question about FAA regs ---

[fairchild]

Hi all---
I have about 4 years of AMT experience. Due to some time having passed-- and people dieing -- my documentation is not 100% complete.
My experience requirements would be under the part 46 section covering experience gained at a repair station or FBO.

If you go to the FAA's web page where they describe the requirements---- they cite 18 or 36 months. They also mention log books and pay stubs. They DONT mention anything
on a more granular level than that. About a year ago I visited my local FSDO and talked with one of the maintenance regulator guys...… and I showed him all my paperwork which
consisted of some check stubs and log books from 2 places. However my log books and check stubs don't continuously cover the whole time. I talked to him there about an hour---
and it seemed that everything I had for him he kind of blew off. He then went on to tell me that he wanted/need to see specific documentation of experience in EACH and every one of the individual topics in the curriculum.

I can find NO stipulation for this anywhere.

This doesn't make sense in a way----- if I worked at a repair station-- (which the regs specifically mention--) just about every repair station I've seen are only licensed to do certain
types of operations under their license. (unlike an FBO which gets around to doing most types of repairs eventually) SO---- If I worked at a repair station for 36 months----
I would be qualified to take the A+P written test------ and I would have not gotten experience in every topic. So -- it sounds to me like this guy just pulled this requirement out of his
backside---- maybe as a CYA maneuver. So if that's true--- he is basically just refusing to help me- and making of a fake nonexistent reg to justify it.

this is very frustrating to me. It seems like he wants me to be able to prove that I don't need to take the test in order to qualify to take the test. This seems like it defeats the purpose
of taking a test...….. or like a bank who you ask for a loan from that wont give you the loan unless you have more cash than the loan in your bank account.

is this gut just afraid of putting his name on ANYTHING ???? and doing a huge CYA ?????? and--- how can I work around it. ?????

Tim

[zkelley2]

FSDOs are like fiefdoms, they like to make up rules that don't exist. You can go to another one or go over his head.
I think if you dig into the 8900 you'll find the guidance you're looking for though.

[Rollie]

I'm having the same issue with my FSDO. I've been working part time in the shop at my airport since 2011 plus I built my Patrol. The A&P IA I work with got his certificate based on experience back in the 70's and he recently told me its time for me to go to one of the A&P finishing schools and get certified, according to him I know more and am more capable than newly graduated A&Ps from schools. I don't feel that is the case but I've never worked with a new, just out of school A&P. Anyway, I talked to a guy at the local FSDO on the phone a couple times and it just seemed like there was no way he was going to accept my experience. He did say that having my repairman's cert from building my Patrol would help but he seemed very reluctant to consider all the hours I had logged building plus my part time experience. Then he said that I would need to come in for an interview where I would present my documentation showing how much time I had put in and then he would ask me some questions, a lot of questions. He said it would basically be an oral, that they don't want to send someone to a school who isn't ready, that its a difficult school, etc. Sounded like a CFI getting ready to sign off a student for a checkride. Seemed weird to me since all he is responsible for is verifying my experience, not for the quality of my training or preparedness.
Plus he would not give me any guidance in how he wanted my experience documented, just kept referring me to the FAA website where it lists the experience requirements but doesn't mention documentation at all. But it was clear that if it wasn't documented how he wanted it he wouldn't accept it. I finally concluded that he wasn't going to sign me off anyway and gave up for now.
Maybe after I move next time I'll talk to FSDO wherever I end up and try again. In the mean time I'll keep gaining experience. I really only want the cert as a back up in case at some point I can't keep flying and I figured now would be a convenient time to get it while I'm medically grounded and can't go to work.

[Bcone1381]

What would the conversation be like if you showed them their regulation, and then showed them the documentation/evidence as to how you fulfilled it? If they view your documentation as fulfilling the requirements, then why are you not entitled to take the test, and get the license? If the inspector wants to see documentation of certain tasks but its not in the FAA requirements, then he owes you an explanation why he's not following the regulations.

With that being said, I can have kind of a confrontational bent about my character and it does not get me very far sometimes.

[spinningwrench]

FSDO’s have changed dramatically with the latest round of retirements. 10 years ago significant experience building an experimental or restoring certified
airplanes got you a shot at the test. Now they are much more interested in breadth than depth which generally implies you went to an A&P school which I did part time in addition to restoring airplanes. It is hard to get the amount of experience you want on your own. It is highly unlikely I would rebuild a gas turbine in my garage shop. Every FSDO is different but they all seem to be less flexible these days possibly because they are not staffed with people having hands on experience.

[Ed.Meyer]

I agree with Brooks. There is nothing wrong with asking to see the documentation that the their "requirements" are based on. It is not uncommon that they misinterpret should to mean shall or to say that a requirement is given in an Adivisory Circular which by definition is advisory only. As long as you are cordial they should have no problem sharing their documents.

[Bdflies]

I guess I’m going to take Brooks' confrontational track, but in a different direction. We’re participating in the Bearhawk forum. Some of us have built other EAB aircraft. Unless one desires to earn money working on, or wants to document work, on a certificated aircraft, beyond FAA alowable maintenance (https://www.faasafety.gov/files/gsla...%20branded.pdf), I’m at a loss as to why one would desire the A&P ratIng. The process of building the Bearhawk almost guarantees you the repairman certificate. The repairman certificate authorizes any and all maintenance, excluding "major changes". You might have to answer some questions about the build, but that’s not much of a hurdle if you built the plane.

If one wants the A&P rating on his ticket, as a notch on the belt, I completely understand. If one wants to do work on and make log entries for that work, I get it. As far as the Bearhawk aspect, why would one want the rating?

Bill

[zkelley2]

The guidance that the inspector at the FSDO is REQUIRED to follow is in FAA order 8900. Look that up, find the area applicable to what you want, follow it perfectly and bring it in with you. If he doesn't follow that order, ask to see someone above him, even if that someone is in Oklahoma City.
If you follow their guidance in the 8900, I really doubt you'll have an issue though.

[svyolo]

There are some really nice people working at the FAA and other government agencies. And then there are "others". Being confrontational with the "others" will never work. Simply go around them until you find one that will work with you. Going directly over their head might work short term, but they will take it out on you later.

I would make a few inquiries about other FSDO's, and try to find one that will work with you. A lot of FAA stuff was written many decades ago, and is interpreted and enforced in ways that the original authors never intended.

[Bcone1381]

There is a phenomenon know as compliance creep. Sometime after the rules are set, a well meaning, maybe new, nice, energetic, and influential inspector starts to add his own personal opinions and interpretations into the original rules taking them to places the original authors and regulators never intended. When an office has several inspectors going this it becomes a goat rope to get anything done, or to pass a check ride. At my work, it has to be identified and fought at the highest levels of management. If its not, then things get really tough on student-applicants.

[svyolo]

At my work, I think there are a couple of Sr. VP's in charge of compliance creep. Increasing it, that is.

[BravoGolf]

I got zero credit from the FSDO for building an EAB aircraft. Although I have a build log which is sufficient for the airworthiness certificate and for my repairman's certificate, I did not have an IA sign off all the various experience requirements. So I went the school route. The building experience certainly helped prepare for the O&P.

[alaskabearhawk]

You are kind of vague in your references and what you are aiming for. Are you looking for a mechanic's license or a repairman's license? Your characterization of your documentation seems pretty vague. Where are you looking for the requirements? I didn't see anything that mentioned pay stubs or 36 months. I looked online and 14 CFR Part 65 is pretty clear for what is needed.

[fairchild]

Here is the 2-nd paragraph ( at FAA.org) talking about how to document your practical experience...…..

"You can work an FAA Repair Station or FBO under the supervision of a certified mechanic for 18 months for each certificate, or 30 months for both. You must document your experience with pay receipts, a log book signed by your supervising mechanic, a notarized statement from your employer, or other proof you worked the required time."

As to my purpose----- it doesn't have anything directly to do with building the bearhawk---- I WAS working full time to get A+P experience. I had to drive an hour each way
where I was working then. After I got situated there- we grew from 4 mechanics to about 20 rapidly. The Boss went to NBAA and advertised and got us swamped.
After a little while we were working from 7 am to 9 and 10 pm. And then on top of that I had another hour's drive each way. With all that chaos --- some of that time I
didn't keep current on my signed logbook entries. We were covered up in work for most of 2 years like that. As this went along-- I think the boss discovered that I could
do 90 percent of what the licensed guys were doing and it was only costing him half the wages. So I never got a day off---- he would not let me go to the PT-6 school even
though it didn't cost him a penny ( its a free school put on by P+W ) It went along hot and heavy like that until the boss started making bad business decisions.
He started promising "favorite" customers work done ahead of the normally sequences customers---- which caused massive overtime costs --- but then he never charged
the preferred customers more to offset the overtime. Great for those customers but bad for the shops finances. We kept explaining this flaw to him but he wasn't interested
in listening. The whole thing kind of de-composed from that point. I stayed for several more months--- but it was clear that the trajectory would not improve. I decided to
leave-- but I now understand that it was a major mistake not to get them to give me a letter stating what I did and for how long explicitly. About a year later someone told
me that the boss had killed himself on a dirtbike on the woods by boresighting a pine tree at about 60. Never could even fin an obit on him---- makes me think it was
intentional. Kind of a shame because he was one of the best and talented mechanics I had ever met. Just not good a business decisions somehow--- a very smart and sharp
guy otherwise. So that is how I came to have discontinuous log books.

The "tone" of the FSDO guy I talked to--- while he was nice---- reminds me of the ATF's propensity to just create legally nonexistent "rules" which are written nowhere--
but serve to constrain us in whatever way the politics of the current administration wishes -- but using methods which never withstand court--- and they go to great lengths
to make sure it never goes to court and set the president that they are over reaching their regs.

I sensed that I would have NO traction disputing him directly. I will look up FAA order 8900 to see what that is. We have an A+P school here in town--- but it is a
private one--- and one of the most expensive ones---- so It would not be in their best interest to help me. We used to have a state Tech school here but they closed
years ago. (the same place I went to TIG school) Its a good place -- and inexpensive--- just No A+P school anymore.

what a frustrating mess it is...…
My other choice is just go back working and re-do the 36 months. Its just that that doesn't fit into my schedule easily now.

Part of the FAA;s own text contradicts the FSDO guys talking points. It says you can do 18 / 36 months at an FAA repair station. Most of those are specialty places
and not wide spectrum places like FBO's generally are. so at a repair station you really COULDNT get experience in ALL of the subject areas---- yet the FAA says
you can use repair station experience.

I will check order 8900 and see what it says ……….

Thanks to all for your thoughts----- I guess all this "resistance" (to use a popular current phrase) is why there is a mechanic shortage. And as yall said--- the more
inexperienced the GOV guys get the more afraid they become to do anything...… for better or worse...…. just look at our horrific ATC system...…. They could have
gone to the free flight system 25 years ago but they just cant bring themselves to do anything which results in them having less power...….

T

PS---- Order 8900
Just found what appears to be the appropriate section of 8900 -----
Here--- http://fsims.faa.gov/wdocs/8900.1/v05%20airman%20cert/chapter%2005/05_005_002rev1.htm

in section G-1 ----- states explicitly that the applicant must have experience in at least 50% of the separate knowledge areas.

So THAT-------- shows the FSDO guy was just sknowing me and trying to discourage me-- as he specifically told me that he wouldn't
budge until I could show him proof of experience in EVERY topic. Silly me---- I thought his job was to HELP me---- Not to BS me and try
to add drag to everything in hopes I will just give up and leave him alone. Sounds like the instruction page out of the beauracrat manual.
"we are not happy until your you are not happy" seems to apply------

[zkelley2]

Here is the 2-nd paragraph ( at FAA.org) talking about how to document your practical experience...…..

"You can work an FAA Repair Station or FBO under the supervision of a certified mechanic for 18 months for each certificate, or 30 months for both. You must document your experience with pay receipts, a log book signed by your supervising mechanic, a notarized statement from your employer, or other proof you worked the required time."

As to my purpose----- it doesn't have anything directly to do with building the bearhawk---- I WAS working full time to get A+P experience. I had to drive an hour each way
where I was working then. After I got situated there- we grew from 4 mechanics to about 20 rapidly. The Boss went to NBAA and advertised and got us swamped.
After a little while we were working from 7 am to 9 and 10 pm. And then on top of that I had another hour's drive each way. With all that chaos --- some of that time I
didn't keep current on my signed logbook entries. We were covered up in work for most of 2 years like that. As this went along-- I think the boss discovered that I could
do 90 percent of what the licensed guys were doing and it was only costing him half the wages. So I never got a day off---- he would not let me go to the PT-6 school even
though it didn't cost him a penny ( its a free school put on by P+W ) It went along hot and heavy like that until the boss started making bad business decisions.
He started promising "favorite" customers work done ahead of the normally sequences customers---- which caused massive overtime costs --- but then he never charged
the preferred customers more to offset the overtime. Great for those customers but bad for the shops finances. We kept explaining this flaw to him but he wasn't interested
in listening. The whole thing kind of de-composed from that point. I stayed for several more months--- but it was clear that the trajectory would not improve. I decided to
leave-- but I now understand that it was a major mistake not to get them to give me a letter stating what I did and for how long explicitly. About a year later someone told
me that the boss had killed himself on a dirtbike on the woods by boresighting a pine tree at about 60. Never could even fin an obit on him---- makes me think it was
intentional. Kind of a shame because he was one of the best and talented mechanics I had ever met. Just not good a business decisions somehow--- a very smart and sharp
guy otherwise. So that is how I came to have discontinuous log books.

The "tone" of the FSDO guy I talked to--- while he was nice---- reminds me of the ATF's propensity to just create legally nonexistent "rules" which are written nowhere--
but serve to constrain us in whatever way the politics of the current administration wishes -- but using methods which never withstand court--- and they go to great lengths
to make sure it never goes to court and set the president that they are over reaching their regs.

I sensed that I would have NO traction disputing him directly. I will look up FAA order 8900 to see what that is. We have an A+P school here in town--- but it is a
private one--- and one of the most expensive ones---- so It would not be in their best interest to help me. We used to have a state Tech school here but they closed
years ago. (the same place I went to TIG school) Its a good place -- and inexpensive--- just No A+P school anymore.

what a frustrating mess it is...…
My other choice is just go back working and re-do the 36 months. Its just that that doesn't fit into my schedule easily now.

Part of the FAA;s own text contradicts the FSDO guys talking points. It says you can do 18 / 36 months at an FAA repair station. Most of those are specialty places
and not wide spectrum places like FBO's generally are. so at a repair station you really COULDNT get experience in ALL of the subject areas---- yet the FAA says
you can use repair station experience.

I will check order 8900 and see what it says ……….

Thanks to all for your thoughts----- I guess all this "resistance" (to use a popular current phrase) is why there is a mechanic shortage. And as yall said--- the more
inexperienced the GOV guys get the more afraid they become to do anything...… for better or worse...…. just look at our horrific ATC system...…. They could have
gone to the free flight system 25 years ago but they just cant bring themselves to do anything which results in them having less power...….

T

PS---- Order 8900
Just found what appears to be the appropriate section of 8900 -----
Here--- http://fsims.faa.gov/wdocs/8900.1/v05%20airman%20cert/chapter%2005/05_005_002rev1.htm

in section G-1 ----- states explicitly that the applicant must have experience in at least 50% of the separate knowledge areas.

So THAT-------- shows the FSDO guy was just sknowing me and trying to discourage me-- as he specifically told me that he wouldn't
budge until I could show him proof of experience in EVERY topic. Silly me---- I thought his job was to HELP me---- Not to BS me and try
to add drag to everything in hopes I will just give up and leave him alone. Sounds like the instruction page out of the beauracrat manual.
"we are not happy until your you are not happy" seems to apply------

The best way to deal with people at the FSDO is to look up the Regs - you have, then look up the order they are required to follow, and put your stuff together in accordance with it to a T. It helps if you have someone that has done this before.
I just did a repairman's certificate(not the E-AB one), I had everything in order, contacted the FSDO by phone and spoke with the guy and told him that I wanted to apply for the certificate and had completed all the steps. He then gave me his e-mail and had me e-mail all the associated forms and paperwork, which I already had done. I included the relevant 8900 section so he didn't even have to go looking. We set an appointment and I walked out 15 minutes later with the temp. One of the keys with them is not to create work for them. Do their whole job for them short of signing the certificate.

Have you also read all of AC65-2D?