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

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#### Deuelly

##### Well-Known Member
Log Member
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").
I'm sorry. I thought you were going off about apprenticeship and school requirements by the FAA. I also thought you were saying you wished there was an easier way for owners to work on there own certified aircraft. I'm glad you weren't. Could you imagine some Idiot with limited training and limited understanding of the regs keeping his plane flying with NAPA parts for 20 years. Then, when he decides he's done with it, instead of scrapping it, he sells it to mom and pop and their two kids. Next thing you know mom and pop and their two kids are on the news. Almost like a doctor doing surgery without training you might say. Anyway, glad we're on the same page. I'd hate to think someone would think those planes would never change hands or never give other people rides.

People by certified planes for multiple reasons. One is that they are supposed to be maintained to a certain standard. As an A&P/IA I see people trying to cut costs all the time on their certified planes. Luckily we have trained professionals out there to catch most of the bad choices. And I know trained professionals make bad choices too. At least their possible loss of livelihood keeps most of them in check. You give a cheap owner the freedom to do maintenance and inspections unsupervised and it will be another hit to the GA industry.

Anyway, can't wait to have coffee with you next Oshkosh.

Brandon

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#### Lynette

##### Member
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.
Light Sport Aircraft Pilot Mechanic <Blue Ridge Community College
They are closed right now. Will not open up until 2022.

#### narfi

##### Well-Known Member
Log Member
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"
The part Turd put in BOLD is all that matters. It is up to your individual Administrator to decide what is satisfactory to them, it is up to you to satisfy them...... It is my recommendation to log everything you do on a daily basis, and have the a&p supervising your work sign off on a weekly or monthly basis or if hopping around between lots of 'supervisors' you are working under by the project. You can satisfy the administrator any way they request, but it is hard to deny a detailed log. (unless you are trying to cheat the system, in which case you shouldn't be allowed anyway)

When I got my a&p I had logged none of my apprenticeship, I took some pay stubs to the FAA and that was enough to convince them. I have had a few assistants under me get their a&p, and they have each been required different sorts of documentation. One was told that he needed a log of all he had done which he didn't have, and he told them that, their answer was to make one from memory best he could, he went back through his phone and memory and built up a log and took it back, the same person said "nice, it looks like you kept a great log here"...... o.0

Also, a small correction, someone said 3 years, you only need 30 months for your a&p or 18 months each for getting the A and the P separately.

#### TFF

##### Well-Known Member
From the FAAs point of view, if you are in the aviation system, you are working in a professional world. GA to the FAA is allowing private people who act like a professional get to play in the same system. Remember all the pictures of people flying with a tie in pictures? Look for some pictures of VanG with his new RV3, he looks like an old man in 1969 the way he is dressed. The system is designed for professionals. If you buy beg or steal an A&P or pilots license, they expect you conduct things like it’s a profession. Even if you are an amateur.

Back to the Breezy wing thing, 20-30 years ago you could get away with it; the plane was designed for donor wings. Today you might get it past because what gets called out can vary, but the stance today is, you need to build your own or at least claim you did.

#### ClaudeR

##### Active Member
HBA Supporter
Earlier in this thread mention was made about wanting to have the FAA allow follow-up owners (ie: not the first owner, but 2nd, 3rd, etc.) of homebuilt airplanes to do condition inspections (I'm paraphrasing). I thought I remembered that the FAA's MOSAIC project included something like this. I found an EAA news article (EAA MOSAIC Article, 10-18-18) which stated in the 7th paragraph, "In the amateur-built area, MOSAIC provides additional options such as ... repairman certificates for second owners of homebuilts...." Hopefully that will come true.

#### pfarber

##### Well-Known Member
The time requirement for A&P is strict. 1900 hours in Part 147 or 18 months under the supervision of an A&P for each airframe OR powerplant, or 30 months total for both. You must prove this. TIme cards/paystubs are usually ironclad. A logbook? Not so sure.

That only gets you the the signoff to take the tests and O&Ps. Can you do NDI? Track A propeller? TIme a mag? Know the regs? Ever service a NiCad battery? Rebuild a turbine engine? etc etc. The written tests are $150-200+ each (you need 3: A, P, General) and the DME for the O&Ps is usually$600+

There are very few people who get A&P by experience unless you are prior military or worked for a repair facility.

#### pfarber

##### Well-Known Member
Earlier in this thread mention was made about wanting to have the FAA allow follow-up owners (ie: not the first owner, but 2nd, 3rd, etc.) of homebuilt airplanes to do condition inspections (I'm paraphrasing). I thought I remembered that the FAA's MOSAIC project included something like this. I found an EAA news article (EAA MOSAIC Article, 10-18-18) which stated in the 7th paragraph, "In the amateur-built area, MOSAIC provides additional options such as ... repairman certificates for second owners of homebuilts...." Hopefully that will come true.
THis is a BAD idea. Unless you personally built that unique aircraft, you simply don't have the knowledge of the inner workings to do a proper condition inspection (Part 43 Appendix D is a joke).

Can you spot all the forms of corrosion? Know what a proper rivet looks like? Have the tools to test cable tension? etc

Its much more than just making sure all the bolts are tight.

#### narfi

##### Well-Known Member
Log Member
The time requirement for A&P is strict. 1900 hours in Part 147 or 18 months under the supervision of an A&P for each airframe OR powerplant, or 30 months total for both. You must prove this. TIme cards/paystubs are usually ironclad. A logbook? Not so sure.

That only gets you the the signoff to take the tests and O&Ps. Can you do NDI? Track A propeller? TIme a mag? Know the regs? Ever service a NiCad battery? Rebuild a turbine engine? etc etc. The written tests are $150-200+ each (you need 3: A, P, General) and the DME for the O&Ps is usually$600+

There are very few people who get A&P by experience unless you are prior military or worked for a repair facility.
As someone who got their A&P this way and has helped several get theirs since, I respectfully disagree with a lot of your post.

1. You only have to prove your time to the satisfaction of the FAA representative signing you off to take the tests.... It is up to them how they want you to prove it. Logbooks very much have been acceptable as the only means of 'proof' for such a signoff in my experience helping others.

2. I haven't met any fresh A&Ps out of school that could do all those things without someone to hold their hand either........ Apprentaces ready for their tests usually know more than the fresh A&Ps and certainly have more real life experience.

3. Obviously the experience has to be from working somewhere aviation..... you cant apprentice as an A&P at the dentists office

#### TFF

##### Well-Known Member
I had to safety wire something for a non fresh A&P once. Career mechanic. In the military he was a Marine One mechanic. He was a pretty boy really. Looked good and talked good. That was his real job. He never really had to wrench in his career, just look good.

147 school or experience is spelled out pretty clearly. If the FSDO is a pain, it can be a stomach ache to go by experience. Some are, some aren’t.

#### pfarber

##### Well-Known Member
As someone who got their A&P this way and has helped several get theirs since, I respectfully disagree with a lot of your post.

1. You only have to prove your time to the satisfaction of the FAA representative signing you off to take the tests.... It is up to them how they want you to prove it. Logbooks very much have been acceptable as the only means of 'proof' for such a signoff in my experience helping others.

2. I haven't met any fresh A&Ps out of school that could do all those things without someone to hold their hand either........ Apprentaces ready for their tests usually know more than the fresh A&Ps and certainly have more real life experience.

3. Obviously the experience has to be from working somewhere aviation..... you cant apprentice as an A&P at the dentists office
How do you show time (18/30 months) with a logbook? A day has a set definition. The time requirements are pretty (or should be) ironclad. The logbook will show knowledge, but not time like a (wait for it) time card will. The FAA never said that you have to be paid, but good luck working for free for 30 months. Its also well know that some FSDO's are questionable. So its completely true that one FSDO, nay, even a specific person at an FSDO will have a completely different viewpoint than the guy in the next desk. The FARs are supposed to prevent this.. but the FAA is gonna FAA.

Also I don't think an FSDO will put much effort into investigating your suitability. Its 100% on the candidate to pass the writtens and O&Ps. At significant cost. Its not like an FSDO has a min pass level for candidates sent to a DME (unlike a CFI -> DPE 80% pass rate).

If you can stay employed for 30 months at a shop as an apprentice then that's a major hurdle. Most people will work at a MRO or manufacturer or be prior military.

The apprentice to A&P path is just not that common (yeah yeah you know did it and you know a guy. So what, I was in classes of 30+ students at schools that had 5-10 classes running at the same time. The ratios are not on your side.

My statement still stands.

#### TFF

##### Well-Known Member
Employed experience is easy to account for. An employer wants work out of you, so you won’t be cleaning the bathrooms… often. As a side gig 30 months of experience could take eight years. Depends on situation, but as an employee, the time is counting when you are slacking; where as if you are going Tuesdays and Thursdays for two hours after work, that’s just four hours.

I will also say that if there is an A&P school around, the FSDO will want you to go there and will give you a hard time to pressure you to go there. I know two people who were put through that. I also know of one who could not stand the A&P school and finished up with experience and he had to fight for it initially. Most of the people I went to school with slept in their cars from the night shift at the air carrier, went to school, and went home after school for a shower and another nap. Where they ran into trouble was after school. No work experience. A big carrier wants minimum 3-4 years preferably on big stuff. Some of the people had pretty high seniority at the air carrier and were able to talk their way in. Others had to have a second job getting work experience while keeping the seniority at the end game. Still sleeping in their car.

#### Turd Ferguson

##### Well-Known Member
HBA Supporter
How do you show time (18/30 months) with a logbook? A day has a set definition. The time requirements are pretty (or should be) ironclad. The logbook will show knowledge, but not time like a (wait for it) time card will. The FAA never said that you have to be paid, but good luck working for free for 30 months. Its also well know that some FSDO's are questionable. So its completely true that one FSDO, nay, even a specific person at an FSDO will have a completely different viewpoint than the guy in the next desk. The FARs are supposed to prevent this.. but the FAA is gonna FAA.
The FAA policy is published in the 8900.1 handbook. A normal working month has 160 hrs. (40 hrs per week times an average of 4 weeks per month). Therefore, 30 months x 160 = 4800 hrs. (It should be clearly evident how the 147 school has the calendar advantage). The months do not have to be concurrent, i.e. one can pursue the experience on a part-time basis.

My standard guidance for someone asking how to show "to the satisfaction of the administrator" the equivalent of 30 months practical experience is to visit or call the FSDO, speak to an airworthiness safety inspector and follow their guidance as they will be the ones issuing authorization for testing. Most give the green light to a "logbook" style of recordkeeping. An upside to the logbook record is to show the actual tasks performed because if all one does is remove and install inspection panels for 30 months, that won't meet the required diversity of experience.

#### pfarber

##### Well-Known Member
The FAA policy is published in the 8900.1 handbook. A normal working month has 160 hrs. (40 hrs per week times an average of 4 weeks per month). Therefore, 30 months x 160 = 4800 hrs. (It should be clearly evident how the 147 school has the calendar advantage). The months do not have to be concurrent, i.e. one can pursue the experience on a part-time basis.

My standard guidance for someone asking how to show "to the satisfaction of the administrator" the equivalent of 30 months practical experience is to visit or call the FSDO, speak to an airworthiness safety inspector and follow their guidance as they will be the ones issuing authorization for testing. Most give the green light to a "logbook" style of recordkeeping. An upside to the logbook record is to show the actual tasks performed because if all one does is remove and install inspection panels for 30 months, that won't meet the required diversity of experience.
FAR 65 Part Sub D is the law. whatever 8900.1 seems to be something you randomly googled. Stop randomly googling stuff.

Also, 65.77 clearly states:

At least 30 months of practical experience concurrently performing the duties appropriate to both the airframe and powerplant ratings.

65.80 also clearly states:

that student may take those tests during the final subjects of his training in the approved curriculum, before he meets the applicable experience requirements of § 65.77 and before he passes each section of the written test prescribed by § 65.75.

There is no 'calander advantage'. If you have records of task completions to satisify the Administrator you can take your tests at any time before the 18 or 30 month requirements. Why? Because you have an FAA approved record of tasks, not an easily forged logbook.

So you're like wrong on everything you posted. Congratulations.

#### TerryM76

##### Well-Known Member
HBA Supporter
This is from FAA Order 8900.1 Flight Standards Information Management System.

"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)."

There are the regulations as defined in the Code of Federal Regulations and there are Orders which provide the details of how to satisfy many CFRs and these Orders are basically the operation manuals for FAA Inspectors, DARs, DERs, and Technical Personnel Examiners, such as myself.

Mr. Ferguson is verrrrrry correct in what he posted.

Terry

#### Turd Ferguson

##### Well-Known Member
HBA Supporter
that student may take those tests during the final subjects of his training in the approved curriculum, before he meets the applicable experience requirements of § 65.77 and before he passes each section of the written test prescribed by § 65.75.

There is no 'calander advantage'. If you have records of task completions to satisify the Administrator you can take your tests at any time before the 18 or 30 month requirements. Why? Because you have an FAA approved record of tasks, not an easily forged logbook.
While a student in an approved 147 school 'may' be eligible to take his oral and practical exams before graduating, he doesn't receive his certificates until he graduates. That provision was put into the regs to facilitate scheduling exams. That's it. It really doesn't provide any other advantage and it does not apply to an applicant using practical experience.

Following a Part 147 curriculum, a student is required to attend ~1950 hrs of classroom and shop classes. That is approximately 41% of the hourly time required using only practical experience. Most would call that a "substantial" time savings. Might say it's a 17 month 'calendar' advantage.

BTW, FAA orders, notices and bulletins are documents that tell FAA inspectors how to do their job. They follow those to the letter.

Finally, the word "concurrently" means "at the same time." Perhaps I should have used the word consecutive as the months of experience are not required to be consecutive.

So you're like wrong on everything you posted. Congratulations.
There are those that have adequate knowledge and experience with the regs and FAA to know how things work...
.....and there are those that don't have enough knowledge about the workings of either to recognize they are wrong. (there's a psychological term for that)

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#### BJC

##### Well-Known Member
HBA Supporter
and there are those that don't have enough knowledge about the workings of either to recognize they are wrong. (there's a psychological term for that)
We call that “dumb as a dirt clod” around here.

BJC

#### TFF

##### Well-Known Member
When you go to a school, part of what you are paying for is them handling the clerical work. They are going to try to make sure you will get through the written with lots of practice tests. They won’t give a final pass to take the written and practical without them thinking you will pass. They also prepare the paperwork to be submitted to the FAA because someone from the FAA does the final sign off.

Some of the fancier schools like Spartan get to pull off fancy stuff. You are paying big money to them to run interference. Taking a test early there doesn’t have the same take, because they won’t give you the diploma that you payed dearly for, if you don’t play by their rules. Regular A&P school, you are not taking something early. They have a hard enough time keeping the students straight. It’s really amazing they herd about half the students.

My hats off for anyone who can do it on experience. It’s the hard row to hoe. They also tend to be on a different career track than school graduates. If you are that independent, you don’t tend to want into work with a crew like in a shop or airline, definitely not a big shop. Personality plays a lot in the A&P world. Certain jobs attract certain people. A&Ps I have worked with are some of the smartest, skilled, and driven people you will ever meet. It is unlike any other job out there. It’s like being a rough neck, lawyer, and a musical instrument maker at the same time. It takes tough skin too. Think comic being heckled by other comics.

#### mcrae0104

##### Well-Known Member
HBA Supporter
Log Member
Turd, TFF, and narfi--you A&Ps are very mighty generous to take your time to correct the misconceptions of the non-A&Ps among us. I don't know that I'll ever pursue that rating, but it has been educational to read your posts.

#### pfarber

##### Well-Known Member
Turd, TFF, and narfi--you A&Ps are very mighty generous to take your time to correct the misconceptions of the non-A&Ps among us. I don't know that I'll ever pursue that rating, but it has been educational to read your posts.
I hope you don't believe what they say, much of it is nothing more a random google searches.

When you go to a school, part of what you are paying for is them handling the clerical work
Have you ever been to a 147 school? I have. Both a University program (Embry-Riddle) and a local CC. THey did nothing more than keep the required records. ERAU never even gave a list of DMEs or test facilities. Other than attendance for the hours and grades... they did absolutely nothing else outside of 'advice'.

They are going to try to make sure you will get through the written with lots of practice tests.
Again, both ERAU and the CC never gave a single practice exam. At most they mentioned the free tests in the ASA books and the ASA apps.

They won’t give a final pass to take the written and practical without them thinking you will pass
ERAU didn't sign off until your semesters bill was paid. The CC way pay first. It was up to the instructor when they would give you the letter stating you completed the General, A and P portions. Once you complete the 1900 hours with a passing grade there is no reason for them to withhold your signoff. I know guys that took the writtens 3-4 times on their own dime and guys that did Os and Ps 2-3s at \$600 a pop.

They also prepare the paperwork to be submitted to the FAA because someone from the FAA does the final sign off.
Lol wut? ERAU and the CC simply gave you a letter of completion. It was 100% up to you to schedule the writtens and the Os and Ps with whatever DME you wanted.

What school is doing all this extra work and withholding your sign offs until you can 'pass the exams'? That's not how 147 works and if I was under those rules, I would raise heck.... I completed the program, if I never want to take the writtens or Os and Ps is my choice (and quite a few guys never do actually take the certification exams.

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#### mcrae0104

##### Well-Known Member
HBA Supporter
Log Member
Edit... meh, not worth it.

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