AOPA Pilot Magazine - August 2023 - 97

first meet the experience requirements.
FAR 65.77 defines two alternative ways to
meet them. One is to graduate from a Part
147 certified aviation maintenance technician
school; the other is to document 30
months of full-time experience (or equivalently
4,800 hours of part-time experience)
swinging wrenches on civil aircraft.
I earned my A&P via door number 2,
and it took me 10 years of part-time work
on my own airplane and a few others
(mostly under A&P supervision) to reach
the 4,800-hour requirement. To put this in
perspective, it takes 1,200 hours of experience
to qualify for the ATP, but four times
as many hours to qualify for the A&P.
Traditionally, one excellent way to
accumulate the required experience was
constructing an experimental amateurbuilt
(E-AB) aircraft. But in 2019 the FAA
changed the rules in the middle of the
game. Change 675 to FAA Order 8900.1
(the FSDO inspector's handbook) added
the following to Volume 5, Chapter 5,
Section 5-1134(C): " NOTE: Manufacturing
of any type of aircraft, including amateur-built
experimental, does not count
towards practical experience. However,
practical experience gained on amateurbuilt
aircraft after the aircraft has received
an Airworthiness Certificate may count. "
Why would the FAA do this? As best I
can determine, the change was based on a
legal interpretation that an aircraft-underconstruction
does not legally qualify as a
civil aircraft until it receives an FAA airworthiness
certificate. This strikes me as a
wrongheaded distinction given the wording
of FAR 65.77, which calls for 30 months " of
practical experience with the procedures,
practices, materials, tools, machine tools,
and equipment generally used in constructing,
maintaining, or altering " airframes and
powerplants. Why would the reg say " constructing "
if it didn't really mean it?
At the time, this struck me as an
ill-considered change. What better preparation
could one have for becoming an
A&P than building an airplane? Shouldn't
the FAA be encouraging more people to
earn their A&P, not throwing up new barriers
to entry?
In January 2022, Brenton Ellis of
Clarkesville, Georgia, requested a legal
interpretation of this issue from AGC-200,
eloquently pointing out that the 2019 policy
change in FAA Order 8900.1 seemed
to run afoul of the regulatory language of
FAR 65.77. A year and a half later, Ellis is
still awaiting that legal interpretation. I
hope he receives one soon, and I hope it
results in E-AB build time being counted
once again as it had been prior to 2019.
mike.busch@savvyaviation.com
savvyaviation.com.
Ask the A&Ps /
Mike Busch, Paul New, and Colleen
Sterling answer your toughest
aviation maintenance questions on
our Ask the A&Ps podcast. Submit
questions to podcasts@aopa.org
97
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AOPA Pilot Magazine - August 2023

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