Average Annual Cost?

[Will.iam]

10 hours ago, Sue Bon said:

Come to Switzerland! It's much cheaper here!

Narrator: Sue was lying, of course. She's actually crying in her coffee reading about $650 annuals. 

 

You are looking at the glass half empty, just fly your plane over to the USA for your annual and the savings in inspection fees will pay for your gas for a free trip to the US!

[ragedracer1977]

11 hours ago, hammdo said:

Owner assisted was ok until the recent FAA MOSS interpretation changed all of that…

-Don

Why would the moss letter change an owner assist? An annual inspection is not maintenance.  Go read part 43 appendix D and see if you can find any where maintenance occurs in an annual inspection. 
 

If you want to get pedantic, appendix D already prohibits owner assistance.  The INSPECTOR has to wash the plane And remove all panels, etc.

 If you want to get REALLY pedantic, it’s not legal for a woman to be an IA.

Each person performing an annual or 100-hour inspection shall, before that inspection, remove or open all necessary inspection plates, access doors, fairing, and cowling. He shall thoroughly clean the aircraft and aircraft engine

 

Edited September 26 by ragedracer1977

[Will.iam]

9 hours ago, ragedracer1977 said:

Why would the moss letter change an owner assist? An annual inspection is not maintenance.  Go read part 43 appendix D and see if you can find any where maintenance occurs in an annual inspection. 
 

If you want to get pedantic, appendix D already prohibits owner assistance.  The INSPECTOR has to wash the plane And remove all panels, etc.

 If you want to get REALLY pedantic, it’s not legal for a woman to be an IA.

Each person performing an annual or 100-hour inspection shall, before that inspection, remove or open all necessary inspection plates, access doors, fairing, and cowling. He shall thoroughly clean the aircraft and aircraft engine

 

Whoop whoop woke police woke police once the FAA is made aware of this fact it will be the first item they change before all others. Inclusion first above logic or safety. Wish i was kidding but will not be surprised if it happens that way. 

[Andy95W]

11 hours ago, MikeOH said:

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.

 

Like @EricJ said, the “first” part IS the Moss interpretation.  The “second” part is simply the supporting rationale for why an in-person A&P is needed, and NOT a remote supervisor.  Mike Busch’s reaction is an emotional knee-jerk to the “second” part that simply isn’t there.  Again, it’s just the rationale for the in-person supervisor.

I appreciate Mike Busch because he does a great job of providing good, common sense advice and information to owners and A&Ps.  But he isn’t always correct.

[Skates97]

11 hours ago, Andy95W said:

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.

This reminds me of my PPL check ride. The DPE said that sometimes the FAA comes by and wants to ride along. Then he went on to say, "You don't need the added pressure of that guy in the plane. If I see someone from the FAA I'm going to ask you if you're feeling ok. You're going to tell me you're not feeling very well today and I'm going to tell you I think we need to reschedule." 

[MikeOH]

1 hour ago, Andy95W said:

Like @EricJ said, the “first” part IS the Moss interpretation.  The “second” part is simply the supporting rationale for why an in-person A&P is needed, and NOT a remote supervisor.  Mike Busch’s reaction is an emotional knee-jerk to the “second” part that simply isn’t there.  Again, it’s just the rationale for the in-person supervisor.

I appreciate Mike Busch because he does a great job of providing good, common sense advice and information to owners and A&Ps.  But he isn’t always correct.

I note that all of you saying, "this is no big deal" are all A&Ps...are you certain your bias isn't showing?

If you watch the Mike Busch video you will note that he says (no, I haven't confirmed) that AOPA and two other aviation organizations (I can't remember their acronyms) are also concerned; I guess all three of them and Busch could be wrong...but, it seems imprudent to just dismiss this memorandum out of hand.

Time will tell.

[Andy95W]

No, honestly, no bias.  I no longer make my living as a working A&P and I don’t think anyone else posting here does either, anymore.

Before I got my A&P, I was an apprentice/mechanics helper at a shop in central Texas.  My boss (and mentor) would give me jobs to do and come check on me every once in a while.  If it was a complex job, he would check more often.  If it was something I hadn’t done before, he did the work with me the first time.  So again, the Moss letter hasn’t changed anything that was a common practice in the early/mid 90s.

There are 2 sentences that Mike Busch seems to have issues with:

— 

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.

— 

Again, this is no different than it was 30 years ago when I was an apprentice.  And it is no different when I am overseeing a non-A&P owner’s work today.  There are some jobs that can be inspected afterward, there are some that can’t.  The supervising A&P should darn well be present full time during a job like oil pump impeller gear replacement, but only needs to spot check when the owner is regreasing the Mooney trim jack shaft in the tail.  But again, this is no different from 30 years ago.

Mike Busch also talks about repair stations and Boeing where there are very few A&Ps on staff.  Comparing this to a general aviation shop or an owner assisted annual is comparing apples and oranges.  Repair stations and manufacturers already have many layers of FAA oversight so this letter simply doesn’t apply to those scenarios.

I’m not surprised that AOPA and others have also expressed concern.  That is a regular reaction to any FAA action or clarification until they’ve had the opportunity to study it or see its implementation on a day-to-day basis.  But for a good shop or an IA doing an owner assisted annual properly, the Moss letter really doesn’t change anything.

[Sue Bon]

17 hours ago, Skates97 said:

This reminds me of my PPL check ride. The DPE said that sometimes the FAA comes by and wants to ride along. Then he went on to say, "You don't need the added pressure of that guy in the plane. If I see someone from the FAA I'm going to ask you if you're feeling ok. You're going to tell me you're not feeling very well today and I'm going to tell you I think we need to reschedule." 

This happened to me for my PPL check ride. It was so unnerving! At the end, the guy complained about my American accent when I spoke on the radio. He said it made me sound like I knew what I was talking about when I really had no clue. 

Afterwards, my actual examiner pulled me aside and told me to ignore that guy. He said, "you sound very professional on the radio, but you're just starting out. Don't ever be afraid to ask for help if you need it." 

[FlyingDude]

I wonder if something happened to trigger this...

[EricJ]

25 minutes ago, FlyingDude said:

I wonder if something happened to trigger this...

I suspect Moss may have been dealing with either some incidents of remote supervision or a lot of questions about remote supervision in their district, and asked to get some official guidance.    That's just my speculation.

[dkkim73]

18 hours ago, Sue Bon said:

This happened to me for my PPL check ride. It was so unnerving! At the end, the guy complained about my American accent when I spoke on the radio. He said it made me sound like I knew what I was talking about when I really had no clue. 

Sue, 

I just get a kick out of the idea that an American accent makes a person sound more competent over there. At least in aviation. OTOH, I guess there are a lot of American aviation pioneers and innovators! 

Meanwhile, back in the US, those with English accents keep fooling others into thinking they are more educated than they are. And when I hear a German accent, I *know* that guy actually read the manual!

David

[A64Pilot]

On 9/25/2024 at 12:54 PM, MikeOH said:

Hmm, I've deliberately used a different shop each year (used two shops twice each, but not consecutive years) and didn't find any signs of any one of them being 'extra cautious' because they've not seen the plane before.  I like this approach because a different set of eyes and maintenance approach takes a look...I've been happy with the results. YMMV.

I haven’t read the whole thread yet so maybe this has been answered, but as an IA I can tell if it’s done correctly an Annual on a new to the IA airplane takes much longer, the reason is the IA has to ensure all AD’s were complied with and all work done since the aircraft’s birth date was done correctly, checking every accessory etc for the correct part number etc. You would be surprised at how many aircraft are out there with incorrect props for example.

However if I did the annual last year I only have to validate the last years work and any AD’s that came out last year etc.

There is truth in switching shops may give you a better annual, as different people find different problems, the more eyes looking the better, but it’s likely to cost you quite a bit more money.

For friends in my neighborhood I charge $300 if they do all the grunt work for simple airplanes, complex ones everyone takes them to shops that specialize in those aircraft which is better, and I don’t want to do Bonanza’s etc anyway, only one asked and I gave a quote that showed I didn’t  want to do it.

When an IA signs off an Annual, he “buys” everything that has ever been done or not done on that aircraft since it was new, but nothing from that date forward.

When an A&P signs off work he “buys” that work, but only that work until the day the airplane is scrapped, buys means accepts accountability of course

 

Edited September 30 by A64Pilot

[A64Pilot]

On 9/25/2024 at 1:32 PM, MikeOH said:

Yeah, I am assuming that will get rescinded...watched an interview with Mike Busch last night.  He's not the only one fired up over that disastrous memorandum!  I think the FAA will come to their sense with this one.

Interpretations, AC’s and memorandums are not law.

If they want me to do something different they need to change the FAR, which IS law, not print opinions, which is what an interpretation is, isn’t it?

My opinion or maybe it’s an interpretation?

[A64Pilot]

On 9/25/2024 at 10:54 PM, 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. 
 

Where this comes from is you asked.

Therefore he HAD to give you what we called in the Military as the most conservative response, because of course he could get into trouble if he didn’t. it goes like this, an inspector asks you why you didn’t repack the wheel bearings and you say Mike told me I didn’t have to, you didn’t say because I can inspect their condition by jacking the wheel up and checking, just like I don’t take the calipers apart every year, I can inspect their condition by inspection for function and leaks. You just said Mike told me I didn’t have to, we’ll it may be that Mike is going to get a talking to, maybe even a reprimand, but if he says repack every year he won’t.

I’m not saying you did anything incorrect, just know that when asked most of the time you will get the answer that covers the inspectors butt not necessarily the one that he feels is correct, if they want to climb the ladder and Retire they have to. It’s a Government Bureaucracy, that how they function. 

Sometimes that changes, the second inspector I got for the Repair station that I was an accountable manager for was near Retirement and he didn’t really have anything to lose, he wasn’t building a Career. He let me take him to lunch whenever he came down for example which is strictly Verboten for example.

[A64Pilot]

On 9/26/2024 at 12:57 AM, Will.iam said:

You are looking at the glass half empty, just fly your plane over to the USA for your annual and the savings in inspection fees will pay for your gas for a free trip to the US!

I know your kidding, but we can usually only work on N numbered aircraft, which hers likely isn’t.

[A64Pilot]

On 9/27/2024 at 5:33 PM, FlyingDude said:

I wonder if something happened to trigger this...

Anytime the FAA does ANYTHING it’s in response to something happening, usually a complaint.

I wouldn’t be surprised if it wasn’t that pencil whipped Annual that was in that IA renewal class, once something gets that public that’s obviously FUBAR the FAA has to respond.

If you’re ever in your hangar and an FAA guy walks in I can guarantee it’s because someone called and made a complaint.

Ramp checks are an exception, they actually have a Quota of those

If it’s a private hangar I’m 99% sure you can tell them to get out so I’ve never even heard of one entering one. But then there is a lot I don’t know.

Edited September 30 by A64Pilot

[MatthiasArnold]

2 hours ago, A64Pilot said:

I know your kidding, but we can usually only work on N numbered aircraft, which hers likely isn’t.

Sue‘s M20J is indeed on Swiss register (HB-..). My M20R, based in Germany, is on N-Reg; like most of the „modern“ Ovations and Acclaims operated throughout Europe. 

[A64Pilot]

2 hours ago, MatthiasArnold said:

Sue‘s M20J is indeed on Swiss register (HB-..). My M20R, based in Germany, is on N-Reg; like most of the „modern“ Ovations and Acclaims operated throughout Europe. 

I understand, a lot of Central and South American aircraft are still N numbered, keeping it US registered for them adds to the value, but I assume makes maintenance a pain as it takes a US Certified mechanic, unless there is a reciprocal agreement and with everything in Europe being EASA now I don’t know there is, there is for Engine and I believe aircraft Certifications but don’t know about mechanics, The Brits for one are extremely regimented, don’t know about the rest of Europe.

I assume keeping it US Registered is done due to it increasing the value even in Europe?

Edited September 30 by A64Pilot

[FlyingDude]

39 minutes ago, A64Pilot said:

assume makes maintenance a pain as it takes a US Certified mechanic,

In Europe they follow the tbo schedule like our part 135. Offsets the shortage of FAA certificated mechanics.

[MatthiasArnold]

13 hours ago, A64Pilot said:

but I assume makes maintenance a pain as it takes a US Certified mechanic

There are FAA certified A&P / I&A available across Europe. For example at ACG, wich is also one of the (two) European MSCs (see also Epilogue to the purchase of a Mooney Ovation in Europe, the registration history of this aircraft was US, Finland, Germany).
I even have a FAA certified A&P / I&A at my home base EDKA.
He typically works on (and owns) several warbirds including Boeing Sterman, T6, and some T28 Trojan.
Long story short - maintaining N-reg aircraft in Europe is doable but requires some more organization and efforts than in North America..

13 hours ago, A64Pilot said:

I assume keeping it US Registered is done due to it increasing the value even in Europe?

There are several Pros and some Cons on doing so:
Pros:

• US = biggest GA market around the globe, much easier for purchasing and selling
• Availability of STCs and accessories (LHS for example), some STCs never make it to EASA ..
• Maintenance as defined in Part 91 including basic maintenance by owner
• ..

Cons:

• As non US citizen (or enterprise) ownership via US based trust (it's just additional cost)
• For operation outside the country where your license has been issued (e.g., for me outside Germany, even if I hold an EASA license) you additionally need a FAA license or the FAA validation of your EASA license..
• When an none EU registered aircraft is based inside the EU (or a certain period of time (6+ months a year or so , I'm not sure) you need a proof, that the EU import taxes/VAT have been paid in full. This is ramp checked especially in (more) southern European countries like Italy, Spain, France, ..  Without a proof the authorities claim tax invasion and simply confiscate the aircraft ;-)

At least for me the Pros certainly outweigh the Cons .

Best,
Matthias

[Ibra]

On 9/27/2024 at 11:33 PM, FlyingDude said:

I wonder if something happened to trigger this...

Likely something unrelated to annuals by owner assisted or trainee mechanic…

My guess it’s likely from a high profile AD compliance (e.g. PA28 wing, B737 tail…)

[MikeOH]

AOPA seems to be taking this Moss' memorandum seriously enough to publish an article:

https://www.aopa.org/news-and-media/all-news/2024/october/01/aircraft-maintenance-new-faa-interpretation-could-devastate-ga

 

[EricJ]

They're saying that, "The certificated mechanic must be available, not just to answer questions, but to notice mistakes and take over if necessary,” is somehow problematic.

This has always been true, and is the point of supervision.    You can notice a mistake and take over during an inspection pass at any time during a repair.   It's what you're supposed to do.   This does not force the conclusion that the supervisor has to be there constantly, but that the supervisor inspects the work that has been done sufficiently to notice if a mistake has been made somewhere along the way.   You can then direct correction of the mistake or take over if necessary.   The idea is just that the inspection has to be sufficient to determine whether a mistake has been made and how to correct it, which might mean taking over and re-doing the work.  This point was made in the Moss letter by the author quoting the relevant regulations and guidances, which should have clarified the issue, imho.

Sadly, I think Mike Bush and the AOPA are jumping on this because they have to justify their existence as "watchdogs" of FAA overreach in these areas, rather than addressing an actual issue.   It still seems like a gross overreaction to me, but they can point to it and say they did something.

[MikeOH]

@EricJ

Well, we are all certainly entitled to our opinions but, as we know, it's the FAA's that counts!

While I understand your arguments and hope that they would prevail, I don't so easily discount that this new 'interpretation' greatly broadens how an inspector could view supervision in a much more controlled (i.e. CONSTANT supervision) fashion.

In the memorandum the author specifically uses the example of how one of the reasons remote supervision with a camera is disallowed is that some important item 'may be out of view' of the camera!  Yes, that was a discussion of 'remote supervision' but the argument still goes to the concept that this interpretation NOW REQUIRES CONSTANT supervision.  Otherwise, by your argument, the supervisor could just ask to have the camera moved to 'inspect' the 'out of view' item.  IOW, the implication is that 'real time' is critical.  THAT was not the case historically.

Again, time will tell on this.  If FSDOs just say, "meh" and continue biz as usual there will be no practical problem...but, if they get 'a wild hair' they now have a document to wield!  And, "Hell hath no fury like an inspector with a document scorned!"

[EricJ]

17 minutes ago, MikeOH said:

@EricJ

Well, we are all certainly entitled to our opinions but, as we know, it's the FAA's that counts!

While I understand your arguments and hope that they would prevail, I don't so easily discount that this new 'interpretation' greatly broadens how an inspector could view supervision in a much more controlled (i.e. CONSTANT supervision) fashion.

It doesn't greatly broaden it, it takes pains to say it's the same as it's always been.

17 minutes ago, MikeOH said:

In the memorandum the author specifically uses the example of how one of the reasons remote supervision with a camera is disallowed is that some important item 'may be out of view' of the camera!  Yes, that was a discussion of 'remote supervision' but the argument still goes to the concept that this interpretation NOW REQUIRES CONSTANT supervision.  Otherwise, by your argument, the supervisor could just ask to have the camera moved to 'inspect' the 'out of view' item.  IOW, the implication is that 'real time' is critical.  THAT was not the case historically.

And this is the AOPAs criticism of that part, that remote medicine is done this way, but the FAA says "supervision" can't be done this way.   I get that, but I'm skeptical of medicine being done this way, too. 

The FAA's point wasn't that it isn't possible to do it, it's that the historical regs and interpretations have contained "in person" language that can't be met remotely.   If the regs and guidance that were in place for the last sixty-plus years didn't consistently use "in person" language, then they probably would have had a means to allow the remote supervision.   Since that "in person" language exists and is consistent, however, they expressed that there wasn't a means to allow "remote" or, "not in person", supervision due to that language.

17 minutes ago, MikeOH said:

Again, time will tell on this.  If FSDOs just say, "meh" and continue biz as usual there will be no practical problem...but, if they get 'a wild hair' they now have a document to wield!  And, "Hell hath no fury like an inspector with a document scorned!"

The letter was just to address the "remote" part, and if you read the letter they addressed that very clearly in the context of the existing regs with "in person" language, and offered examples of why "in person" is important in that context.   Then they were careful to say that this didn't change "in person" supervision, it just meant that "remote" isn't possible.    By my reading of it it is a bit of a stretch to read it to mean that now "in person" means something completely different than it used to.   I don't see a justification for that anywhere in the letter.