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Hi Guys, let me answer your questions in order...

Gary, even though it was very late Sunday night when I posted my looooong diatribe, I tried to get everything as correct as I could. There's a lot of misunderstandings among pilots about annuals/100hr inspections/mods/placarding inop equipment/etc and I didn't want to add any more confusion.

Nonetheless, what I tried to convey about the nav light thing was that IF an aircraft's Type Certificate stated that nav lights were required items, then simply placarding them as being inoperative and then launching on a day VFR flight would still be illegal. You see, some items (such as a Hobbs meter) are optional for flight and their malfunction CAN be placarded until it can be repaired or removed entirely. But any items that the TC states as being REQUIRED cannot simply be deferred at the pilot's whim. True, my mention of the IA submitting a 337 to temporarily or permanently remove the nighttime certification of the aircraft was a bit extreme (although I've seen it done), it is still the only legal way to keep flying without fixing the nav lights in this example. Of course, the preferred recourse is to either fix the lights prior to further flight, or ferry the aircraft to a place where they can be fixed. Please note that my example pertains ONLY to an aircraft whose TC states that opearable nav lights are mandatory, with no exception for daytime ops. (Note that I'm not saying that they must be turned on for day flights, only that they must be operable.) My intent was to make a point about optional vs required items on the Type Certificate - If the TC says that an item is required, it cannot be placarded as inop and the aircraft continued to be flown.

You mentioned an MEL and I know that you know what one is, but for those others who are reading this and aren't really sure, an MEL (Minimum Equipment List) is usually developed for more complex aircraft such as large singles and most twins. It specifically spells out what minimum items are required for flight and, to a certain extent, may modify the equipment requirements of an aircraft's Type Certificate. As an example, the TC may require two fully functioning VOR receivers during both VFR and IFR conditions but an approved MEL for that aircraft may allow one to be inop (properly placarded, of course) during a VFR flight. An MEL is a ready list of what is (and, therefore, also what is not) required for legal flight without the pilot having to research the TC to see if he can still fly when the map light burns out.

As for my "spot on" remark, those were the words that my PMI used when he e-mailed his critique of my rough draft back to me on Sunday afternoon. I can see now where it could be construed as being flippant. I assure you that that is not so and I appologize for giving the wrong impression.

And now for Grants Pass Bill (as if that were REALLY your real name... :-)

Bill, I can't provide an answer to your example because I do not perform A&P/IA work on a daily basis. (I am actually full time electronics maintenance in the military.) I got my IA to keep my hobby affordable and I limit my "outside" A&P/IA services to just a few close friends. Therefore, while I am fully capable of performing the complex inspection that you described, I am not able to provide you with an accurate estimate of how much time and money it would take because I do not do it on a daily basis.

However, if I were to tackle such a project, the first annual would take much longer than normal because there would be a lot of modifications that I would want to inspect very closely; partly because I'm a perfectionist, and partly because I don't immediately trust other people's work. Once I'm satified with the quality of the work previously performed (or fixed it until I am) the following annuals would be quicker.

Of course, there's also the possibility that I'm just a 12 year old kid sitting at his parent's computer in his pajamas. :-)

J. Wilson, the interpretation that you go with is, hopefully, the one that will keep you out of trouble with the feds. And I fully agree with, and don't take offense to, anyone who wants to get a second or third opinion. The FARs are way too complicated to ever find an easy and simple answer!

Harvey

Ha Ha! Grants Pass Bill gets his name because his name is Bill, and he lives in Grants Pass, Oregon. No offense taken, nor are there any hard feelings regarding any perceived flippancy on your part.

I've just never heard the bit about a 337 being required. I maintain a King Air and just last year, we revised our maintenance program, working hand-in-hand with our PMI. We operate part 91 and choose not to encumber ourselves with an MEL, but rather to deal with inoperative equipment (if we can't fix it on the spot) IAW FAR 91.213 with the inspection of such inoperative instruments/equipments IAW FAR 91.405.

In fact, 91.213(d)(4) states "An aircraft with inoperative instruments or equipment as provided in paragraph (d) of this section is considered to be in a properly altered condition acceptable to the Administrator." So, although an aircraft may have originally been certified with a particular instrument or equipment, so long as it's not required for day VFR and the conditions spelled out in 91.213 have been met, there's no need for the 337. If it is beyond the scope of 91.213, a special flight permit may be required, or perhaps no flight would be authorized, or even safe.

Thank you for your military service. You're undoubtedly giving the country some of the best years of your life. You'll never regret it!

Now, back to airplanes.

Republic of Texas Gary,

The 337 thing is something that was brought up during our last IA seminar and believe me, it raised quite a few eyebrows in the crowd. After the FAA explained it, it DID seem to make sense (but of course, it made "sense" in an FAA sort of way which increased the frequency of our facial twitches.) But I could also relate to the issue because I used to own a 1947 Luscombe that had been officially converted from Day/Nite VFR to Day-only VFR when it received an engine change (many years before I bought it) and the new engine didn't have a place on the accessory cover for a generator. The IA submitted a 337 (he couldn't go with just a simple logbook entry) to officially remove the nighttime authorization. It was still a FUN airplane!

Thanks for the thanks. I've been in the USAF/TXANG since Dec 1971. I'm thinking of making it a career! :-)

YOU go back to airplanes. I'M going to bed!

Houston Harvey

Well Harvey and Gary, you did help prove a very valid point. And that is no matter how well one thinks one knows the regulations. There is always somebody else who has a very different interpretation. Who is right? Only that certain individual of some Government agency that is overlooking your case at any particular time. And that individual had better not go and ask another Governmental representative. For they too would also get a different answer.

Thanks Fella's! You get a person to do some thinking! And THAT is ALWAYS good!

Well, mostly? Now, since I now know that I am not who I think I am. Then I think I had better go in search of myself...........

Hey Bill...you're in the FAR's...FAR FAR away!!!