always fun

[Yetti]

56 minutes ago, MikeOH said:

Coleal Letter of Interpretation:

https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2009/Coleal-Bombardier Learjet_2009_Legal_Interpretation.pdf

YMMV

Thanks for that.   I am not really looking for an interpretation of the existing rules.    More a how do we add a task to the list of PM items that were arbitrarily determined some time back during the Wright Brothers Era.    

 

 

[EricJ]

12 minutes ago, Hank said:

So, the end of the second paragraph on p.2 states (written in early 2009), "It is our understanding that Flight Standards' Aircraft Maintenance Division is planning to clarify this issue in a future revision to the AC," referring to Advisory Circular 43-12A, Preventive Maintenance. 

I remember some discussion about changes to the interpretation of the list of preventive maintenence tasks enumerated in 14 CFR Part 43, Appendix A, paragraph (c), along the lines that the list was not all-inclusive and that similar tasks within the general categories of "not requiring complex assembly operations" could be performed by us PPL types. A close reading of this paragraph of the Coleal letter seems to indicate agreement with this thinking, subject to forthcoming changes to the AC.

Have these changes actually been published?  Hoping for a change to 14 CFR Part 43 defining this is a long shot, but updating an AC should be a comparatively simple matter that should have been resolved in a fraction of the 16-1/2 years since this letter was published. Or am I confusing this with the looser permissions for Vintage Aircraft More Than 30 Years Old? Because my 1970 Mooney fits into that category, too . . .

The beauty of the Coleal letter is that it pretty much leaves what is or is not Preventive Maintenance up to the operator/owner under some very general guidelines.    My takeaway has been that if you coordinate with your regular A&P/IA and if they bless you changing brake pads (for example) as preventive maintenance, I'd think you're good to go.  I also think that's not an unreasonable thing to do for the reasons mentioned previously.    The IA's blessing matters, since they have to sign off the condition of everything at the end of the year.   

A similar thing is doing "supervised" maintenance under your A&P's supervision.   An A&P can "supervise" anybody doing anything and sign it off.    The person doing the work should make the logbook entry with their certificate and signature, and then the A&P signs off the return to service.   There is very little distance, in my opinion, between being supervised doing a brake change and doing a brake change under PM, for somebody the A&P deems competent to do so.   For the PM case it's the opinion of the guy that signs off the annual that matters, so my advice is to coordinate with them, too, if they're not your regular A&P.

FWIW, any maintenance is supposed to be logged in the aircraft maintenance records, so anything somebody chooses to do under PM should be recorded in the usual aircraft records with the name and certificate type and number of whoever did the work.    This allows the IA to know what's up at the end of the year, and to make certain everything is okay.    If you've previously coordinated with the IA, then there aren't any surprises.

[EricJ]

11 minutes ago, Yetti said:

Thanks for that.   I am not really looking for an interpretation of the existing rules.    More a how do we add a task to the list of PM items that were arbitrarily determined some time back during the Wright Brothers Era.    

Be careful what you wish for.   A re-do of the existing list could open the door for somebody claiming it is again a comprehensive list.    The Coleal letter gives a lot of wiggle room for good judgement and coordination with maintenance personnel.   I think that's a preferrable method.

[Yetti]

Thanks @Hank  used your description.   I have a friend on the EAA tech Committee.  Or something like that.   He also spent 4 years getting the Dynon Autopilot approved for the Baron.   I sent him this email:

The summary is:

How can we get an item added to the list of the PM items that an Owner/Pilot is able to perform?   The Item to be added is the ability to change brake linings. 

 

Discussion:   Pilots are able to change tires under the PM section of the Rules.   Generally this task involves: jack up plane; remove the wheel and brakes lining holder; remove the brake rotor from the wheel; remove the wheel bearings; separate the wheel halves; replace the tire and/or tube; reassemble the wheel halves; inflated the tire and check for leaks; add the brakes lining holder; clean and repack the wheel bearings; put the wheel bearings back in; mount the assembly onto the gear leg; lower the plane from the jacks.

 

The removal and replacing several rivets along with the brake linings does not seem to be that much more complex of a task than the above.

 

I would also see this as a test case to adding other items to the PM list of items that can be performed.

Since a rule/law needs to be rewritten possibly rewrite it as "list of PM items as approved by the Commissioner"  which would not require the law to be changed to add an item. 

 

[EricJ]

8 hours ago, Yetti said:

Thanks @Hank  used your description.   I have a friend on the EAA tech Committee.  Or something like that.   He also spent 4 years getting the Dynon Autopilot approved for the Baron.   I sent him this email:

The summary is:

How can we get an item added to the list of the PM items that an Owner/Pilot is able to perform?   The Item to be added is the ability to change brake linings. 

 

Discussion:   Pilots are able to change tires under the PM section of the Rules.   Generally this task involves: jack up plane; remove the wheel and brakes lining holder; remove the brake rotor from the wheel; remove the wheel bearings; separate the wheel halves; replace the tire and/or tube; reassemble the wheel halves; inflated the tire and check for leaks; add the brakes lining holder; clean and repack the wheel bearings; put the wheel bearings back in; mount the assembly onto the gear leg; lower the plane from the jacks.

 

The removal and replacing several rivets along with the brake linings does not seem to be that much more complex of a task than the above.

 

I would also see this as a test case to adding other items to the PM list of items that can be performed.

Since a rule/law needs to be rewritten possibly rewrite it as "list of PM items as approved by the Commissioner"  which would not require the law to be changed to add an item. 

 

I would suggest not poking the bear.

 

[N201MKTurbo]

Nobody from the FAA gives a rip what you do to your airplane as long as you do it right. If you do it wrong and it causes a problem and you did it outside of the regs, there will be trouble for you. If you do good work and nothing bad ever happens, you have nothing to worry about. The FAA doesn't have time to go snooping around in our hangars.

As @EricJ said, work with your A&P IA and everything will be OK. That is what an IA is, the FAA designated representative who gets to decide if your plane is airworthy.

[Fly Boomer]

2 minutes ago, N201MKTurbo said:

Nobody from the FAA gives a rip what you do to your airplane as long as you do it right.

I once heard an FAA person say "if it's not a problem, then it's no problem, but if it is a problem, then that's a problem."

[N201MKTurbo]

I have had conversations with FAA principal inspectors who have said that they feel a lot better about an involved owner who tries to keep their airplane in pristine condition as opposed to an airplane that only gets a cheap annual every year. Just don't do things like use unapproved parts or do any other improper maintenance to save money.

[Yetti]

6 minutes ago, N201MKTurbo said:

I have had conversations with FAA principal inspectors who have said that they feel a lot better about an involved owner who tries to keep their airplane in pristine condition as opposed to an airplane that only gets a cheap annual every year. Just don't do things like use unapproved parts or do any other improper maintenance to save money.

Seems like there should be a Maintainer category of mechanics for simple stuff and a Major category (rebuilding engines and OH major components like fuel servos. 

[N201MKTurbo]

50 minutes ago, Yetti said:

Seems like there should be a Maintainer category of mechanics for simple stuff and a Major category (rebuilding engines and OH major components like fuel servos. 

I agree, but the administrative overhead could get out of hand. 
 

The way I would do it, is for an A&P, or maybe an IA could give you an aircraft specific endorsement for different tasks, such as:

Wheels and brakes

Landing gear 

Engine, ignition

Engine fuel

Engine, charging system

fuel systems and tanks

Flight controls

Sheet metal, non structural 

Interior

Electrical

 

These endorsements would only be applicable to a single aircraft. You wouldn’t be able to work on any other aircraft without additional endorsements.

This would give regulatory credibility to what has been going on for a long time.

[Andy95W]

Rich- you and I are thinking exactly the same, I was writing up the same recommendation when you posted this.

It would be like a CFI adding a tail wheel endorsement or complex endorsement to your pilots license, it would be a simple signature and statement from an A&P/IA that you were authorized to perform a specific maintenance task on a specific aircraft type.

[N201MKTurbo]

6 minutes ago, Andy95W said:

Rich- you and I are thinking exactly the same, I was writing up the same recommendation when you posted this.

It would be like a CFI adding a tail wheel endorsement or complex endorsement to your pilots license, it would be a simple signature and statement from an A&P/IA that you were authorized to perform a specific maintenance task on a specific aircraft type.

I wouldn’t do a specific aircraft type, I would do a specific aircraft. I don’t want you working on other peoples airplanes.

[Marc_B]

It will be interesting to see how 'supervision' is eventually interpreted.  I thought after all Mike Bush's consternation and complaints about the letter of interpretation of what constitutes Supervised Maintenance that there may be developments of remote video supervision. 

I could easily see work being recorded and then key steps reviewed as needed.  This could easily be expanded to owner-assisted maintenance where certain steps are supervised by a video camera and then checked off by an A&P remotely.  If you "bought in" to a service, you might be supplied with a headlamp video camera and instructions on what was needed to be captured for a variety of maintenance tasks.  A company like Savvy would be poised to do this easily through their network of A&Ps.  i.e. if something needed onsite assistance or confirmation they could have an A&P stop by for an upcharge.  Then the log entry is electronically signed and printed by the owner.

Tele-medicine meet Tele-maintanence!

[Yetti]

50 minutes ago, N201MKTurbo said:

I wouldn’t do a specific aircraft type, I would do a specific aircraft. I don’t want you working on other peoples airplanes.

Agreed.  I just had this conversation with my friend from above post.   The Owner is already required by the regs to ensure the Airplane is Airworthy.    That infers that an Owner has the knowledge to know what makes the Airplane Airworthy.     Simplistically the hanging Adel Clamp from the picture at the start of this thread would make the Airplane not airworthy because it was not as specified in the Maintenance Manual.    So if as an owner I can see the unairworthyness of the item, denying the owner the ability to fix a simple non complex item seems rather silly as the owner is already been made responsible.

 

[Shadrach]

2 hours ago, N201MKTurbo said:

I agree, but the administrative overhead could get out of hand. 
 

The way I would do it, is for an A&P, or maybe an IA could give you an aircraft specific endorsement for different tasks, such as:

Wheels and brakes

Landing gear 

Engine, ignition

Engine fuel

Engine, charging system

fuel systems and tanks

Flight controls

Sheet metal, non structural 

Interior

Electrical

 

These endorsements would only be applicable to a single aircraft. You wouldn’t be able to work on any other aircraft without additional endorsements.

That would work great but I think few mechanics in this day and age would want that liability without a strong financial incentive. I would pay generously to have the ability to sign off specific maintenance items as related to my airplane. Not so much for saving money, but also time and avoiding an AOG away from home. They’re a great number of airworthiness items that I can remedy in a day or two that might take five or more when trying to schedule shop time.

I’ve often wondered how things are done in the bush flying community. Is every bush pilot that flies a certified aircraft an A&P/IA?…I am sure that that is not the case. I am also sure that in the backcountry, there many repairs made by non-credentialed pilots when the alternative is spending several days in the bush under brutally cold conditions.

[N201MKTurbo]

21 minutes ago, Shadrach said:

That would work great but I think few mechanics in this day and age would want that liability without a strong financial incentive. I would pay generously to have the ability to sign off specific maintenance items as related to my airplane. Not so much for saving money, but also time and avoiding an AOG away from home. They’re a great number of airworthiness items that I can remedy in a day or two that might take five or more when trying to schedule shop time.

I’ve often wondered how things are done in the bush flying community. Is every bush pilot that flies a certified aircraft an A&P/IA?…I am sure that that is not the case. I am also sure that in the backcountry, there many repairs made by non-credentialed pilots when the alternative is spending several days in the bush under brutally cold conditions.

I’ve heard in Alaska, you are lucky if the pilots have a license.

I don’t think any big shop mechanics would endorse anyone they didn’t know real well.

This would only apply to the mechanics that work out in the GA hangars with their buddies. I don’t know about where you live, but there is a lot of that going on around here.

[Shadrach]

2 hours ago, Yetti said:

The Owner is already required by the regs to ensure the Airplane is Airworthy.    That infers that an Owner has the knowledge to know what makes the Airplane Airworthy. 

I’ve always thought this aspect of airworthiness a bit ironic. It’s akin to saying:

 You’re responsible for the performance of this system and ensuring its continued performance, just don’t touch it…

Of course, responsibility for airworthiness has to be assigned to someone and it’s hardly realistic to ask a mechanic her last saw the plane seven months ago during an annual inspection to take responsibility for its current day condition.

I think enabling owners to be more involved in the maintenance of their aircraft would likely increase safety by reducing the prevalence of unauthorized maintenance.

[Shadrach]

35 minutes ago, N201MKTurbo said:

I’ve heard in Alaska, you are lucky if the pilots have a license.

I don’t think any big shop mechanics would endorse anyone they didn’t know real well.

This would only apply to the mechanics that work out in the GA hangars with their buddies. I don’t know about where you live, but there is a lot of that going on around here.

There’s a lot of that going on here, but it takes decades to build those kind relationships (I know firsthand). It would be cool to create a regulatory pathway to making it more accessible. 

[N201MKTurbo]

When it comes to airworthyness, I don’t think they expect the owner or operator to be an IA. They expect you to make sure all inspections are current and all AD have been complied with. 
 

Let’s say you have a recurring AD that expires 6 months after the annual inspection. There is no way they can hold your IA responsible for compliance. The operator has to track these things.

[Schllc]

There is no doubt in my mind that the things I choose to do on my own airplanes, are done as well if not better, than any mechanic that has ever touched it.  
I do not tinker with things beyond my comfort zone, and I always consult with my AP, but I’ll be damned if I am going to ground myself in some foreign airfield over something I can easily and competently address.  Even things that I do not feel comfortable with, I am eager to assist or get involved so I understand what is being done, and can inspect the process. 
I had this delusion in the beginning that aircraft mechanics would be super competent and diligent. Much to my surprise, they are human. There are good ones, bad ones, some that pay attention to detail, and those that can’t wait for 5:00 to punch out.    I have found rags, tools, loose bolts, old parts etc in my cowling and plane after service.  I realized very quickly that most are inured to some extent with the “life and death” issue and are just going through the motions.
You absolutely must inspect, what you expect. 
Common sense, doesn’t appear to be, so I understand the rules serve a valuable function, but good decision making isn’t limited to pilot choices…

[Yetti]

2 hours ago, N201MKTurbo said:

When it comes to airworthyness, I don’t think they expect the owner or operator to be an IA. They expect you to make sure all inspections are current and all AD have been complied with. 
 

Let’s say you have a recurring AD that expires 6 months after the annual inspection. There is no way they can hold your IA responsible for compliance. The operator has to track these things.

Pretty sure the horse is not dead so a couple more kicks.       Let's define Airworthy Found this one.    

"ANSWER: There are two conditions that must be met for an aircraft to be considered "Airworthy”

1. The aircraft must conform to its type design (TC). Conformity to type design is considered attained when the aircraft configuration and the components installed are consistent with the drawings, specifications, and other data that are part of the TC, which includes any supplemental type certificate (STC) or other approved alterations.

2. The aircraft must be in a condition for safe operation. This refers to the condition of the aircraft relative to wear and deterioration, for example, skin corrosion, window de-lamination or crazing, fluid leaks, tire wear, etc.

If either of these two conditions cannot be met, the aircraft is considered to be un-airworthy.

So, the goal for those persons who operate and maintain aircraft is to keep them in an airworthy condition or what is referred to as “continued airworthiness”. "

 

If you took a large sample of late 1900s airplanes and reviewed them against the Type Design I bet that about 50% would not pass.     

[N201MKTurbo]

§ 91.403 General.

(a) The owner or operator of an aircraft is primarily responsible for maintaining that  aircraft in an airworthy condition, including compliance with part 39 of this chapter. 

(b) No person may perform  maintenance,  preventive maintenance, or alterations on an  aircraft other than as prescribed in this subpart and other applicable regulations, including part 43 of this chapter. 

(c) No person may operate an  aircraft for which a manufacturer's maintenance manual or instructions for continued airworthiness has been issued that contains an airworthiness limitations section unless the mandatory replacement times, inspection intervals, and related procedures specified in that section or alternative inspection intervals and related procedures set forth in an operations specification approved by the  Administrator under part 121 or 135 of this chapter or in accordance with an inspection program approved under § 91.409(e)have been complied with. 

(d) A person must not alter an  aircraft based on a supplemental type certificate unless the owner or operator of the  aircraft is the holder of the supplemental type certificate, or has written permission from the holder.

[Docket 18334, 54 FR 34311, Aug. 18, 1989, as amended by Amdt. 91-267, 66 FR 21066, Apr. 27, 2001; Amdt. 91-293, 71 FR 56005, Sept. 26, 2006]

[Andy95W]

9 hours ago, Shadrach said:

That would work great but I think few mechanics in this day and age would want that liability without a strong financial incentive. I would pay generously to have the ability to sign off specific maintenance items as related to my airplane.

That’s why it would be similar to a CFI’s complex endorsement.  If you forget to put your landing gear down, nobody’s going to sue the CFI that signed you off to fly a retract gear airplane.

[Pinecone]

On 6/27/2025 at 11:04 AM, N201MKTurbo said:

I agree, but the administrative overhead could get out of hand. 
 

The way I would do it, is for an A&P, or maybe an IA could give you an aircraft specific endorsement for different tasks, such as:

Wheels and brakes

Landing gear 

Engine, ignition

Engine fuel

Engine, charging system

fuel systems and tanks

Flight controls

Sheet metal, non structural 

Interior

Electrical

 

These endorsements would only be applicable to a single aircraft. You wouldn’t be able to work on any other aircraft without additional endorsements.

This would give regulatory credibility to what has been going on for a long time.

Sort of like the Repairman's Certificate you can get for a homebuilt you actually built.

I agree, that that makes a lot of sense. 

[cliffy]

As a long tie A&P and having come in behind many many "owner's  maintenance" issues I am VERY dubious of "owners" doing their own maintenance.

I had a recent experience though with one who wanted to change his own C model engine mount (paint it) and I agreed to "interview" him at his hangar. Much to my surprise he turned out to be as good as the best A&Ps I have ever worked with BUT bear in mind he was the exception to the rule. After his work, I found only 2 minor issues to address before I signed it off. 

Just my experience tells me most owners own evaluation of their abilities to do quality aircraft maintenance  is way beyond their actual abilities. Having done hands on training at maintenance seminars and letting owners just safety wire two bolts AFTER showing them how to do it bares the reality of what I speak,

I'm sure there are a few that can but not the majority by my experience.