Small Operator Maintenance.

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

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Cat Driver
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Small Operator Maintenance.

Post by Cat Driver »

Well from my perspective and experience in aviation it is my opinion that two of the most backward steps TCCA has taken was the forcing of AMO's on the owners of AOC's.

And next the forcing of PRM's on the owners.

The AMO can be turned into a license to steal and the PRM is just a sad joke that does nothing but up the cost of being in business.

Then what else can one expect from a third world country?
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Re: Amateur Built Maintenance Question

Post by robertw »

Cat Driver wrote:Well from my perspective and experience in aviation it is my opinion that two of the most backward steps TCCA has taken was the forcing of AMO's on the owners of AOC's.
You prefer some anonymous AME working out of his pickup truck to certify the maintenance done on a business jet that some aircraft owner leases to the public to make money off of?
Cat Driver wrote:And next the forcing of PRM's on the owners.
You prefer to have no one responsible for ensuring that your maintenance provider meets the requirements of the regulations?
Cat Driver wrote:The AMO can be turned into a license to steal and the PRM is just a sad joke that does nothing but up the cost of being in business.
I would think that the cost of the parts going into your aircraft have a far greater impact on the cost of doing business than the salary of a PRM.
Cat Driver wrote:Then what else can one expect from a third world country?
I don't know what country you live in, but the system of aviation control in Canada is one of the reasons we have one of the lowest accident rates in the world.
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Re: Amateur Built Maintenance Question

Post by photofly »

robertw wrote: I would think that the cost of the parts going into your aircraft have a far greater impact on the cost of doing business than the salary of a PRM.
Not when you have a fleet of two C150s and a C172.
I don't know what country you live in, but the system of aviation control in Canada is one of the reasons we have one of the lowest accident rates in the world.
I suspect you could actually reduce the accident rate to zero if you just make complying with the rules a leetle bit more expensive, so absolutely nobody can afford to fly.
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Re: Amateur Built Maintenance Question

Post by Cat Driver »

Cat Driver wrote:
Then what else can one expect from a third world country?
robertw wrote:
I don't know what country you live in, but the system of aviation control in Canada is one of the reasons we have one of the lowest accident rates in the world.
I live in Canada, which is a socialist basket case and aviation has been crippled by morons in Government building a self serving empire.

The CARS are a nightmare of convoluted rules that are almost impossible to understand. Proof of which can be easily shown by asking several TCCA regions or offices for an explanation of a rule you want clarified....the answers will vary from region to region and office to office and from inspector to inspector.

As Photofly pointed out as more and more of us owner operators quit aviation because it is just to difficult to deal with TCCA your accident rate will get even lower as more people leave aviation.

Fortunately I spent the latter decades of my career flying in over 50 different countries and I know a third world country when I work and fly in one.

Canada is a third world country in my opinion, there is no way I would gamble my hard earned money in aviation here..
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Re: Amateur Built Maintenance Question

Post by PilotDAR »

Canada is a third world country in my opinion, there is no way I would gamble my hard earned money in aviation here..
Yet Canada is the envy of third world countries, and many others too. Our system is not perfect, but it seems to be one of the best. I've certainly never come to know a national regulation structure which could topple Canada's. Approvals I issue on behalf of Transport Canada, as well as maintenance releases produced by AME's o AMO's will be accepted world wide. Having worked with the FAA, the CAA, the Hong Kong Certification Authority, and EASA, I'm sure happy I can come home to Canada, and do my free [to do my own thing] flying here!
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Re: Amateur Built Maintenance Question

Post by photofly »

You're a DAR, and therefore thoroughly embedded in the system. It's good that you're enthusiastic about it but that enthusiasm is not a ringing endorsement from a disinterested party.

I don't imagine many AMO's are crying about the maintenance requirements for an FTUOC or AOC, either.

And when you're free to do your own thing flying here, you don't have to pay your own fees.
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Re: Amateur Built Maintenance Question

Post by PilotDAR »

You're a DAR, and therefore thoroughly embedded in the system
Or, perhaps understand the system (well, at least my corner of it). We can manage things that we understand. A part of the understanding is not only what is permitted/expected/required etc. but also why. Transport Canada as an entity is at the top of the group of authorities for my experience, who will help you understand why something is required. Often, once understood, the aviation industry person may be less resistant to it.

Many of us have learned lessons the hard way. Sometimes that results in the "I'll never do that again", or more commonly, a different approach next time. It makes flying safer. Safer flying is 95% of TC's objective, with a whole bunch of the other 5% being stuff I don't like either!

I am very confident that if over a long term sampling, Canadian Aviation were to reduce the accidents & incidents to zero by totally effective good behavior and self oversight, TC staff would say "Yippee!" and let aviation do more of that....

The amateur built world is a good place to exercise the freedom to do one's own thing to a much larger degree. Can (certified) industry follow a lead of success demonstrated by the amateur built sector?

We're not there yet....
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Re: Amateur Built Maintenance Question

Post by photofly »

Next time you meet Top Cat, ask him why a one or two person FTU needs a shelf full of paperwork and an expensive, difficult to find, AMO on hand to service a fleet of two Cessna 152s. What kind of horrible risks is he mitigating with these requirements that our cousins south of the border who have much more straightforward requirements are oblivious to?

Further, please ask him, what kind of good behaviour and oversight such a one or two person FTU can demonstrate that will, in time, lead to a relaxation of those rules?

Please ask him these questions - but I'm not going to hold my breath for a helpful or meaningful answer.
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Re: Amateur Built Maintenance Question

Post by robertw »

photofly wrote:Next time you meet Top Cat, ask him why a one or two person FTU needs a shelf full of paperwork and an expensive, difficult to find, AMO on hand to service a fleet of two Cessna 152s. What kind of horrible risks is he mitigating with these requirements that our cousins south of the border who have much more straightforward requirements are oblivious to?
The reason is because that 2 A/C FTU is charging the person off the streets money to use it's aircraft, just like a large airline does. The guy wanting to buy some flight time should have the same reasonable expectation that the aircraft he's about to put himself in is going to be subject to the same maintenance standards that a major airline has to meet. Why should a student wanting to learn to fly have to accept that the aircraft he's about to take off in is maintained to a standard lower than other fare paying passengers are entitled to? Is his life worth less? I don't think so.

There are many owner operators out there want things to be easy and cheap and don't think that regulations should have any impact on their bottom line. Cat Driver may think that the Canadian system is third world because it places limits on him he doesn't want or doesn't think he should have to abide by, but I beleive that it's his thinking that is third world. We have a complex system for a reason. We have a complex aviation industry that NEEDS regulation. If the government does not draw lines in the sand and say "Thou shalt..." and "Thou shalt not", we'll end up with a first world country with a bunch of third world operators and a third world safety record to boot.
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Re: Amateur Built Maintenance Question

Post by photofly »

The only difference in the maintenance provided by an AME and an AMO is paperwork.
Are you really suggesting that an operation running 2 C150s needs the same paperwork as Air Canada?

Demonstrate the risk, first, don't just assume it exists. Even the FAA understands that. Go look at the FAA requirements, then come back to the discussion.
The guy wanting to buy some flight time should have the same reasonable expectation that the aircraft he's about to put himself in is going to be subject to the same maintenance standards that a major airline has to meet.
There's no logic behind that statement. Even if you can demonstrate an increased risk with less-than-airline maintenance requirements for an FTU (and you can't) - people pay to do lots of really dangerous activities: skydiving, scuba diving - heck, they even pay to ride motorcycles. Moreover, the man in the street already thinks that learning to fly is terribly terribly dangerous. Why do you assume that anyone learning to fly cares in the slightest for airline-style maintenance? Have you asked?
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Re: Amateur Built Maintenance Question

Post by iflyforpie »

Its because Transport Canada assumes that more rules and paperwork make the world a safer place.

In spite of operators like us who in-house our maintenance and could easily pencil-whip the paperwork.. but instead we actually exceed the maintenance requirements given to us because we don't like to see aircraft with mechanical problems.

And in spite of operators like--take your pick of any scab operator with a battered Navajo--who can't even make the paper look right... but are still allowed to operate until they have a fatal accident... after which if they promise to be really really REALLY good... and some quid pro quo I'm sure... they operate again in pretty much the exact same way. :roll:
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Re: Amateur Built Maintenance Question

Post by robertw »

photofly wrote:The only difference in the maintenance provided by an AME and an AMO is paperwork.
Not true. There are a whole lot more checks and balances that exist in an AMO than with a lone AME. AMO's are supposed to assign responsibility, ensure proper training and competency and as well are subject to internal audit. AME's on their own are not.
photofly wrote:Are you really suggesting that an operation running 2 C150s needs the same paperwork as Air Canada?
No I am not. There is an obvious difference between a 150 and an A320 or CRJ. The simplicity of a 150 lends itself to fewer paperwork requirements.
photofly wrote:Demonstrate the risk, first, don't just assume it exists. Even the FAA understands that. Go look at the FAA requirements, then come back to the discussion.
Sorry, I don't have any risk assessment studies in my back pocket. I hope this doesn't disqualify me from the discussion here. TCCA has shown that they consider there to be a higher risk by requiring by regulation that Part 7 or Part 4 (people who make money selling services to the general public) operators to use the services of an AMO (where a higher degree of maintenance and process control exists) when conducting maintenance.
photofly wrote:
The guy wanting to buy some flight time should have the same reasonable expectation that the aircraft he's about to put himself in is going to be subject to the same maintenance standards that a major airline has to meet.
There's no logic behind that statement.

Makes perfect sense to me. People want to be as safe getting into a little airplane as they do in a big one.
photofly wrote:Even if you can demonstrate an increased risk with less-than-airline maintenance requirements for an FTU (and you can't) -

As I've stated above, TCCA has already demonstrated that they consider the risk with part 7 and part 4 operators to be higher that that of others by requiring that maintenance providers to these operators be subject to more controls than just your average itinerant AME.
photofly wrote:...people pay to do lots of really dangerous activities: skydiving, scuba diving - heck, they even pay to ride motorcycles. Moreover, the man in the street already thinks that learning to fly is terribly terribly dangerous.
Yah... They're paying for the risk. They want the thrill. In my opinion, there is inherently more danger in those type of activities than jumping in a 150 for some circuits. I don't think I've ever heard of someone thrill seeking in a 150. That would be akin to thrill seeking in a 1976 Pinto station wagon. Not sure I agree with the "terribly dangerous" comment.
photofly wrote:Why do you assume that anyone learning to fly cares in the slightest for airline-style maintenance? Have you asked?
You're right, they probably don't (and no, I haven't conducted a survey), but they do care about being safe. Getting maintenance done at by AMO is a lot more controlled than getting it done by just any AME off the street. Control = Higher degree of safety.
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Re: Amateur Built Maintenance Question

Post by photofly »

I think it would be wrong to assume that just because a regulation exists it must be optimal. Clearly regulations need to be, and are, sometimes changed.

I'm definitely not persuaded that just because someone at TC - at one time - thought the current AMO requirements for tiny operators were a good idea, that they were right then, or are still the best way, now. It makes perfect sense for all levels of regulation to be reviewed, and I think this should be one of them.
Makes perfect sense to me. People want to be as safe getting into a little airplane as they do in a big one.
I really don't know why you say that. I suspect you're trying to justify the regulations, after the fact. People accept all kinds of risk for many reasons, not just for thrill seeking. Nobody gets into a C150, for any purpose whatsoever, and expects it to be as safe as an Air Canada 767. And even with perfect maintenance practices, it's not going to be.

I believe the public would be better served by a wider choice of small operators, something which the current regulatory regime works hard to prevent. I know for a fact the public would like lower prices. If you're sure that people are prepared to pay more for extra maintenance paperwork then there would be no harm in relaxing the requirements - nobody would patronize smaller operators.

It's only because people don't want to pay for extra maintenance paperwork - because they (rightly) don't think it adds significantly to safety - that TC feels it has to legislate for it. You don't have to ban something that nobody wants. It's very nanny state, isn't it, having to save people from themselves?
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Re: Amateur Built Maintenance Question

Post by PilotDAR »

It's very nanny state, isn't it, having to save people from themselves?
Well, at least protect the nannies from themselves, 'cause it's the nannies will sue TC, I mean the taxpayers, if they get hurt or scared, or PTSD because a commercial aircraft went bump.

Yes, for TC, it's risk management, or, more precisely, perceived risk management. TC will regulate heavily where the headlines could be big (Dash 8 lands on one, and sheds propeller blades into the cabin in YEG). Nannies, like the rest of us just want to get where we're going, without the worry of a prop strike, while we're napping in our seat. Nannies might decide to live on the wild side, and ride in someone's private plane, and because TC required close to commercial quality maintenance, there's low risk on that wild side. But if the nanny reads to bilingual words on the side of a non certified aircraft, the deal will be broken - no flight = tiny public risk.
I'm definitely not persuaded that just because someone at TC - at one time - thought the current AMO requirements for tiny operators were a good idea, that they were right then, or are still the best way, now.
It wasn't just someone at TC, it was a group of TC and industry people in a CARAC meeting - for many years, I was one of them. Words I thought up, typed, and presented became CARS, because no one, including TC had a better idea. TC staff member Don S. would open the meetings by saying to everyone: "We're not here to get what we want, we're here to assure we all leave with what we can live with". So, when a participant could explain why a proposed regulation would kill something which was needed, that regulation did not progress.

It was industry people, not TC, who developed the standards for tachometer recertification, parts redocumentation, and owner maintenance, to name a few. TC deferred to the expertise in the room, which certainly included industry people.

TC has created many maintenance "lets" over the decades, which certainly include amateur builts. How many nations simply do not allow non certified aircraft? Or even private? Commercial only - pay the price!

If a person thinks that the maintenance portion of the rental aircraft is too much, no problem: Buy their own plane, maintain it privately, and hire an instructor. Otherwise, they are bound by (and paying for) a higher standard of maintenance.
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Re: Amateur Built Maintenance Question

Post by Strega »

Robert,

A couple of things, you mentioned earlier in the thread "as a professional AME"... unfortunatly.. you are not. If you were, you would be able to put P.AME. behind your name, end of story.

You also mentioned comparing a C-150 and a large jetliner. These 2 aircraft are not the same, were not manufactured to the same standards, and therefore have much different "expectations of safety", if you disagree, go fly a C-150 in the mountains at night in the winter, you will soon understand. The changes that Cat mentions are killing GA in Canada.

A "Pinky Engineer" (as most AMEs like to call them) are actually Engineers, that for the most part, do engineering work.

AMEs - (or as I like to call them, "mechanics" not to mention everyone else in the world) are aircraft mechanics that follow guidelines and standards, that have been created by "Pinky Engineers" (and others with professional responsibility).

Good day.
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Re: Amateur Built Maintenance Question

Post by photofly »

That's two votes in favour of the current regime, both from people who earn their living maintaining aircraft. PilotDAR claims credit for writing the regulations, so his position isn't a surprise.

But I am somewhat shocked by the ultra-dismissive "if you don't like it, go buy your own plane." I think the people who pay for the planes and who pay the AME community to fix them deserve a little more consideration.
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Re: Amateur Built Maintenance Question

Post by AirFrame »

robertw wrote:I don't think I've ever heard of someone thrill seeking in a 150. That would be akin to thrill seeking in a 1976 Pinto station wagon.
It comes down to perspective. When I was 16, a 1976 Pinto Station Wagon would have been as good as a Ferarri if it was *mine*. I had no real perspective on cars then. For a brand new pilot, flying a 150 is pretty damned impressive. You can go anywhere you want at 160km/h non-stop, and carve lazy-8's through the sky. And imagine the fun if it's an Aerobat. :)

You're overlooking something more fundamental in the comparison of 150's to Airliners though: It's reasonable even for an outsider to aviation to expect that a single person could learn everything necessary to maintain a 150. It's unreasonable to expect that a single person could do the same on something as large and complex as an airliner. Something on that scale necessarily has that much more complexity, and will need more manuals, more procedures, and more people to look at different parts before it's all put back together after an annual.

In a similar vein, as a private pilot I can go hop into almost any single-engine (piston-powered) airplane available and go fly, legally. A pilot qualified on one airliner can't just go switch to another without significant re-training. There's too much that's different, with too many passengers at risk if it goes sideways.
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Re: Amateur Built Maintenance Question

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photofly wrote:I think it would be wrong to assume that just because a regulation exists it must be optimal. Clearly regulations need to be, and are, sometimes changed.
I never argued that regulations shouldn't be changed or reviewed. I agree that they should be. Times and circumstances change and so should regulations. I just happen to believe that requiring Part 7 or Part 4 operators to have maintenance done by an AMO needs to remain as a regulation. There needs to be a level playing field across the board. If you give "small commercial operators" an advantage by allowing them to be exempt from such a regulation, then you'd quite likely end up with unqualified, unfamiliar with type, under equipped individuals performing and signing out maintenance on aircraft that the general public are renting to use for flight training. Heck, you'd eventually end up with those operators that get their pilots or students to do their own maintenance (without a licensed AME), and have a "special arrangement" with a local AME to come sign the work off. Don't say it won't happen.
photofly wrote:I'm definitely not persuaded that just because someone at TC - at one time - thought the current AMO requirements for tiny operators were a good idea, that they were right then, or are still the best way, now. It makes perfect sense for all levels of regulation to be reviewed, and I think this should be one of them.
I think PilotDAR handled this one when he said
PilotDAR wrote:It wasn't just someone at TC, it was a group of TC and industry people in a CARAC meeting - for many years, I was one of them. Words I thought up, typed, and presented became CARS, because no one, including TC had a better idea. TC staff member Don S. would open the meetings by saying to everyone: "We're not here to get what we want, we're here to assure we all leave with what we can live with". So, when a participant could explain why a proposed regulation would kill something which was needed, that regulation did not progress.

It was industry people, not TC, who developed the standards for tachometer recertification, parts redocumentation, and owner maintenance, to name a few. TC deferred to the expertise in the room, which certainly included industry people.
I guess it's your industry peers that are to blame for this regulations mess.
Strega wrote:A couple of things, you mentioned earlier in the thread "as a professional AME"... unfortunatly.. you are not. If you were, you would be able to put P.AME. behind your name, end of story.
Yes, you've got me there. I do not have a degree. I am not part of some fraternal society that makes me part of the "professional" club. I do not put P.AME behind my name in emails or on my business card. I've always kind of thought that adding your educational credentials to your name or email signature was a bit pompous and smacked of self importance, but hey, that's my own opinion. I merely meant to say that being an AME is my profession and I conduct my self in a professional manner. There are lots of people out there with degrees that I would not consider professionals. A persons conduct in their trade and respect for others is what makes them professional, not a degree or fraternity.
Strega wrote:AMEs - (or as I like to call them, "mechanics" not to mention everyone else in the world) are aircraft mechanics that follow guidelines and standards, that have been created by "Pinky Engineers" (and others with professional responsibility).
Thank you for this very relevant comment. It has added greatly to the discussion.
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Re: Amateur Built Maintenance Question

Post by photofly »

If you give "small commercial operators" an advantage by allowing them to be exempt from such a regulation, then you'd quite likely end up with unqualified, unfamiliar with type, under equipped individuals performing and signing out maintenance on aircraft that the general public are renting to use for flight training. Heck, you'd eventually end up with those operators that get their pilots or students to do their own maintenance (without a licensed AME), and have a "special arrangement" with a local AME to come sign the work off. Don't say it won't happen.
Pure conjecture on your part based on no evidence whatsoever.

Further, your implicit assumption (which is false) is that operators who are ready and willing to flout simpler regulation are somehow keen on obeying stricter regulation. The component you are missing is inspection and enforcement: it's possible to enforce lighter regulation, just like it's possible to enforce stricter regulation. TC shows a complete lack of imagination by slapping in layer upon layer of paperwork instead of doing what it should be doing.

The "level playing field" argument is BS, and counter to settled government policy to encourage small businesses. Here's a whole page of government "initiatives" aimed at making life easier for small businesses:
http://actionplan.gc.ca/en/initiative-s ... l-business
A selection of the headlines there include:
"Canada Revenue Agency Delivers on the needs of Small Business"
"Canada Small Business Financing Program"
"Hiring Credit for Small Business"
"Reducing Red Tape for Small Business - BizPaL"
"Reducing Taxes for Small Businesses"
"Small Business Job Credit"
"Supporting Internships in Small and Medium-Sized Enterprises"

Why is Transport Canada not engaged in this? Why does a mom-and-pop operation have to pretend to be Air Canada to pass muster with TC?
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Re: Amateur Built Maintenance Question

Post by robertw »

photofly wrote:Pure conjecture on your part based on no evidence whatsoever.
Listen, I'm speaking from my own experience as an AME. I've worked on numerous small FTU, 702, 703, 704 operator aircraft and the majority of them are the first to squawk about costs or whether or not something needs to be fixed. More so than private operators. It always came down to the bottom line. If there was a way to get around a regulation to save money, they'd try it. Years ago, I knew first hand that that a couple of them were doing their own maintenance without documenting it or even having it reviewed and signed off by an AMO. I was an apprentice at the time and was not really aware of what the regulations were, so nothing was said. I try not to make accusations without backup.
photofly wrote:The "level playing field" argument is BS, and counter to settled government policy to encourage small businesses.
I absolutely disagree on the BS comment. Aviation is an industry that needs solid regulation. Peoples lives depend on it. If a regulation happens to discourage small operators in a particular segment of an industry, then maybe, just maybe it should be left to bigger fish in the pond. There are other ways to make money. A true entrepreneur knows this and won't whine and complain about regulations making their business so hard to carry on. They reinvent themselves and carry on somewhere else or they suck it up and continue to deal with the regulations by meeting them.
photofly wrote:Why is Transport Canada not engaged in this? Why does a mom-and-pop operation have to pretend to be Air Canada to pass muster with TC?
No one is asking Mom and Pop to be Air Canada. Just get your commercially used aircraft serviced at an AMO to ensure that there is a system of control over the maintenance done to the aircraft.
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