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FAA Coleal Interpretation - pilot maintenance privileges

This has been mentioned here previously a couple of times, by @jacko.

US AOPA article

Relating to FAR 43.3:

…preventive maintenance Part 91 pilots are permitted to do is not limited to the 31 items on the list.
That means that if you want to change a burned-out post light lamp, it can still be considered preventive maintenance. I would consider changing a post light lamp to be no more difficult, complex, or risky than changing a landing light or nav light (both of which tasks are on the list), so what reason could the FAA have for not considering it to be preventive maintenance?
Similar logic would seem to apply to repairing faulty nav light or strobe light wiring, which is not on the list even through repairing landing light wiring is on the list. How could one of these reasonably be considered preventive maintenance and the others not be?
You get the idea. Given what the FAA said in the Coleal letter, if you do something not on the list that’s similar to something that is on the list and no more difficult, complex, or risky, you have an FAA letter of interpretation to point to should your action ever be challenged. Contrary to conventional wisdom – which might have been valid prior to 2009 but no longer is – you’re not limited to the 31 items on the list.

This is potentially quite useful.

Coleal_Bombardier_Learjet_2009_Legal_Interpretation_pdf

Administrator
Shoreham EGKA, United Kingdom

Normally, FAA and EASA pilot maintenance privileges are broadly similar. This can significantly extend them.

I normally do my servicing with an A&P/IA and he signs it off but this can be useful to N-reg owners who have to work alone in between Annuals.

Administrator
Shoreham EGKA, United Kingdom
2 Posts
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