The FAA will soon reverse a policy that barred homebuilders from counting time spent building an aircraft toward a maintenance rating, such as Airframe and Powerplant certificates, according to a new report from the Experimental Aircraft Association (EAA).
In late 2019 the FAA changed Order 8900.1 to exclude time spent building any aircraft, including homebuilts, from the types of practical experience eligible to count toward a maintenance certificate.
No reason was given for this change, and officials with EAA say they have been advocating for it to be rescinded.
In a meeting at EAA AirVenture Oshkosh 2022, the FAA agreed to change the policy back, however the publication of an amendment remains forthcoming.
The FAA released an interpretation letter July 7 in response to a “well-written and pointed request for interpretation” by EAA member Brenton Ellis.
The letter “confirms that not only is the current exclusionary policy not logical, it is also contrary to regulation that clearly states aircraft construction counts as experience toward maintenance ratings,” EAA officials said.
The letter also states that the policy change is “imminent.”
“We have talked to several homebuilders who wanted to use their experience to earn their maintenance ratings,” said Tom Charpentier, EAA government relations director. “In an era with a shortage of A&Ps, and particularly A&Ps willing and able to work on amateur-built aircraft, this policy made no sense and we are happy to see that this letter confirms that relief is at hand.”
There are some EAB builders out there that shouldn’t be A&Ps for sure. They are a slim minority in my opinion. To be fair, I’ve also seen A&Ps that I wouldn’t let anywhere near my airplane. There is no question that building a single airplane of one type might not be enough overall experience but neither is working at a shop that does annuals on flight school 172’s all day everyday and that happens all the time.
It’s not possible to get all the experience to work on everything. I’d love to get my A&P but most of my experience is on EAB aircraft. I’ve built an RV, and a Pitts S1C and am building a Christavia Mk1. I’ve done welded steel tubing, wood, fabric, sheetmetal, fiberglass, engine work, overhauled mags, electrical, avionics, fuel systems etc. I’ve worked on gliders, spam cans and rag and tube taildraggers over the years under supervision but not nearly enough for the 4800 hours. I’m a machinist, an engineer and I’ve been wrenching on everything under the sun since I was a kid. By the time I graduated from High School I’d done a couple dozen engine overhauls. I think I’d make a good A&P but the hours are standing in my way. If the FAA reverses this ruling I can reduce the mechanic shortage by one. I promise that I’ll stay in my lane.
Phil, I believe we are in agreement but looking at it from different sides of the fence. I also believe that if you do this long enough, you might see it from my perspective. I applaud what you are doing to get an A&P. It appears you and I have a similar background and experiences and I’m sure you will be quite an asset to aviation. What I see in your statement are the words “under supervision” and I think that, along with your other EAB experience should be more than satisfactory and I’m sorry the 4800 hour requirement is in your way. Perhaps my statements should have been tempered to say one project. Or more aptly a 51% project. The individual I spoke of built a 51% project and managed to “whodo” the FAA into an A&P authorization. Clearly considerably less experience than you have obtained thru your dogged determination. Personally, I’ve grown tired of dealing with owners of certified aircraft wanting to save money by building their own and getting an A&P “so they can do what they want”. But in the same breath bragging about the “tricks” they’ve learned. These have included utilizing nylon toilet seat hardware ($2.98) for hinges on movable panels, utilizing hydraulic fluid from the local tractor shop because they can buy 5 gallons (w/ higher flash point…) for the cost of 1 quart of 5606. Then there are the hoses from the tractor shop. Yes, they might be rated for 6K psi but they’re still not certified. Oh, despite the differing angles of the flanges and fittings, “just get them really tight and they will not leak.” Often I’ve seen sheet metal repairs done where the owner /builder couldn’t identify the type of metal much less an alloy or temper but they know the pop rivets came from NAPA (National Aviation Parts Association). On an experimental OK, but often I see this on their certified planes and have to be the bad guy. And again in all fairness, some A&Ps are this way too but we don’t need more. Occasionally, I get homebuilders come in with really great questions and I usually stop and help in anyway possible. Those guys are always welcome and generally present really good work and are accepting of a better way.
As I see it, many (not all) of the experimental folks want to have their cake as cheaply as possible and eat it too. They don’t want to follow the same strict guidance we must follow with respect to maintenance and I’m OK with that. However, if they want to be a certified A&P mechanic and work on certified aircraft they should be required to follow the same requirements that we followed. Not only the path I followed over 45 years ago but the one you are on now. Admittedly not all of your time is certified but is supervised and a great indicator of your knowledge, skill and ability. I would hope any reasonably FAA guy could see it and get your authorizations ASAP. Unfortunately the FAA is not always populated with reasonable folks.
Good luck moving forward and I wish you well.
I disagree with allowing homebuilding experience to be utilized for the A&P. Are there some great builders out there? Yes, absolutely! But, there are some cowboy know it all’s that are a danger to themselves and others as well. In the experimental world, have at it but, buyer beware. I know of an individual that utilized their experience building a homebuilt to get an A&P sometime ago. This guy wasn’t a wrench turner before and building the homebuilt was a retirement gig. But, instead of removing components to install a wing attach bolt, he just trimmed off the side of the bolts head. The elevators had about a 20 degree split between left and right as well as twisting in the vertical. He was advised of all these issues along with additional hardware and wiring/avionics problems but chose to move on. Did he fix these items? I don’t know but he was very insulted at the notification of some serious discrepancies. I haven’t seen him since. I understand he now travels about as homebuilt advisor/consultant assisting others with their projects. By now with his years of experience he must know enough to be an IA. What danger does he pose to general aviation now? Can we say $100 dollar annuals or pencil whipped inspections? I have seen this behavior in many builders over the years not just this one and in all honesty, some A&Ps as well.
Yes, there is a shortage of A&P Mechanics and technicians in all trades and backgrounds in the world. Does this mean we should lower the standards. Let’s say for the sake of argument we reduce the requirements for Surgeons. Should we allow trained EMT’s to operate on our gall bladders? Maybe a really good veterinarian could do it but, not my first choice. How about teachers? No, just get a guy that’s good at “Trivial Pursuit” or “Jeopardy”. I’ll take Aviation Safety for $200 Alex.
I’ve been an A&P for 45 years and worked in aviation for several years before that. I’ve seen great work done by rated and unrated mechanics. The license really does mean something. It at least shows you have a basic working knowledge and should understand the responsibilities of the A&P. I’ve always been willing to sign off great work but disappointed when some shoddy and/or dangerous conditions are let go by some builders saying, “it’s experimental, I’m doing it anyway”. The problem with many is they don’t know, what they don’t know and aviation isn’t very forgiving. Arrogance and Attitude can be the culprits here.
If you built it, you should be able to maintain it. Just yours, not someone else’s, not your friends, not your Brother-in-Law’s or, the guy down the street for a quick few bucks. In general, the average “Joe” building a project isn’t enough broad experience an A&P.
As an old (school) A&P instructor, school director, IA and long time pilot/mechanic I will remind this forum that experience is relative. If the homebuilder is pulling pop-rivets he’s not learning the FAA quality trade. At the same time, most if A&P training isn’t as much learning to “do” as it is learning how to find correct instruction, read and follow a specification, apply FAA regulations (read ADs ). In the end he/she must pass the three writtens and impress the examiner with a level of skill at an FAA specified level of quality in an extensive oral and practical.
IMHO this change will add greatly to the A&P pool. This applicant is more likely qualified to work on smaller, GA aircraft and is better suited to that than an airline focused A&P will be. The material one must show to get their 8710 signed represents bits and pieces of the industry. A certificate hardly makes the applicant qualified to do all things but it does show a level of accomplishment that includes knowing that there ARE rules, specifications and instructions to be adhered to and how to find and apply them. Building a homebuilt, to an FAA airworthy condition is a fair way to enter the realm.
I find it a bit interesting in that in my letter requesting permission to take the exams for the A&P, I mentioned work on completing two amateur built airplanes. The FSDO ASI reading and approving my request, asked more questions about that than any of the rest of the letter. I’ll take it that it didn’t count, and just call it “interesting.”
I think this is good news, with some pros. and some cons. I personally don’t think building a Zenith is enough experience to work on a complex plane or a Fabric plane, and I don’t think building a Cub is enough experience to work on a RV. I agree the time should count, but it should not be your entire time.
I also think it makes more sense to add a category that gives someone specific authority to inspect or do A&P work. – If you build an RV7 and can pass a knowledge and skill test specific to that type, you should be able to perform A&P work on them. Likewise, if you purchase an experiment that you maintain, you should be able to pass a knowledge and skills test that lets you inspect that plane.
When I was in A&P school, we used to go to airshows and find defects in homebuilts. Mostly poorly driven rivets, tool marks on fluid lines, etc…There are a lot of homebuilts flying around with workmanship that wouldn’t pass the practicals. Hopefully DMEs do their job properly so we don’t see a dilution of the reputation of the A&P. Frankly, there was already a massive difference in knowledge and overall quality between the Part 147 mechanics and the folks who met the time requirements for testing from military experience.
This is good, all A&P applicants get to take a written and a deep dive oral to explore their knowledge of all things flinging and flopping on an airplane! This on top of the knowledge bank a builder Acquires after building one’s own plane!
It’s about time👍🏻
Good News for Aviation
I have not read the language associated with this change [in direction], however, hope the final version leans toward the technical/mechanical experience credited “aligning” with a “standard” that we endlessly use, being the 43.13/65-12 (or similar). Sure, generic mechanical aptitude goes a long way, in theory, but when it is specifically applied to receiving “experience” to garner a recognized government “certification” (A&P), hopefully we are all “singing from the same hymnal”.
This is the result of the recent SCOTUS ruling EPA vs West Virginia, and others where the Supreme Court is reigning in rogue administrative agencies. In other words, tyranny is being shut down. This is the end of Chevron deference.
😂
Could be. In any case, the 2019 decision was very wrong. I suspect the shortage of A&Ps may have also been involved in the decision.
Huh?😂