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Doug Hereford

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About Doug Hereford

  • Rank
    Co-Pilot Member
  • Birthday 01/23/1971

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  • Location
    Kansas City
  • Gender
    Male
  1. 12 year mandatory overhaul

    Tom, Yes. What I should have said is that his opinion will likely be more respected and likely seen as more credible. I realize that I find myself in unpopular positions on this forum. I don't mind it though. Even though I have never had any kind of enforcement or disciplinary action from the FAA, I have been in numerous heated discussions with them when their opinion and mine did not match. Fortunately I have always managed to come out on the right side of things. No guarantee for future events though. If I have legal questions, I do put them to the chief counsel, never the FSDO.
  2. 12 year mandatory overhaul

    WmInce, Sound fair to me. Hopefully Roger's FAA guy will give his opinion on it. Obviously his opinion will carry much more weight than mine does. Maybe we will have an expert opinion on Monday.Until that time, I stand firmly on everything that I have said. If the joke is on me, then it is on me.
  3. 12 year mandatory overhaul

    Corey, Read the original rule preamble. It confirms the intent to include 43 app A as preventive maintenance tasks for SLSA. Runtoeat, Another thing about preventive maintenance is it generally done as its name implies...................to prevent an unsafe condition. Sediment in a carburetor would most likely always be an unsafe condition. WmInce, You may not care, but I do. Like I said earlier, I wouldn't have known about the video if one of my customers had not mentioned it to me. See he thought he would be doing me a favor if the part 141 flight school's airplane lost power while he was renting it. I happen to perform maintenance on that plane. My name is all over the records. The last thing anyone needs is unauthorized, undocumented maintenance taking place behind a required inspection or other work. I explained all that to him and he agreed with me. I think if you ask any inspector they will tell you the same thing.
  4. 12 year mandatory overhaul

    Runtoeat, I agree that taking the bowl off of this type of carburetor is pretty basic. The preventive maintenance tasks make no assumptions about specific brands/designs of products, just that they not involve complex assembly operations. When you remove the bowl, there is more going on than first impressions might see. A carburetor bowl does much more than collect sediment. In fact, I think that Bing would say there really shouldn't be sediment in the bowl at all, and if there is, its source should be found and corrected.........................unlike a gascolator who's purpose is actually to trap sediment and water and stuff. There is a lot of individual interpretation needed with 43 app. A I will admit. When Roger hears back from the FAA we can all know for sure. WmInce As I said before, I have no problem with the video content, just the context. That is why I was laughing. On one hand, as Roger eluded to, we don't want owners working by themselves unauthorized and unsupervised, and yet the video promotes just that. Furthermore, it has one working in a very non-standard situation.
  5. 12 year mandatory overhaul

    Runtoeat, Your are correct about the gascolator. Cleaning it is preventive maintenance, and can be done by an owner/operator sport pilot. The carburetor bowl would not be a part of that. When you remove a carburetor bowl, your disassembling the carburetor. Replacing safety wire is also preventive maintenance. Corey, 43 App. A list of preventive maintenance items absolutely apply to SLSA. The manufacturers have no authority to say WHO can perform maintenance/preventive maintenance with the possible exception of a Safety Directive. Roger, I do not mean to ever berate anyone. I apologize if you think that I am doing that. As far as I know, I am still on the Rotax forum, and have been for years.
  6. 12 year mandatory overhaul

    Runtoeat, FAR part 43 app A gives a list of items of preventive maintenance. 43.3(g) is the regulation that allows pilots and sport pilots to actually PERFORM any of those listed items on their aircraft (in the field or road or podunk airport). 43.7(f/h) lets that same pilot/sport pilot approve that SLSA aircraft for return to service. Then he/she can legally (and safely) fly back home. So contrary to what Roger said above, an owner can work on the aircraft when an A&P is not present........................under certain specific circumstances. I don't know what certification you hold, but unless you are a student or recreational pilot, you can perform and approve for return to service, items of preventive maintenance on your own without any supervision. Just remember to make that maintenance record entry in the aircraft records before you are "wheels up". Roger, Disassembling a carburetor is still not on the list of preventive maintenance items in 43 app. A. Therefore, the many times aforementioned "self rescue" techniques of debris removal from the carburetor in an SLSA is reserved for supervised pilots, or pilots who also hold appropriate mechanic or repairmen certification. I am still laughing at your last post and looking for that Prilosec. Don't forget to up date the forum with the FAA's opinion on the "self rescue" video. Mr. Morden, I don't know what certifications you hold either. If you have not read 43 app A, you may want to. I think you would be pleasantly surprised at how many mechanical type things that you are allowed to do as just a pilot (I realize that you might be a mechanic and consequently do not care). In my opinion, we are actually not that heavily regulated in this country when it comes to "Joe Blow" general aviation.
  7. 12 year mandatory overhaul

    Roger, I am Literally laughing out loud. Your "self rescue" video has the owner working by himself.............................in a field. Hard to stomach again.
  8. 12 year mandatory overhaul

    Another thing about supervising that is interesting to me. I generally looked at the supervising provision in the regs. and thought of it as a nice perk. I think that it may have had a more practical intended purpose. As an example: When installing solid rivets, may times one person cannot access the manufactured head, and the tail at the same time. Obviously two people are then necessary to install the rivet. Driving the manufactured head and bucking the shop head are both critical functions, and both are arguably maintenance functions. Once the work is done, only one person signs the maintenance record entry though. It would seem to me that the other person would have therefore been supervised technically speaking. Installing larger flight controls and some torqueing operations would be another example. Basically anytime two or more people are simultaneously performing maintenance subtasks, supervising is necessary.
  9. 12 year mandatory overhaul

    Runtoeat, I think Corey posted the link to the relevant reg. 43.3(d). To me, the important details in that rule are: Supervisor must have prior experience with the work that he/she is supervising. The supervisor must be physically there, and required inspections cannot be supervised. If those conditions are met, then a non-certificated person can perform maintenance. Another detail to remember in the case of the self rescue scenario is that even if a pilot were supervised disassembling and cleaning float bowls, the aircraft still has to be approved for return to service after they PERFORM the supervised maintenance. This would be done by the supervisor, and must include a maintenance record entry. So if I were to supervise you, we would need to make a maintenance record that has all of the items in FAR 43.9. I would be the one that actually approves the aircraft for return to service when I sign the entry. I was corrected on this forum years ago with regard to LSRM supervising maintenance. Although the regs. are a little vague, the Light Sport rule preamble clearly states that LSRM are not allowed to supervise. I have a personal problem with this, but nonetheless, I was incorrect in my initial thoughts back then.
  10. 12 year mandatory overhaul

    Runtoeat, Good news, you survived an aircraft incident. You may want to thank God (or whoever) that you have the option to appreciate cell phone coverage but if not, just sit tight. Help is on the way......................... Very appropriate attachment, and as I think you are aware, video supervision doesn't count. Roger, You may want to actually read the attachment. Things aren't always what they seem to be. Be sure to update the group on what the FAA says about your "self rescue" video so that Runtoeat can get home.
  11. 12 year mandatory overhaul

    Roger, Glad you are listening. Don't forget to post your response from the FAA on your video. My customers have seen it too and have asked me about it, otherwise I wouldn't have known that it existed. Resume time again. A&P since 1990 Pilot since 1986 Coincidently, I am also in the fire service...................................Fire Medic since 1991 in Kansas City. WHO cares. Say something that makes sense and stop lecturing with half-truths. Also, go back through all of your posts since day one and correct all of the misinformation that you have spread as fact. Then get with Carol Carpenter and have her do the same. You are obviously a very competent technician and aviator, but some of this stuff is hard to stomach.
  12. 12 year mandatory overhaul

    Andy, I do not think that you are in the minority. In my experience, when one really digs into what the GA regs. require, there is a lot of room for personal responsibility and judgment. At the same time, the general public has a very reasonable expectation of safety don't they? If you thought that I did not care about following the rules, would you be ok with letting your family fly with me in my FD? It is not unreasonable to have some level of oversight. I think that if one compares the system in this country to other developed countries, you would find that we allow a lot of latitude to the individual, and still maintain a very high level of safety. Roger, I am probably going to hound you for the results of your inquiry to the FAA on your "self rescue" video. I hope you just referred them to the internet link so that they can watch for themselves just like everyone else in the field would. I am sure that you will have something to report back with on Monday, if not before. Please feel free to actually read any/all of my posts on this site and quote them to your beloved FAA contact.
  13. 12 year mandatory overhaul

    Roger, I am not sure if I am understanding you correctly. If you are asking a leading question about whether I have ever been violated by the FAA, you are seriously out driving your headlights. I see the FAA about once a month for normal surveillance and other oversight activities. This has been the norm for me for about 17 years due to the fact that I am DOM for two 135 charter certificates, operate a 145 repair station, perform and manage mx for the area's only 141 flight school, and perform/manage mx for numerous corporate flight departments and small part 91 operators in the area as an A&P IA. I also occasionally exercise my pilot privileges. The FAA knows just where to find me. I have NEVER been violated by the FAA……………………ever. I have never had any kind of enforcement activity initiated against me or my employees. I have never had so much as a verbal warning or written notice in my file. None of this makes me an expert at anything, and I would not even post it were it not for your offensive inference. I suspect that you are referring the ridiculous Rotax training issue that came up back in 2009. That whole thing was based on a bunch of misinformation put out by self-proclaimed experts in the field and some in the FAA. The only ones who conceded there were AFS 300 in Washington (not me). Discussion threads like this one on mandatory stuff are likely due in large part to that very type of misinformation. I haven’t seen a lot of retractions or corrections though over the years. Please report back to the forum about what the FAA thinks of the video on “self-rescue”. Had you asked my opinion ahead of time, I would have strongly advised you to take it down, and never go to the FAA about it, but looks like that ship may have sailed.
  14. 12 year mandatory overhaul

    Tom, That's fair enough. Do you think in your experience that rubber changes need to be made mandatory? Maybe I don't have my facts straight, but there seems to be a lot of discussion about how the 5 yr. rubber thing is vitally important to safety. It sounds to me like it might be. I have much more limited experience with Rotax, but I have changed hoses here and there do to inspection findings or pilot reports. I haven't seen chronic repeat issues on the engines that we have maintained through several thousand hours of operation. None of our aircraft have ever had a flight plan change due to hoses, but it seemed like this forum had a number of them in years past. Like I said, maybe I got my facts a little wrong. Roger, Just for the record, I don't think that pilots or owners are dumb, and I am not at all against training videos for maintenance tasks. My issue with the aforementioned video is the context for which it is presented. I stand firmly on that, and the very bad situations that I think could be created by pilots using it as a "self rescue". Disassembling a carburetor is not a preventive maintenance task. Even if it were, a maintenance record is required, and I would have serious doubts about the aircraft safety unless I found the root cause of the debris, which the video does not speak to. I gave the example above where a previously done condition inspection could be called into question by unauthorized and undocumented maintenance performed. To be fair, if the person using the video happens to be a mechanic or repairmen, they would be fine, so long as they document their work. I would still make the case for reporting to promote the continued airworthiness system of Safety Directives and/or Airworthiness Directives if the aircraft had an incident. I am also not an advocate for needless regulation. But I am an advocate for trying to properly follow existing regulations whenever possible.
  15. 12 year mandatory overhaul

    The topic of overhaul requirement time limits are really a symptom of the bigger "required vs mandatory" discussion that has gone on and on. I mention Safety Directives in this thread because it directly pertains to the mandatory side of things. I mentioned the Piper AD that was referenced by Corey earlier because it is an example of how an otherwise non-mandatory maintenance event is correctly made mandatory in an effort to enhance aviation safety. As for the video, Roger you are DEAD WRONG here, but I will make this concession to placate you: Pilots, if you do perform this illegal maintenance on your aircraft to self rescue, please properly document your action in the maintenance records for your aircraft, and do so before you depart from the field or road. This is already required by regulation. I have to warn that you will be incriminating yourself by doing so, but it will save the poor inspector that performed your last condition inspection. See, his entry may very well be the last one in your records prior to the "self rescue" event. This way when the FAA and NTSB come to investigate, if there is anything left of the records, they will be able to discover why the carburetor bowl fell off, and not pin it on the poor inspector.
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