Where do you service your aircraft?

[drseti]

Of course, Roger, owner approved PM does not need to be supervised. And much of that PM occurs during the course of a Condition Inspection, so the owner can do that part, with or without supervision. I've had owners (especially the first time) ask me to check them out on PM tasks - show them how, and look over their shoulder to make sure they're doing this right. That might not technically be supervision, but it's helpful to the owner, it's not prohibited, and it's a service that I (and many LSRMs - probably you too) are happy to provide.

[drseti]

Interestingly, the question of owner assistance is addressed in today's AOPA Aviation eBrief. Attorney Mike Yodice writes:

A qualified pilot is permitted to perform preventive maintenance concurrent with the annual inspection, such as changing oil and cleaning spark plugs, but may not help with the performance of the inspection itself. What about removing cover plates, cowlings, and fairings? Interestingly, in Part 43 Appendix D subpart (a) it says, “Each person performing an annual or 100-hour inspection shall, before that inspection, remove or open all necessary inspection plates, access doors, fairing, and cowling. He shall thoroughly clean the aircraft and aircraft engine.” Does that mean only the IA can do this work when it’s associated with an annual? No, I don’t think so. A 2015 FAA legal interpretation clarifies that “… inspection plate removals and aircraft cleaning are preliminary and incidental to the actual inspection of the required items. As such, they may be performed by individuals under the supervision of the holder of the IA.” This same interpretation authoritatively states that “…any assistance provided by a non-IA holder must not include an inspection and airworthiness determination of the item at issue.” Thus, the owner may perform the preliminary and incidental tasks to an annual inspection without running afoul of the regulations.

Although there is no mention of LSRMs or LSAs (as this opinion was specific to IAs and certified aircraft), this seems to support my contention that owners of an LSA can help an LSRM with the PM parts of a condition inspection, and in fact the LSRM can provide training to the owner in the process, without violating the restriction on an LSRM's supervisory privileges.

[3Dreaming]

Paul, to be clear the privilege of supervision of a task is specifically granted to the A&P, and it is not granted to the LSRM.

§65.81 General privileges and limitations.

(a) A certificated mechanic may perform or supervise the maintenance

(c) The holder of a repairman certificate (light-sport aircraft) with a maintenance rating may—

(3) Only perform maintenance, preventive maintenance, and an alteration...

[drseti]

And Tom, to be clear, I am not advocating an LSRM supervising maintenance. I am arguing for the right of the LSRM to instruct and assist the owner in owner-allowed preventive maintenance tasks. How else is the owner to learn to change the oil, or even burp a Rotax engine -- is he or she required to hire an A&P (who may not know about PM on a Rotax as well as an LSRM does)?

At the conclusion of his AOPA article, Mike Yodice says:

I am not advocating for a change to the aviation lexicon. “Owner-assist annual” is a time-honored expression. Rather, I think it’s useful to deconstruct it for the sake of clarification. And, by the way, “Owner-assist maintenance during and/or preliminary and incidental to the annual” just doesn’t flow very well.

[3Dreaming]

Interestingly, the question of owner assistance is addressed in today's AOPA Aviation eBrief. Attorney Mike Yodice writes:

A qualified pilot is permitted to perform preventive maintenance concurrent with the annual inspection, such as changing oil and cleaning spark plugs, but may not help with the performance of the inspection itself. What about removing cover plates, cowlings, and fairings? Interestingly, in Part 43 Appendix D subpart (a) it says, “Each person performing an annual or 100-hour inspection shall, before that inspection, remove or open all necessary inspection plates, access doors, fairing, and cowling. He shall thoroughly clean the aircraft and aircraft engine.” Does that mean only the IA can do this work when it’s associated with an annual? No, I don’t think so. A 2015 FAA legal interpretation clarifies that “… inspection plate removals and aircraft cleaning are preliminary and incidental to the actual inspection of the required items. As such, they may be performed by individuals under the supervision of the holder of the IA.” This same interpretation authoritatively states that “…any assistance provided by a non-IA holder must not include an inspection and airworthiness determination of the item at issue.” Thus, the owner may perform the preliminary and incidental tasks to an annual inspection without running afoul of the regulations.

Although there is no mention of LSRMs or LSAs (as this opinion was specific to IAs and certified aircraft), this seems to support my contention that owners of an LSA can help an LSRM with the PM parts of a condition inspection, and in fact the LSRM can provide training to the owner in the process, without violating the restriction on an LSRM's supervisory privileges.

No where in part 65 where the FAA has granted supervisory privileges to a LSRM. They do however grant those privileges to a A&P.

[drseti]

Tom, I maintain that instructing an aircraft owner in how to perform owner-permitted preventive maintenance is not supervising maintenance, it is teaching a necessary pilot skill. If I'm not permitted to provide this instruction while wearing my LSRM hat, certainly I am allowed to do so in my capacity as a CFI. (PM is a standard part of my curriculum whenever teaching a student in his or her own aircraft -- and was so, long before the LSRM rating even existed.)

[3Dreaming]

Back to the original point. An A&P can supervise maintenance the goes beyond preventive maintenance, while a LSRM cannot. For example I can supervise a owner disassembling their carburetors for inspection wile you can't.

[drseti]

That, Tom, is undeniably true. You as an A&P have supervisory privileges that I, as an LSRM, do not!

[drseti]

Note to all the lurkers out there: Tom and I are not arguing, we're simply educating each other (over the years, Tom has taught me much, and I'm grateful for his participation here).

[3Dreaming]

Paul, thanks for the kind words.

[Merlinspop]

Note to all the lurkers out there: Tom and I are not arguing, we're simply educating each other (over the years, Tom has taught me much, and I'm grateful for his participation here).

Also worth noting was, despite more than one "round" of back and forth, no insults were hurled, no resume references were made, and both parties acted like mature adults (no, I'm not calling anyone old.... or *am* I......?).

Still and all, it seems this thread is missing something... Hmm... oh yeah:

.....

Yeah, I really wish I was at KLAL now. Have a great time to those who are there!

[MikeP]

I love a place where the practice of one upping someone else is NOT part of the routine. Discussions of things by those knowing just makes it better for all of the rest.

[FastEddieB]

I love a place where the practice of one upping someone else is NOT part of the routine.

Me, too. But a cage match at the end to settle it once and for all would certainly liven things up!

[MikeP]

I love a place where the practice of one upping someone else is NOT part of the routine.

Me, too. But a cage match at the end to settle it once and for all would certainly liven things up!

Haha. I'm on too many of those kinds of sites. Laid back is more my thing. I'm no expert or probably not even very informed on a lot of aviation related stuff. I'm just a homebuilt enthusiast trying to learn.

[drseti]

I harbor no illusions. I would lose a cage match to Tom in about 30 seconds!