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  1. #1
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    Default how much latitude for feds ?

    Hi yall---

    I have been trying to figure out how to qualify to take the A+P written test under 14 CFR part65 section 65.77 --------
    I have about 4 years of practical experience. about 3 at FBO's and about 1 year of my own IA supervised work.
    The FAA's web page says that you can use pay checks, or you can have a daily signed logbook--
    I have some of both-- but not continuously.

    One place was a flying club with about 15 cessna's and pipers.
    another was a FBO specializing in PT-6 powered beechcraft (KingAir 90,200, 350's) with a few jets thrown in.

    The AI at the flying club passed away from old age and the club later closed.
    The One servicing KingAirs---- the owner killed himself (I think-) and it later closed. (about a year after I left)

    So I am trying to re-create my documentation to show what and how long to the guys at the FSDO.
    I sat and talked to a guy there for about an hour and showed him my documents. I have signed logbooks
    from both places but they aernt continuous. also have some pay check stubs from both- but not all.

    The FAA web page says its just based on time alone. But then when going through all this with the FSDO guy--
    he says I have to have proof of time in each and every one of the 28 ( I think its 28) subject knowledge areas.
    I cant see anywhere in the regs it says THAT. all I see is 18/36 months.

    Does this guy at the FSDO have the latitude to just set the bar anywhere he wants without reguard to what
    the regs actually say ? That seems kind of contradictory----- the whole point of the test should be to find out
    how much you know. Seems silly that you have to be able to prove that you dont need to take the test in order to
    qualify to take the test........ This seems to me why there are fewer and fewer mechanics being made........

    The FSDO guy was nice enough that I talked to----- but he seemed like he wasnt going to extend himself one
    milimeter to help me...... I feel sure he probably had visited both places I worked and probably knew the owners.
    (I say that because he was probably one of the ones who inspected them - however infrequently that might have been)
    And- to top it off--- both of my supervisors at the FBO's became raging alcoholics and no one knows where they are now. The IA who supervised the plane I restored--- he was the DOM for a huge FBO and he was going to hire me
    but before I got done with the restoration----- one of his FBO's Barons broke a fuel pump shaft-- crashed - killing
    his best friend (pilot) and a big wig VIP passenger. The broken shaft was a known defective part which they missed
    on the last annual about a week before the crash. The DOM/IA disappeared permanently about a week later. Word
    was he went underground for fear of the impending civil suit because of the dead big wig. So I dont have him around
    for documentation either. Shame -because he was a hell of a nice guy.


    On yalls knowledge of how this SHOULD work---- is this guy following the regs in what he is telling me ?
    I remember there is a phrase like "to the satisfaction of the administrator" in the part 65 reg---- Is the Guy
    im talking to considered "the administrator" ? or is the administrator the head of the FAA ?

    Am i being snowed by a guy who is protecting his job too much... ? or--- is this just the norm allowed for
    by the part 65 regs ???? This is very frustrating.....

    Any guidance would be wonderful !

    Thanks, Tim B.

    FYI--Here is the cut and pasted text from FAA.gov's own page describing what qualifies as 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.

    OK-- there it says it "THE REQUIRED TIME" To me-- this would mean simply however many months of full time work you have accomplished at an FBO or repair station.
    Last edited by fairchild; 11-22-2018 at 02:39 AM. Reason: typo

  2. #2
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    Default

    Quote Originally Posted by fairchild View Post
    Is the Guy im talking to considered "the administrator" ? or is the administrator the head of the FAA ?
    Thanks, Tim B.
    As to this, yes, the guy you are talking to is the same as the Administrator
    As to the rest..... I wish I had a some better guidance other than this.
    As the the "Applicant", you have to SHOW compliance to the requirement.
    The inspector "finds" compliance.
    Or as Jack Webb use to say "just the facts."
    Last edited by mnttech; 11-22-2018 at 12:26 AM.
    "My life experience tells me that people talk about other people for one of four reasons: because you’re dying, because you’re dead, because you’re one of the best in your field, or because you’re one of the worst. My question for you is, why don’t I hear people talking about you?” Jason Dahl to Capt Mark Hoog

  3. #3
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    Default

    OK--- here I found something relevant ----- this is a chunk of FAA order 8900 ----
    http://fsims.faa.gov/wdocs/8900.1/v0...05_002rev1.htm

    In section G-1----- it states that the applicant seeking authorization to take the tests--- needs to be able to show documentation for having practical
    experience in at least 50% of the knowledge topics.

    The FSDO guy I talked o told me he would not do anything for me until I could show experience in each and every knowledge topic.

    Clearly this is not conforming to the FAA's own rules governing their designated inspectors who sign off your permission to take a test.(or not)


    So it appears that I must show experience in at lest 1/2 of the topics and also show the required time of 18/36 months.


    It appears to me that Order 8900 was an attempt to unify the standards so that the individual inspectors couldn't just make up the rules depending on the
    politics of if you were one of their good ole boys or an outsider who aint in the club.

    Tim

  4. #4
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    Quote Originally Posted by fairchild View Post
    It appears to me that Order 8900 was an attempt to unify the standards so that the individual inspectors couldn't just make up the rules depending on the politics of if you were one of their good ole boys or an outsider who aint in the club.
    Tim
    Very nice digging, can you do what it says?
    Applicants will document a proportionate amount of experience directly applicable to the certificate and ratings sought. The applicant must have verifiable experience in 50 percent of the subject areas listed for the rating sought (refer to part 147 appendices B, C, and D) in order to be eligible.
    Can you do that?

    BTW, actually there is an "order" to things.
    14 CFR xx.xxxx are the legal rules, posted in the federal register and all that mess
    Orders/Policy Memos are what tell the FAA (and their delegates) how to "find" compliance to the rules
    Advisory circular (AC) are means but not the sole means to "show" compliance to the rules

  5. #5
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    My brother and I, through our company Northrop Rice, are developing a structured OJT program that will help track your experience, study theory, link to the practical test standards (now the ACS) and meet guidance from the 8900. We are learning more from the industry and individuals like you all, who can help provide us with insight on making this an effective way to obtain an A&P through experience. I would like to add to this forum as we develop the program.