Often, the purpose of a column like this is to create an opportunity to begin a discussion. By opening the floor to a wide-ranging collection of potential readers, especially because many of those readers can share real insights and personal experiences on the topics raised, the community as a whole can benefit.
That sounds good in theory, but this process is not without occasional discomfort.
The ideas expressed may challenge firmly held beliefs. Practices and procedures that are recommended may rub any one of us the wrong way for a variety of reasons.
Opinions vary, and can sometimes lead to heated exchanges and hurt feelings.
There is also the distinct possibility that any one of us may find ourselves in the unenviable position of being flat out wrong, in public. Ouch.
Ain’t nobody got time for that.
As regular readers know, I am not immune from this experience. The piece that ran in this space last week, “Ask an Expert,” was 80% on point.
In most respects it was true, and it was entirely well intentioned. But it was also wrong — at least in the latter portion where I related a story about a gentleman who suggested it was acceptable for an owner to make parts for their own airplane even if they aren’t an A&P mechanic.
I took the opposite position. I said owners could not make their own parts unless the airplane was a classic or antique that was out of production, making factory parts unavailable as a result.
I was wrong. Entirely, completely, absolutely wrong. You can make your own parts and be completely within your privileges doing it. The FAA says so.
Imagine my surprise!
The regulation that allows for an action I’d always believed to be unacceptable is one I’d never heard of, and frankly, probably wouldn’t have found had I searched the regs for a considerably longer period of time.
It’s in 14 CFR Part 21, which is not a section I spent time in when doing my research for that piece.
Silly me.
Thankfully, the cumulative brain power of General Aviation News’ readership is considerably more powerful than the limited gray matter encased in my skull.
Two readers brought my error to light, and I’d like to thank them for doing so.
Jim Hausch shared the correction first in the comments section of the online blog post, complete with a link to an article that dealt very specifically with the issue of owner made parts.
A couple hours later, a reader known only as DeWayne shared his correction, as well as a link to a column written by the renowned aviation mechanic, Mike Busch, on the exact topic I’d stumbled over.
Later, he cited Advisory Circular 20-62E, which spells out the procedure for how an owner can make their own parts for the aircraft they own.
While I was initially less than pleased with myself, I have to admit, I’m thrilled to have been corrected. While being outed for being wrong may be unpleasant, it doesn’t have to be a negative experience. In fact, it can be quite enlightening.
Remember the first paragraph of this piece, the one that explains the reason for writing and publishing columns like this one? Well, that’s exactly what happened. The column sparked discussion, and the discussion was beneficial.
And while I would love to be able to say I have never been wrong, both you and I know that would be a ridiculous assertion to make.
After years of writing about aviation, aviators, and the machines we enjoy so much, I can readily admit I have been wrong often enough to recognize my errors as prime opportunities for learning.
Like you, I don’t know everything. Age and an overload of information leads me to forget some things, too.
Perhaps this is one of those cases, perhaps not. It doesn’t really matter. The important thing is, a column resulted in a discussion of the topics expressed, and the readership (as well as the writer) came away better informed as a result.
Winning!
Best of all, if you go to that column and read those comments, you’ll notice there is no animosity. The readers who had something productive to offer weren’t slinging mud or proclaiming superiority. They were, simply and graciously, offering their own insights and knowledge for the benefit of others.
Oh, if only all human discourse could be conducted so well. What a wonderland we would live in.
Thank you, Jim Hausch. Thank you, DeWayne. You both offered a great service to the rest of us, and I am truly grateful.
Humble pie really isn’t all that bad. Especially in a case like this, when I can take it a la mode.
As a very long time A&P and multiple GA airplane owner, this subject is something everyone who owns an airplane ought to both know AND have a copy of the Advisory Circular. Especially para 4n
“n. Owner/Operator Produced Part. Parts that were produced by an owner/operator for installation on their own aircraft (i.e., by a certificated air carrier). An owner/operator is considered a producer of a part, if the owner participated in controlling the design, manufacture, or quality of the part. Participating in the design of the part can include supervising the manufacture of the part or providing the manufacturer with the following: the design data, the materials with which to make the part, the fabrication processes, assembly methods, or the quality control (QC) procedures.”
It is the FAA’s position that as long as an owner participated in ONE of those actions, HE is the producer of the part. He could, for example, spec. a new instrument panel which mirrors the original with only a few changes. At that point, he could give his drawing to a mechanic and the mechanic can build and install that panel. BUT … the mechanic CANNOT build a non-standard part without owner participation. That’s the part that doesn’t seem right … but is.
There’s a couple of other items worth mentioning while you’re on the subject. Lets take the potential case of an owner who wanted to replace a cigar light socket with something that offered a USB power output for his iPad. Could that be done. Absolutely. The power protection (fuse or C/B) and wiring has to be correctly sized and any necessary labeling has to be visible. If it weighs under a pound, W&B is not impacted, or converse. It is a minor alteration (because it isn’t on the list of MAJOR alterations) and it would require only an A&P final signature. SOME A&P’s would balk at this but if they do … find someone who knows what they’re doing. Mike Busch, the famous A&P has MAJOR heartburn on this subject.
Let’s take another common issue. Avionics. Two issues. There are several manufacturers of fine low cost avionics that do not have a TSO. Most folks think that everything has to be TSO’d, STC’d or PMA’d. That IS true if the mechanic is doing ALL of the work. But if an owner participates, he and his mechanic can make the determination that the (com) radio, let’s say, meets the intent of para. 4 b (3). Years ago, there was a company in Grass Valley, CA who manufactured kit avionics. Many mechanics thought that equipment could not be installed but — in fact — the Advisory Circular says otherwise.
The dividing line in the situation is that you can only modify YOUR OWN PRODUCT (translated … your airplane). You can’t come up with some better mouse trap and start selling them to other owners.
An exception to the avionics story is ADS-B position equipment that’s feeding into a Mode S transponder OR a UAT unit. Because of the need for absolute accuracy, this equipment AND the installation must be done under STC. It gets complicated fast.
Lastly … don’t forget that if you do any work on your airplane, it has to be signed off by an A&P (as long as it’s a minor alteration) or IA on a Form 337 (if it’s a major installation).
EAA has an excellent webinar by Mike Busch on this subject available via their website. It’s time well spent.
With respect to Kent’s comment about SOME FAA employees … here’s a story that fits. At a Florida airport, numerous airplanes had been modified by the installation of Air Gizmo GPS mounts in the radio stack. An overzealous FAA type from XYZ FSDO shows up and tells them that they can’t have that piece of plastic — PLASTIC — in the airplane and the GPS can’t be hard wired into the bus. Well, it got so bad that the FAA Small Aircraft Directorate in Kansas City had to write a letter to the field setting them straight. I had seen an Air Gizmo mount in a brand new American Champion airplane at Airventure and asked the CEO what was up. He explained it all to me but I don’t think it’s appropriate to say more here other than … mount your Air Gizmos to your hearts content … just follow AC 43.13.
These days, the FAA seems to be finally recognizing that safety comes first and dotting T’s and crossing I’s comes second … a close second but nevertheless second. Who’da guessed that it’d be OK to put a Dynon or Garmin AH in a certificated airplane just a few years ago.
It was Hiram Percy Maxim, founder of the American Radio Reay League who said:
“As ye transmit, so shall ye receive”
It’s an understandable mistake. It certainly seems counter-intuitive that you can use home-made parts on a certified aircraft.
That shows character, humility and professionalism. That takes balls.
Wouldn’t it be nice if you could find a few FAA employees that had that attitude? Most of them I have to deal with have no character. Most of them don’t know their own regulations, don’t know much about aviation, drunk on the power of the Administrator and have been neutered.
Once in a long while you will run into a good one but that is a rare bird indeed.
hi Kent; and you thought the DMV was BAD? It’s called: “I’M GO-ON ON BREAK NOW!
Great Article.
Thanks, Jamie, for a good article and discourse from the beginning. Such is exactly a main reason why I am involved in this activity known as “aviation” – to learn. I personally learn something on every flight, and usually in every publication I read. And you’re correct – isn’t this why we read and write, in order to get feedback, a discussion, an honest debate? As you stated, it’s a win-win…and it’s appreciated.
I wouldn’t beat myself up about it – your initial misunderstanding and being in error is exactly what prompted the responses, which led to an education for most of us. That’s in large part what any form of the written word is for. Thanks!
If the apoplectic response to the disposition of the Santa Monica airport is any indication, the reaction to your piece is entirely understandable seeing that an awful lot of people in the GA community are old, angry, unevolved, far-right, stubborn jerks with the intellectual capacities of cabbages and the purely mechanical ability to “fly” airplanes.
You didn’t need to be so abject in your apology. These people only like to holler and condemn because they see their own impotence and irrelevance.
I think it was Eisenhower who said something to the effect, ” Beware the fury of a free people “.
And it has been obvious by the way, for decades, the reason why you are still free is the industrial military complex.
What Jamie is exhibiting is graciousness , an attribute people like you sorely lack.
My pleasure. You are very welcome.
If only the rest of the media world would so embrace corrections as you have, rather than relegating them to tiny blurbs hidden deep from casual view.
GAN remains one of my most pleasant morning rituals.
Some are so accustomed of being regulated to the extreme that the concept of freedom does seem strange.