what can be logged toward repairman cert or A & P?

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Aviacs

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Many operations toward building or repairing aircraft include tool making.
How much of that can be logged toward the Repairman's Certification, or even an A & P?

Time spent machining and building simple tools for, say, alignments of aircraft assemblies; or fixtures for machining parts themselves, would seem to be eligible?
How about more extensive generalized prep work?
How about a wing alignment fixture for someone else's project but no actual work on re-skinning or other parts of the AC?

For instance, i'm currently building an oven to blow a canopy.
(all theory at this point, performance TBD :) )
The Q is, is all of the time loggable? If not, some would seem to be appropriate? How to apportion?

The way this forum trends, people tend to focus on every aspect but the actual Q's :)
So more info includes:

I am working to miscegenate parts from different experimental airplanes with 2 shortish term objectives, & one long term:
S1.) obtain E/AB AWC (if possible as opposed to Exhibition)
S2.) include a number of convenient improvements not envisioned in the original design including wet wings, flaps, inboard walk/step, etc. . As well as necessary structure & mods to fit me, including raised canopy, increasing tail/vertical stab & rudder surface, etc.
L1.) potential retirement age A & P: given work i do/have done on airplanes including owned and others, it could have been logged over the years. Having my own airplane again makes that interesting.

Aerodynamicist friend (PhD) is involved in the specifics of the project. Our FSDO is friendly toward apprentice route toward A & P.
After a long Covid lapse, they will present in our hanagar again in Sept, so i can address some of the specifics with the reps on site.

Again, my actual Q to start prepping and not "losing" more loggable time is: How much of toolmaking is elibible to be logged, how should it be apportioned?

Thanks!
smt
 

BJC

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TFF

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All of it can be logged. I know of a few who got their repairman certificate and their A&P.

Think though, repairman only count for the one specific homebuilt. If you work on ten homebuilts, for the homebuilts that’s ten different repairman certificates you are trying to quantify for. For A&P ten can be added together.

For the A&P, it has to be logged like a pilot log. What you did, amount of work , and date. It has to add up to a full time job working for 3 years. If you complete an airplane, probably not fast build, start to finish that is usually enough.

If you worked on a certified plane , you need the signature of the A&P you were working under just like a CFI.

When you think you have enough time, you take your documentation to the FSDO, and they will review it and if it’s enough, they will sign the recommendation form for you to test. What you might get stymied with is turbine engine knowledge and time. You are required to have training in all facets, so it’s not just working on rudders for 3 years.
 

Turd Ferguson

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Our FSDO is friendly toward apprentice route toward A & P.
My advice would be to have the friendly FSDO provide written guidance on how to comply with language in FAR 65.77 where it says: "documentary evidence, satisfactory to the Administrator"

I also suggest making face contact with the ASI at the FSDO at every opportunity to let them know you are still working on gaining practical experience. You don't want to walk in 4 yrs from now, a total stranger and say "I wan't my practical experience signoff"

Please note there are some "gotcha's" in the FAA 8900.1 manual highlighted below:

]C. Presenting Documented Evidence. Applicants who only present evidence in the form of documented practical experience in maintaining airframes and/or powerplants must go through a FSDO/International Field Office (IFO) to receive authorization to test. Applicants must present at least 18 months of practical experience appropriate to the rating requested. For a Mechanic Certificate with both ratings, the requirement is 30 months of experience concurrently performing the duties appropriate to both ratings. If the applicant has not met the required 30 months concurrently performing the duties appropriate to both ratings, calculate each rating separately using the 18-month requirement for each. The practical experience must provide the applicant with basic knowledge of and skills in the procedures, practices, materials, tools, machine tools, and equipment used in aircraft construction, alteration, maintenance, and inspection. All applicants who apply based on experience only must have verifiable experience in 50 percent of the subject areas listed for the rating sought (refer to part 147 appendices B, C, and D) in order to be eligible. There is no expectation that an applicant be highly proficient in overhauls, major repairs, or major alterations in the minimum 18/30 months of experience. Types of practical experience that may be evaluated are (see evaluating procedures in subparagraph 5-1134D):
1) Practical experience gained on U.S.-registered aircraft.
2) Practical experience gained while serving in a U.S. Military aviation maintenance occupation. Military experience/records may be evaluated for authorization to take the mechanic knowledge test based on documented experience and Military Occupational Specialty (MOS) code, Air Force Specialty Code (AFSC), or Navy Enlisted Code (NEC), as authorized in § 65.77. See Figure 5-135, Military Occupational Specialty Codes, for FAA-accepted military codes.
3) Practical experience gained in foreign-registered civilian and military aircraft.
4) Practical experience gained from a combination of all of the above to meet the 18/30-month experience requirement.
NOTE: Manufacturing of any type of aircraft, including amateur-built experimental, does not count towards practical experience. However, practical experience gained on amateur-built aircraft after the aircraft has received an Airworthiness Certificate may count.

NOTE: During the evaluation of part-time practical aviation maintenance experience, the applicant must document an equivalent of 18 months for each rating individually, or 30 months concurrently, of experience for both ratings. This is based on a standard workweek that has 8 hours per day for 5 days per week, or a 40-hour workweek, or a total of approximately 160 hours per month. The time is cumulative, but the days, weeks, and months are not required to be consecutive. The practical experience for non-JSAMTCC COE, and those who do not hold a part 147 graduation certificate, must present evidence of experience to an authorized person (see paragraph 5-1132).
*It clearly says building an E-A/B does not count. I have seen ASI's sign off on that as acceptable.

*Both the reg and 8900 manual suggest experience gained while "performing the procedures, practices, materials, tools, machine tools, and equipment generally used in constructing, maintaining, or altering airframes, or powerplants" can be used. My liberal interpretation of that is a "jig" is a tool and is standard practice for some operations. So using the tool should count, building it, not so sure.

*The guidance calls for a broad experience background, 50% of the subject matter. Working on only one type component for 30 months is not going to float.

*The 160 hrs per month seems to suggest an accurate time record should be kept. This needs to be clarified with an ASI.
 
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GeeZee

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Aviacs

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All of it can be logged.
That is good to know.
Should have started 40 years ago. :(
My experience is not deep, but you look back and it accumulates.
I certainly could not begin to think about testing any time soon, but it gives encouragement to where to start filling in gaps.

I know of a few who got their repairman certificate and their A&P.
Me too, hence the Q.

For the A&P, it has to be logged like a pilot log. What you did, amount of work , and date. It has to add up to a full time job working for 3 years. If you complete an airplane, probably not fast build, start to finish that is usually enough.
Do you reccommend any of the logs for beginning the task such as
or other?

If you worked on a certified plane , you need the signature of the A&P you were working under just like a CFI.
Always had the (certified) airplane logs signed. Did not keep personal records.

When you think you have enough time, you take your documentation to the FSDO, and they will review it and if it’s enough, they will sign the recommendation form for you to test. What you might get stymied with is turbine engine knowledge and time. You are required to have training in all facets, so it’s not just working on rudders for 3 years.
My biggest interest at the moment is to try to get the finished airplane certified under E/AB.
This is still my Sonerai 2 plans-built in Canada, potentially with wings from a RV3, and "other modifications & parts" as we've discussed in previous posts. Since extensive mods need made to fit me, how much further can i take it to make it a new airplane, and how much of that = 51%. Hence, documenting and logging time for all mods would seem useful.

I'm currently building a rather large (experimental :) )oven for the canopy and realized it was past 40 hrs. It is photo documented for other reasons.
Whether this is "loggable" or not is a question, but i'll keep records (Like i did for construction and machine shop contracts) until discussing with the FSDO reps at our meeting in Sept. From this forum, is sounds like "Kinda depends"? I also wondered if anyone had experience building extensive fixttures, like, say a fixture to re-skin the center section of a large airplane, and logged it? Or any similar airplane specific tooling?

Good info so far.
Thanks!
smt
 

gtae07

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I briefly inquired about this with the local FSDO and they told me I had to log all my time and have it "supervised" by an A&P.

I then decided to ask the local community college that has an A&P program; the classes were only available on a full-time, 9-to-5, Mon-to-Fri basis. You had to work exactly to that schedule, no part-timing or evening classes because that was the only way the FAA had approved them. Why the FAA is concerned with the class schedule, and what genius thought that would be a good schedule for working people, I have no idea.

Finally, it's unfortunate that there's no real middle ground for most private owners. You're either the original builder (in the FAA's eyes), or you need to go to school to do any work, on all types of airplanes belonging to others, for pay. No option for "I just want to fix my own personal plane". Yes, E-AB can be worked on by anyone except for the condition inspection. I'm referring to all those old certified ships and the secondhand homebuilts needing CI's.

There's a personal gripe here; if I one day wind up with my dad's RV-6 it's going to stink that some A&P who may not have touched a piston engine in 30 years could do the CI, but I could not (despite having helped build said airplane, building/having built a similar one, and having engineering experience maintaining aircraft)...
 

Bigshu

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Interesting wrinkle, If you get a LSRM (3 weeks full time) then time spent working on light sport aircraft OR BUILDING a light sport counts as experience to qualify to test for A&P. I only know of two schools offering the LSRM certificate.
I know someone who went through Rainbow's course when they were in California, he thought it was very good. Now they're in Missouri, so I'm thinking of taking the course. Should be plenty of LSA needing work/inspections.
 

TFF

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Canada may do things differently.
Tooling that is part of a repair would be part of the repair so you are working on one job. Saying you made tooling to the FAA would not be airplane work. Kind of double talk. How you log it is important. Wrong words and it doesn’t count. They are not impressed if you make an oven; they are impressed if you make a canopy. Not the same in their book.

If it’s already an airplane, you don’t get 51% even if you did 99%. 51% only counts to newly built craft. You have to figure that one out a different way.
 

Deuelly

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I briefly inquired about this with the local FSDO and they told me I had to log all my time and have it "supervised" by an A&P.

I then decided to ask the local community college that has an A&P program; the classes were only available on a full-time, 9-to-5, Mon-to-Fri basis. You had to work exactly to that schedule, no part-timing or evening classes because that was the only way the FAA had approved them. Why the FAA is concerned with the class schedule, and what genius thought that would be a good schedule for working people, I have no idea.

Finally, it's unfortunate that there's no real middle ground for most private owners. You're either the original builder (in the FAA's eyes), or you need to go to school to do any work, on all types of airplanes belonging to others, for pay. No option for "I just want to fix my own personal plane". Yes, E-AB can be worked on by anyone except for the condition inspection. I'm referring to all those old certified ships and the secondhand homebuilts needing CI's.

There's a personal gripe here; if I one day wind up with my dad's RV-6 it's going to stink that some A&P who may not have touched a piston engine in 30 years could do the CI, but I could not (despite having helped build said airplane, building/having built a similar one, and having engineering experience maintaining aircraft)...
A guy has been doing surgery on himself for years. He's even cut himself open pulled his guts out. Shortened them by four feet, put them back in and lived. He goes to the state and says "I taught myself how to do surgery, I want a medical license".

Now, should they give him a license so he can work on you and your family? Or, possibly, should they tell him to go to school?

Brandon
 

Aviacs

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Canada may do things differently.
(Possibly a reminder from previous posts?)
Airplane is not in Canada. It's in upstate NY
Hence, in FAA eyes, it does not have an AWC/does not exist as an airplane

Tooling that is part of a repair would be part of the repair so you are working on one job. Saying you made tooling to the FAA would not be airplane work. Kind of double talk. How you log it is important. Wrong words and it doesn’t count. They are not impressed if you make an oven; they are impressed if you make a canopy. Not the same in their book.
:)

If it’s already an airplane,
Well, in FAA eyes, it isn't. It does not have an AWC.
(If i live long enough) I'm going to build a new, never before designed or constructed airplane. (potentially)
An SMT-1

I might be under a misapprehension:
The guys that used to lop the wings off a J3 (before they were valuable); clip of modity them, draw somer chalk lines on the floor, & use them to build a "special". How many were licensed as E-AB? I personally know of one Breezy- type, e.g. (That landed on a truck for pay. )

Here's an unlicensed fuselage of unknown provenance (no dataplate) that will be heavily modified (new inpection), plus a never completed wings kit intended for an experimental. To which will be added various other parts many constructed by me or from other donor AC. How is this different from progenitors before amateur built segued into "kit built" in the modern idiom?

Keep it coming, you guys are good practice to formulate my pitch for Sept. :)

smt
 

Turd Ferguson

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The guys that used to lop the wings off a J3 (before they were valuable); clip of modity them, draw somer chalk lines on the floor, & use them to build a "special". How many were licensed as E-AB?
All of them. That was a large segment of homebuilding at one time. Round up salvaged parts, weld or rivet a fuselage or spice one or two together and go fly. Paul's "Little Audrey," for example. There was no "major portion" checklist and it' was only casually enforced.
What happened? Kits started showing up with a large amount of fabrication and assembly already done. To top it off, builders were paying a third party to assemble they plane so all they did was write a check. This clearly violated the intent of the rule so now we have builder checklist and major portion enforced to the letter. Sound familiar?
 

TFF

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Clipping J3 wings is in the type certificate. You can debate it doesn’t even need a 337.

I understand what you are saying with no airworthiness certificate, it’s about suspicion. FAA suspects its a cheater, theirs is the only word that counts. Anyway it has debated on your threads and others, and essentially to pull it off you have to forever forget what the parts came from. They are your parts shaped similar to others that inspired you.

I see that you said it came from Canada, not in Canada.
 

Aviacs

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Clipping J3 wings is in the type certificate. You can debate it doesn’t even need a 337.
Missing the point completely.
My actual text was:
The guys that used to lop the wings off a J3 (before they were valuable); clip of modity them, draw somer chalk lines on the floor, & use them to build a "special". How many were licensed as E-AB? I personally know of one Breezy- type, e.g. (That landed on a truck for pay. )
IOW, Breezy's (as stated) and several others we all can picture. "Many" in the history of EAA up through the 70's at least. There is no original piper cub under there, the parts were re-assembled into a "special" often low or midwing, and they got E-AB cert. Mine is no different.

OTOH, Mr T Ferguson got it immediately and made an astute point: kit buyers caused a reflex defense response at FAA especially after they started gaming the regs & hiring the build itself out.

My contact there (FSDO) a couple years ago certainly seemed to be trying to imagine a scenario that could consider E-AB; though he pointed out that the obvious/easy category would be exhibition. That discussion was part of my pre-purchase planning. Part of what changed during the interim was the decision to buy an airplane anyway after i tried it on and it didn't fit, combined with falling into a pile of other airplane parts at a machine shop auction that were not on the radar at the time of my original planning. Giving more scope for "originality" in the build.

Keep pecking, though - It's the FSDO guys, who are mostly on our side, that i need to provide with enough ammunition to feel good about whatever response they make. Your arguments help refine mine. :)


smt <-------in favor of originalist vs textualist approach re: experimental aviation.
 
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rv7charlie

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Haven't we been down this road?
The original question is really two separate questions, under current FAA rules. For the a&p, it will still come down to how 'friendly' your local FSDO is willing to be.
 

gtae07

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A guy has been doing surgery on himself for years. He's even cut himself open pulled his guts out. Shortened them by four feet, put them back in and lived. He goes to the state and says "I taught myself how to do surgery, I want a medical license".

Now, should they give him a license so he can work on you and your family? Or, possibly, should they tell him to go to school?
I suggested nothing of the sort. I don't have an objection to the "experience through supervised work" way of going at an A&P; I just can't feasibly do it myself because I haven't been logging all that time and haven't gotten anyone to backsign for the work I did. Stop putting words in others' mouths.

I'm suggesting that there should be some sort of option like the LSA repairman and inspector certificates for the owners of certified airplanes that would let them work on their own--and ONLY their own--airplane, or a way for purchasers of secondhand homebuilts to earn a repairman certificate for their own airplane. Because there's a really big difference between "I'm just going to fix my own stuff" and "I'm going to get paid to fix other peoples' stuff". And someone doing the former (working on their own spam can) doesn't need to get into thrust reversers, helicopter rotor tracking, and air cycle machines.

Pilot certificates have graduated levels like this (private pilot for someone just flying themselves for fun, commercial and ATP for those doing it for money). We don't set the minimum pilot experience at the equivalent of commercial pilot with multiengine, glider, seaplane, and rotary wing ratings. Sure, pilots in general would be much safer and better-trained, but sport aviation as we know it would cease to exist. But for maintenance, there isn't really any such option. It's all-or-nothing--get trained to do all the work, on any kind of airplane, for pay, or stick to changing tires and oil, with no in-between.

I'm also suggesting that maybe the FAA should stick to approving the content of A&P schools, and not regulating the specific class schedules, so that said schools don't need to go get additional approval just to offer the same classes at different times of day. It's ridiculous that my local A&P school would have to get specific FAA approval to offer the very same classes on a part-time evening/weekend schedule. I don't see why the FAA gets into that level of detail. I'll note that there is an industry movement seeking to implement "competency-based" training rather than time-based--that is, instead of a rigidly-fixed hours-based curriculum, it would be more "show us you can do it".



Finally, I'm not in any way trying to denigrate the work that A&Ps are doing, or the training and experience they get along the way; I think that education and experience is definitely necessary if you're going to be doing that work for others. I'm just saying that perhaps, in light of the decades of experience "we" have with people maintaining their own second-/third-/fourth-hand homebuilts, and in Canada with "owner-maintained" aircraft, that just maybe there could be a way found for people to work on their own non-homebuilt airplanes. We already have such a path for LSA's and the FAA itself proposed such a thing in 2013 (see "primary non-commercial").
 

Aviacs

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Haven't we been down this road?
Not exactly, though it is the nature of posting on forums to encounter some redundancy as details keep getting lost and re-explained to people who didn't read other info, or commonly, read without comprehension. :)

What i think has been clarified for me:
Hours logged toward an A & P would be on actual certified AC or parts to repair same. The airplane could be certified spam can or Experimental, but would have to have an AWC and the work, specifically, would always need to be "supervised" and signed off by an A & P. So truly apprenticeship in concept.

It is probably prudent to log hours for work done on an experimental build, but the work is not supervised until the inspections so time spent has no intrinsic value toward an AWC or toward a Repairman's Cert.
The FAA does not specifically consider hours logged in determining 51%.
If the FAA grants an AWC and the builder applies for and receives a repairman's certificate, that experience can be applied toward an A & P.

Further, time spent building a hangar would not count toward building an airplane. Time spent building a plug and a mould to take essential composite or aluminum parts probably would. Building an oven to blow & anneal a canopy probably does not count. Building a hard inside or outside form and successive experiments might. etc.

The real summary of both processes might be stated "if the end product is successful it counts" Until that point, the time is almost irrelevent & the FAA is not interested. (IOW, time counts building if granted AWC, time fixing airplanes counts if all other steps accrue to A & P)

Thanks!
smt
 

Aviacs

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I'm also suggesting that maybe the FAA should stick to approving the content of A&P schools, and not regulating the specific class schedules, so that said schools don't need to go get additional approval just to offer the same classes at different times of day. It's ridiculous that my local A&P school would have to get specific FAA approval to offer the very same classes on a part-time evening/weekend schedule. I don't see why the FAA gets into that level of detail. I'll note that there is an industry movement seeking to implement "competency-based" training rather than time-based--that is, instead of a rigidly-fixed hours-based curriculum, it would be more "show us you can do it".
A lot of merit there.

During the 1970's & 80's my local EAA chapter met in the facilities of a community college Aviation Technology Center (now defunct) on the local airport (where AOPA is now based). It was often interesting toward the end of a school year when people who had completed the course work had to continue to show up and log time for sometimes a few weeks, to fulfill the hours accumulation. Lot of paper airplanes and other such in those pre-cell phone days. Some did productive work, some didn't. Some weren't finished & soldiered on.

More recently, but still a decade/15 years ago when the Warplane Museum was still on the airport here, a late friend/former chief pilot and aviation director of a local Fortune 500 International flight department tried to start an evening A & P school. Both because it used to be popular with some retirees, and because there were younger people who could be interested but could not afford to drop out of full time work. The facility was open to the public during the working day so evening classes would have been efficient use. Although other logistics & economic issues ended up shelving the effort, I remember a big factor was how to effectively manage the time requirements.

smt
 

Turd Ferguson

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The word "supervised" is somewhat nebulous and I think FAA published a legal opinion on that but I don't have it on this computer.

I'll have to look it up because in the cellphone / factime world, do they need to be on premises?
 

Turd Ferguson

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Yeah, FAA tried to update Mechanic certification in the 90's by revamping Part 65 into Part 66.

The proposed changes were slammed by industry and ended up in the circle file. Good luck.
 
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