Owner Performed Maintenance

[Av8r3400 1179]

Would our on-call A&P like to comment on the ongoing debate, over at Matronics, on what the owner - who is not the original builder - of an Experimental, Amateur built aircraft can or can not do?

As an example:  I am the owner, but not the original manufacturer of my Kitfox IV.  What am I allowed to do to this plane for maintenance, repair and/or modification?

There seems to be a lot of shooting from the hip, again, with a never ending supply of half-informed commentary.  (MTOW revisited?)

Thanks.

[akflyer 1427]

LMAO, so you were around for the MTOW arguments   oh those were fun.  Steve actually got me to open my eyes and read the FARs.  One thing I never knew about was the discussion part of the rulings where the thought process is written out to give you a clear understanding of what was ment by the ruling.  Kinda cool.. Thanks Steve.

Now the issue that the stooges have over there is kinda funny, partly sad, and a good sprinkling of dumbass.  Mr, I hold an inspection rating but cant read is really on a mission to push his whopping 16 hr class time knowledge.  Things that can only be learned by spending lotsa money on a 16 hr course.  Things like,

1. how not to read or interpret the actual FARs that regulate your plane

2. how to pull a smelly answer straight from you ass instead of the FARs

3. how to argue that you answer is not smelly, by pulling yet one more smelly answer outa yer ass.

I am thinking you get thepicture and I dont need to carry on with a morning rant anymore

[kl7jw 1]

Leonard,

That bunch of self-appointed experts really do get going at times, don't they? 

Same kind of thing my daddy used to raise hell at me about - "I buy you books, send you to school, and you still don't know how to read." 

[84KF 4]

Q.   "What am I allowed to do to this plane for maintenance, repair and/or modification?"

A.    You may do any repair and all maintenance.  

  Some modifications, (that you may also do) may require contacting the FAA to update operating limitations and establish a new Phase ! period.

Title 14: Aeronautics and Space

PART 43—MAINTENANCE, PREVENTIVE MAINTENANCE, REBUILDING, AND ALTERATION

43.1   Applicability.

(a) Except as provided in paragraphs (B) and (d) of this section, this part prescribes rules governing the maintenance, preventive maintenance, rebuilding, and alteration of any—

(1) Aircraft having a U.S. airworthiness certificate;

(B) This part does not apply to any aircraft for which the FAA has issued an experimental certificate, unless the FAA has previously issued a different kind of airworthiness certificate for that aircraft.

The A&P is only needed for the "Condition Report" which is required at least once every 12 calender months.

The only benefit the original builder gets is, if he complied with the 51% rule,  the chance to apply for the Certification of Repairmen (Experimental) which allows the holder to perform the yearly condition report while he owns the plane and AFTER ownership is transferred.

http://rgl.faa.gov/Regulatory_and_Guidance_Library/rgAdvisoryCircular.nsf/0/8863795eae3ee7438625736f004a9a0b/$FILE/AC%2065-23A%20CHG%201.pdf

[Av8r3400 1179]

Thank you.

[akflyer 1427]

Leonard,

That bunch of self-appointed experts really do get going at times, don't they? 

Same kind of thing my daddy used to raise hell at me about - "I buy you books, send you to school, and you still don't know how to read." 

Hey John,

You ben getting any stick time down there in the way to damn hot part of the country?  I made a flight to Chisik Island yesterday to run a couple boat plugs to a friend.  First time I took my bird over open water without a wingman   I forgot how much the engine misses when you are 20 miles from shore and on wheels...  I could not go over 4,500' due to cloud and smoke cover.

[kl7jw 1]

Leonard,

You're right, it's been too hot here the last week or so until today.  We only got to 90 degrees here so far today.  It's been up to 104 the last week.

I got a few hours in in the last couple of weeks.  Had surgery on my left knee a month ago and it was just too damn sore to get in the Kitfox and fly, but its improving.  I did a bunch of reworking of things on the Kitfox while I couldn't bend that knee. 

Re-did the brake lines, installed the Grove gear, re-did the fuel lines (I just couldn't see the need for two shut off valves in each line from the wing tanks to the header tank).  I replaced the SS Braided fuel lines with the alcohol resistant stuff and got rid of all those shut off valves.  Took about 6 pounds of old lines and valves out, put back less than 2 pounds.

Yeah, them engines just go to automatic rough, it seems like, when you're beyond power off gliding distance to shore, and it gets even rougher running when you're ot there at night with overcast skies in a single engine landplane.

John Hart

Wilburton, OK

[84KF 4]

Back on topic here....(cough cough..,)

Here is a favorite of mine..... from the List, naturally.

..I hold a repairman certificate and am laid up with a broken leg. My neighbor who owns a J3 comes over and using my check list inspects my airplane. I am satisfied with his inspection and sign the log book beginning with the standard text, "I certify that this aircraft has been inspected according to...". Some one tell me where I have violated the FARs.

..."

The FAA does not allow a "repairman" to "supervise" any required inspection..., and it is spelled out quite clear in the FAR's.

§ 65.104   Repairman certificate—experimental aircraft builder—Eligibility, privileges and limitations.

(B) The holder of a repairman certificate (experimental aircraft builder) may perform condition inspections on the aircraft constructed by the holder in accordance with the operating limitations of that aircraft.

Perform the inspection...YES.   Supervise the performance of the inspection by others....NO.

Compare this to the rules for A&P's......

§ 65.81   General privileges and limitations.

(a) A certificated mechanic may perform or supervise the maintenance, preventive maintenance or alteration of an aircraft or appliance, or a part thereof, for which he is rated ......    Perform OR supervise...

Continue to .... § 65.85   Airframe rating; additional privileges.

(a) ........ In addition, he may perform the 100-hour inspection required by part 91 of this chapter on an airframe, or any related part or appliance, and approve and return it to service.

Perform only..... I say again....Perform only.

The FAA does not allow "delegation of authority" when it comes to required inspections for aircraft, be it type certificated or Experimental amateur built.

I'll be blunt here... If you really want to fuck yourself, let someone else do the inspection only you were authorized to do, and then sign the maintenance logs as if you personally did the inspection.

As harmless and trivial as all this sound, it would.., has.., and will be... considered a violation of the FAR's and shit will fly if the Feds got involved with the paperwork in the future, say due to an accident or incident.

You would get burned under....

§ 65.20  Applications, certificates, logbooks, reports, and records: Falsification, reproduction, or alteration.

(a) No person may make or cause to be made—

(1) Any fraudulent or intentionally false statement on any application for a certificate or rating under this part;

(2) Any fraudulent or intentionally false entry in any logbook, record, or report that is required to be kept, made, or used, to show compliance with any requirement for any certificate or rating under this part;

The Condition Report is require under the FAA issued aircraft operating limitations.

The FAR god has spoken....... 

[akflyer 1427]

Damn Steve, I would say that you and my AI buddy are cut from the same cloth.  He said damn nearly the same thing you did in regaurds to the inspections after he did a little research when he came over to do my Condition Inspection.  It had been a long time since he had done one for an experimental so he brushed up and called his inspector from the ANC FSDO.

[akflyer 1427]

After reading some of the posts on the super duper chock full of knowledge site (no not this one ), I think I have seen higher IQ's on a Jerry Lewis telethon......

[kl7jw 1]

Some folks just don't get it when it comes to them asking you to sign off on either mechanical or inspection work or flight instruction.  When you put your name on the line, you are asserting that you have inspected and found the aircraft in a safe condition for flight, and that you have evaluated the person's flying skills and found them to be competent for whatever endorsement in the case of flight instruction.  ANYTHING that goes sour after that inspection will be attempted to be tied to your endorsement/evaluation by any investigation.  I don't mind signing off an owner assisted inspection when I personally look at work the owner has done while I'm with him, but damned if I'll jeopardize my A&P ticket by just signing a logbook without personally inspecting the work.    

I've had person come to me with over 100 hours of solo cross country flight time in their logbook, without an instructor's endorsement for it, wanting me to "sign it off so they could take the private pilot checkride".  Damned if I'll do that either.  Anybody wanting me to recommend them for a Practical test for flying, or a written exam is going to have to show me they have the knowledge and experience to successfully pass the test, and a verbal assertion by them don't show me that.   In the case of the person with all the solo cross country time, just a few weeks later, and without having his pilot certificate, he was out solo without any instructor endorsement and got killed due to weather.  I'm damn happy my signature was not in his logbook.

John Hart

KF IV, NSI Subaru

Commercial Pilot

CFII

A&P