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Moving to N-reg - why exactly won't people do it?

Just spoke to my A&P/IA.

An A&P license never runs out. You need to remain in aviation work in general terms.

An IA has to do at least 8 annuals every two years, documented to the FAA in Oklahoma every 24 calendar months (used to be Heathrow but that one shut a while ago; later it went to Frankfurt and that one shut also). Alternatively every 2 years you take an approved course (Gleim is one). Or 8 major alterations a year (signing off 337s in the approval section).

So there is no problem. The problems, if any, are elsewhere…

C210 Flyer – I agree with your drift but it is a matter of detail. If you are based somewhere and there is no A&P for 300nm then obviously you have a problem. This has been a problem in say Greece and I used to know one N-reg owner who paid a UK IA to fly down there. I knew them all well and we had a nice time in Paros… Any IA will be delighted to take a little break in Greece But maybe not in Scotland where you will have to pay top dollar for his travelling. In the southern UK, A&Ps are everywhere and IAs (required for the Annual only, normally) are fairly common too.

As always in GA, politics are a big factor and a guy who is working full time for one company may not be able to do your plane on a freelance basis unless you fly it somewhere out of sight of his employer… (would be true for an EASA66 guy too of course) This restricts the available pool of IAs especially because they do get checked by the FAA and can easily be banned, and yes very much so here in Europe where the FAA is more watchful than the CAAs, for 6 months or even for life if they have signed off something which has been bodged and they didn’t spot it, and nobody will stick their neck out signing off your 337 if they have a full time job to keep and they need the IA rating for that.

An IA does need to be very careful what he signs off and some (that I have known) have been burnt by people they trusted and should not have trusted. It’s one thing for a CAMO to sign off some 30 year old wreckage under their organisation approval (not least because nobody will be able to prove the defect(s) existed when they signed it off) but it’s another thing for an IA to sign off the same and then the thing gets sold and the new owner discovers something the IA clearly didn’t spot, so the IA gets summarily banned by the FAA, and now with the European offices closed he may have a job getting his IA rating back. So the chances of getting a “mail order signoff” (you get what I mean?) are already negligible and will become zero.

So, as with most aspects of aircraft ownership, it comes down to building up a team of people you trust who are nice and competent and hopefully “very freelance” so they are keen to do your work. Alternatively, you will always be able to take your N-reg to a big “main dealer” type of shop and they will do the usual thing i.e. half the work for twice the money, which is OK since 99% of owners never remove the inspection covers. The less you get involved, the more you will be over a barrel.

If I had a hangar of my own, I could make money by setting up my A&P/IA colleague in it, doing work for a load of N-regs owners. You get a few dozen N-regs on your books and you are in business! Get a few dozen N-reg King Airs on your books and you will be making loads of €€€€€ because those people just pay anything and since they don’t care about Part 91 you make loads of money on throwing out serviceable parts.

Administrator
Shoreham EGKA, United Kingdom

An IA has to do at least 8 annuals every two years, documented to the FAA in Oklahoma every 24 calendar months

My IA has two planes and I have two, which ‘coincidentally’ adds up to eight annuals every two years. He trusts me to do some work under supervision, saving him physical effort, and he doesn’t have time to take the class… There is a certain method in his madness. (i.e. money is not the motivation to do the annuals on my planes)

nobody will stick their neck out signing off your 337 if they have a full time job to keep and they need the IA rating for that.

The same is true if they sign off their own planes every year, and perhaps other planes outside of a job – that is very strong motivation not to cheat and thereby to keep the IA. Bear in mind however that a 337 is only approved once. The IA who approves an annual inspection is not responsible for the validity of a previous 337 signoff done by a different IA, he is only responsible to make sure prior approval exists for any mods on the plane.

Last Edited by Silvaire at 05 Feb 16:08

True, but the IA is 100% liable for the work done by an A&P (or under A&P supervision) for which he is signing off the Annual. This means he should not sign anything unless all the inspection covers are open, etc. If the company which did the work doesn’t like to play ball on that, the IA should head for the door at 150kt.

He could presumably also get burnt for a previous 337 which was just written out, no approved data, no understanding of what a 337 is about, put in the logbook, and never sent to Oklahoma (I’ve never seen a UK 145 company which did that, of course, so this is purely hypothetical, you understand )

Another bit of politics I have seen is where an IA walked off a job because what he saw was a bit more involved than he liked, and he didn’t want to risk his easy-money full time job (down the road).

Administrator
Shoreham EGKA, United Kingdom

The IA who approves an annual inspection is not responsible for the validity of a previous 337 signoff done by a different IA, he is only responsible to make sure prior approval exists for any mods on the plane.

NOT TRUE.

IF an IA signs off an Inspection and clearly the mod and/or repair was not executed properly, then signing off that Inspection puts his responsibility on the line, period.

FAA A&P/IA
LFPN

NOT TRUE. IF an IA signs off an Inspection and clearly the mod and/or repair was not executed properly, then signing off that Inspection puts his responsibility on the line, period.

There is no physical way for an IA to review physical compliance details for STCs & field approvals for every prior modification installed over many decades, for example a modification installed inside the engine in 1952, under an approved 337. Nor (obviously) is that within the scope of an annual inspection – the regulatory requirements for which are contained in a simple one page list. With that in mind it’d be useful to see some documentation for the ‘not true’ assertion. Obviously if current non-compliance with an STC or field approval is hugely obvious the IA is going to be nervous during an annual inspection, but equally the word “clearly” is subject to interpretation, and therefore lacks regulatory weight if it is in fact used. The number of STC/field approval non-compliance issues that could be defended as ‘not clear’ when no detailed technical documentation for the STC/field approval is on hand during the inspection, nor physical access available, vastly outnumbers those that would be “clear”.

He could presumably also get burnt for a previous 337 which was just written out, no approved data, no understanding of what a 337 is about, put in the logbook, and never sent to Oklahoma (I’ve never seen a UK 145 company which did that, of course, so this is purely hypothetical, you understand )

During the annual, the IA is responsible for identifying unapproved modifications, i.e. identifying a visibly obvious modification has been done with no record of approval for that modification. I think that goes only as far as reviewing the prior logbook entry referencing an approved 337 being filed, a opposed to some less obvious fault. FAA A&P IAs do not have internet access to individual FAA aircraft records, that requires a DAR. A more common annual inspection issue is a major modification with zero logbook entry, zero approval.

Verifying compliance with the FAA TC, STCs and field approvals can get tricky when you understand that many older, currently unsupported FAA certified types have very little available component documentation, perhaps 75 years after they were certified. An example would be the type of gascolator installed in some types – some aircraft manufacturers sourced these concurrently from different tractor part manufacturers almost at random and at the time nobody cared. This gets into an area where ‘almost nobody’ in the real world wants to go… because it hasn’t caused any problems over many years. Also because removing somebodies property rights is not an FAA function.

Last Edited by Silvaire at 05 Feb 19:51

There is no physical way for an IA to review physical compliance details for STCs & field approvals

FALSE.

An IA signs off an Inspection and any one of the previous modifications, no matter when it was executed, is clearly non-conforming, then that IA is “on the line” for it.

FAA A&P/IA
LFPN

I think you’re missing the point, Michael. It is obvious, as I wrote above, that an A&P IA must not sign off an aircraft that has a “clear” non-conformance with the TC, any STC or any Field Approval. That’s within the scope of an annual inspection, but the issue there is to determine what is “clear”, which in itself is never clear.

It is equally obvious that an A&P IA cannot be held responsible for what he cannot see and is not required to see within the regulated scope of an annual inspection. That’s why a 337 is approved once, and once only.

Would you sign off the annual inspection for an aircraft with a Ranger engine having an STC’d piston ring modification, without detailed verifying compliance with the STC, on all six cylinders? If you would, would your annual inspection meet FAA requirements?

Last Edited by Silvaire at 05 Feb 20:12

I think you are missing the point, whoever you are.

A 337 may be approved once and only once, but it can just the same be found to be non-conforming; erroneous or just plain “pencil whipped” to use the American expression.

(Ask me how I know)

The point is crystal clear: the LAST IA that signs off the Inspection, owns it.

FAA A&P/IA
LFPN

It would be helpful if you’d answer the question about the Ranger engine:

Would you sign off the annual inspection for an aircraft with a Ranger engine having an STC’d piston ring modification, without detailed verifying compliance with the STC, on all six cylinders? If you would, would your annual inspection meet FAA requirements?

Thanks.

If I had reason to believe that the modification was either non-conforming or had been removed, then I would sign off the Inspection with the mention “un-airworthy” .

BTW : I see you’ve gone back and re-edited your original post ..

Last Edited by Michael at 05 Feb 20:26
FAA A&P/IA
LFPN
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