Welcome to GlobalAir.com | 888-236-4309 |    | Please Register or Login
Aviation Articles
Home Aircraft For Sale  | Aviation Directory  |  Airport Resource  |   Blog  | My Flight Department  | MaxTrax
Aviation Articles

When is the 100-Hour Inspection Due for Aircraft Used for Rental and Flight Instruction?

by Greg Reigel 27. August 2015 17:32
Share on Facebook

If you work for or operate an FBO or flight school that offers aircraft rental as well as flight instruction, whether Part 61 or 141, you know the timing for completing aircraft inspections can sometimes be confusing. Now, I'm not talking about the annual inspection that must be conducted on all aircraft every twelve calendar months or sooner pursuant to 14 C.F.R. 91.409(a). That requirement isn't particularly confusing. Rather, it is the 100-hour inspection under 14 C.F.R. 91.409(b) and its timing and limitations that are sometimes misunderstood.

Section 91.409(b) states that "no person may operate an aircraft carrying any person (other than a crewmember) for hire, and no person may give flight instruction for hire in an aircraft which that person provides, unless within the preceding 100 hours of time in service the aircraft has received an annual or 100-hour inspection." Thus, unless the aircraft is subject to a progressive inspection program, or is a large aircraft (to which 14 C.F.R. Part 125 is not applicable), turbojet multiengine aircraft, turbopropeller-powered multiengine aircraft, or turbine-powered rotorcraft which has selected an inspection program under Section 91.409(f), then that aircraft must receive an annual or 100-hour inspection if it is going to be used for flight instruction.

Keep in mind that the 100-hour limitation may be exceeded by up to 10 hours as long as that time accrues while the aircraft is enroute to reach a place where the inspection can be done. However, if that happens, the additional time used to fly to the facility performing the inspection must be included in computing the next 100 hours of time for the aircraft to be in service.

Now, in order to determine whether the 100-hour inspection is required for an aircraft that is used for both flight instruction and rental, and when that inspection is due, we need to look at how the aircraft is operated during a particular flight. And this is where some of the confusion occurs. If the flight is operated for the purposes of providing flight instruction, then the aircraft must have had an annual or 100-hour inspection within the preceding 100 hours of time in service. But if the aircraft is simply rented to a customer without a pilot or flight instructor, then the aircraft need not have had an annual or 100-hour inspection within the preceding 100 hours of time in service.

How does this apply in real-life? Here are some scenarios where the FBO or flight school uses an aircraft for both flight instruction and rental and how Section 91.409(b) may or may not apply to the example flights.

Example 1: A customer reserves an aircraft for rental only and anticipates flying approximately 10 hours. When the customer reserves the aircraft, it has a total of 95 hours of time in service since the aircraft's last annual inspection. If the customer's flight does not exceed 10 hours and a 100-hour inspection is performed upon the aircraft's return, does this violate Section 91.409(b)? No, because the aircraft is not being operated for hire or to provide flight instruction. In fact, when the customer returns the aircraft does not need an annual or 100-hour inspection unless it is going to be used for flight instruction, or 12 calendar months have elapsed since the aircraft's last annual inspection.

Example 2: The FBO or flight school dispatches an aircraft on a local training flight with a flight instructor and student pilot that is anticipated to, and does last one hour. At the time of dispatch, the aircraft has accumulated 99.9 hours of time in service since the aircraft's last inspection. A 100-hour inspection of the aircraft is performed when the aircraft returns from the flight.

Is this a violation of Section 91.409(b)? Yes, because the flight instructor and student pilot clearly intend to fly beyond the 100-hour limitation during their training flight. The 10-hour grace period does not apply because the aircraft was not being flown enroute to a location where the inspection will be performed. Rather, the aircraft was operated on a local training flight which does not benefit from the 10-hour grace period. As a result, Section 91.409(b) is violated after the first tenth of an hour during the training flight. If the FBO or flight school wants to continue to use the aircraft for flight instruction after this flight, an annual or 100-hour inspection must be performed and the next inspection after that must be performed before the next 91 hours of time in service.

Example 3: An aircraft is dispatched on a cross country training flight with a flight instructor and student pilot. The flight is anticipated to take 1.5 hours of flight time to the destination and also 1.5 hours of flight time on the return trip. When the flight departs, the aircraft has accumulated 97 hours of time in service since its last inspection. During the cross country flight, unexpected winds and ATC vectoring result in the trip taking a total of 3.1 hours flight time. Upon return, a 100-hour inspection of the aircraft is conducted.

This situation does not violate Section 91.409(b). Why? The flight instructor and student pilot did not intend to overfly the 100-hour limitation. Additionally, the 100-hour limitation was exceeded while the aircraft was enroute to a location where the required inspection will be performed (e.g. the original departure airport). When the aircraft returns, an annual or 100-hour inspection will be required before the aircraft may be used for flight instruction, and the next inspection after that must be performed before the next 99.9 hours of time in service in order to continue to use the aircraft for flight instruction.

Example 4: An FBO or flight school owns an aircraft that has accumulated 100-hours since its last inspection. Although the aircraft is used for flight instruction, an inspection cannot be performed within the next week. As a result, the aircraft's schedule is marked "for rental use only." During the next week the aircraft is rented to customers, without a flight instructor, who accumulate a total of 15 hours of flight time. Additionally, no flight instruction is performed with the aircraft during the week.

Similar to Example 1, this situation does not violate Section 91.409(b). The 100-hour inspection requirement does not apply to aircraft operated for rental purposes and the FBO or flight school is free to rent the aircraft to customers as long as it is not providing a flight instructor or pilot and the customer is not operating the aircraft for hire. However, before the aircraft is again used for flight instruction an annual or 100-hour inspection must be performed and the next inspection after that must be performed before the next 85 hours of time in service in order to continue to use the aircraft for flight instruction.

As you can see, in order to apply Section 91.409(b)'s 100-hour inspection limitation it is important to not only look at the purpose of a flight, but also the intention of the operator in conducting the flight. Further, as is the case with all areas of regulatory compliance, it is critical that you have documentation or other evidence to be able to prove the purpose and intention for the flight. Aircraft schedules and rental agreements should include the purpose of the flight (e.g. rental or flight instruction) as well as the intentions for the flight (e.g. local, cross country etc.). With an understanding of Section 91.409(b)'s limitations and documentation in hand, you will be able to prove that you properly performed your 100-hour inspections in compliance with the regulations.

Tags:

Greg Reigel | Maintenance

Understand Your"Why"

by David Wyndham 27. August 2015 15:15
Share on Facebook

Simon Sinek published "Start with Why" back in 2009.  Sinek is fascinated by the leaders and companies that make the greatest impact, especially those with the capacity to inspire. In his book, Sinek discusses the patterns about how they think, act and communicate. Examples include the Wright Brothers and Apple. These companies focus first on the why of their existence - the reason they exist. Not just what they do or how they do it. Read the book or watch his TED talk for more. So how does this relate to our aviation department?

Do you know why your company exists? Why does it do what it does? If your company can express this, then you can explore or define they ways the business aircraft can help achieve this. While this may sound like navel gazing, it is not. It involves a deep understanding the differences between successful and "nice try."  It is from this perspective that you can identify those things that the business aircraft can do to facilitate and advance the business at the most core level.  Tie the use of the aircraft into to loftiest, highest-meaning levels of the company's existence.

Where does the aircraft add value to your company or owner? Yes, it makes better use of time. To what end? What is the importance of that time, and more over, the value of that time? Does the business aircraft enable your company to make the most productive uses of its passengers' time? For one company, it may be that the leader is so incredibly valuable to the company's future growth, enabling that person to have one-on-one contact with customers, clients, and division leaders produces significant value in terms of motivation, desire, focus, and profit. For another company it may be that enabling scattered teams to work more frequently together in one place enhances their cohesion and unity, and enabling goals to be accomplished sooner and with fewer resources. 

Attaching the corporate goals and aspirations with the use of the aircraft enables you to define (and defend) the use of the aircraft as a valued business tool. Identify the most important mission for the aircraft. That is the mission which enables the aviation department to select the right aircraft by defining the parameters the aircraft must meet in order to help the corporation succeed. 

“Mission drives requirements”

In defining the mission, we get to the importance of quantifying the mission. While a decision maker may select an aircraft from emotion, we need to make sure that they have the information needed to quantify their decision.  We need to quantify the mission, the aircraft requirements, and the costs. Then we can allow emotions in the process.

I had one client who needed frequent trips between New Jersey and Oregon & Washington. One part of the mission was passenger loads rarely exceeded four persons. That opened up a number of aircraft that had the passenger load been 15, would have defined a different aircraft all together. Since these individuals were senior executives, and the trip length relatively long, an en route stop for fuel left them with little time remaining in their travel day for significant productive work. They needed non-stop capability. Defending the use of a larger aircraft that will spend most of its time half-empty was easy once the mission was understood to require a non-stop capability. But why that non-stop capability was needed (and not just wanted) was important.  They ended up with a super mid-size business jet that accomplished their primary mission, and one that was cost-effective.

Understanding the missions assigned to the aviation department and being able to quantify them is vital in making the right aircraft choices. But when the company stock price plummets, understanding and articulating the aircraft as it relates to why the business does what it does is vital in keeping the aviation department. 

Tags:

David Wyndham

Paying It Forward: The Importance of Giving Back to Aviation's Next Generation

by Sarina Houston 16. August 2015 15:34
Share on Facebook

Remember back in the good ole' days, when you were eating ramen noodles and living out of a crash pad so that you didn't have to move in with your parents after college? Remember when you had nothing but your dreams ahead of you, only to be knocked down once or twice because you couldn't afford to follow through with them? Were you, by chance, one of those starving pilots who handed over your paycheck for a single flight in a 152, or a budding manager who lived out of your car during your first low-paying airport job? Or maybe you just came to your aviation career later in life, after struggling, maybe even giving up once or twice along the way, only to find some other way to make it happen years later?

Maybe your parents helped you along the way, or maybe a stranger, or maybe a supervisor who saw potential in you and gave you that well-deserved promotion. Perhaps you got a scholarship, or maybe you had a good mentor, or friends who made important connections for you along the way.

However you got to where you are, chances are good that you had some help. Whether it came to you financially, through a scholarship or a leg up from your parents, or whether you just worked hard every single day, you probably witnessed the importance of a helping hand as you worked your way to where you are.

Had I not had help along the way, my life would have taken a very different course. Perhaps I wouldn't even be in aviation today. Perhaps I'd have been pushed into a different, higher-paying job just to make ends meet. I'm certain I'd have found my way back into aviation, but it would have been a much longer road. But that didn't happen, thanks to a variety of generous people who helped me along the way. It seems like each time I ran out of money or resources or good fortune, I was offered a helping hand. Whether it was in the form of a place to stay, extra cash, a scholarship, or just words of encouragement, those acts of kindness and pure generosity meant that I could continue on my path to become a pilot.

During the early years of anyone's developing career path, this kind of help is so important. And aviation's next generation can use all the help they can get. Aviation is expensive, right? Flying, for those of us not blessed with unlimited financial resources, can seem so far out of our reach that some people just can't or won't even consider it. And even for those who have the resources, or those of us who have dug down deep and saved enough money, it seems like it's just never enough to get where you want to go.

I remember the feeling I had when, years ago, I got a scholarship letter in the mail. I was so grateful. It was more than just money, although that was important, too. It meant that somebody, somewhere, believed that I had what it takes to become a pilot, and that my hard work spent keeping up my grades and volunteering had paid off. It meant that I, and my family, would struggle less to come up with money for me to fly. And it meant, for at least the following year, I could continue on with my dreams. Months later, I met the generous man who had given me this scholarship, along with a couple of other scholarship recipients, and what he said has stuck with me. He didn't want anything in return, he said. He wasn't going to track our whereabouts or even our grades. He was just going to trust that we'd do the right thing, and that someday, after we've "made it," maybe we could pass on our good fortune to a younger generation. Pay it forward.

If you've "made it" in the aviation world, have you considered giving someone else a leg up? If you're financially sound, have you considered offering a scholarship to a young person who wants to follow their dream to work in aviation? If you succeeded, even in part, due to someone else's mentorship or coaching in the early years, have you made an effort to mentor someone else who may benefit from a friend in the industry? If your success in the aviation world today is due in part to the generosity of someone else, whether in the form of a scholarship, a mentor, a friend who offered you a place to stay or a supervisor who put in a good word for you, have you thought to pay it forward?

Pay it forward. You might just make someone's dream a reality. And the aviation industry will thank you.



Did you know that GlobalAir.com offers a scholarship? Track last year's scholarship recipients here, and stay tuned for more news on the 2015 scholarship winners!

Tags: , , ,

Flying | GlobalAir.com | Sarina Houston

FAA Updates Its Compliance Philosophy: A Move in the Right Direction?

by Greg Reigel 4. August 2015 16:22
Share on Facebook

The FAA has issued Order 8000.373 effective June 26, 2015 to explain its current compliance philosophy. That is, as the FAA explains it, its "strategic safety oversight approach to meet the challenges of today's rapidly changing aerospace system." What does that mean? Well, as the regulator of the aviation and aerospace communities, the FAA is charged with establishing regulatory standards to ensure that operations in the National Airspace System are conducted safely. And as we all know, compliance with those regulatory standards is mandatory.

However, not only does the FAA expect us to comply with the regulations, but it also believes that we have "a duty to develop and use processes and procedures that will prevent deviation from regulatory standards." Thus, we are required to conduct ourselves in a way that not only complies with the regulations, but that will also ensure that deviations are prevented. Sounds great, until something (e.g. a deviation) happens. Then what? In the past, the result was typically unpleasant. But that may be changing.

According to the FAA's new philosophy, "[W]hen deviations from regulatory standards do occur, the FAA's goal is to use the most effective means to return an individual or entity that holds an FAA certificate, approval, authorization, permit or license to full compliance and to prevent recurrence." This appears to be a shift from the FAA's past compliance philosophy. At least from my perspective, in the past the FAA's response to violations has leaned heavily toward enforcement and punitive action (e.g. certificate suspensions and revocations). And that approach never made sense to me.

If we truly want to encourage compliance and ensure that a certificate holder is safe, why would we want that certificate holder to be sitting on the ramp and out of the system for 30-180 days or longer with a suspended certificate? Wouldn't it make more sense to educate certificate holders and do what may be necessary to get them back into compliance and in a position where future compliance is more likely?

The FAA's current policy appears to be a step in this direction, at least on paper. The Order explains that

The FAA recognizes that some deviations arise from factors such as flawed procedures, simple mistakes, lack of understanding, or diminished skills. The Agency believes that deviations of this nature can most effectively be corrected through root cause analysis and training, education or other appropriate improvements to procedures or training programs for regulated entities, which are documented and verified to ensure effectiveness.

Sounds to me like the FAA is talking about letters of correction with remedial training. I think that's a good thing. The Order also notes that "[M]atters involving competence or qualification of certificate, license or permit holders will be addressed with appropriate remedial measures, which might include retraining or enforcement." Here again, the concept of retraining rather than enforcement (which was typically revocation in cases involving alleged incompetence or lack of qualification) appears to more appropriately address the situation in a more positive and productive manner. Maybe not in all cases, but hopefully more cases than in the past.

Of course, this doesn't mean that certificate and civil penalty actions will go away. If a certificate holder fails or refuses to take steps to remediate deviations or is involved in repeated deviations then enforcement may result. That makes sense. Additionally, in those situations where a certificate holder's conduct was intentional or reckless, the FAA indicates that it will pursue "strong enforcement." Also not a surprise.

Although this appears to be a positive shift in the FAA's philosophy/national policy, the rubber really hits the runway with the inspectors at the FSDO level. Will this policy shift actually trickle down? I hope so. But only time will tell.

 

Tags: , ,

Greg Reigel

Textron To Develop New Single-Engine Turboprop

by GlobalAir.com 4. August 2015 15:45
Share on Facebook

By Mary Grady
AvWeb
Textron Aviation

Textron Aviation has "been listening to the market" and sees an opportunity to introduce a new single-engine turboprop, the company confirmed in an email to AVweb on Monday. "This is an entirely new, clean-sheet design aircraft -- not a derivative or variant of any existing product," the company said. The company is not yet releasing details about the project, but said their intent is to "outperform the competition" in parameters including cabin size, acquisition cost, and performance capability. "By leveraging the newest technologies, we expect this aircraft to have a range of more than 1,500 nautical miles and speeds in excess of 280 knots, while offering best-in-class operating costs," according to the company's statement. The design will be on display next year at EAA AirVenture.

In its recent second-quarter shipments report, the General Aviation Manufacturers Association said 191 single-engine turboprops had been delivered in the first six months of 2015, compared to 217 delivered in the same period last year. Textron already produces several turboprop aircraft, including the single-engine Cessna Caravan line and the Beechcraft King Air twins.

Tags: , , ,

Aircraft For Sale





GlobalAir.com on Twitter