Welcome, Jan! This week, we've been having a discussion about the letter on the cover of Coupe Capers last month. It was a letter Paul Poberezny had sent to the EOC and other type clubs about developing a program for owner performed maintenance. I'll summarize it for those who don't get Coupe Capers or who didn't see that issue.
Poberezny said he had a meeting with the FAA regarding maintenance of
older GA
light aircraft. They discussed the possibility of developing a program for
owner performed maintenance on their personal aircraft. He said they
discussed
the fact that the many type clubs are the only repository for information
on
many of these aircraft and that their knowledge and cooperation is the
basis
for the continued operation of these aircraft.
Poberezny discussed the "repairman" program by which the home built
aircraft
builders are allowed to conduct all the maintenance including annual
inspections.
Many owners, he says, are restoring their older aircraft with minimal
oversight
by either FAA certificate persons or inspectors. He says this is enhanced
by
the training programs given by organizations or individuals who are highly
qualified, but not "FAA approved" to conduct this training. This is mainly
because the courses are tailored to a specific subject or aircraft.
Poberezny said that, while attending the FAA Kansas City meeting on aging
or
"orphaned aircraft," the FAA was looking for a solution for ensuring
continued
airworthiness of these aircraft.
Canada is adopting a program called the owner maintenance program which
would
DE-certify light aircraft and put them into a program similar to the
successful
homebuilt program. It is not a mandatory program, but the airplane owner's
choice to accomplish the maintenance ** or modifications ** which are at
the
owner's discretion. i.e. making them experimental. In Canada, the
maintainer
must be a licensed pilot and owner of the aircraft and the aircraft cannot
be
used for compensation. (Note: it may not be possible to bring the plane
back
out of this special category in Canada.)
Poberezny suggested a repairman certificate, awarded by a type club which
has
been delegated this authority by the FAA and which has prepared a
maintenance
training program for the particular aircraft and issued for the owner's
aircraft only (not for compensation or hire). Or, alternatively, the
repairman
certificate could be issued by the FAA similarly to the amateur-built
repairman
certificate based on completion of training and/or demonstration of
competence.
This would be administered by the type club.
The EAA Alexander Workshop program that is a hands-on program could be
modified
or extended so as to be recognized by the FAA in the possible issuance of
an
airman repair or maintenance certificate for a specific type of aircraft,
according to Poberezny.
-------------
Roy Prugh asked me to come over to his house to help him hammer out and
write
down ideas he had for implementing such a program. We spent four hours
working
over the concept and came up with the proposal below. Based on comments
made
here on the list, we've made some tweaks to the wording of the proposal
and
expect to make more. Large revisions are possible. This is just a starting
point document.
A major contribution was made by Vern Hendershott, that a big effort be
made to
create a multimedia resource CD with all the information mechanics, IAs
and
pilot maintainers would need to do the work. For example a we could have
an
annual inspection checklist with descriptions, drawings, photos, hot links
to
related reference (i.e. correct brake fluids), ADs, Service Bulletins and
Memorandum, the Type Specifications and more. Even in the absence of a
pilot
maintainer rating or any change in the current maintenance system, Vern's
proposal ** really ** should ** be followed through upon, IMHO.
Below is the proposal Roy and I put together for the creation of two new
maintenance options for those who would like to use them. These would not
be
intended to reduce the privileges or powers of currently rated mechanics
and
inspectors. You will also find a Microsoft Word-6 formatted attachment
with the
same proposal which can be viewed with the built-in Windows application
WordPad
or imported into any word processing program.
Please look through the proposal and post suggested revisions here to the
list,
as specific as possible, and all the supporting discussion you would like
to
toss in. Your special expertise is invaluable, Jan, just as we welcome
input
from everyone.
--
Ed Burkhead
Peoria, Ill.
Ercoupe N3802H, 415-D
-----------------------
Roy and Ed's proposal for new maintenance privileges, as modified this
week.
By Roy Prugh, EAA 466372 and Ed Burkhead, EAA 575594
Statement of problem:
Some antique aircraft no longer in production now have a small population
in
the fleet. Though some had a large population in the 1940s or 1950s, due
to
maintenance and incidents, there are few aircraft of these types now in
the
fleet. Some are orphans, some have minimal support from current type
certificate holders. These aircraft, such as Stinsons, Funk, Culver,
Swift,
short wing Piper, Ercoupe, 120/140 Cessnas and others have maintenance
issues
that are specific to the aircraft type. This has led to difficulty finding
mechanics and AIs with type-specific knowledge for maintenance.
After years of maintenance by mechanics with little experience in a rare
type,
a type-specific mechanic can often find thousands of dollars of
maintenance not
common to the general fleet. Some of this overlooked maintenance can be
critical to flight safety.
The FAA assumes that all inspection authorized A&P mechanics (IA) are
capable
of working on and approving work on any small aircraft. In spite of this,
we
have the problems listed above.
A need for type trained mechanics is apparent and has been suggested by
the EAA
in a recent letter sent to aircraft type clubs.
Suggested solutions:
The EAA or any type club that chooses could develop a type specific
certification program for A&P mechanics who would like to inspect or
sign-off
work on the aircraft type.
For normal annual maintenance, a pilot who has received the special
training
program would be allowed to perform and sign-off most annual inspections.
Open for discussion are the needed qualifications for the person
performing the
regular, annual inspection. We think that, even on unusual aircraft, it
is
valuable for a highly experienced, outside inspector to review all
maintenance
on a periodic basis, i.e. once every 3-5 years, provided the intervening
annual
maintenance is performed by an appropriately qualified person.
We would observe that an aircraft owner is ultimately responsible for the
mechanical state of the aircraft for every take-off - much more so than is
any
A&P or AI mechanic. We trust that the owner/pilot will monitor all parts
of
the aircraft and perform certain preventive maintenance.
In addition, an aircraft owner is dedicated to the aircraft type. This
dedication is intensified for out-of-the-ordinary aircraft.
As the aircraft owner of the out-of-the-ordinary aircraft takes the plane
to
the mechanic each year, it is often necessary to re-train the mechanic or
train
a new mechanic of the specific maintenance needs of the aircraft.
Our proposal is that pilots and A&Ps be trained in the necessary annual
maintenance of specific out-of-the-ordinary aircraft.
This training should be developed cooperatively by the specific aircraft's
type
club, the EAA and the FAA. It would specify what the pilot would need to
know
to perform annual inspections on that specific aircraft type.
The pilot type-specific maintenance authorization (TSM) will be a
certification
of skills necessary for regular maintenance of the aircraft. This would
be
similar to, but not as extensive as, the privileges allowed to
experimental
aircraft builders, a program with a long, successful history.
A second, higher level of rating, would be the type rated A&P
certification.
These TS A&Ps would have all AI privileges for the certified aircraft
types.
To exercise the privileges of these certifications, the person must be
member
of an organization which will distribute information related to the
aircraft
type.
Pilot TSM certification
The certification test should spell out very high minimum levels of
competence
for every task needed in a normal aircraft annual and normal maintenance
of
that specific aircraft type.
It should include regular replacement of parts (i.e. replace an alternator
or
magneto, or doing maintenance on the landing gear).
However, the Pilot TSM would not fabricate parts, recover wings or do
similar
maintenance without approval by an IA or a type-rated A&P. Pilot TSM
maintenance on the avionics of an IFR certified aircraft must be inspected
by
an IA to maintain the IFR certification.
The Pilot TSM rating would only apply to aircraft owned by that pilot or
to one
or two specific aircraft, listed by serial number, of which that person is
a
pilot. No maintenance may be performed under a Pilot TSM certification
"for
hire."
Type Rated A&P (TR A&P)
The certification test should spell out IA competence levels for the
specific
aircraft type as agreed between the FAA, the EAA and the type club. The
TR A&P
would not need IA skills for other aircraft types. The TR A&Ps must be a
certified A&P mechanic and, with the additional type specific
certification,
would have all the IA privileges for the aircraft type(s) for which they
are
certified.
Periodic and time-of-sale IA or TR A&P inspection
To ensure that all maintenance gets regular review, we suggest that Pilot
TSM
maintained aircraft have a time-of-sale inspection performed by an IA or a
TR
A&P. Similarly, no aircraft should go more than five years without an
annual
inspection reviewed by an IA or a TR A&P. Consideration should be made of
whether this interval should be once every five years, every four or every
three, depending on type of aircraft. We suggest that an IA or TR A&P
review
should not be needed more often than once every three years.
Benefits:
Those who fly in out-of-the-ordinary aircraft would be in an aircraft in
which
the pilot has special training to be a mechanic of that aircraft type,
enhancing safety.
The minimum maintenance of the aircraft would be specified by those
knowledgeable in the aircraft type. The certifying groups would create
minimum
inspection checklists for the aircraft type.
The ongoing maintenance would be performed by a certified Pilot TSM who
would
be performing maintenance throughout the year and before each flight.
The pilot of the aircraft, because of the training and certification,
would
have improved knowledge and consciousness of necessary maintenance.
Summary:
Flight safety for out-of-the-ordinary aircraft will be improved by
developing
type specific certification for maintenance of the aircraft
Due to the rarity of these aircraft, most general aviation mechanics won't
choose to undertake the extra training needed for these aircraft.
Therefore
pilot type specific maintenance (Pilot TSM) and type rated A&P (TR A&P)
certifications should be developed to improve the ongoing maintenance and
period inspections of these aircraft.
Finally, the improved safety will be best enhanced by training and
certifying
the person who has the most intense and long-term interest in the
aircraft's
safety, the pilot.
-- end of Roy & Ed's new maintenance privilege proposal --
-----------------------
-- Reprint of Vern Hendershott's excellent proposal: --
Lets start with just the "Statement of problem". The first and second
paragraphs are fine and correct. The third is correct but it does not
convey the correct problem IMHO. The problem is one of not having complete
and correct information to work from so the poor A&P who has to work on a
Coupe does the best he can with the very poor manuals we have available
and
with the information in the FAA publications. He may well miss something
that people with greater type knowledge would not have missed and this can
happen on any aircraft large or small old or new. The correct problem to
deal with first is the need to develop modern manuals that do provide
detailed information on proper maintenance and inspection requirements for
all of our Coupes. While we are doing this we can make them easy to use
and
have them written for a less technically advanced reader so that we may
all
be able to read and understand them. With today's computer technology it
would be simple (but a lot of hard work) to produce such a manual on CD
with hypertext links to any references so that when the page text said to
use 5606 to fill the strut we could click on 5606 and have details of what
it is pop up. If we are looking at a drawing we can zoom in and get a
better look and we can point to a part and click and get full details
including alternate parts. All items that come off the aircraft can be
covered with how to information including the tools needed, the list of
parts that must be changed or that frequently need to be changed such as
seals, gaskets or crush washers. We could also be told what service
products we would need such as lubricants, fluids or special sealants. In
short we can read and plan a job (including printing the instructions) and
be sure that we are ready to do the job before we start it. This is the
way
large aircraft are done and it will work for us even better.
I agree that some kind of "Repairman Certificate" is a good idea and that
it should be specific to a given owned aircraft much like the Experimental
Aircraft Builder gets. It should not be as broad in scope as we still do
not have the skills to make major changes with our limited knowledge in
most cases. I think Percy had a very good idea when he pointed out the
need
for training and supervision. First, we must know the minimum basics that
a
new A&P must learn in an academic sense, which I see as having to pass the
three A&P knowledge (written) tests and the Oral. Then a type specific
practical could be developed. Yes you will need to know a few things that
you will not find on your Coupe but that will not hurt you and if you take
one of the home study courses like the King course it can be done very
simply. What most of us do not have the time for is the 5000 hours of
experience required to be a "Real A&P". This is where the type specific
issue works we only need to learn the hard part about one aircraft. The
experience you could log working on your aircraft could count towards
becoming a full A&P and in time some would like to go on to this. I think
any Repairman needs to have some supervision and I would suggest that a
requirement for an A&P sponsor who would inspect the work done on the
aircraft at least once a year and certify that you have done the work
correctly under his sponsorship could be reasonable. He does not sign off
each job and he does not have to be there each time the aircraft is worked
on he is just there to make sure that mistakes are caught and that you
have
someone to call if you have a question that you should get answered before
you proceed.
I have seen much concern about the Annual inspection and the desire to get
away from IA's. IMHO this is not a good idea. I am sure that if the basic
maintenance is being done well any worthy IA will not be a problem and any
A&P with three years of current experience can get an IA if he wants to it
is not a real big deal. I agree that we could extend the Annual time
period
but the device to do that would be an Approved Maintenance Program. The
Approved Maintenance Program could have several levels of required checks
in it and the one that approximated the Annual could be set for the first
to occur either 300 hours or two calendar years (any combination the FAA
would accept) and this check could have the requirement that it be signed
off by an IA. All smaller check could be accomplished today by an A&P and
if we are successful we could have them done by a "Repairman".
I would see such an Approved Maintenance Program having detailed "Work
Cards" just like big aircraft with all the information you need to do that
particular maintenance task included. These frequently have drawings of
the
task, a list of tool, all the supplies and parts required to do the task
and even a man-hour standard time. It is a very effective system and if
used correctly by someone who has been trained in that system many of us
could do the work with no problems. That is how major large aircraft
maintenance facilities are able to use effectively non-certified mechanics
and still be sure that the work is done correctly.
Give it some thought, these are things small groups of people in the club
can do with the talents available and they will benefit all of us. I might
add that an aircraft that was clearly on such a maintenance program could
be expected to have a greater sales value as it would be in generally
better condition than most and it would be documented clearly as to what
had been done in the way of recent maintenance.
-- End of Vern Hendershott's maintenance document proposal
--
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