Owner Maintenance Question

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matt17
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Owner Maintenance Question

Post by matt17 » Thu Sep 19, 2019 7:05 pm

In my search for a plane I have come across one that interested me but there is a concerning point that I was hoping those more experienced on this board could help me out with.

I looked at a Cessna 172 that is in owner maintenance and I am curious on the paperwork behind one "Mod" that was completed. Apparently there was a group of owners who all put their 172s into owner-maintenance, got together as a group and purchased one Sportsman STOL kit which they then used to copy, create and install kits in multiple planes (with only one set of STC paperwork). From my preliminary viewing the work appears to be well done (owner had multiple homebuilt planes previously and the group included at least one AME) but I am unsure on the legality over what they did. I am mostly interested in the "airworthiness" perspective not the commercial/ethics of copying someones work without paying for it.

The one AME I spoke was of the opinion that what was done was not technically legal but would be fine as long as nothing happened (i.e. insurance/TC investigation after an incident) similar to several O-300s in the same area with High compression pistons installed without paperwork. If the work was well done with appropriate materials are there any issues that I should be aware of?

Thanks in advance for the input.
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PilotDAR
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Re: Owner Maintenance Question

Post by PilotDAR » Thu Sep 19, 2019 7:36 pm

Matt, you've noticed one of the wrinkles in the OM system. I presume from what you are writing that the STOL kits were installed following the entry of the plane into OM.

The TC policy on this (#1212867, Rev 3, of July 01, 2008, reads in part:
2.3 The provisions of the CAR’s and related standards allow the owner(s) of a small aeroplane to perform the maintenance on their aircraft, effect modifications and repairs without Transport Canada approval and install uncertified parts; the provisions also authorize the owner(s) to sign the maintenance release for all maintenance performed on their aircraft.
And, from the CARS:
571.06 (1) Except as provided in subsection (5) and in the case of aircraft that are operated under a special certificate of airworthiness in the owner-maintenance classification, a person who signs a maintenance release in respect of a major repair or major modification on an aeronautical product shall ensure that the major repair or major modification conforms to the requirements of the relevant technical data
So, although the OM category was not really intended to be a free for all for modifications, (I was present at all of the CARAC meetings for this new rule back in the day), the rules have been written to allow mods to squeak through. In particular, because the possibilities for approval of the mods on OM aircraft are now limited. As a DAR, I cannot issue a serialized STC to an OM airplane (TC rules, and on one every asks!).

So it really becomes up to you to make the determination if the work accomplished on the plane meets your standards of airworthiness! The work might be excellently done, and you'd be proud to own the plane. OM does not mean the plane is poor, it just means that it is possible that an AME/AMO has not been involved in work accomplished. It is fair that you would ask to see detailed work reports for mods accomplished, and evidence that the work was actually done in accordance with installation instructions which you accept as appropriate. Though an AME will not sign a maintenance release for the plane, you can still ask an AME to perform a pre purchase inspection against the certified standards for the plane, and see where the differences (if any) are. The fact that a plane is in the OM category is not reason that it need have poorer documentation of the work accomplished! It's just who signed for it!

I'm a proponent of OM, having one plane in that category, and planning to put another in before too long. And, I'll still use appropriate data for modifications, and keep good records.

One cautionary note, and that is that the person signing out the work might overlook the standard STC mod requirement (on the bottom of every certificate)
Prior to incorporating this modification, the installer shall establish that the interrelationship between this change and any other modification(s) incorporated will not adversely affect the airworthiness of the modified product.
Once you start mixing STC mods together, this can have real implications, and must be considered. Some STC mods do not mix well with others, and in some cases, this can include STOL kits. I'm a big fan of STOL kits, but they must be considered in context on the plane.

I know that I have not exactly answered your question, I'm not certain that there is a certain answer. On the other hand, if the work is well done, and never contributes to a defect or problem, probably no one is worried about it! Buyer beware, and if you want to own OM, you'd best either be well acquainted with the requirements, or employ an AME who is. You can sign for his/her work with an OM plane.
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Heliian
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Re: Owner Maintenance Question

Post by Heliian » Fri Sep 20, 2019 5:04 am

You won't be able to register outside of the OM category in this case, at least not economically.

You can't just slap STC paperwork on top of homemade parts as then those parts would be classified as suspected unapproved parts, they were not made by the certificate holder or anyone else approved.

I thought the intention of OM was for people with aircraft that couldn't be supported anymore and not cheapo's who are constantly cutting corners.

I wonder how many people remove the warning stickers from the plane after they go OM?
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photofly
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Re: Owner Maintenance Question

Post by photofly » Fri Sep 20, 2019 5:43 am

Lots of STCs have instructions for the installer to manufacture their own parts for the installation. Whose hands actually do the work is not really important as the installing AME is making them or having them made under their authority.

Doesn't sound like that is the case here, but I have an engine installation STC on a certified aircraft that comes only with paper plans: every new bracket has to be made by the installer.

Even without the STC, you would never be able economically to reverse a transfer to OM. Although there is a list of requirements to do so in the CARs, TC makes it clear with the OM application that they consider the process to be one way, and they have (deliberately) avoided creating an approved process to reverse it.
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Heliian
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Re: Owner Maintenance Question

Post by Heliian » Fri Sep 20, 2019 6:14 am

Yes, exactly. You need the STC to make the parts, it's a one way deal.
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Re: Owner Maintenance Question

Post by AirFrame » Fri Sep 20, 2019 7:02 am

matt17 wrote:
Thu Sep 19, 2019 7:05 pm
I looked at a Cessna 172 that is in owner maintenance and I am curious on the paperwork behind one "Mod" that was completed. Apparently there was a group of owners who all put their 172s into owner-maintenance, got together as a group and purchased one Sportsman STOL kit which they then used to copy, create and install kits in multiple planes (with only one set of STC paperwork). From my preliminary viewing the work appears to be well done (owner had multiple homebuilt planes previously and the group included at least one AME) but I am unsure on the legality over what they did. I am mostly interested in the "airworthiness" perspective not the commercial/ethics of copying someones work without paying for it.
Was the airplane inspected by TC after it was modified? Any modification affecting structure, performance, or airworthiness must be reported and approved. If that was done, then there's nothing left for you to do. If it wasn't, your C-of-A may not be valid.
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Re: Owner Maintenance Question

Post by PilotDAR » Fri Sep 20, 2019 7:55 am

You can't just slap STC paperwork on top of homemade parts as then those parts would be classified as suspected unapproved parts, they were not made by the certificate holder or anyone else approved.
You may not part mark, certify and sell parts which were not made under an approval.

AWM 571.06 allows "repair" parts to be made by the installer under some circumstances. However, a newly made STOL kit, where that kit was not previously installed, really would be new parts, rather than a repair.

CAR 571:
571.07 (1) No person shall install a new part on an aeronautical product unless the part meets the standards of airworthiness applicable to the installation of new parts and, subject to subsections (2) and (3), has been certified under Subpart 61.

(2) No certification referred to in subsection (1) is required where

.........

(d) a new part is installed on an aircraft that is operated under a special certificate of airworthiness in the owner-maintenance or amateur-built classification; or...........
The modification authority for OM aircraft is a little fuzzy, simply because there is no means to actually approve mods on these aircraft through the aircraft certification office of TC. That leaves it up to the TC M&M Inspectors, who simply do not want all of the work involved in the evaluation, and are generally not staffed for that type of work anyway. On a few occasions, I have been asked by TC M&M to evaluate a mod on a flight permit aircraft, so they they might reissue the flight permit for a mod. In that role, I'm not acting as a DAR though, just a person that M&M knows can apply the evaluation process properly. So far, this has not come up for an OM airplane.

As said before, unless there's a defect in the work, and a resulting fuss, a home made STOL kit on an OM Cessna which has been well done is unlikely to attract any unhappy attention. In the worst case, if it did become a problem, it could be declared to TC, and the flight authority reissued to include it. That's possible, though really low on TC's interest scale.
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Re: Owner Maintenance Question

Post by boeingboy » Fri Sep 20, 2019 12:18 pm

Overall - because it's owner maintenance. The mod is probably legal. The sportsman stol is just a bunch of sheet aluminum skins and some foam nose blocks. I wonder what they did about the fiberglass fairings though???

Aside from that - I would never buy an aircraft in the OM category. For the simple reason that it's value is radically decreased - (even though owners think they can ask just as much for it) The simple fact is - that you can not sell that aircraft outside Canada - so the re-sale market is extremely small and if anything happened - you could not even sell it for parts. So essentially - you end up with an aircraft worth next to nothing.
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Re: Owner Maintenance Question

Post by PilotDAR » Fri Sep 20, 2019 3:35 pm

So essentially - you end up with an aircraft worth next to nothing.
Well, except for the fact that it's a flying aircraft, what's one of those worth? More than next to nothing, if you're happy to fly it within Canada....

The plane in my avatar has been OM for nearly a decade, I've enjoyed more than 500 hours of great flying in it. It does not know that it's OM!
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Re: Owner Maintenance Question

Post by boeingboy » Fri Sep 20, 2019 3:55 pm

Well, except for the fact that it's a flying aircraft, what's one of those worth? More than next to nothing, if you're happy to fly it within Canada....
...and that's fine if that's what you like.

My point was - that resale is extremely limited. Wether it's you, or your estate, or whatever. It's something to consider when you think about purchasing one. You can't fly t the US - you can't sell outside the country, and if you have an accident or the plane sits for years - you can't even part it out. That's going to have a serious impact on the sale price when it gets sold.
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Re: Owner Maintenance Question

Post by goingnowherefast » Fri Sep 20, 2019 4:07 pm

With that argument, should be able to buy the OM plane for equally as cheap.
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matt17
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Re: Owner Maintenance Question

Post by matt17 » Fri Sep 20, 2019 5:45 pm

Thanks for the input. I am aware that OM is a one way street. I am intrigued by the benefits of Owner Maintenance after doing a lot of research on an amateur built but like the idea of all aluminum vs fabric for my use. If I move forward I will definitely work with an AME for a through pre-buy and will work with an AME on the maintenance doing what I and they are comfortable with.

It sounds like the STOL kit install should not be a deal breaker if it was as well done as it appears. It would be the overall condition of the plane and the documentation both before and after it was converted to OM.
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Re: Owner Maintenance Question

Post by JasonE » Fri Sep 20, 2019 9:41 pm

The biggest issue I have purchasing an OM aircraft is having confidence in the last owner who maintained it. I would certainly have some lengthy conversations to get an idea if the work was up to snuff.
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jakeandelwood
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Re: Owner Maintenance Question

Post by jakeandelwood » Fri Sep 20, 2019 10:07 pm

I know some owners that have their aircraft in the OM category and they are absolutely fanatical about their maintenance and their plane shows it. I think that an OM aircraft in some ways may be better maintained because the maintenance is more affordable. There are things I'd like to do on my plane that Im not permitted to do myself and I can't afford to do at the moment, they are not necessary for airworthynes but they are things that would make the plane better. Your own labour is free and that makes many improvements and maintenance items way more attainable for the average small plane owner.
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Re: Owner Maintenance Question

Post by PilotDAR » Sat Sep 21, 2019 11:29 am

I know some owners that have their aircraft in the OM category and they are absolutely fanatical about their maintenance and their plane shows it. I think that an OM aircraft in some ways may be better maintained because the maintenance is more affordable.
This is an important theme. When you can do the maintenance yourself, and record it properly, it means that it is a little more likely that things will get done sooner, rather than waiting for the next time the plane is at the shop, and, for my experience, on my OM plane, I will happily spend time tinkering, and making things just right, which I would be less eager to pay a shop those few extra hours, for something I don't really need, but would just like to be better.

As you get to know your plane better, you're better at preventing degradation, as you are more aware. And if you're stuck somewhere by a snag, you're more able to rectify it.

An inspection of the plane, reading the records, and meeting the owner/maintainer will tell you a lot about the condition of the plane, and thus it's value, be it certified or OM.
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Re: Owner Maintenance Question

Post by Mapleflt » Sat Sep 21, 2019 1:31 pm

A well maintained, documented OM C of A aircraft is far less concerning then a "just on time, only as required, pencil whipped" standard of C of A airplane. I own an OM aircraft, enjoy working on it and when the task is above my knowledge base I seek out those wiser then I for their guidance and advice. If I was considering an OM aircraft I'd retain an AME to complete a full pre-buy inspection like a standard C of A aircraft. A proper Pre-buy inspection assess value, determines maintenance status, general condition and thereafter proceed with the purchase if the indicators where favorable.

On a related note there are now manufacturers that in a small, likely unintended way are catering to the OM market by offer non-certified versions of their otherwise identical certified product, usually at a lower price point. Some examples of these items are the Garmin G5, B & C starters and alternators and recently the AeroVonics AV-30. These items are intended for the amature built market however having a "certfied" big brother makes them viable for use in the Canadian OM market
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Last edited by Mapleflt on Sun Sep 22, 2019 5:00 am, edited 2 times in total.

jakeandelwood
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Re: Owner Maintenance Question

Post by jakeandelwood » Sat Sep 21, 2019 4:44 pm

I'm sure there are also many certified airplanes that are not on the OM eligibility list that have had work done on them by the owners and nothing was written in the log book.
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