Opinion: Problems with how pilot/owner responsibility is addressed and trained

[kontiki]

I personally believe there are some fundamental problems with how aircraft owner responsibility is currently addressed and trained in General Aviation.
The Federal Regulations (CFR Title 14, FAR 3.5) defines airworthiness as (I paraphrase):
1 - must be in the approved configuration and
2 - must be maintained in a safe condition.
(This excludes the experimentals.)
In a airline (granted more demanding rules, more demanding operation) there are usually at least three departments devoted to aircraft operations.
1 -an engineering department that controls aircraft configuration and configuration changes, configuration management records, and maintains manuals and drawings to support continuous airworthiness and safe operation of modified aircraft.
2 - A Maintenance department that maintains the aircraft in a safe condition, accomplishes the mods developed or approved by the engineering department and maintains aircraft maintenance records.
3 - Of course the 3rd group is the Operations group containing the pilots working through all the rules for operations.

The airline model is probably not the only way to do it, but generally that's what I see now. It's probably a reflection of operator cert requirements. I can't speak for Military.

In General Aviation, you have the pilots, pilot/owners, mechanics and mechanic/inspectors doing everything. Now everyone in GA understands the oil changes, compression checks, and annual/100 hour inspection requirements.

The big problem I see is that most pilot owners and mechanics really don’t get much training on aircraft configuration management. Those are the topics related to TC, STCs, PMA, 337 & Major/Minor Alteration processes, Field Approvals and to some degree PMA etc.

Given that the very first requirement for airworthiness is “approved configuration,” technically, even if the mods are done properly (I said if), if you don't have the records, no one has any way to even know if plane is airworthy (much less maintained in a safe condition).

If you see controls in the airplane that aren't in the approved pilot hand book, and no records in the log book, you have no idea what you have.

If you find devices installed on the airplane with no paperwork documenting the changes to the electrical loads, no wiring diagrams, no STC, you really don't know what you have. And you really have no way to maintain or operate it until you do. Are the emergency checklists still valid? Who knows?

If you have equipment installed by an STC and there is no authorization to use letter for that STC, it’s also violation of both the FARs and public law.

I personally feel when you by an airplane, the paper airplane is very important if you expect to operate your airplane safety, expect it to be maintainable, expect it to have resale value. A lot of that responsibility falls on the owner, just like it’s the owner’s responsibility to make sure maintenance records are properly maintained.

On those matters, what I see and hear in GA looks more to me like a cargo cult. I think it's worse with very old airplanes with numerous modifications necessitated by obsolescence and fairly complex new requirements.

Many A&P/IAs never own an airplane and have no idea how or why some of the paperwork is even developed. I’m not sure I believe some of the folks at FAA do either. Maybe my perception will change as I enter my 3rd and 4th year of ownership, but right now, that’s how I see it. Just my 2 cents.

 

[Capt. Geoffrey Thorpe]

Or, one could argue that it is the obsession with paperwork that is killing general aviation. For example; hundreds of dollars for 5 dollar parts (switches, belts, etc.), maintenance deferred or even overlooked due to excessive cost and overhead. The claims that taking a back seat out renders an aircraft un-airworthy because of some detail on some document. etc. etc. etc.

I just put new pads and rotors on the wife's car. No big deal. No problem.

I re-lined the brakes on my E-AB aircraft. No big deal. No problem.

But, were I to do the same on a Cessna 150? O.M.G!!!!! One of the 7 deadly sins!

On what planet does this sort of thing make sense?

 

[JHW]

Agree with Geoff. I know my airplane inside and out because i've touched and fixed every inch of it. A thick ops manual won't substitute for getting your hands dirty.

 

[James331]

Or, one could argue that it is the obsession with paperwork that is killing general aviation. For example; hundreds of dollars for 5 dollar parts (switches, belts, etc.), maintenance deferred or even overlooked due to excessive cost and overhead. The claims that taking a back seat out renders an aircraft un-airworthy because of some detail on some document. etc. etc. etc.

I just put new pads and rotors on the wife's car. No big deal. No problem.

I re-lined the brakes on my E-AB aircraft. No big deal. No problem.

But, were I to do the same on a Cessna 150? O.M.G!!!!! One of the 7 deadly sins!

On what planet does this sort of thing make sense?

E X A C T L Y

 

[GlennAB1]

Ok, you open an aircraft supply company and charge automotive prices and see how long you last. I believe aircraft supply companies would all close and that would end GA in its self.

 

[kontiki]

I'm just saying every owner should be made aware of what's behind the processes involved and what the relative value of certain key documents are to safe flight and to some degree getting their moneys worth. They should get that before they buy an airplane. They should not be relying on providers to tell them what their responsibilities are. Looking over the ongoing confusion on some topics, I see a need. I can't really speak to many of the confusions authoritatively myself after a carrier in the business. Not without a lot of research anyway. I can only draw conclusions based on my own experience. Fortunately (or not) I work in an environment where we modify the heck out of old airplanes.

 

[Everskyward]

I'm just saying every owner should be made aware of what's behind the processes involved and what the relative value of certain key documents are to safe flight and to some degree getting their moneys worth. They should get that before they buy an airplane. They should not be relying on providers to tell them what their responsibilities are. Looking over the ongoing confusion on some topics, I see a need. I can't really speak to many of the confusions authoritatively myself after a carrier in the business. Not without a lot of research anyway. I can only draw conclusions based on my own experience. Fortunately (or not) I work in an environment where we modify the heck out of old airplanes.

This is probably a good idea but how would you provide this training and who would you provide it to? I don't think it should be part of the required training for a pilot rating because a large percentage of pilots never become owners.

I also think that there is a lot of controversy over many regulatory items based on the bickering I see in the Maintenance Bay forum. In most cases I don't know enough to determine which poster is correct.

 

[kontiki]

How about -> http://www.faa.gov/regulations_policies/handbooks_manuals/aviation/media/faa-h-8083-19A.pdf

 

[Everskyward]

How about -> http://www.faa.gov/regulations_policies/handbooks_manuals/aviation/media/faa-h-8083-19A.pdf

While that's a great overview, it doesn't go into the detail you specified in your first post.

 

[weirdjim]

Ok, you open an aircraft supply company and charge automotive prices and see how long you last. I believe aircraft supply companies would all close and that would end GA in its self.

And by the same token, you open an aircraft maintenance shop and try to comply with the LETTER (not the spirit) of the entirety of the FARs and see how long you last. The paperwork mill will kill you, so you do what you believe the reasonable person would do and you stay in business long enough to keep just a few of these old spam cans with air between their tires and the ground.

So along comes some freshly minted FAA puke and tells you that what you are doing is all wrong. If enough of us ***** about him (or her) to the FSDO manager, pretty soon that puke winds up transferred to inspecting ski installations out of the Anchorage FSDO in winter.

It is just a game, and you play it by the rules as you interpret them.

Jim

.

 

[hindsight2020]

exactly. It's a paperwork game that shouldn't be. So the entire premise of the OP is the problem itself. I should not need a de facto part 25 process in order to legally fly this motorized kite, yo. Part 23 re-write was DOA, so we're screwed. Frankly, I don't bemoan whatever scofflawing that may be going on. And no senator, I do not have any clue how that alternator and attitude indicator just keep on trucking after 10 years since the last installation entry on that musky paper logbook from the korean war, I'm just lucky

Here's another glass raised to ExAB, is all I got to say about this....

 

[bnt83]

There are some owners with multimillion dollar airplanes that are just as clueless as a bloke that just goes out and buys a cessna 150.

You don't need any type of certificate to buy an airplane.

I've noticed that pretty much all IA renewal seminars never really get into the actual process of approving a major repair or alteration. It's almost as if the FAA doesn't really care if mechanics and inspectors know what happens within the FAA.

 

[kontiki]

Just to clarify, I'm not talking about maintenance and inspections. Everyone knows how to maintain an aircraft. Pilots that will never own an aircraft are taught that.

I'm talking about explaining how different aircraft modifications are approved. When the advantages of one method outweighs another. When can you make a change simply by installing a different PMA part and when you cannot.

I'm talking about owners and operators knowing how to get their airplane modified, knowing what records they should preserve to show the resulting aircraft configuration is approved (and not intellectual property theft), and ensuring owners and operators have the information required to take it someplace for maintenance or further modification afterwards.

There are people that do have the money and desire to do everything per the regulations, that just have no guidelines on how to do that. There are commercial operators that want to mount special equipment on airplanes that may not know how. There may be speculators willing to fund development of innovations if they only knew more.

I'm not suggesting anyone undercut an A&P/IA's ability to maintain and inspect airplanes. Could it be that innovation in GA was actually killed by ignorance?

 

[weirdjim]

There are some owners with multimillion dollar airplanes that are just as clueless as a bloke that just goes out and buys a cessna 150.

You don't need any type of certificate to buy an airplane.

I've noticed that pretty much all IA renewal seminars never really get into the actual process of approving a major repair or alteration. It's almost as if the FAA doesn't really care if mechanics and inspectors know what happens within the FAA.

You are absolutely correct. I've just been through one of those IA renewal mills, just a GLEAM in my eye, and I know all about dirty spark plugs and mushy wood means a fungus infection of a wooden spar. Not a FREAKIN' word about the distinguishing between major and minor. Not a word about how to make a judgment call at all.

But I'll tell you this. I teach engineering drafting and I have for over 40 years. I commented on a couple of the drafting questions that they asked and I "missed" and commented to them that they were wrong, and told them via email "here is why you are wrong". Their answer comes back, "Oh, no, we are right and you are wrong." Some armchair expert in Florida who has never put a pencil to vellum has some bogus book that they took the question from and they have not a CLUE but the FAA lets them get away with this sort of crap.

Just like everything else, play the game, don't raise a lot of stink, and we all get along. Right or wrong, we all get along. I'm just old enough and about ready to punch out of this mess that I'm going to blow the whistle on stuff like this and a lot of the renewal mills are going to have to justify their curriculum to practicing industry professionals to get their ticket punched.

Jim

 

[murphey]

Just to clarify, I'm not talking about maintenance and inspections. Everyone knows how to maintain an aircraft. Pilots that will never own an aircraft are taught that.

I'm talking about explaining how different aircraft modifications are approved. When the advantages of one method outweighs another. When can you make a change simply by installing a different PMA part and when you cannot.

I'm talking about owners and operators knowing how to get their airplane modified, knowing what records they should preserve to show the resulting aircraft configuration is approved (and not intellectual property theft), and ensuring owners and operators have the information required to take it someplace for maintenance or further modification afterwards.

There are people that do have the money and desire to do everything per the regulations, that just have no guidelines on how to do that. There are commercial operators that want to mount special equipment on airplanes that may not know how. There may be speculators willing to fund development of innovations if they only knew more.

I'm not suggesting anyone undercut an A&P/IA's ability to maintain and inspect airplanes. Could it be that innovation in GA was actually killed by ignorance?

Many years ago, about 4 after I bought the cherokee, I was out of work. Usually, when that happens, I head over to the local university and take a class until I find a job. But this was the middle of the semester, can't wander in. But the local A&P school starts modules frequently. I ended up taking and completing the General portion of the A&P. Learned all about paperwork. Learned what the shop is taking about in between the words "here's the logbooks" and "here's the bill". Would have gone thru the A part, but I got a job, and by the time I could spare 8 months, the school was shut down.

 

[arnoha]

Problem: This was $300.

 

[bnt83]

Problem: This was $300.

View attachment 44761

Was the flap selector lever as worn out too? (The side that grinds against the detent plate)?

Did that include installing it or was that just the part?

 

[GlennAB1]

Problem: This was $300.

View attachment 44761

Make one. That's what I tell people when I hear them complain about the price of a new car.

 

[bnt83]

Make one. That's what I tell people when I hear them complain about the price of a new car.

Trophy shop probably would have for half that. Might need to take them some sheet for a blank tho.

 

[UngaWunga]

Trophy shop probably would have for half that. Might need to take them some sheet for a blank tho.

hand paint it and call it owner supplied?

What I would like to see is another tier of owner maintenance that would be allowed on certified planes if the owner could indicate somehow that they aren't idiots, have some mechanical aptitude, and can follow instructions. Like, take a few night classes at a tech school for planes, here's the new expanded list of things you can do. Hell, make them type specific, and have owners groups put together some curriculum or something. Have it cover Cessna 17*/18* and Cherokees, and that's half the GA fleet right there.

 

[weirdjim]

hand paint it and call it owner supplied?

What I would like to see is another tier of owner maintenance that would be allowed on certified planes if the owner could indicate somehow that they aren't idiots, have some mechanical aptitude, and can follow instructions. Like, take a few night classes at a tech school for planes, here's the new expanded list of things you can do. Hell, make them type specific, and have owners groups put together some curriculum or something. Have it cover Cessna 17*/18* and Cherokees, and that's half the GA fleet right there.

You've already got that tier. It is called the owner getting together with their A&P/IA and getting their approval IN ADVANCE with drawings and all. I"ve been doing that for over 40 years and not a hint of a problem.

Jim

 

[arnoha]

Was the flap selector lever as worn out too? (The side that grinds against the detent plate)?

Did that include installing it or was that just the part?

The plate was $271, so $300 with install. But the lever was fine.

For $271, I can't make the part myself. Cut and silkscreen a part to a quality level that renters won't notice? Yeah, that's not going to happen for a single part, even one that simple.

And, no, that doesn't make the price reasonable that I can't duplicate it for the same price. That argument would hold water if Cessna could replicate what I do for that kind of price. Of course they can't, but it doesn't mean that I could use my monopoly status ethically that way.