gypsywagon wrote:I wanted to bring this back up, may be more appropriate for restoration/home build, may be a question already answered. Can anyone who is A/P like Bigrenna tell a cert. pilot, such as myself, how much interior work he can do on his own plane and be within the regs of CFR 43.3? It is not feasible for someone such as myself to get the hours in for an A/P although that would be awesome so the next best thing is to determine how far I can go with a restoration myself as a cert. pilot and what must be pushed off to a certified A/P, resto shop.
Thanks,
H Nay

Check out #11. Include details of what work you performed in your logbook with your signature, certificate number, and the kind of certificate held by the person approving the work. In your case, a private pilot (PP).


The 31 items that you CAN do yourself as an owner of an aircraft:

1. Removal, installation, and repair of landing gear tires.

2. Replacing elastic shock absorber cords on landing gear.

3. Servicing landing gear shock struts by adding oil, air, or both.

4. Servicing landing gear wheel bearings, such as cleaning and greasing.

5. Replacing defective safety wiring or cotter keys.

6. Lubrication not requiring disassembly other than removal of nonstructural items such as cover plates, cowlings, and fairings.

7. Making simple fabric patches not requiring rib stitching or the removal of structural parts or control surfaces. In the case of balloons, the making of small fabric repairs to envelopes (as defined in, and in accordance with, the balloon manufacturers' instructions) not requiring load tape repair or replacement.

8. Replenishing hydraulic fluid in the hydraulic reservoir.

9. Refinishing decorative coating of fuselage, balloon baskets, wings tail group surfaces (excluding balanced control surfaces), fairings, cowlings, landing gear, cabin, or cockpit interior when removal or disassembly of any primary structure or operating system is not required.

10. Applying preservative or protective material to components where no disassembly of any primary structure or operating system is involved and where such coating is not prohibited or is not contrary to good practices.

11. Repairing upholstery and decorative furnishings of the cabin, cockpit, or balloon basket interior when the repairing does not require disassembly of any primary structure or operating system or interfere with an operating system or affect the primary structure of the aircraft.

12. Making small simple repairs to fairings, nonstructural cover plates, cowlings, and small patches and reinforcements not changing the contour so as to interfere with proper air flow.

13. Replacing side windows where that work does not interfere with the structure or any operating system such as controls, electrical equipment, etc.

14. Replacing safety belts.

15. Replacing seats or seat parts with replacement parts approved for the aircraft, not involving disassembly of any primary structure or operating system.

16. Trouble shooting and repairing broken circuits in landing light wiring circuits.

17. Replacing bulbs, reflectors, and lenses of position and landing lights.

18. Replacing wheels and skis where no weight and balance computation is involved.

19. Replacing any cowling not requiring removal of the propeller or disconnection of flight controls.

20. Replacing or cleaning spark plugs and setting of spark plug gap clearance.

21. Replacing any hose connection except hydraulic connections.

22. Replacing prefabricated fuel lines.

23. Cleaning or replacing fuel and oil strainers or filter elements.

24. Replacing and servicing batteries.

25. Cleaning of balloon burner pilot and main nozzles in accordance with the balloon manufacturer's instructions.

26. Replacement or adjustment of nonstructural standard fasteners incidental to operations.

27. The interchange of balloon baskets and burners on envelopes when the basket or burner is designated as interchangeable in the balloon type certificate data and the baskets and burners are specifically designed for quick removal and installation.

28. The installations of anti-misfueling devices to reduce the diameter of fuel tank filler openings provided the specific device has been made a part of the aircraft type certificate data by the aircraft manufacturer, the aircraft manufacturer has provided FAA-approved instructions for installation of the specific device, and installation does not involve the disassembly of the existing tank filler opening.

29. Removing, checking, and replacing magnetic chip detectors.

30. Removing and replacing self-contained, front instrument panel-mounted navigation and communication devices that employ tray-mounted connectors that connect the unit when the unit is installed into the instrument panel, (excluding automatic flight control systems, transponders and microwave frequency distance measuring equipment (DME)).

The approved unit must be designed to be readily and repeatedly removed and replaced, and pertinent instructions must be provided. Prior to the unit's intended use, an operational check must be performed in accordance with the applicable sections of part 91.

31. Updating self-contained, front instrument panel-mounted Air Traffic Control (ATC) navigational software data bases (excluding those of automatic flight control systems, transponders and microwave frequency distance measuring equipment (DME), provided no disassembly of the unit is required and pertinent instructions are provided. Prior to the unit's intended use, an operational check must be performed in accordance with applicable sections of part 91.

There's the FAA list of owner-approved work, but the reality is you can do anything "under supervision". This doesn't mean an IA stands over you the entire time, but they will need to periodically inspect your work at minimum, and it needs to be work you're skilled enough to accomplish within the FAA's maintenance guidelines. As you can imagine, it also requires a special and trusting relationship with the IA who will attach his name/reputation/certification to your work. I would also encourage you to get familiar with FAA owner fabricated parts rules, including the vintage aircraft modifications. At some point most of this will be necessary to pursue an A&P from logged time as owner-approved maintenance is limited by design.

In my 1957 182 restoration, the only way it remotely makes sense to do this kind of project is by doing it myself. I'm not an A&P, but I started doing small projects building trust with one. When it came time to do major work, we had enough familiarity that he was willing to let me take on the tasks I felt I could do. We're also very clear on the part where I stop before I get in over my head, and he either shows it to me, or I have him do it. I've still done a large portion of the work though, and the things I am comfortable taking on now are greater than they were at the start. I haven't exercised the owner-fab rules too much yet, but will be doing more of that later on. Finding someone to let you do these things isn't common, but not impossible either.

I've been logging my work, and while this alone won't be enough to get a certification, I've made serious headway in that aspect. I haven't covered everything listed in Bigrenna's list of skills and won't with a fixed-gear 182, but have hit on quite a number of those things. I believe the FAA's time guidance also isn't about just demonstrating the skill once, but in having enough varied expertise that you could be trusted to get paid for the work, since that's the point in their eyes. It's seemingly onerous but they want to make sure you won't kill people by doing shitty work. On the other hand, I have fixed a number of questionable items done by 'approved' people, so I think there's some variance in how deeply they probe your skillset.

I think it's a good goal in any event. Knowing how the machine works helps me fly it better, understand why it's doing what it is, and realize when glitches are actual problems vs quirks. On top of that it's just a really cool experience, even in the moments when I'm cussing out some bastard post-war Cessna engineer from decades ago or taping up bloody wounds. In the early 50's a team of people designed this machine, and then a little later some other group of people put it together. 61 years later, I am gaining practical, useful knowledge through them and making their creation even better. Maybe I will get an A&P cert out of that effort eventually, but for sure will have something to show for it when I'm done.

WOW! Thanks for the reply that is exactly what I was looking for. Your words are ringing loud and clear, go find and IA and befriend them, help them so they may help you at some point, take on small projects within the guidelines and go from there.
THank you so much for the answers you have given.
H Nay

There is a big grey area there you can take advantage of. You can do nearly any work you please on your airplane "under supervision' of an A&P. As little as a phone call is considered supervision, obviously they need to be comfortable with your work and sign it off if its over the scope of owner maintenance.

Just this past spring (2018) I penned a letter for a friend to take to FSDO to get the signiture to take the test. I have been supervising his work for the past two-three years, he was doing full blown restorations of tube/fabric planes under my supervision. I would just make a point to stop in and check on him every couple weeks, or at least make sure to check out the project progress before he put fabric on and then do the final inspections, annual and paperwork at the end. He took many photos of the work he did and when he felt like he had enough (again, 2-3 years worth of restoration projects) he printed out pictures and took my letter basically saying he was of good character and that I witnessed the work he was claiming to be his own to be true. In less than 30 mins with FSDO he had the signiture to go take the A&P tests. Then book the course at Baker, you can walk in there with basically zero knowledge and come out with your A&P two weeks later.

Nowhere did he claim to meet the "minimum requirements" nor did I say he did in the letter I wrote, he just sat down with FSDO, discussed his experience and backed it up with photo evidence and my letter (He may have gotten a letter from another A&P as well) and the FSDO guy decided to give him the signature. I think they have a lot of leeway and ultimately it is up to the person you get at FSDO to accept what you bring in as experience.

For this to work, you obviously need a good relationship with an A&P who absolutely trusts you to supervise some work that is over the scope of owner maintenance, I really trusted my "apprentice" and he absolutely deserved to get the certification, he was (still is) beautifully restoring and painting tube & fabric planes for a living. I've been working on airplanes for about 12 years now, have my A&P and IA, my "apprentice" has so much more knowledge than I do when it comes to tube/fabric aircraft and antique aircraft in general. I never charged him anything other than my standard rates for the annual inspections I did on his customers airplanes. I would happily vouch for someone else in the same situation if it were to come up again and I know there are plenty other mechanics like me out there that would do the same. I think some guys don't like to do this in fear of competition, I don't look at it as competition when more guys get their A&P's, in fact I really like having more of us around to bounce questions off of and seek advice.

Lastly, another reason more people don't go this route is they either don't understand it or they are too lazy to follow through with it. It is in no way the "easy" way, you still need to produce evidence of work that the FDSO guy deems meets the requirements of the experience rule. You still need to actually do the work, its not something someone else is going to do for you, you need to take the reigns and log/photograph that work. You could get a letter from each A&P that witnesses you or just have someone endorse your logs along the way, I'm not exactly sure what the FSDO needs if anything from a licensed A&P or IA to back up your experience but I'm sure it cant hurt and in my friends case he went in with a binder full of photos and a letter or two. He said the FDSO guy picked out a handful of photos and asked him some questions about what was going on in them, his answers seemed to appease the guy.

Bump. Has anyone done this recently? I’ve been logging time since 2018, still a ways to go but just curious if there is anything new to know on this topic.

Last summer my local FSDO reviewed my maintenance logbooks along with a letter from my IA detailing all the work I've done, and they were happy enough to sign me off to go take my written, oral, and practical tests.

I've had zero formal training. Never attended any school or courses of any kind.

I passed everything and have had my A&P certification for a little more than a year.

Nothing really changed for me after getting the rating. I'm now able to sign some more stuff myself but my IA still has to take care of most everything on all our certified aircraft.

Aryana wrote:Last summer my local FSDO reviewed my maintenance logbooks along with a letter from my IA detailing all the work I've done, and they were happy enough to sign me off to go take my written, oral, and practical tests.

I've had zero formal training. Never attended any school or courses of any kind.

I passed everything and have had my A&P certification for a little more than a year.

Nothing really changed for me after getting the rating. I'm now able to sign some more stuff myself but my IA still has to take care of most everything on all our certified aircraft.

Do you recall how many hours you had when you were signed off?

hamer wrote:

Aryana wrote:Last summer my local FSDO reviewed my maintenance logbooks along with a letter from my IA detailing all the work I've done, and they were happy enough to sign me off to go take my written, oral, and practical tests.

I've had zero formal training. Never attended any school or courses of any kind.

I passed everything and have had my A&P certification for a little more than a year.

Nothing really changed for me after getting the rating. I'm now able to sign some more stuff myself but my IA still has to take care of most everything on all our certified aircraft.

Do you recall how many hours you had when you were signed off?

I can go look up the exact numbers in my logbook and report back. I was in excess of the requirement and that's going by actual hours of work, not calendar days.

A few of the pictures I had of me learning how to cover a Champ for the first time at 12 years old put a smile on the inspectors face as he audited my logs.

Gotcha, I think the requirement is around 4500 or so, I’ve heard some people not having all 4500 but still getting a sign off because of a letter from an IA basically stating they are qualified. But I haven’t really met anyone who has done that recently.

You just have to meet the requirements in FAR 65.71-65.77

"You must get 18 months of practical experience with either power plants or airframes, or 30 months of practical experience working on both at the same time"

https://www.faa.gov/mechanics/become/basic/

There is no hourly requirement listed, it's only based on months.

One inspector we encountered said 30 months = 130 weeks, & 40 hours * 130 weeks = 5,200 hours to meet the 30 month requirement. That's based on equivalency with a full time school program (according to him).

Remember that FAA inspectors are just regular people, and each person is different from the next.

3 people in my family have had different inspectors at our local FSDO review the logged experience and a letter from an IA, and each inspector interpreted and applied the 30 months of practical experience requirement in a different way.

One inspector didn't even look at the log books, he just conducted an interview asking about the experience referred to in the letter from the IA.

Another inspector flat out refused to sign any 8610-2 forms for people based on practical
experience and an IA recommendation. He believed a FAA approved full time school/program or DD-214 for military experience was the only acceptable way to qualify to take the test. Move on to the next inspector!

So keep in mind you're subject to satisfying the requirements of a human being and how they interpret the requirement.

The best advice I can give you is bring your IA who is writing your recommendation letter when you meet with the inspector. Hopefully your IA has a good track record with the FSDO and has a lot of experience under their belt. It looks better and less questionable to the inspector.

Also connect personally with the inspector. Ask about their history, how they came to be in aviation, how many mechanics they have signed off over the years, any tips for how to prepare for the tests, advice to you as an aspiring mechanic, etc. My interview was a little more than an hour and we spent a great deal of time letting the inspector tell us all about himself. LOL!

So just like many other things with the FAA, your experience may vary (greatly). It's like getting a field approval for something. One office/inspector may bless it, another may not. Such is life with the FAA.

hamer wrote:
Do you recall how many hours you had when you were signed off?

5,832 hours (145.8 weeks @ 40 hours per week) total experience logged over 29 years