-licensed person and his relationship with the supervising mechanic.  Each situation is different.

@jetdriven

Have you read the Moss memorandum just issued Sept. 3, 2024?  I'm just SGOTI, but Mike Busch is worried enough he held a video presentation yesterday.  What you describe is the way it WAS; this Moss memo changes that!  It is requiring an A&P  "to stand over the guy's shoulder"

[jetdriven]

No, I havent.   Whats the deal with that?  I just skimmed over it, it sounds like video remote supervision is disallowed.  Im surprisewd anyone has even tried that, the reg says "in person"

 

[MikeOH]

2 minutes ago, jetdriven said:

No, I havent.   Whats the deal with that.

Here you go (actually issued Sept. 3, 2024): https://www.faa.gov/media/84326

 

[Fly Boomer]

3 hours ago, hammdo said:

BTW, Drs do remote operations - of course not to supervise unlicensed docs - I don’t think?

How would you know?  General anesthesia is usually two drugs -- one to knock you out and the other wipes your short-term memory in case you start to wake up, or you hear what the doc and the OR staff are discussing.  

[MikeOH]

26 minutes ago, jetdriven said:

No, I havent.   Whats the deal with that?  I just skimmed over it, it sounds like video remote supervision is disallowed.  Im surprisewd anyone has even tried that, the reg says "in person"

 

@jetdriven

Yes, that part is okay, and probably the original question that the Arkansas FSDO guy wanted addressed.  Unfortunately, if you read the memo in careful detail you'll see the response went well beyond that narrow issue.  I covered some of it in my posts above.  If you can find the Mike Busch video (from Social Flight) it's worth watching Mike's take on this; he IS concerned.

[haymak3r]

10 hours ago, Ragsf15e said:

Too many variables to say for sure.  You want a top shop, all squawks fixed, zero owner help?  It’s likely more.  You want owner assisted, in your hangar, local IA, it might be $1500.

Mine at a local shop in Washington with me doing all the opening and closing of all panels (that’s a lot of screws) has been ~$2500 for just the inspection.  Squawks extra of course.  I believe the inspection is about 35-40 hours on the Mooney checklist, so maybe im wrong and it’s a bit more $$ (remember, im doing a good bit of the work).  My shop is at $120/hr.

Exact same thing for me. I get the plane all ready for my IA to do all of the inspecting. Then I button it back up. Help with compression checks, oil change, lubrication of everything. takes about 40 hours as stated. My IA is also now 120 an hour.

[EricJ]

6 hours ago, MikeOH said:

@EricJ

See @hammdo's post.  The issue is this Moss memorandum now REQUIRES constant supervision!!  It is NOT business as usual; it's way more restrictive than just saying you can't supervise remotely.  I think the key cogent parts of the memorandum are, "The certificated mechanic must be available, not just to answer questions, but to notice mistakes and take over if necessary", and "In other words, mechanics must be able to physically intervene at every step of the process".  I don't see how that can be accomplished now without the A&P standing over the non-certificated employee performing the work!

Sorry, but this seems pretty draconian to me.  I think many A&Ps are going to feel the same way and there is going to be a very chilling and expensive effect if the FAA doesn't rectify this pretty damn quick.

I don't read it that way at all.

https://www.faa.gov/media/84326

The question deals with whether supervision can be done remotely, e.g., over zoom or facetime or whatever, and if so, can the return to service signature by the remote supervisor then be supplied remotely.

The answer is NO, remote supervision and return to service is not allowed.     I don't find this unreasonable at all.

The letter emphasizes "in person" in this context, that remote supervision is not supported by the regulations or previous legal interpretations that have been issued.    It cites multiple previous interpretations:

"This interpretation is consistent with previous administrative rulings. In Exemption No. 5139 (January 22, 1990), a petitioner asked to be allowed to train its own “workers” to perform preventative maintenance. This petition was denied. The FAA noted that: [I]t is not clear why the petitioner states that a non-certificated “worker” need not be physically observed by the certificated person “directly in charge” when maintenance is performed by the non-certificated worker. Section 43.3(d) states, in essence, that a certificated mechanic or repairman must be readily available, in person, when he is supervising maintenance performed by a non-certificated person.

In Re New Creations, Inc., FAA Exemption No. 5139, Jan. 22, 1990, at 3. The phrase “readily available, in person, for consultation” contemplates a physical, hands-on approach to supervision. The certificated mechanic must be available, not just to answer questions, but to notice mistakes and take over if necessary. In Blakey v. Sugen, National Transportation Safety Board (NTSB) Order No. EA-5128 (December 10, 2004), the NTSB upheld the suspension of the respondent’s Commercial Pilot Certificate for performing unsupervised maintenance—specifically, for performing some maintenance tasks while in earshot of certificated mechanics, but without any mechanic directly watching him. “One American Avionics employee testified, essentially, that he observed respondent applying sealant to the radome on his own, but this witness also conceded that he didn’t physically observe the installation itself and ‘assum[ed] he [respondent] probably had to have somebody [from American Avionics] over there to help him out.’” NTSB Order EA-5128 (2004), 5 (emphasis added, alternations in the original). In other words, mechanics must be able to physically intervene at every step of the process."

"Finally, § 43.3(d)’s “in person” language has remained consistent since its enactment in 1964.  3 It is worth noting that “in person,” to the rule drafters of the late fifties and early sixties, could only have meant physical presence. Interpreting “in person” to mean something other than physical presence would therefore be a significant departure from the original meaning of the text. Interpretative rules issued pursuant to section 553(b)(A) of the Administrative Procedure Act (APA), such as this one, serve merely to “advise the public of the agency’s construction of the rules and statutes which it administers.” 4 They cannot change the meaning of the underlying substantive rules they construe.5 For these reasons, the Office of Chief Counsel finds that 14 CFR 43.3(d) does not allow for remote supervision of maintenance. Because remote supervision is not allowed, the question of electronically documenting the return to service is not raised and therefore is not addressed by this interpretation."
 

The footnotes carry on some of the same ideas:

"3 The language that now makes up 14 CFR 43.3(d) comes from Civil Aeronautics Manual (CAM) § 18.10- 1 (December 15, 1959). Compare § 43.3(d) (“…if the supervisor personally observes the work being done to the extent necessary to ensure that it is being done properly and if the supervisor is readily available, in person, for consultation.”) with CAM 18.10-1 (“Direct supervision means that the supervising mechanic personally maintains such observation of the work being performed as is necessary to insure [sic] that the work is being performed properly, and the supervising mechanic is readily available in person for consultation with the person performing the work.”)"

Realize that this is saying that interpretations of what supervision is have not changed since interpretations from 1959 through 1990 to today.    The letter just clarifies that these interpretations do not extend to remote, virtual supervision through things like Zoom, Facetime, etc., etc.

I don't read any of this to say that a supervisor has to be constantly observing or even constantly present in order to supervise.    That would be a nonsensical departure from normal practice over the last sixty-plus years under the cited regulations and interpretations that are offered as the status quo.    The letter takes a fair amount of time saying that the common practice of "personal availability" "to the extent necessary to ensure that is is being properly" and is "readily available in person for consultation" is the historic standard that isn't met by remote virtual "supervision" in the current opinion.   It's not at all unusual historically that work is performed and the "supervisor" comes along at some point to inspect and approve the work and correct deficiencies and consult as necessary before approval for return to service.   I see nothing in this letter that forces the extreme interpretation that some seem to be taking, especially in the context that the examples given are done so to emphasize the inability of remote, virtual "supervision" to meet them.

Much ado about nothing, imho.

[PT20J]

I think it is best to look at the Mooney checklist as a recommendation. Does it really make sense to do every item on the checklist every year for an airplane that is well maintained, hangared, and flies 100 hours or less per year? Example: Wheel bearings. My first Mooney was tied down outside and had the old felt grease seals. Almost every year there was mild corrosion on the bearing races that I had to clean up. Now my airplane is hangared and I installed the new rubber seals and only look at the bearings and repack them when I have a wheel off to reverse a tire to even wear or replace a tire, and they are always perfect and well lubricated. My IA is fine with this. He spins the wheels and if they rotate fine with no play or bearing noise he calls it good. An experienced mechanic knows what to look for and also how to minimize inspecting things that pose little or no risk. I learned a ton from a mechanic with 45 years of experience that maintained 20+ airplanes at a museum where I used to volunteer. We did annual inspections on every airplane. Some like the cub flew maybe 5 hour in a year; the B-25 and the DC-3 maybe 50 hours. The mechanic knew the weak points of each airplane and we inspected the heck out of those, but we didn't waste time on stuff that posed little or no risk and was more likely to just wear out the airplane taking stuff to pieces repeatedly every few hours.

[N201MKTurbo]

3 minutes ago, PT20J said:

I think it is best to look at the Mooney checklist as a recommendation. Does it really make sense to do every item on the checklist every year for an airplane that is well maintained, hangared, and flies 100 hours or less per year? Example: Wheel bearings. My first Mooney was tied down outside and had the old felt grease seals. Almost every year there was mild corrosion on the bearing races that I had to clean up. Now my airplane is hangared and I installed the new rubber seals and only look at the bearings and repack them when I have a wheel off to reverse a tire to even wear or replace a tire, and they are always perfect and well lubricated. My IA is fine with this. He spins the wheels and if they rotate fine with no play or bearing noise he calls it good. An experienced mechanic knows what to look for and also how to minimize inspecting things that pose little or no risk. I learned a ton from a mechanic with 45 years of experience that maintained 20+ airplanes at a museum where I used to volunteer. We did annual inspections on every airplane. Some like the cub flew maybe 5 hour in a year; the B-25 and the DC-3 maybe 50 hours. The mechanic knew the weak points of each airplane and we inspected the heck out of those, but we didn't waste time on stuff that posed little or no risk and was more likely to just wear out the airplane taking stuff to pieces repeatedly every few hours.

I asked the FAA man about wheel bearings once. He said they need to be inspected along with the wheels. You cannot inspect them properly without cleaning them. After you inspect them, you need to repack them. 
 

[MikeOH]

@EricJ, @jetdriven, and anyone else that thinks this Moss memorandum is "much ado about nothing".

I respect Mike Busch's opinion.  He IS concerned about this and, according to his comments in the video I referenced, AOPA and a couple of other aviation organizations are also concerned.  You all keep referencing the FIRST part regarding not allowing remote supervision; Mike has no real issue with that.  The memo sure looks like it reaches beyond that to him and to me.

Look, I hope you guys are correct and there's nothing to worry about.  I'm just the messenger here and I'm tired of getting shot

Do as you please.

 

[PT20J]

42 minutes ago, N201MKTurbo said:

I asked the FAA man about wheel bearings once. He said they need to be inspected along with the wheels. You cannot inspect them properly without cleaning them. After you inspect them, you need to repack them. 
 

Well, Rich, you should know by now that there is no "FAA man." There are lots of FAA "men" that have different opinions and unless it is explicitly written down somewhere, a lot of things are open to interpretation. My IA's interpretation is that checking for freedom of movement, lack of noise and proper preload is "inspecting." 

[Andy95W]

Frankly, it seems like it clarifies/codifies the normal, common sense interpretations from before.  If an FAA inspector stops by your hangar and you’re doing something that you’re authorized to do, ie., changing a tire, installing the cowling, etc., then he’ll probably just shoot the bull with you for a while and leave.  If you’re doing something complex like installing a magneto, he’ll expect to see an A&P somewhere in the hangar with you, or he’s going to have to do something official about it.  If you tell him your buddy the A&P will sign it off later, he’ll want to talk to him also.

As I was told 30 years ago before I got my A&P: if a fed stops by, grab a broom and start sweeping.  Tell the fed you’re cleaning the hangar for when your A&P gets there to do the work.

But honestly, the FAA is so short staffed that nothing will really change.  But if you are caught, they now have an official letter showing why what you did was wrong.

[hammdo]

3 hours ago, Fly Boomer said:

How would you know?  General anesthesia is usually two drugs -- one to knock you out and the other wipes your short-term memory in case you start to wake up, or you hear what the doc and the OR staff are discussing.  

https://en.wikipedia.org/wiki/Remote_surgery#:~:text=Remote surgery (also known as,is a form of telepresence.

[EricJ]

3 hours ago, jetdriven said:

No, I havent.   Whats the deal with that?  I just skimmed over it, it sounds like video remote supervision is disallowed.  Im surprisewd anyone has even tried that, the reg says "in person"

At one of the IA seminars I attended a case was described where the entire annual inspection was done through the mail.   The owners had sent the logbooks and photographs of things requested by the IA and the IA looked them over, signed off the logbooks and sent them back.   Unfortunately, the airplane had crashed a couple days before the logbooks were signed and sent back, and the owners couldn't provide the logbooks during the investigation because they were still in the mail.   So when the logbooks did show up, the investigators found logbooks that were signed off as in an airworthy condition while the aircraft was a twisted pile of wreckage.

That didn't go over very well, obviously.    Given the mechanic/IA shortage I'm sure there's pressure to do stuff like that, so this letter is likely helpful to many considering "remote" inspections and supervision.

[EricJ]

28 minutes ago, MikeOH said:

You all keep referencing the FIRST part regarding not allowing remote supervision; Mike has no real issue with that.  The memo sure looks like it reaches beyond that to him and to me.

That's not the first part, it's the entire letter.   That's the question the letter is answering.   It is using examples that clearly demonstrate the cases where it makes it clear that remote, virtual supervision doesn't fit the regulations or previous, consistent interpretations over history.    Imho there's no reason to read any more into it than that.   Since it just cites previous interpretations that are more than thirty years old, I don't see how it is reaching to any new conclusions about what supervision is.   It makes it clear that it is not reinterpreting those, and says specifically that it is maintaining consistency with previous understanding about what supervision is.    If it's a problem, it's been a problem for more than thirty years, which doesn't seem to be the case.

[MikeOH]

12 minutes ago, EricJ said:

That's not the first part, it's the entire letter.   That's the question the letter is answering.   It is using examples that clearly demonstrate the cases where it makes it clear that remote, virtual supervision doesn't fit the regulations or previous, consistent interpretations over history.    Imho there's no reason to read any more into it than that.   Since it just cites previous interpretations that are more than thirty years old, I don't see how it is reaching to any new conclusions about what supervision is.   It makes it clear that it is not reinterpreting those, and says specifically that it is maintaining consistency with previous understanding about what supervision is.    If it's a problem, it's been a problem for more than thirty years, which doesn't seem to be the case.

@EricJ

I guess I'm a glutton for punishment

You really need to watch the Mike Busch video; he makes a VERY compelling case that there are TWO issues in the memorandum:

https://www.youtube.com/watch?v=heMP11PqI4A&list=PLIxlJDjC25RVjoZUO6t8HCwtGJ6mxna_M&index=1