Small Operator Maintenance.

This forum has been developed to discuss maintenance topics in Canada.

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photofly
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Re: Small Operator Maintenance.

Post by photofly »

Why does our government decree a system of paperwork that's so complex to initiate that the only way to get it approved within in a mortal lifetime is to pay $20k+ to a retired TC employee as a "consultant" to do it for you?

If Colonel Sanders couldn't get it done within six years, what hopes do the rest of us have?
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Re: Small Operator Maintenance.

Post by DonutHole »

photofly wrote:Why does our government decree a system of paperwork that's so complex to initiate that the only way to get it approved within in a mortal lifetime is to pay $20k+ to a retired TC employee as a "consultant" to do it for you?

If Colonel Sanders couldn't get it done within six years, what hopes do the rest of us have?
Who pays a consultant? Not small operators.

It's not difficult it just takes time. you can get it done quickly, or cheap, not both. Even with a consultant, it might not be quick. What makes the process quick and cheap is knowing wtf you are doing and doing it right the first time.

Sanders couldn't push a free lunch and a box of tims through t.c. not because of his credentials, or bad tc not wanting small operators to exist, but because of his personality And history with the boys.

Is it right? hell no. But it is what it is. You're using the absolute extreme to justify your position. Like calling all Muslims terrorists because there happen to be some Muslim terrorists.
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Heliian
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Re: Small Operator Maintenance.

Post by Heliian »

^ therefore, colonel sanders is a terrorist?
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DonutHole
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Re: Small Operator Maintenance.

Post by DonutHole »

Heliian wrote:^ therefore, colonel sanders is a terrorist?
Lol
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Re: Small Operator Maintenance.

Post by PilotDAR »

Why does our government decree a system of paperwork that's so complex to initiate that the only way to get it approved within in a mortal lifetime is to pay $20k+ to a retired TC employee as a "consultant" to do it for you?
My experience has been that if the applicant is well conversant with the type of maintenance undertaken, and the scope of work, achieving the approvals required is attainable - it is a test! On purpose! The worthy can pass.

One of the very first PRM exams, in it's draft stage, was vetted on me. As a PRM applicant, I was asked to try to test, to test the test, not so much me. TC greatly amended the test following my, and perhaps others, trials with the test. It was not well laid out, and upon my comments, changes were made. It was made much more appropriate to the role of task specific AMO operations, and, is in my opinion, is fair, as are the regs for achieving AMO approval. Bear in mind that I am not an AME, I just studied the requirements, as any other applicant could do. My airplane experience got me in the door, but my studying got me the approvals I needed.

If someone cannot achieve success, they have more work to do to get to the minimum standard for taking care of planes, sorta like the standards for flying them!
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Re: Small Operator Maintenance.

Post by Cat Driver »

If someone cannot achieve success, they have more work to do to get to the minimum standard for taking care of planes, sorta like the standards for flying them!
Ahh, now I get it the Colonel and I just don't meet the standards in your Canada huh?
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photofly
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Re: Small Operator Maintenance.

Post by photofly »

PilotDAR wrote:One of the very first PRM exams, in it's draft stage, was vetted on me. As a PRM applicant, I was asked to try to test, to test the test, not so much me. TC greatly amended the test following my, and perhaps others, trials with the test. It was not well laid out, and upon my comments, changes were made. It was made much more appropriate to the role of task specific AMO operations, and, is in my opinion, is fair, as are the regs for achieving AMO approval.
I thought the PRM was attached to the operator, not to the AMO?
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Re: Small Operator Maintenance.

Post by CamAero »

photofly wrote: I thought the PRM was attached to the operator, not to the AMO?
Operators have a Person Responsible for Maintenance Control.
http://laws.justice.gc.ca/eng/regulatio ... ml#docCont

AMOs have a Person Responsible for Maintenance.
https://www.tc.gc.ca/eng/civilaviation/ ... tm#573s_04

If one organization holds both certificates, the PRM and PRMC must be the same person.
706.03 (7) If the holder of an air operator certificate is also the holder of an approved maintenance organization (AMO) certificate issued under section 573.02, the person appointed under paragraph (1)(a) shall be the person responsible for maintenance of the AMO appointed under paragraph 573.03(1)(a).
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Re: Small Operator Maintenance.

Post by AirFrame »

Reviving an only recently-demised thread as the topic is now coming close to home...

My dad has a Cessna 150 now after owning a Cessna 190 for almost 40 years. In that time, almost every annual on each plane was done by the same mechanic, a sole proprietor who had an AMO at the local airport. The mechanic would come to dad's hangar after dad stripped the inspection covers/panels and got everything ready. The mechanic would inspect, and then they'd close it up and sign everything off. The mechanic was happy with this, because it reduced his overhead and the time spent away from the AMO. Dad was happy with this because the number of hours to pay for was reduced as he did a lot of his own legwork getting things ready.

That AME passed away, and dad found a roving mechanic who didn't have a fixed base but would come to you. Unfortunately, that mechanic is now retiring and won't be available anymore (I haven't asked but I understand that the paperwork burden was part of the reason). Dad hasn't found another mechanic yet so he's now seriously considering putting the plane into Owner-Maintenance. I'm trying to discourage him, but the only alternative he sees is "taking it to a shop" where he believes he'll just get taken to the cleaners financially. I don't think the situation is quite that dire, but I can't argue that he'll pay more taking it to a shop.

What i'm curious about, is that I know there are other people on the field who do the annuals on their own certified aircraft, who have AME tickets of some form. How is it reasonable, in terms of the amount of paperwork or overhead needed, for someone to hold an AME license good enough to do their own plane, but yet it's too much of a burden for a sole proprietor AME to maintain a client base?

I admit I have no understanding of different AME license levels/qualifications... Other than I think there are different qualifications for structures, engines, and electronics...

Any suggestions?
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Re: Small Operator Maintenance.

Post by DonutHole »

Ask those guys how they do it.

There is no shortcut. You have to put in the time, write the tests, and fill the task log.

What I suspect is happening is those folks are 'doing the annual' and the paying for a signature.

If they do have a license, ask themy if they'll do your annual. You don't need to have an Amo to service private aircraft
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Re: Small Operator Maintenance.

Post by SeptRepair »

I'm not sure where the paper burden is on doing an annual on a C150. Pretty straight forward. Liability insurance is pretty dam steep for a solo AME, so they may just not want the hassle of dealing with another persons aircraft, especially if they aircraft owner wants to do a lot of the work themselves.
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Re: Small Operator Maintenance.

Post by GyvAir »

There are at least a couple other threads discussing (sometimes somewhat heatedly) why it's hard to find affordable maintenance for small private aircraft and why private AMEs aren't lining up to work on them. Short version of the story from my point of view is that it comes down to balance of effort, hassle and risk versus reward.

It is possible of course to have a good working relationship between a private owner and an AME working on his own, but there are a lot of factors that have to be working in favor for this to happen. Looking at it from a pure monetary perspective, if the aircraft is of low value, or in poor condition and requiring a lot of work, the chances are small of the owner being happy with the quote or bill from the AME. If the aircraft doesn't have a hangar, that adds difficulty. Where does the work get done? No suitable AMEs within 100 miles? Who pays for the trip or trips? There will almost always be trips, plural, as it's pretty rare for a properly done annual to result in zero issues. Throw in the personalities of the parties involved, and it’s little wonder that AME-owner relationships are difficult to cultivate and maintain.
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Re: Small Operator Maintenance.

Post by PilotDAR »

Dad hasn't found another mechanic yet so he's now seriously considering putting the plane into Owner-Maintenance.
The only reason to not do this is that the US border is a stopping point (for now). I suppose there would be a slight perception of loss of value as it will not have an immediate market to the US either. But, it's a 150, knocking 10% off its value is two AMO annual inspections!

I understand the AMO system well, and it is appropriate to commercially operated complex aircraft. 172's and 150's barely have a need to be maintained to this level of accountability, but there is no regulatory appetite to start creating two tiered systems, and nor should there be.

I own an O-M aircraft, and my 150 would be there too, other than it's an "M", and not on the list (yet). We in Canada need to exercise the O-M privilege more, for two reasons: To show TC that it works, and AME/AMO is not needed for these simple aircraft when private, and to show the US that they are safe, and should be allowed in. Other nations are getting it. I just left the UK, where they have a new light weight catagory which has no regulatory oversight, other than you must register it, and have at least an ultralight license. The authorities need to see that these simplified systems work for aircraft, then the system will grow to capture more types.

Always remember, going the O-M route does not mean that you can't have an AME do the maintenance, he just does not have to sign for it. Low risk for him, less cost for you.
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Re: Small Operator Maintenance.

Post by AirFrame »

DonutHole wrote:Ask those guys how they do it.
...
You don't need to have an AMO to service private aircraft
I think that's the key I was unaware of... I thought when all the extra requirements were brought in, that even the single-person AME operating independently was being told he/she had to meet the same requirements as an AMO. If an AME can service private aircraft without an AMO, then that's almost certainly how the others are doing it. I know they are licensed.
pilotDAR wrote:The only reason to not do this is that the US border is a stopping point (for now).
Unfortunately, that restriction is unlikely to be lifted in my dad's lifetime, or even mine. The FAA is adamantly against allowing "unmaintained" certified aircraft into the US, and has said on many occasions that if TC pushes on this issue that they will close off the door to amateur-built aircraft on the same basis. Many amateur-built aircraft in canada are owned by people who didn't build them, which really isn't much different than someone having an owner-maintenance aircraft.
GyvAir wrote:It is possible of course to have a good working relationship between a private owner and an AME...
I like to think that my experience isn't unique, but my family has never had a bad working relationship with any AME they've dealt with. It should always be this way for everyone, but I know there are people who dread the annual trip to the mechanic because they feel they're going to be poor when they leave. Usually it's the ones with poorly maintained ratbag airplanes though, so they really do get what they deserve.
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Re: Small Operator Maintenance.

Post by GyvAir »

AirFrame wrote:I like to think that my experience isn't unique, but my family has never had a bad working relationship with any AME they've dealt with.
No, it's hardly unique. In fact, it's likely the majority situation. Sadly, it's the owners who, for one reason or another, can never seem to get along with anyone in the maintenance end of things that rant on AvCanada and sit in the airport restaurant grumbling about how everybody is out to screw them. Hopefully your dad will get hooked up with someone soon.
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Re: Small Operator Maintenance.

Post by PilotDAR »

pilotDAR wrote:
The only reason to not do this is that the US border is a stopping point (for now).

Unfortunately, that restriction is unlikely to be lifted in my dad's lifetime, or even mine. The FAA is adamantly against allowing "unmaintained" certified aircraft into the US, and has said on many occasions that if TC pushes on this issue that they will close off the door to amateur-built aircraft on the same basis. Many amateur-built aircraft in canada are owned by people who didn't build them, which really isn't much different than someone having an owner-maintenance aircraft.
This is sadly true, but not for as long as you fear. The FAA will not clamp further down on Canadian aircraft, because their own trend is in the direction of less regulation. Right now they are posturing, and I have pressed the issue with the FAA, ans understand the sensitivities (though don't concur). But I know of one B.C. O-M aircraft which has repeatedly been permitted US passage, so there is hope.

A privilege will grow and expend because it is being exercised by more people. If more Canadian aircraft elect to be O-M, that will broaden the statistical base for safety information which supports the request for open boarders. The FAA is noticing the statistical reality that O-M aircraft are at least as safe as certified. They have acknowledged this in reports. They can't talk out of both sides of their mouth forever!

That said, honestly, for a C 150, I would fully expect your dad can forge a good working relationship with an AME, which allows him to prepare the aircraft for inspection a lot. But, the best thing is to develop that relationship quietly (certainly not on AvCanada!). The AME will be more relaxed that way... (you'll notice that I have not described the circumstances of the AME release to service of my 150 :wink: )
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Re: Small Operator Maintenance.

Post by AirFrame »

PilotDAR wrote:But I know of one B.C. O-M aircraft which has repeatedly been permitted US passage, so there is hope.
I've heard of this as well. FAA HQ is apparently *not* impressed, as it apparently violates absolute regulations prohibiting it. I don't know the exact details, but I understand that the local FSDO is giving permits that are not authorized higher up.
The FAA is noticing the statistical reality that O-M aircraft are at least as safe as certified.
I don't know that you can say that with statistical certainty...yet. It's coming, I agree, but O-M is still a small percentage of the Canadian fleet, and O-M incidents are not tracked separate from Certified. So there's no accurate way to show that O-M is "as safe as" certified.
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Re: Small Operator Maintenance.

Post by PilotDAR »

Airframe, you are right on all counts. However, everything starts with regulatory creep, and the regulatory creep in this case is in the direction we would like it to go, so anything which smooths the path, and exercises it, is a good thing!

By the way, the successful O-M US traveler is based at your airport, and his plane is magnificent.
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