He often does write about the positive side too, but negative stories always “trend” more than positive ones, so they get all of the attention.
The positive ones I see are the ones where Savvy is the hero. More like an infomercial to me.
Yes, some of the places I have called that wanted to perform annuals on a time and material basis rather than a fixed rate quote is problematic. If you want to quote me 100k for an annual that’s fine, I will say no and you won’t get the work (and you probably don’t need it anyways) but don’t tell me I will find out the bill after I already owe it, yea … no lol
That’s a hustle and an attempt to run up the bill
And thank you, it’s unfortunate that I don’t have a choice but to go through this onerous process so I can use my own private property but I suppose at least we are still a step or 2 behind Europe, I wonder what countries have less or no regulation?
So if I had an A&P and IA and I did my continuing Ed class online and did work on my one airplane and one annual a year I would be current based on current FARs
Did you just do nothing at all for years? Not even the continuing Ed class?
Doing one continuing Ed class seems pretty easy to get back in the saddle?
I don’t flat rate annuals but I do specialize in several models of rag and tube airplanes. I can tell a potential customer how many hours it is going to take me to do the inspection and what that cost is. Any repairs needed will have to be discussed at that time. There has to be some trust on both sides for sure.
That’s completely fair as long as I know the total price for inspection only, that’s not what I experienced, I think it’s an issue that is particularly bad in my state even if the trend is nation wide.
Your rate can be $1000 hr but then I better only be billed for 1 hr, all I care about is a total quotes price.
Its not reasonable for you to know every repair that might need to be done, also once I get my A&P you can cut me a list and I can do the repairs and return to service as well. That actually reduces the IAs liability as well.
I think an argument can be made that the overturning of Chevron deference will turn out to be disastrous. But whatever makes you a buck, eh?
I don’t think it will matter for ga because litigation costs are beyond most people
A real effect would be a right to repair law for planes making it legal for owners of ga aircraft not flying other people for hire to fix their own planes.
No, this is the first year I have not had a plane to work on. I am retired, but can’t get aviation out of my life or my head. I’m an addict. However, I am not that much of an addict that I want to work for a living. I could find another plane to take care of or do some annuals. However, I don’t want the responsibility of losing everything I have due to litigation that was not my fault. We’ve all seen Techs hung out to dry by owners, FAA, insurance companies, Engine and Airframe manufacturers etc.
To answer your question: If you have a plane to maintain, and you do the online refreshers for your IA, you are good to go.
No, I retired in 2010, at age 60. My choice. I kept my hand in aviation doing a variety of things plus consulting for a few years, and the last few years I’ve been helping a widow dispose of her husband’s aviation assets, sorting through many details, logbooks, and other things. The end of the job came last year, when we sold the last aircraft, a Cessna 190 that had been sitting for 5 years when I came along to help out. However, now that I don’t have that plane to put down as current experience per the FAR, I can’t keep my A&P in active status. So therefore my IA can’t be renewed. It’s my choice, but I felt I needed to highlight the change in the regs that many people to this day, are not aware of. This is a fairly recent change, sneaked in with little fanfare. As I understand it, many of the FAA folks are not happy about it either. Take a look at FAR 65. but here’s the guts of it.
§ 65.83 Recent experience requirements.
A certificated mechanic may not exercise the privileges of his certificate and rating unless, within the preceding 24 months-
(a) The Administrator has found that he is able to do that work; or
(b) He has, for at least 6 months-
(1) Served as a mechanic under his certificate and rating;
(2) Technically supervised other mechanics;
(3) Supervised, in an executive capacity, the maintenance or alteration of aircraft; or
(4)
Been engaged in any combination of paragraph (b) (1), (2), or (3) of this section.
The feds are tightening the noose around our collective necks in areas that don’t need change. The regulations are already clear enough. However, I see that the Moss interpretation or rule, whatever you want to call it, has some benefit. Oh, by the way, I ommitted a fact when I was talking about having an owner assist in annuals, or do the opening and closing: I forgot to say that the owner does an inspection and writes up any squawks. However, I do the inspection required by the FAR’s to satisfy myself that the aircraft is in condition to be approved for return to service. This of course includes a look around after the job is done, to make sure all panels are on and closed etc, and all the usual things that are part of the checklist. I don’t want to insult anyone, or criticise what they do regarding owner assisted or performed annuals. However, the onus stops with the IA who signs the job off and approves for return to service. FAA will not come after the owner, individual or other person who did the annual. They will only come after the IA who signed it off. That’s why my mantra has always been, “Trust but Vefify.” As IAs when we do an annual, we are trusting that every other person who has worked on the plane, including signing off annuals, has done the job properly. I think as a whole, us Techs, do a very good job. But we are always trusting that a properly licensed and qualified individual has performed the last inspection or repair or whatever.
I’ve spent my career in many different facets of aviation maintenance, including Airline maintenance, FBO, private aviation, Corporate aviation, flight engineering with appropriate ratings, I’ve also done consulting with legal entities for accident litigation etc. I’ve seen a lot, maybe too much. Im 74 now, but I love aviation!
??? I don’t know what you mean. How do I make a buck in this situation?
That’s interesting, although if the status quo was unwritten and the new rule is more the letter of the law, then the agency will probably get its way. The most likely exception would be if there were insufficient compliance with the Admin. Procedures Act. The feds run afoul of this on the regular, and have to put things on pause while they do a mandatory notice and comment period, etc.
I think this is the most likely scenario. This is a “redefinition” of a rule that’s been in effect for decades, and it will fundamentally change the way the industry operates. I don’t see how you can make that kind of monumental change on a whim.
So true. It is crazy how owners want to argue about a missing placard. Especially an AD required “Intentional Spins Prohibited” combined with the requirement for a “Spin Recovery Proceedure” placard in the same aircraft!
I am an A&P/IA and have been a mechanic for over 45 years. There is no substitute for a skilled technician with experience in the tasks being performed, being present on the shop floor. Not only can flight safety be compromised, life and limb are at risk in the shop. (See the Delta tire change catastrophe) An experienced person on a shop floor is using all 5 senses to be aware of what is occuring. We can hear a tool chattering, an improperly lubricated drill bit, the arrival home of a driven bearing race, and correct sound of a welding arc. Sense of smell may identify overheating and whether it is electrical or not, and perhaps cause further investigation that prevents an inflight fire. We can see a .001" imperfection and feel imperfections in a surface that the eye can’t discern. Remote supervision is too far removed for timely response to details like this.
Even as A&Ps we can’t perform a task unless we were supervised previously in that task by a certificated person. There are many A&Ps with minimal skill sets. When being tested by a DME, if you are asked to do a task (like a fabric repair) that you have never done before, you tell him so, and you will not be expected to perform that task on the practical exam. Try to BS the examiner and you will fail. You will be expected to know where to find approved data for the task, and to state that you would reach out to someone with experience in that task. One of the things I love most about aviation maintenance is the knowledge sharing aspect.
Even experienced and certificated mechanics can make errors. Mike Busch rails against MIFs (maintenance induced failures). As far as GA maintenance goes we do have AC 43-12A and the Coleal letter (2009) to guide pilots in maintaining their aircraft. Coleal suggested an update to 43-12A should probably be done, but of course the FAA has not done that either.
I think we really need to know what Moss is going to do with his letter. Maybe he found some very significant abuse, or perhaps it is a power play where somebody is going to be made an example of.
Your example A&P does not need an IA observing his detailed work. He is good to go. If engineering was done (work was in the pressurized vessel) a compliance inspection would need to be done. That being said, an interim inspection is a great idea. I know of one repair (jet aircraft) that had to be completely drilled out (and factory replacement skin scrapped) due to 3 out of hundreds of rivets not having the required edge distance in one panel. That being said, there are non A&Ps with experience like you cite.
First, the FAA is essentially an insurance corporation. As such in today’s optics, for example Boeing, the quality of work has declined over the decades. Management is more concerned about the bottom line and quality suffers. Pushed to complete an avionics install can introduce several critical factors, such as bonding to prevent massive discharges from lightning strikes. The same human failures occur in mechanical installs, maintenance, etc. Compare the aircraft to human health or computers. Trash in trash out. I wrote and published a book for techs long ago. Visited Cessna, worked at Beech Aircraft and got dragged into a lawsuit involving a pilot who installed his own avionics in his plane. When returned the next day the power unit voltage regulator failed went overvoltage and wiped out several systems, including the windshield, relays, indicators, etc. He sued when the shop insurance would not pay for repairs. In the end, the pilot and wife’s health was severely affected. The lawsuit lasted over five years. It was unlikely he was going to be flying, anytime soon. I managed to convince the judge, disregarding the fury of the four insurance suits, the pilot should be made whole for the damage incurred to his plane. However, to accomplish this I took the avionics off the table. It should not be reimbursed. Why? Simple, he was working in a plane, in a FOB, without oversight, and was not covered by insurance due to his decision to use the shop to perform the work. An insurance policy like this is common in automotive repair shops, so why be surprised it would be different in an aviation repair facility? The pilot’s previous attorneys had failed to resolve this issue. Continuing this lawsuit would be futile, making his and his wife’s lives even more tenuous. They were not completely satisfied, but time is not kind. Considering the history of the lawsuit failures, the cost of experts, and attorneys, not to mention the money behind the insurance company. They had to consider their options, and their health and sell the plane. All because a pilot was doing his own work without an inspector, inside a FOB knowing the restrictions of being a facility where his presence was a risk in of itself. My investigation confirmed the source of the damage. Regardless of his working in the plane the shop had the power unit operating for their own work. they turned it on after he left.
He was working on the plane without power for obvious reasons.
I like your analysis. My original thoughts were that Moss is unreasonably broad and I still think so.
I rethought my earlier comment on the costs of litigating the Moss interpretation as well as your story here.
As others have pointed out and I had not considered, the Moss interpretation could be subject to successful litigation under Relentless v. Department of Commerce, the key case which overturned the Chevron deference.
This interpretation by FAA counsel is broad, far reaching and upsets 60 years of field practice, but is just an agency interpretation which has not gone through formal rule making. It is just this type of action that I think the Court contemplated when it ruled that the fisheries industry could not be forced to bear oversight burdens by fiat of an agency and the Courts, not the agency, have final say in how far they can reach and interpret their rules and the law.
This gives me hope that a reasonable compromise can be reached and one that will probably be pretty close if not exactly the pre-existing practice, policy and interpretation.
I have worked on airplanes under the supervision of four a&p/IAs for 30+ years and probably have enough experience to get an a&p rating myself. This includes some activities I will not do to this day unless the A&P is on site and watching every move I make watching over my shoulder and insuring the job is done precisely correctly, like reinstalling a cylinder, despite the fact that I have R&R’d probably a dozen cylinders, read every manual, AC and SB each time before, during and after. Some things are just too important not to have the IA or powerplant mech looking at every move I make, and be paid for his knowledge and time. Others, such as a comprehensive borescope inspection where I take lots of pictures of everything all organized to present to my a&p then put the plugs back in finish the oil change on the 50 hour don’t require the same level of supervision.
With this ruling, I may go visit the local FSDO and have a talk about getting an a&p with the documented work I have done. If I ever do, though, I’ll still pay my A&P/IA to watch me do a cylinder, start to finish.
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