National Aeronca Association Bulletin Board

Larry -

Full timne doesn't mean "big shop", whatever that is.

I read your post, and we all can tell stories of being overcharged and under served when it comes to aircraft maint., service on a car, a trip to the dentist, or a few dozen other purchases of services.

I love small shops, and have no problem with them. My mentor in my early flying days ran a two man shop for years, doing some of the best work in our locale.

The issue I raised was pointed toward one type of mechanic/IA: The guy with no manuals, few if any specialized or calibrated tools, who "wings" it and will work on about anything, and who has no insurance to cover his mistakes, choosing to leave the liability after an accident to the aircraft owner, since this mechanic runs bare. This is the guy who needs to go; not competent people like yourself.

Personal opinion here but I think if it gets too tough this may drive a number of us into home building. I may be unusual but I'm more into restoration rather than flying. I've done the flying bit over my younger years when I had my Cherokee and actually, my Champ sits a lot simply because I can't find a reason to bore holes in the sky when I could be working in the shop. One of the guys on our airport is ex-miliary, ex-airline and has built four plane since he retired: RV-6, RV-8, Savannah and a Sonex. The bottom line is that as the builder he's able to do his own maintenance and inspections. That's pretty appealing to a 'motor head' like myself and if I had known ahead of time how much energy and $$$$ it would have taken to bring this L16 back from the dead (literally) a Sonex might have started to look pretty good. I know it wouldn't have cost any more and I could do my own inspections. Of course then I wouldn't have a reason to hang out on this forum .

MikeB

Boy am I disappointed. I had a long rebuttal going here and one wrong click and gone!! And Jerry, I am disappointed that you would leave out facts to color the issue to support your and the FAA's position that mechanics working out of pickup trucks are detrimental to aviation.
http://www.ntsb.gov/ntsb/brief.asp?ev_i ... 0800&key=1
Guys read the full narrative.
1. The IA was the airport manager at a private airfield.
2. The IA had a hangar on this airfield.
3. The accident airplane was based at this airfield.
http://www.airnav.com/airport/3OH0
According to the above, there are 119 single engine airplanes based at this field now. According to the NTSB the IA had done 42 inspections that year. I don't think this IA had to travel very far in his pickup.
4. The passenger who was killed was a Commercial Multiengine CFII Lt. Colonel in the Air Force Reserve. He was not an innocent lamb who had no idea of the risks of flying.
5. The aircraft was flown to HOC to have work done on the autopilot. At completion they took off and had smoke in the cockpit. They returned to the airport because of the smoke and when the cause of the smoke was NOT determined, they took off again.
There were many places to point fingers in this one. Like the vast majority of accidents there was a chain of events that lead to the final result and there were several opportunities to break the chain. jrh

Quote" they returned to the field with smoke in the cockpit, did not find source, took off again." That pretty well sums it up doesn't it? In 55 years of flying, I have never had work done at " a big professional shop", rather , always at a small one or two man operation but usually by "old pros". In western NYS, the fellow had been head of maintenence for 35 years at a larger airport and at 75 years old had his Chrysler van outfitted with everything he needed. (Air comp. tool box-large, shelves full of screws, bolts, etc. (Carburators he took home to rebuild) A real fine person and an ace A&I. He finally gave up the AI license a few years back said it was too much paperwork and so forth. Reading the history....CFI, former Air Force officer, etc. etc. it really makes one wonder what he was thinking. Maybe not too much. (I like Paul's answer best.) I think its the end of an era to quote a fellow at the airport, retired doctor, who owns a magnificent Stinson 108, 4 T-Crafts and a Maule. He said "The older pros are dying out, the ones who needed NO manuals to inspect a BC12D. They knew it inside out. Or a Stinson, or whatever." Younger mechanics usually don't have a clue as they are not exposed to these older aircraft and I don't want them learning on mine! JP

Back to the Policy Change... I don't see a problem here. After getting flooded with alarming emails from AAA, EAA and AOPA I had a 3 hours phone call with my IA about the change. Here's the proposal, with the fluff cut out and text added from citations: This is gonna be long but hang with me.

Discussion of the Proposal

It is a longstanding FAA requirement that an applicant for an IA or for renewal of an IA be actively engaged. An applicant can demonstrate that he is an active A&P in a number of ways. An applicant who is employed full-time has been considered actively engaged. An applicant who is employed part-time in those maintenance activities may be actively engaged. An applicant who participates in (regardless of employment status) those maintenance activities part time or occasionally may be actively engaged.Whether that part-time or occasional employment constitutes actively engaged depends on the circumstances. For that reason, those determinations must be made by the ASI. To make the determination, the ASI should consider the type of maintenance activity performed, considering any special expertise required, and the quantity of maintenance activity. In some cases, such as a mechanic performing maintenance in geographical area that has limited access to some special expertise or a retired mechanic who occasionally performs maintenance as needed,the type of maintenance activity may be the determining factor even when its quantity is relatively insignificant. Because the ASI's determination is unique to each applicant, the ASI would use documentation or other evidence provided by the applicant detailing the maintenance activity. Accordingly, this policy defines the factors an ASI should consider when reviewing an application or renewal for an IA.

Additionally, FAA Order 8900.1 restricts the types of maintenance that ASIs can perform because of ethical concerns. The FAA does not intend for ASIs to lose their IAs because of these limitations. Accordingly, the FAA proposes a carve-out for ASIs who also hold an IA.
The FAA intends this policy to clarify rather than change the definition of “actively engaged” and provide clear guidance to ASIs that can be applied consistently.

Proposed Amendment
(For an initial I/A)

The ASI must establish the applicant's eligibility per part 65, § 65.91

(1) Hold a currently effective mechanic certificate with both an airframe rating and a powerplant rating, each of which is currently effective and has been in effect for a total of at least 3 years;
(2) Have been actively engaged, for at least the 2-year period before the date he applies, in maintaining aircraft certificated and maintained in accordance with this chapter;
(3) Have a fixed base of operations at which he may be located in person or by telephone during a normal working week but it need not be the place where he will exercise his inspection authority;
(4) Have available to him the equipment, facilities, and inspection data necessary to properly inspect airframes, powerplants, propellers, or any related part or appliance; and
(5) Pass a written test...

A. The applicant must hold a current mechanic's certificate, with both airframe and powerplant ratings, that has been in effect for at least 3 years. The applicant must have been actively engaged in maintaining certificated aircraft for at least the 2-year period before applying.

Actively engaged means exercising the privileges of an airframe and powerplant mechanic certificate in the maintenance of civil aircraft. Applicants who are employed full-time are considered to be actively engaged. Applicants who are employed or participate part-time or occasional basis will be evaluated by the ASI to determine whether the applicant is actively engaged. The ASI will evaluate the scope of part-time or occasional activity based on the type of maintenance activity, including any special expertise required, and the quantity of maintenance activity performed. To evaluate the scope of the part-time or occasional maintenance activity, the ASI will use evidence or documentation provided by the applicant showing inspection, overhauling, repairing, preserving, or replacing parts on aircraft.

B. There must be a fixed base of operation at which the applicant can be located in person or by telephone. This base need not be the place where the applicant will exercise the inspection authority.
C. The applicant must have available the equipment, facilities, and inspection data necessary to conduct proper inspection of airframes, powerplants, propellers, or any related part or appliance. This data must be current.
D. The applicant must pass the IA knowledge test, testing the ability to inspect according to safety standards for approval for return to service of an aircraft, related part, or appliance after major repairs or major alterations, and annual or progressive inspections performed under part 43. There is no practical test required for an IA.

(For an IA renewal...)

A. Application Requirements. Application for renewal may be required to comply with the following:
(1) Show evidence the applicant still meets the requirements of § 65.91(c)(1) through (4).

(1) Hold a currently effective mechanic certificate with both an airframe rating and a powerplant rating, each of which is currently effective and has been in effect for a total of at least 3 years;
(2) Have been actively engaged, for at least the 2-year period before the date he applies, in maintaining aircraft certificated and maintained in accordance with this chapter;
(3) Have a fixed base of operations at which he may be located in person or by telephone during a normal working week but it need not be the place where he will exercise his inspection authority;
(4) Have available to him the equipment, facilities, and inspection data necessary to properly inspect airframes, powerplants, propellers, or any related part or appliance
(5) Pass a written test

(2) Complete Form 8610-1
(3) Show evidence the applicant meets the requirements of § 65.93(a) for both the first and second year in the form of an activity sheet or log, training certificates, and/or oral test results, as applicable.

(1) Performed at least one annual inspection for each 90 days that the applicant held the current authority; or
(2) Performed at least two major repairs or major alterations for each 90 days that the applicant held the current authority; or
(3) Performed or supervised and approved at least one progressive inspection in accordance with standards prescribed by the Administrator; or
(4) Attended and successfully completed a refresher course, acceptable to the Administrator, of not less than 8 hours of instruction; or
(5) Passed an oral test by an FAA inspector to determine that the applicant's knowledge of applicable regulations and standards is current.

nkh

So the only thing that has changed is they defined 'Actively Engaged.'

The funny part about all this... if you comply with part 65.91 and part 65.93; you fulfill the requirements to obtain/renew your IA. So there's no question if you're actively engaged.

Maybe I'm missing something.
Can anyone point out specifically how this is bad???

nkh

So I do get to stay in aviation? Thank you lord!

Based on what all the experiences listed here are added to my experience, I think that you can find really knowledgeable mechanics, that want and do a great job out of their pick up trucks as well as shops that do a bad job, even though they have all the bells and whistles. I think it is important to find out if the person that is going to do the work has the experience and interest along with the correct tools and manuals. The reverse is obviously also true in both cases.
Speaking of which, maybe we each should have the manuals for the aircraft that we own, which will help. I like the owner assist also due to the learning experience as well as keeping tabs on what is being done to my airplanes. I am not sure I know all of what to watch for, but I think we can all tell when someone is at least doing really bad work. The money savings are secondary there, but welcome.

Nathan,
I think the ASI evaluation is the one I'm concerned with. Most of the ASI's I run across are more into the regulatory issues rather than the maintenance issues. And to have that person doing the evaluation is just wrong.
The second issue is the exclusion of the ASI from the IA process. If this is accepted, all of the ASI's will become IA's just by filling out the paperwork. These people should be excluded due to the ethical issues previously mentioned. They do not fit the definition of actively engaged in the maintenance of civil aircraft.
The current process has been used for many years and is working. Typically "clarifications" usually mean your about to feel a pounding sensation from behind.
Paul

As an I.A. and operator of a small shop, I'll throw my two cents in. Like it or not there are some aircraft owners out there that care very little about keeping their airplanes in a safe airworthy condition, they just want to fly as cheaply as possible and there are I.A.'s out their that are happy to oblige them for a few quick bucks. Neither are doing aviation any favors. I would guess that's what the FAA wants to crack down on but guys like Larry are going to get caught in the net.
This will be difficult for part time I.A.s that just want to stay involved, help people out and makes some income because justifying yourself to the FAA can be intimidating. Guys like me who deal with the FAA all the time don't think anything of it and despite popular belief most the FAA inspectors I deal with are pretty decent guys. That said they are government workers and sometimes trying to get them to move on something can test your patients, their biggest bitch is always how much work they have. So why would they push for more workload? Besides wasn't the reasoning of going to a two year I.A. renewal to decrease the ASI's workload? Mixed signals.
And Paul's right about the ASI exemption, why do they need an I.A. in the first place? I don't believe they should be preforming any I.A. work period. They can always get it back when they leave the FAA.

Chris, you're doing fine. Don't throw the baby out with the dirty water.

Robert, it's a smart idea to have the manuals. It can help you trouble shoot a problem before tossing a lot of money at it. If nothing else, you can learn about your airplane while sitting in the "library."

Paul; I know what you're saying about the ASI getting a free pass, but that's always been that way. But you have to remember; he might be an IA only to keep his airplanes annualled, just like you and me.

Al Hatz wrote:This will be difficult for part time I.A.s that just want to stay involved, help people out and makes some income because justifying yourself to the FAA can be intimidating.

But you don't have too, look at the proposal again. No where do you have to prove you are "Actively Engaged;" only meet the requirements in 65.91 and 65.93 like you've always done.

Nathan K. Hammond wrote: (For an IA renewal...)

A. Application Requirements. Application for renewal may be required to comply with the following:
(1) Show evidence the applicant still meets the requirements of § 65.91(c)(1) through (4).

(1) Hold a currently effective mechanic certificate with both an airframe rating and a powerplant rating, each of which is currently effective and has been in effect for a total of at least 3 years;
(2) Have been actively engaged, for at least the 2-year period before the date he applies, in maintaining aircraft certificated and maintained in accordance with this chapter;
(3) Have a fixed base of operations at which he may be located in person or by telephone during a normal working week but it need not be the place where he will exercise his inspection authority;
(4) Have available to him the equipment, facilities, and inspection data necessary to properly inspect airframes, powerplants, propellers, or any related part or appliance
(5) Pass a written test

(2) Complete Form 8610-1
(3) Show evidence the applicant meets the requirements of § 65.93(a) for both the first and second year in the form of an activity sheet or log, training certificates, and/or oral test results, as applicable.

(1) Performed at least one annual inspection for each 90 days that the applicant held the current authority; or
(2) Performed at least two major repairs or major alterations for each 90 days that the applicant held the current authority; or
(3) Performed or supervised and approved at least one progressive inspection in accordance with standards prescribed by the Administrator; or
(4) Attended and successfully completed a refresher course, acceptable to the Administrator, of not less than 8 hours of instruction; or
(5) Passed an oral test by an FAA inspector to determine that the applicant's knowledge of applicable regulations and standards is current.

nkh

Nathan,
The difference is that with the current renewal process you attend 16hrs of training or provide the list of Annuals performed that meets the FAR's. The clarification lets the ASI determine if you meet the FAR requirement by this new clarified definition.
Currently the ASI don't meet the IA criteria.
Paul

Nathan K. Hammond wrote: But you don't have too, look at the proposal again. No where do you have to prove you are "Actively Engaged;" only meet the requirements in 65.91 and 65.93 like you've always done.

Sure you will.

Applicants who are employed or participate part-time or occasional basis will be evaluated by the ASI to determine whether the applicant is actively engaged. The ASI will evaluate the scope of part-time or occasional activity based on the type of maintenance activity, including any special expertise required, and the quantity of maintenance activity performed. To evaluate the scope of the part-time or occasional maintenance activity, the ASI will use evidence or documentation provided by the applicant showing inspection, overhauling, repairing, preserving, or replacing parts on aircraft.

That will probably vary in different FSDO's, I'm sure they'll each set their own policy as to what it'll entail but at the very least it's going to include the question "what kind of maintenance do you preform on aircraft and on whose airplane?". If you don't do any or lie to the FAA about it you're going to get yourself in big trouble, one thing the Feds hate is getting lied to.

Bingo

Thanks Al

The big unknown being where is the FAA going to draw the line and how much harassment is there going to be?