Ed Burkhead wrote: > Below are a distillation of the comments from the list and the revised > proposal. > > Roy Prugh and I are ready to send the revised proposal to the EOC and to
> the > EAA. There's a certainty that this can be no more than one of many > suggestions > sent in to them. It'll be interesting to see what comes from the final > negotiations between the EAA, the FAA and any type clubs which choose to > become > involved. > > I'll make sure it is clear this is a proposal sent by us, as > individuals, and > NOT a proposal from the Ercoupe Owners Club. > > Thanks to all of you for your input. You've helped us fix flaws and made > this a > document which, if it were implemented just as we have it now, we could > mostly > be happy. > > For those who like, please review the final section which is the revised > proposal. The revised proposal is also included as a Word 6 attachment. > > -- > Ed Burkhead > Peoria, Ill. > Ercoupe N3802H, 415-D > > > Distillation of comments received: > > From lots of people: > > Not for cheap maintenance > > Not a method for paper sign-offs > > Examples of IA signed-off annuals with bad maintenance & bad paperwork > > Examples of apparently unauthorized, un-signed-off owner maintenance > > Expressions that Coupes aren't special and no special certification is > needed > to do maintenance upon them. Emphasis that no proposal should reduce the > rights > of current A&Ps to work on Coupes or for IAs to work on or sign-off > Coupes. > Emphasis that it must NOT be required that only a type certified A&P or > AI > could work on Coupes. > > From George Frebert: > I read this in the recent AOPA magazine and I can see trouble. There are > people > who will actually do a thorough inspection on their airplanes and others > who > will do a "Paper Annual". The big excuse will be, "Hell, I only flew it > 20 > hours last year, what could it need? (As you know inactive airplanes > seem to > go to hell quicker than ones used on a regular basis. I think this "self > maintenance" could devalue our airplanes. The knowledge of using the > correct > hardware alone is HUGE! > > I have an agreement with my AP/IA that I open up the airplane, inspect > it on a > check sheet, then he comes back and checks over everything and signs it > off. I > put the airplane back together. The price generally runs about $300. > > I would rather see a list of HONEST and QUALIFIED AP/IAs that are > willing to do > annuals at a fair price. > > If I understand this right, if we do our own annual inspections under > this new > proposed program, the airplane now moves into the EXPERIMENTAL category. > > Right? > [Answer: Not our intention for this proposal. The maintainers would be > certified by the FAA to do the maintenance they do, the maintenance > allowed > would still have to conform to current rules, i.e. authorized parts, > technique, > etc., but an aircraft with it's most inspection signed by a Pilot TSM > could not > be used for compensation or hire. Due to this comment and discussion > from Glen > Ward, clause added to proposal to cover this concern.] > > Canadian de-certification program, converting old planes to experimental > From Steven Finkelman > I don't know if you know about this but Transport Canada has recently > approved > a plan to allow for full owner maintenance of some older aircraft > including > Coupes. > > It was started by Transport Canada about three years ago because of a > feeling > that the regs were making it prohibitive to maintain older aircraft. As > well > there was a feeling that > because of parts unavailability many older planes did not conform > strictly to > their type certificate. The third reason was that if was felt that the > expertise to maintain some of the > older types often rested more with the owners than the mechanics. (I my > own > case this is true. My plane has been apart three times and each time I > tell my > mechanic how it should be put together, and then he makes sure I have > done it > according to proper standards) > > The owner maintenance category has been a difficult one to get approved, > in > fact the new category is really not ready yet, but it is being allowed > to go > forward as an exemption from the airworthiness rules, until the category > is > finally approved, which is expected to take a couple more years (for > bureaucratic reasons.) > > Basically, what it does is allow a private aircraft owner (you must OWN > the > aircraft) to decertify it, similar to homebuilts. Yes you do have to > post a > warning similar to the EXPERIMENTAL warning. And once the aircraft is > decertified, recertifying it would be a nightmare. > > The rules say the category applies to planes that are out of production > and > fewer than 25 percent are in commercial service. (I guess they are > worried > about parts swapping.) Simply put it covers coups, pacers, Tripacers, > cubs > Aeroncas, etc. > > Now, why am I doing it. First, I think I can handle it...I've been > working on > my place for > years (with help) and am pretty confident in my abilities. I also know > where to > turn for help and when to call in an expert. > > I am tired of the annual routine of "your plane is airworthy on Aug 23 > but not > on Aug 24th" simply because of the calendar date. > > It will provide me a bit more leeway in maintaining the Coupe. (I am > installing > the spacers in my main gear legs, and was dreading getting Transport > Canada to > approve the spacer 337. The feds here don't always like American 337's. > > Finally, I believe that since the category is there for people like > myself, I > should avail myself of the right to use it. (we asked for it...now we > should > use it). > > I have heard many people say "the plane will lose value". Maybe, maybe > not. I > don't own my Coupe as an investment. If I counted dollars I would have > sold it > long ago. (does anyone really keep tab of all the costs?) > > So I will be glad to keep you all informed how I fare. As I said it is > not a > solution for everyone, but I think it is right for me. > > > From Spike Kavalench > In a nutshell, if an aircraft is on the list (and most older out of > production > planes are), and once the plane has been switched to the owner > maintenance > category, the owner, provided he has a pilot's license or permit, may > carry out > and sign for maintenance on his airplane. No special training required. > This > includes modifications and deviations from the original equipment. > > There are a few hoops to jump through first, including stamping X's all > over > anything that has a serial number on it. (Engine, prop, and airframe for > sure.), filling out the required paperwork, maybe going through an MOT > inspection (if the airplane was rebuilt or restored) and paying the > smallish > fee. As a result of all this, I don't believe recertification will be > that > simple. > > We also have the pleasure of having to paste a huge placard on the side > of the > plane in both official languages of course, warning potential passengers > of the > status of the aircraft's airworthiness or lack thereof, and sagely > advising > onlookers that they are taking their very lives in their own hands > simply by > standing near it. > > For all the details on the Canadian Owner Maintenance program, go to > http://www.copanational.org > > > From Rolly Meisel, Port Colborne, Ontario, Canda: > According to articles published in Canadian General Aviation News, it > will be > nearly impossible to change a registration from the owner-maintained > category > back to a standard category. I'm not sure if this will apply to an > airplane > being exported to the US. As I understand it, moving to the > owner-maintained > category gives the owner much the same rights as a homebuilt. The > aircraft may > be modified with non-certified parts or even a non-certified engine. > Obviously, both Transport Canada and the FAA would be reluctant to > re-certify > an aircraft which may have been modified in many ways from the original > type > certificate. > > > From Craig Hinton: > I think it would be a big help (United States) if we could just go > longer (say > 100-125 hours or 24 months, which ever comes first) between inspections. > My > coupe shows wear and tear from taking things apart constantly for > annuals. If > the commercial types can go 100 hrs between periodic inspections it > would seem > reasonable we could! > > Rephrased for clarification: If not used for compensation or hire, an > aircraft > must be inspected every 24 months or 125 hours, whichever is less (but > it is > not necessary to inspect more than once every 12 months no matter how > many > hours are flown). [Ed] > Instead of pushing for this controversial proposal maybe we should try > to get the list of items allowed under Part 43 expanded. I.E, > repair/replace brake pucks,master cyl,gen/starter/oleo struts, etc. > Staying away from critical items like mags,structural repairs,and engine > overhauls. This in addition to my suggestion for 125 hrs or 24 months > for annuals. Craig Hinton 2623H > From Percy Wood: > I agree that something has to be done about maintenance. The FAA is > really > geared up to protect the public, and not the private flyer - especially > if he > is out over the countryside or the desert. > > So I'm going to go with Ed and Roy as stated. Implementation, I feel, > should > be like getting any other rating - so much time "dual." Now, I know > that you > do not just go to class and pass the tests to get you're A&P (oops - > very > un-PC! Aircraft Maintenance Technician, please!) You actually "log" so > many > hours doing the tasks. I think the owner should start a log for his > maintenance, just like he has for his flying. Yes, like dual flying > time, you > have to pay someone already certified. That way the current Aircraft > Maintenance Technician (AMT) can get paid - which will make the changes > a lot > more acceptable to them! > > From Mike Shipley: > If our coupes had always been maintained by those who are familiar with > them, > they would have been in better shape when we purchased them. AND if we > could > really trust our own existing A & P skills, we wouldn't have bought a > piece of > PURE CRAP to begin with. Although additional education can be an > beneficial, > it isn't always necessary. > > From Glen Ward: > It is just that I don't want to see them making type ratings mandatory > for an > A&P, as far as regular A&P privileges are concerned. The idea to type > rate an > A&P to give them IA privileges for a particular plane is a really good > one. > > One thing that I think somebody needs to make a proposal to the FAA for > - to > make a required, type-specific checklist for annuals. This is so > obvious that > they should have done it long ago. They need to have an official volume > of > checklists which they can sell on CD-ROM which will cover the things to > go over > on each type. This would be simple since most groups already have such > a > checklist! > > I wonder if the ever tighter insurance companies will even insure an > owner-maintained factory plane when they first switch the system over. > > From Andy: > To the nay-sayers... remember this is an OPTION and not a requirement. > You may > choose to continue on with it the way it is... or to participate. As far > as the > drop in value? If I personally was buying a previously certified > aircraft from > someone who had participated in this program, it would be no different > than > buying an experimental aircraft that was built in a garage. I'd rather > purchase > an Ercoupe properly maintained by it's proud owner than a Coupe that has > been > "annualed" and had many overlooked problem areas for years by an A&P > that > doesn't understand vintage aircraft. > > I have a few friends that are A&Ps. Straight out of school they walked > down the > street to Boeing and hired on. Do these guys have what it takes to work > on my > coupe efficiently? Fresh out of school when the info on fabric covering > and > small engine maintenance was clear in their minds I'd say yes. Years > after > their schooling on General Aviation gave way to what is required for > their > occupational requirements (Airliner production, Jet > powerplants, interior, high tech avionics, wiring... ) I'd have to say > No. > Until something like this happens in the U.S. I will appreciate the > General > Aviation A&P and learn as much as I can. I fear that the competent A&P > (for > light aircraft) will go where the BIG money is ... leaving small > aircraft > owners to suffer. > > From David: > IMHO, Type Rating A&Ps is a very bad idea. If the FAA likes that idea, > they > will require it. Then, unpopular and orphan planes will have very few > qualified > A&Ps available. How would it be if there were only a handful of > Ercoupe-qualified A&Ps in the entire country? Would you get a ferry > permit and > fly hundreds of miles to get certain repairs done (as > well as paying more)? > > Coupes are very easy to repair and inspect. The published checklists > I've read > don't contain anything that isn't done on many other aircraft and the > parts > used are similar as well. While there are some portions of the aircraft > not > completely illustrated in the parts > books, AC43.13 seems to cover those instances. I also would not want to > have > some of the folklore I've read about coupes in "Coupe Capers" or this > mail > reflector codified into law that I am required to follow. > > Except for the well-meaning proposal to improve documentation, I'm not > sure > anything else I've heard is more than a means to pay less for > maintenance by > doing-it-yourself. Unfortunately, the cost of good documentation will be > far > beyond anything most people will pay - how many requests are there to > this list > that the requester could have gotten from the $30 worth of books he > should have > already purchased? This proposal will result in a lot of junk flying > around and > ultimately higher costs for the certified aircraft remaining. > > --> Ed Burkhead wrote: We should probably add the stipulation that, not > only > can the Pilot Type Specific Maintainer certificate not be used for > compensation, but the plane maintained by this would not be eligible > for use > for compensation or hire until next return to service after an annual or > 100 > hour inspection by an IA. <-- > > IMHO, this will be about as possible as returning an experimental > aircraft to > Normal Category. While theoretically possible, IAs will shy away from > this work > because of the liability incurred if they miss any work the owner has > performed. It will also be far more expensive than a normal annual, so > owners > will not have this done. > > > > -------------------------- > Proposal > -------------------------- > > 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 person who has received the special > training > program would be allowed to perform and sign-off the annual inspection. > > 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 experience, 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. > > Aircraft certification > Aircraft with annual inspections signed-off by a Pilot TSM will remain > fully > certificated but may not be used for compensation or hire until returned > to > service after an annual or 100 hour inspection by an IA or TR A&P. TR > A&P > maintained aircraft will remain fully certificated and may be used for > compensation or hire. > > 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. __________________________________________________________________________ ______ To unsubscribe from this list please send mailto:[EMAIL PROTECTED] ___________________________________________________________ T O P I C A The Email You Want. http://www.topica.com/t/16 Newsletters, Tips and Discussions on Your Favorite Topics
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