Could Your Airplane Be A PNC

An Aviation Rule Making Committee (ARC) issued a 346 page report to the FAA on how to streamline small airplane certification in ways that maintain and improve safety while cutting costs. In that report is the recommendation for a new certification category called Primary Non-Commercial (PNC).

An airplane in the PNC category could be maintained by its owner, and would not need to use FAA certified equipment or replacement parts. A PNC would be very much like a homebuilt in terms of maintenance and equipment requirements.

To qualify for PNC category an airplane or glider would need to have a standard production category airworthiness certificate, be at least 20 years old, not be turbine powered and be unpressurized. The airplane would need to have a current annual inspection with all ADs addressed. The airplane owner would apply for PNC which would be granted jointly to him and the airplane. The only physical changes required would be placards to announce to passengers that the airplane in in the PNC category.

Once the owner completes a yet to be created FAA approved maintenance course he could maintain his PNC airplane, add new equipment, and modify it. The only requirement is that the owner use aviation appropriate equipment and maintenance techniques and keep very complete records of all modifications and maintenance procedures.

Once each year the PNC would be required to have a condition inspection by a licensed A&P mechanic. This is different from the annual inspection required for standard category airplanes. An annual is intended to confirm that the airplane conforms in every respect to its type certificate. The condition inspection confirms only that the airplane is airworthy.

A PNC could be returned to standard category by going through an annual inspection to determine that every part of the airplane conforms to its type certificate, STCs and ADs. In other words, any non-certified equipment or modifications made to a PNC would need to be removed or brought into conformity for the airplane to return to standard category.

The PNC would actually operate in a dual certification category. The operating limitations of its standard certificate would still apply, but maintenance and modification procedures would not. A PNC could not be used for hire in any way, except the owner could pay a flight instructor to fly with him in the PNC.

The owner of a PNC could also make major modifications but that would put the airplane into a Phase 1 flight test program similar to newly built or highly modified homebuilts. For example, if a PNC owner dropped a 300 hp engine into his Skyhawk that would almost certainly require a Phase 1 flight test program. But if an owner installs non-certified avionics, for example, no additional approval would be required. Or he could install an improved restraint system, or better wheels and brakes and so on without needing approval. Many of the better and less costly equipment options that are now available for the homebuilt airplane could be installed in the PNC.

The ARC report on changing FAR 23 is 346 pages long, but there are still missing details of how the changes would exactly work. In one part of the report it recommends the PNC be limited to any fixed wing CAR 3/FAR 23 airplane that is not turbine powered or pressurized. In another section you can see a proposal that limits PNC to basic fixed gear singles with no more than four seats. Who can guess what a final rule may be.

In many respects I think PNC airplane owners will self-sort to basic airplanes, including classics and antiques. It makes sense to do your own maintenance on a basic airplane where construction methods and materials are common and systems are simple. To do your own maintenance on a high performance rectractable, for example, is more daunting, would demand more specific tools, and may risk your investment.

For example, a 20 year old A36 Bonanza is still worth a lot of money. If an owner converted the Bonanza to PNC, made many non-certified changes, and then wants to sell it what will it be worth? Less than a standard A36 I would guess because a new owner may not agree with the changes the PNC owner made. The ARC is very upfront about the airplane value issue and they believe that risk of resale value will restrain really big modifications to many airplanes.

So what are the chances we will see the PNC category become a rule. It’s hard to say. Even though the PNC was in the final ARC report it did not make it to a final version that Congress requires the FAA to adopt. The fact that the committee recommends it is powerful, but not a done deal.

Most of the recommendations in the report deal with the process of certification, and how a manufacturer can demonstrate conformity with less variability and uncertainty. Those are worthy goals, but not many are concrete actions. Creation of the PNC category is a very specific recommendation, not a process change.

Yes, the devil is still in the many details of a PNC that may emerge from the FAR 23 rewrite. We can keep the pressure on FAA to include the PNC even though it is not yet under the Congressional mandate.

I think the PNC fits in perfectly with the growing demand for changes in the Third Class medical. When flying is totally personal and private it should be lightly regulated. There is no reason that an airplane built in a factory can’t be maintained and updated by a trained owner just as owners of experimental airplanes have done for decades.

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95 Responses to Could Your Airplane Be A PNC

  1. Len Assante says:

    Wow. Someone in government circles is displaying a shocking degree of common sense here. If the CNP came to be and the third class medical went away (or was modified), these two changes could have a huge positive economic impact on GA as we know it. We’re talking thousands of former active pilots who would come back to flying and the industry would have an easier time attracting NEW pilots to the fold. Costs would go down, innovation would go up, and (shockingly!) FUN might be had.
    If this was April 1 instead of March 25, I’d be thinking Mac has pulled the wool over my eyes!

  2. Bill Berson says:

    Read through the past 60 years of Sport Aviation (as I have) and you find these deregulation attempts occur about every ten years. With names like Recreational Pilot, Primary Category, Small Airplane Certification Program, Light Sport…None have worked since the FAA was created in 1958. No single seat has been certified in 60 years or more and only two or three two seaters.
    The cost of certification exceeds the profit potential for these light planes.
    The only solution is to delete the requirement for Type certification entirely.
    As an ASTM member, I will propose this. But I don’t expect much support, unfortunately.
    Bill Berson

  3. Steve Sokol says:


    Thanks for highlighting this revolutionary but as yet largely unknown component of the Part 23 rewrite. I fly a 1977 Cherokee 140, and I’m chomping at the bit to re-categorize it as PNC. The cost of upgrading it using certified gear simply don’t make economic sense. PNC would allow me to replace the tired systems with non-certified (but field tested) gear. The value of the aircraft (currently $20K) can’t go anywhere but up, and the potential for improvements in safety, efficiency and workflow are significant.

    Late last year I traded emails with John Colomy and Earl Lawrence in the Small Airplane Directorate regarding the PNC proposal. Colomy (who has since retired) was very positive on the idea. Lawrence, who’s the manager of the directorate, was a bit more cagy, indicating that the FAA had yet to make any decisions on that portion of the proposal. I also talked with a number of ARC participants who described the agency’s response as lukewarm.

    I would love to see the EAA and the AOPA both step up behind the idea and do their best to make sure that it survives the rulemaking process. Any chance you could help put together a special discussion of PNC at this year’s Oshkosh?

    Best Regards,

    Steve Sokol

    • Len Assante says:

      “I would love to see the EAA and the AOPA both step up behind the idea and do their best to make sure that it survives the rulemaking process. Any chance you could help put together a special discussion of PNC at this year’s Oshkosh?”

      • TedK says:

        I traded comments with EAA and VAA Advocacy folks on the blue board. They think FAA is going to implement the manufacturing aspects of the study but are opposed to the PNC concept. Len’s idea of PNC discussion at OSH-AV is a great one.

        Thanks Mac, great and timely article! :-)

        • Mac says:

          Well, all, I didn’t quite get the facts right in the first version since updated. The PNC language is in the ARC report, but did not make it into the bill that Congress passed. So the FAA is not required to create the PNC category, though there is some pressure since Congress agreed overall with the report.
          So, yet another logical proposal is in limbo even though aviation friends in Congress support it.
          Sorry for misleading you with the first version.
          Mac Mc

          • TedK says:

            To paraphrase Monty Python: “We’re not dead yet!” Law says to implement the report. FAA is trying to turn a blind eye to the PNC portion so it may not come out in the initial NPRM, but there are two things we can do. 1. Bombard the FAA with comments when the NPRM is released. (Like people did on the LSA Amphib Retraction issue), and 2. Bombard Congress at that same time.

            Keep saying, “I know we can, I know we can, …”

  4. Sarah A says:

    An excellent article related to Sport Aviation. Keep these coming.

  5. Kayak Jack says:

    As my son used to say when he was a teenager, “We can’t do that, dad. It makes too much sense.”

    I’m amazed that Congress stepped up to even consider this idea, and disappointed that PNC language didn’t make it into the final bill.

    Even so, FAA continues to be mostly drag, and very little thrust. A distinct shame.

  6. GeorgeH says:

    Thanks for a very good article.

    I also think Steve Sokol makes some good points. PNC could be a second lease on life for many airplanes that are currently parked because of tired, unreliable, and unsupportable systems. Replacing them with field tested systems should make those aircraft more valuable, even if only allowing the current owners to get more use from them.

    Getting a discussion set up for AirVenture 2014 is a must. This is still a proposed rule change and getting it across the finish line will not be easy. A good engagement strategy for those who would benefit most from the rule change should part of the discussion.

  7. Paul Randall says:

    The PNC is a great idea!

  8. Harold Bickford says:

    This is a proposal that could have legs but would have to be well thought out and performed to avoid unintended consequences. It would create a very interesting nexus with E/AB and GA certificated aircraft in terms of people choosing airplanes for their desired activities.

  9. This PNC concept sounds like the best idea I’ve heard in a long, long time. In fact, it sounds too good. The skeptic in me says the FAA will never buy it in a million years.

    I truly hope I’m wrong. This, combined with the drivers-licence replacement for the 3rd class medical, is precisely what GA needs to stay alive and indeed become reinvigorated.

    Mac, be my hero and please take Administrator Huerta out for a beer and talk him into this PNC concept.

    • TedK says:

      Buy Huerta whatever he wants, send me the bill.

    • JR A&P/IA says:

      Mike, I hope you’re wrong about the FAA. It makes so much sense. Start out with a certified airplane and maintain and modify it like a homebuilt. I can see Dynon avionics, autopilot, LED lights, solid state electronic ignitions. Safer and more-modern airplanes. Oh, the possibilities! Let’s lobby congress and the FAA for it!!

    • Steve Sokol says:


      You’re another of the well-known voice of the industry. If you, Mac, Mark Baker, Jack Pelton and a few other experts got the two major personal aviation associations behind the idea, it would fly. We pilots are lucky to have friends in high places: Mike Pompeo, Sam Graves and the 273 other members of the General Aviation Caucus would likely be happy to sponsor a follow-on bill to SARA with specific language covering PNC.

      This is personal aviations’s last, best chance. This is the one that’s worth pulling out all the stops to get done. Cost is the single biggest reason people aren’t learning to fly. It’s what keeps tens of thousands of legacy aircraft rusting away in hangars and on ramps. PNC has the potential to cut costs drastically, getting more people flying.

      Would you be willing to serve as the maintenance chair / guru on a committee dedicated to making PNC a reality?

      Thanks in advance,


  10. Bill Berson says:

    Why 20 years?

    Why not 30 years? Or 50 years. Or maybe just one year.
    How do they come up with these rules that restrict aviation, with dartboards?

    • Steve Sokol says:

      Possibly because at 20 years out, the manufacturer is off the hook. The General Aviation Revitalization Act of 1994 effectively terminates liability after 19 years. If they let us ordinary citizens go mucking about with our own property at any point prior to that limit, the waters become muddy. At 20, we’re on our own.

      I fear that the manufacturers might fight this proposal for several reasons. First, they don’t want to be competing with thousands of remanufactured and updated aircraft selling at a fraction of what you would pay for new. Second, they probably don’t want to find themselves in the news when some highly modified version of one of their products decides to come unglued.

      It might be a sensible requirement to “unbadge” PNC aircraft: remove the logos and alter the call sign. Instead of “Cherokee 3480Q”, my plane would be “Non-Commercial 3480Q” or something – just like all E-AB aircraft are “Experimental XXX”.

      • Bill Berson says:

        Good insight Steve. But it seems to me a manufacturer should have the right to sell a new airplane that includes owner maintenance. That way the factory new airplanes can have the same owner maintenance appeal as with a Kitplane.

        It seems odd that the so-called safety rules are based on whims of business. But of course that is how it works.

        • Sarah A says:

          I do not think you would find a manufacturer that would want anyone but a certified A&P touching the aircraft while their liability is in place. The 20 year rule sounds like a good attempt at getting around that roadblock. It might be clear that it was owner maintance that caused a crash but laywers are very talented at taking what is obvious and working up a good alternative to base their case on. The cost and risk associated with litigation tend to make those companies settle regardless. So no, lets stay with 20 years and not risk getting GAMA with their deep pockets on the other side of the fight.

          • Bill Berson says:

            Hi Sarah,
            Current law allows owners to do considerable maintenance. See FAR43 Preventive Maintenance. As a shop owner, I had one airplane owner that removed his oil screen plug ( legally) and forgot to replace it. The engine seized on takeoff. He didn’t blame me or anyone.

            It is not just certified A&P’s that are touching aircraft.

          • Sarah A says:

            Yes there are a good number of things that the owner can do and I am sure that figures into the insurance rates. It is obvious though that there is the desire to do more on the part of the owners. I have a friend with a Mooney 201 and having just got it back from the first annual under his ownership he really wishes he could do what the guy in the next hanger does with his RV. Not to mention the sticker shock he is faced with to upgrade his panel vs. what he has seen in the Sport Aviation issues I pass along (he likes the Mike Busch articles).

      • TedK says:

        Pink 3480Q. ;-)

  11. Jon C. says:

    Why limit to small/non-turbine? The experimental category currently contains things like the Epic LT, a 300+ kt pressurized turboprop with 6 seats. How does an airplane like a TBM700 not fit with the private flying concept as well as the Epic if the owner so chose and assumed the risk of reduced valuation?

    • Sarah A says:

      And how many of those “Builders” really built those aircraft vs. having someone build it for them and lie on the paper work. yes some of those high end complex EAB’s are truly owner built but that is not the norm. For the most part I do not think there are many people who own those sort of certified aircraft that would be interested, not to mention what their insurance companies might think about the potential risk they would be exposed to in a crash. No the insurance companies will want those high value certified aircraft to have A&P’s doing the work.

  12. Pete says:

    Funny I just said to my friend, it really stinks that I can’t put cool stuff like skyview in my 56 172. Wait maybe one day I can..

  13. Thomas Boyle says:

    Meanwhile, there’s some alarming language in the latest draft of the regulations for operating limitations (Order 8130.2 – version G is current, the draft is 8130.2H).

    This is regulation on the way, not yet adopted. The part that’s new, is custom-designed to kill off electric Experimentals before they are born.

    Also, under the planned change, if you modify your SLSA, you won’t be able to carry passengers – ever. Since LSA is not covered by the proposed PNC rule, you won’t escape via that route even if PNC becomes real.

    Here’s the language: (See PDF page 293, in Appendix C, which talks about the procedure for imposing operating limitations.)

    “5 Procedure…

    c. Prohibit the carriage of passengers, flight over densely populated areas, and night or instrument flight rules (IFR) operations in the following:
    (1) Experimental LSA aircraft that formerly held a special LSA airworthiness certificate;

    (6) Electric-powered aircraft”

    • Sarah A says:

      Good point on the effect on the SLSA aircraft. They should be included and it would seem to be reasonable to include EAB aircraft that have changed hands. Now why in the world would they include Electric Aircraft as an exclusion ?

      • Bob says:

        Why is *any* part of that proposal “reasonable”? If I go buy an RV-10 off someone else, I should be forever restricted to single-pilot VFR operations in a defined area? Why is building an E-LSA RV-12 and modifying it later ok, but buying an S-LSA RV-12 and converting/modifying it not ok? Please tell me that’s not what you meant.

        Now, I’ll tell you exactly why electric airplanes and converted S-LSAs would be included. It’s the same reason why the third-class medical certificate was invented, and the same reason the sleep apnea issue came about–because some dolt at the FAA whose only personal experience with aviation is riding in the back of an airliner imagined that there was a remote possibility that something could go wrong with an electric or converted S-SLA due to an inherent flaw, turned that remote possibility into “it will happen on every flight”, and decided to write a regulation as a “solution” to a problem that has never yet been, isn’t, and will never be.

    • Bob says:

      What the hell?! Is someone in the FAA determined to do as much damage as possible? First we have VIP TFRs, then the sleep apnea mess, and now someone wants to make modifed S-LSA and electric airplanes useless, based on absolutely nothing but wild speculation.

      It seems like, as we realize that many of the current regulations are useless if not counterproductive, someone entrenched in the system wants to not only crack down harder on those regs, but actually impose more onerous ones by fiat (“Let them eat cake!”), and double down on those new proposals when everyone (up to and including Congress) pushes back.

      • Thomas Boyle says:

        EAA has posted a release on its web site this morning, to the effect that they have been working on some of these issues for the past couple of months.

        But, yes, it does appear that there are folks at the FAA who sit around trying to imagine things that could go wrong, and writing regulations to address them – and also folks who sit around wondering what regulations could be simplified/cut back.

        We get caught in the crossfire.

        I was VERY happy to see Mac make the statement, “When flying is totally personal and private it should be lightly regulated.” Unfortunately, his former colleagues over at Flying, such as Robert Goyer and Stephen Pope, don’t seem to have come to that realization yet, and remain generally biased toward supporting heavy regulation (this morning, on the electric aircraft issue, Pope writes “it’s probably a prudent move until such aircraft can prove their safety in flight” – a sentence that is chilling if you think about the ways it could be used). In fairness, there are signs that Goyer is starting to see the light: he recently wrote an article titled “Fear the Regulator”, but still felt it necessary to open the piece with “I am a fan of regulation” – not “some regulation is necessary”, but “I am a fan“…

  14. Brent Taylor says:

    For all those seeing this PNC proposal as a panacea that will magically lower the cost of owning/operating your aircraft, you may want to be careful what you wish for. For example, what do you think will happen to your insurance costs? Do you think the maintenance community (A&P’s, maintenance facilities etc.) will be supportive of turning formerly type certificated aircraft into airplanes that are neither certified nor amateur built? Are you as the owner willing to assume the increased personal liability resulting from becoming, in effect, the manufacturer for your particular make, model & sn# aircraft? What will happen to all the perceived $$ savings, when to sell you have to remove all the “non-certified gear” and unapproved modifications in an attempt to return the aircraft to standard category? To me, this PNC business sounds “penny wise but pound foolish”

    • Steve Sokol says:

      Great, then don’t switch. But please don’t stand in the way of the rest of us fools who are willing to take the risk. Nothing is a panacea. Everything is a compromise, but as it stands today, we aren’t even allowed to make the choice.

    • Adam Smith says:

      Brent a very similar concept already exists in the UK as the LAA (formerly PFA) Permit to Fly and it’s been very beneficial to the vintage aircraft community, especially for the owners of aircraft that are no longer supported. No pushback from mechanics or insurers that I’m aware of, or any noticeable problems with safety. The LAA Permit to Fly is a worse deal than this “PNC” idea as it’s quite restrictive (Day VFR) and a one-way street (once an aeroplane is on a Permit, it can never go back to being Standard Category). But that hasn’t stopped a lot of people using it for the practical benefits.

      • Brent Taylor says:

        Hi Adam, I’m familiar with the LAA Permit to Fly. I believe the Canadian Owner Maintenance category is somewhat similar and also is a one-way street (once in the OM category it cannot return to standard category). That caveat would make sense to apply to the proposed PNC as well. Curious, do you think your new employer would be willing to put any of their aircraft (the ones that would be eligible) into the PNC category ?

      • Nigel Hitchman says:

        The LAA Permit to Fly may be slightly worse in that its day VFR only. However it is a lot better in that if your aircraft is in this category you don’t have to go on a course to be able to own it and do the maintenance. Its more restrictive in that anything more than a minor modification has to be approved by the LAA, but that is an awful lot cheaper than getting anything approved by the CAA (our FAA). We have an annual inspection required to be done by an LAA approved inspector, many of which are volunteers, but also many of whom are also equivalent to FAA A+Ps and also work on certified aircraft.
        In the UK there is no problem with insurance for these aircraft and the insurance companies treat them exactly the same as a certified aircraft of the same type. Interestingly when there are aircraft of the same type on a LAA permit or Certified, the LAA examples tend to be worth more and easier to sell because of the significantly reduced costs and ease of maintenance.
        Unfortunately in the UK you cant chose to put your aircraft on this system, the CAA only allow certain types and those with grandfather rights. This is why there were hundreds of Cubs, Luscombes, Tcraft, Aeroncas etc imported into the UK in the 80s/early 90s when all these could go onto a LAA permit, but almost none now because currently the CAA says any new imports have to be kept as certified aircraft.
        Interestingly with a number of no longer supported aircraft coming onto the LAA permit system in recent years, it has been found that the maintenance standard of these formerly certified aircraft is not good enough for the LAA standards!

        • Brent Taylor says:

          Hi Nigel, Thanks for the LAA info but I would be curious as to the total number of aircraft that currently are in the LAA category ?

    • Sarah A says:

      I think the switch to PNC would be a one way street. It would be prohibitive, if not impossible, to go over the aircraft and ensure that there were no modifications and everything with regards to maintance was up to specs. That is why keeping a certified aircraft’s logbooks is so critical. Without them you have no idea what had been done with regards to required AD’s and such or the time on any life limited component. With no logbook and you have to assume the worst and good luck getting at IA to sign it off again.

  15. Josh Johnson says:

    So, why not just drop your Cessna 172 into Experimental Exhibition now and do whatever you want? Seriously, it’s just about that easy, but you’re gonna kill the value of the aircraft. I maintain a 450 Stearman that’s registered just that way, it’s a bit of a hassle, but not much. A program letter and yearly condition inspection and life’s good.

    • Steve Sokol says:

      Interesting. I’ve always heard that the limitations on what you can do with a certificated aircraft in the Experimental category are stringent enough to make it unappealing. Are you allowed to fly whenever and wherever you want, or can you only fly to/from and at air shows? Can you take passengers? Do you have to file any kind of request before doing a cross country?

      • Josh Johnson says:

        Faa order 8130.2g has a matrix depending on they type aircraft that lists the operating limitations you get – basically for experimental exhibition you can get vfr/IFR/night, passenger carrying and cross country everywhere (for non-jet) within the US, you do have to do a yearly program letter (no big deal) and have an a&p do a yearly condition inspection. I don’t know what my guy pays for insurance, I know it’s a named pilot policy only, but it’s a stearman, not a 172, so a different animal.

  16. Mike Massey says:

    After an accident:
    I can see one set of lawyers suing Joe the pilot. While another set of lawyers sue Joe the guy who maintained the airplane. And still another set of lawyers are busy suing Joe the guy who modified the airplane. All at the same time.
    But Joe was not able to buy insurance for a self modified, self maintained airplane. And if Joe was killed in the accident, his family will be defending his estate without him to explain and defend his modifications and maintenance practices.

    The PNC concept may lower component costs some, but how are the insurance companies and lawsuits going to effect its practical use. Will a modified airplane even be insurable? If owners are treated the same as homebuilt owners and every accident in any modified airplane results in the owner getting sued, how many people will actually use the program? I love the idea of allowing non certified avionics in our airplanes. But in our society, will that even work from a liability standpoint for a Bonanza or Cessna 210 or a Seneca owner?
    I think the out of hand lawsuit situation in America will have to be addressed before we can really solve our high cost of ownership problems and that’s like wishing for rain in west Texas. Or common sense in our Government. It hasn’t happened yet.

    • Sarah A says:

      If we can get insurance for an EAB than insurance for a PNC should seem reasonable. I would not expect the coverage to be anything but liability for harm to other persons and property, no coverage for the value of the aircraft. Look at it this way, the PNC started from a proven aircraft so there is only so much the owner could screw up. On the other hand the EAB is a complete unknown regardless of the relative success of the design because it had to be assembled from scratch and was never subjected to the full FAA certification regardless what testing the designer / vender might have done. So it would come down to the decision of whether you feel comfortable with forgoing coverage for the value of the aircraft in exchange for the freedom to maintain and modify as you wish.

    • Steve Sokol says:

      If enough people are interested in PNC, the insurance industry will show up. Insurance is rarely an “all-or-nothing” business. The costs will be higher – probably on the same order as E-AB insurance – but somebody will be willing to write policies. If not, then there’s a business opportunity. Perhaps it could be done on a mutual basis (PNC Owners Association, anyone?) if the commercial underwrites really can’t stomach the idea.

      As for the lawyers – good luck. The original aircraft manufacturers are off the hook thanks to GARA. The owners of these aircraft are generally not the deep-pockets sorts. Any victims of accidents will, by-and-large, be limited to what the insurance coverage pays.

      I’m actually a fan of trading insurance for regulation. If the feds want to protect the public from GA accidents, asking pilots and owners to carry a minimum level of coverage is a much more reasonable and measured approach than promulgating thousands of pages of rules and regs. It works perfectly well for personal automobiles. Every state in the nation requires proof of insurance to license a car.

  17. Hi, Mac:

    Exciting stuff. How about a compare-and-contrast between the requirements and operational advantages/disadvantages of the proposed Primary/Non-Commercial category and the existing Primary Aircraft certification? What does PNC give us that we don’t already have? Why might PNC be a game-changer when Primary certification was not?


    • Bob says:

      Primary certification wasn’t a game-changer because it did nothing for compliance or production certification, and the associated paperwork burden. That’s where the real cost is; the requirements in Part 23 are mostly just basic due diligence and good engineering (if a little outdated and restrictive in methods). The way the FAA wants you to prove you meet those requirements, however, is very manpower- and paperwork-intensive. So are the costs associated with building airplanes the FAA’s way, and those costs hit you with every single airframe that rolls off the line. For example:

      The FAA still wants to do its own independent conformity check in person for every test, whereas other regulatory agencies accept reports from the manufacturer’s configuration management system.
      The FAA insists on a flesh-and-blood representative witnessing qualification and certification tests, when modern digital recording systems provide a far better (and repeatedly viewable) record of the test.
      The FAA insists that it must approve every step of every process used to manufacture the airplane or its parts. Suppliers have to be approved separately. Quality management has to be done the FAA way, too, and the FAA wants to know in writing if you so much as move a fixture on your production floor. Somehow, other safety-critical industries like automakers and pharmaceutical companies manage to make products according to accepted industrywide standards and processes without every step being under the microscope of a regulator. There’s no reason light aircraft production can’t be run the same way.

      There’s a lot more to all this, and you can read a lot of it in the ARC’s final report.

      The PNC proposal attacks a different problem–the cost of maintaining and upgrading an older airplane–by allowing you to convert it to something like a second-hand homebuilt. That means you could upgrade a tired old 70′s-era 172 with things like a glass cockpit, autopilot, electronic ignition, and a new interior (and also run on mogas) without having to go through mounds of paperwork and STCs, and do so at a fraction of the cost. And you could do far more of the maintenance yourself, further reducing cost.

    • Mac says:

      Hi Tom,
      The selection of the word Primary for the proposed new category is a little confusing. I wish the “P” stood for Private. As you know, there is a primary certification category that is intended for very basic airplanes of modest performance. As recommended by the ARC the PNC could be high performance pistons and flown night and IFR. The only significant restriction would be no use for hire of any type except for the owner receiving instruction. I as I read the recommendation you couldn’t even loan your PNC to a buddy to use while paying a CFI.
      Mac Mc

  18. Richard Montague says:

    This sounds like a great idea, an viable opportunity for a lot of us to use to advantage. I suspect the manufacturers would love it, as soon as an airplane becomes a PNC. they get a free pass on liability.

    As a cautionary note, I have every confidence in the FAA’s ability to render the final product as largely undesirable for the most part.

  19. TedK says:

    Congress didn’t have to insert themselves into what is normally a regulatory function. They did so for a reason. We shouldn’t let the FAA deny us what is given to us in Law. See

  20. Tim P says:

    I am not a mechanic and have no desire to do maintenance on my airplane, but I would love to have access to the great avionics available to the experimental crowd. Why does the FAA think it’s safer to fly around with a 36 year old autopilot than a brand new, state of the art, non-certified one? To put in a new certified autopilot is cost prohibitive, but a non-certified one is affordable and, in my mind, safer than the old technology I presently have. New regulations can’t come fast enough for me!

  21. Roy Mcclure says:

    This new far23 is going to kill alot of pilots most of them already think so highly of themselves now just because they are pilots. I have repaired more mistakes made by want to be mechanics / pilots than i can count. I see this new far23 a danger i know how my teeth work and why they are there but i still go to the dentist for repairs.

    • LARRY says:

      Give us a break, Roy. There are 25,000 E-AB airplanes out there that fly just fine. They’re built by people who may never have touched an airplane before. Every year, thousands of ‘em return to Oshkosh and the pilots are still on the right side of the grass.

      I’ve been an A&P for 35 years and it’s MY finding that airplanes that have owners that dive into their maintenance are usually in better shape than those maintained by others. And, how many times have you seen an airplane fresh out of “maintenance” having an issue.

      Lead, follow or get out of our way. If you don’t want to work on these PNC’s … then don’t. But, for heaven’s sake, don’t poopoo an idea whose time has come!

    • brett hawkins says:

      Roy, Good Buddy:

      I built a Glasair 1 back in the 1990′s and have put nearly 700 hours on it since then. I (for the most part) inspect and maintain it with my Repairman`s Certificate and am (surprise, surprise) still alive.

      I share hangar space with an ex-military, extremely anal-retentive and excellent AP/IA. I have in fact requested, and paid without complaint his fees to perform, certain maintenance tasks and he is a genuine wizard.

      While I know that he can fabricate parts to .001 tolerances and I can’t, I have yet to experience an in-flight problem with my plane. BTW, do you polish the inside rims of your snow tire rims to .001 run out just because you can?

      While I appreciate your self-promotion efforts I can hardly respect them as safe engineering dogma.

      PS: if I die due to an in-flight problem attributable to my piss-poor amateur homebuilding efforts I will send you a god-damned $100 bill.

      Good luck, bro.

  22. Carl Hopkins says:

    This is the first I’ve heard of this but I think it is GREAT. The number one reason I like it is for modern avionics. And I suspect that is where the bulk of the modifications would be. And I’ll bet a lot of them would be installed by avionic shops, not owners.

  23. Mike Berg says:

    I’ve been flying long enough to remember all the horrible things that would happen to us and our engine if we used auto fuel. I’ve used it for 25+ years in my Cherokee and Champs with zero problems so guess the ‘sky really didn’t fall’ (pun intended). I’m not going to fly if I’m not fit to fly (medically) and I’m not going to take the aircraft off the ground if it’s not fit to fly. Besides, who paid for the plane and whose name is listed as the owner?

  24. Tom says:

    How embarrassing for the FAA to have congress over rule them on so many things these days.

  25. Jon Byrd says:

    As an A&P/IA, aircraft owner/pilot, and Director of an FAA Part 147 AMTS in Rome, Georgia, I have mixed emotions about this. We see so many certificated aircraft that owners have performed preventive maintenance (and sometimes beyond) on and it’s quite scary. Parts from the local hardware store, wiring from Radio Shack, (and I could go on and on…) and by the time I have put my eyes on it, something is about to terribly go wrong. This rule may very well give ignorant owners a pass on doing whatever they want to their aircraft, and as a result, we may see an increase in general aviation accidents. I’m not a fan of all the heavy ink on paper/regulation we’re bound by every day, but the FAA’s number one mission is safety, and I must admit, when the regulations are followed, more GA aircraft take-off and land with no incident(s).

    I’ll be watching this one closely. There are definitely pros and cons to this, but as with ADS-B and its implementation in 2020, we could do a little more homework here.

    • Tim P says:

      Why can’t we have avionics shops install some of the excellent non-certified products?
      This way they would be installed properly.

    • LARRY says:

      Jon … I AM an A&P who specializes in electrical and avionics type work and I can tell you that I’ve seen OOdles of airplanes that A&P’s worked on with electrical tape keeping things from shorting out. 25,000 E-AB airplanes built by folks who may never have touched an airplane say you’re wrong.

      Unless and until we get the FAA out of our business, GA is dead … DEAD, I say!

  26. Joe B says:

    What if your airplane is owned by an LLC (that you own) and then you pay a per-hour rental fee to the LLC?

  27. John Worsley says:

    I think Carl is right. I would like a better autopilot in my ’74 Cherokee 6, but not for $20K+. And, recognizing my limitations as an electronics expert, I would have my local avionics shop install a lower cost, non-certified system. As a former professional mechanic (cars, trucks, motorcycles, etc.-not airplanes) I already do a lot of work on my plane (with sign-off by an A&P when needed) but pass it off to an airplane pro when I don’t have the knowledge, experience or equipment to do the job. I would like to have club seating, but mine was the last year without it and there is no STC. Of course, if the proposal limiting PNC to 4 seats, none of this will do me any good.

  28. Brent Taylor says:

    As many of those commenting here are comparing this proposal to the Canadian Owner Maintenance (OM) category, I wonder how many have bothered checking out the total number of Canadian OM aircraft (since that programs inception in 2000) ?? Well here’s the link, . As can be seen, only 612 (as of Feb 2014) aircraft have been moved into the OM category since that programs inception in 2000. For comparison Canada currently has 4072 homebuilt aircraft registered. Ergo, it doesn’t look as if the Canadian OM has been an overwhelming success (similar to the US Recreational Pilot category of which their are less than 500) !! So why is Mac, hence the EAA, supporting the addition of a whole new section of FAR’s/regulations (which we all know will not reduce cost) for a very, very small percentage of US aircraft owners ??

  29. scott fohrman says:


    First of all, the ARC recommendation does not limit the aircraft to 4 seats. See draft regulation 21.24 subsection C. (I think you stopped at subsection A which applies to Primary Category Aircraft, not non-commercial) Trust me there was no confusion on the ARCs part on what this applies to or how to implement it.


    The Primary Non-Commercial is very different from Canadian OM, probably the biggest difference is that one can actually easily go back to standard category. But in the end, this proposal is a voluntary program – you might be right, it might fizzle like many other ideas on how to make aviation more viable – but in the end this is a voluntary program. If people want to have the option of operating their aircraft with less intrusive government oversight, why not offer the option?

    People should have the freedom to choose how the operate their aircraft.

  30. Planeguy says:

    The regulation may not limit the seating capacity of the craft but, it does recommend weight limitations to <1700lbs. A move that kills the efforts… Find it in the back in the recommended verbiage section (sorry to be vague… I'm on vacation and don't have it in front of me.)

    I believe this is a great step in the right direction and believe it noteworthy that these ideas were generated by the regulators at the behest of the policy makers. As a professional in the industry I find their call for a shift of mentality surprising and actually somewhat startling. For those who are speculating here about the intentions or ramifications of the ARC I recommend you read the report for yourself. I have made almost a decade of reading publishings from the FAA and have found this one extraordinarily progressive…

    As the owner / restorer of a vintage twin I find the PNC a cause of insomnia. To think that my plane could once agin be as great as it was the year it was conceived is a powerful notion. Diesel power plants, glass cockpits, advanced flight guidance, automatic climate control… It's enough to make me go cross eyed! I believe there would be a niche market for highly modified aircraft from reputable shops (Think West Coast Customs) much as there is today for the VVIP crowd today. (Check out Business Jet Interiors International for a peek at how air travel should be…)

    I believe there are many more interesting points that will affect the rest of the industry in the ARC as well. Given credit (for certification) based on field service a product could be planted in the EAB/PNC and gain operational history eventually evolving into higher levels of certified aircraft eventually to the benefit of the Transport Category.

    See you at Sun-N-fun,


  31. scott fohrman says:


    No offense my friend, but I wrote the rec. The confusion I think is stemming from that primary category and primary non commercial are two separate categories.

    There is no weight limit for ANV category- the regulation is to be found in the rec (posted in the forums) under 21.24 subsection c. The weight limitation you speak of is in subsection a and only refers to primary category aircraft, not primary non commercial (ANV).

  32. Planeguy says:


    Thanks for the quick turn. None taken.

    I would love to buy you a beer and bend your ear on this matter.

    I was inaccurate in my recollection of the weight limit… My apologies.

    Appendix G, Attachment A, SEC 21.24 “Issuance of type certificate: … Primary Non-Commercial Category” (a-1-[ii]) “Weights not more that 2700 pounds…”
    I really hope I’m missing something here!?!

    Perhaps you can clarify?



    PS working from my phone so please forgive any language or documentation issues.

  33. scott fohrman says:


    That is for primary category aircraft produced under a Production Certificate. Look down at subsection F for primary non commercial.. repeated below,

    (f) Issuance of an airworthiness certificate for a Primary Non-Commercial category aircraft.
    (1) Purpose. The FAA issues a Primary Non-Commercial airworthiness certificate to
    operate a Primary Non-Commercial aircraft
    (2) An owner of an aircraft registered within the United States may apply and is entitled
    to for an airworthiness certificate for a Primary Non-Commercial aircraft provided:
    1. More than twenty years have elapsed since the aircraft’s date of manufacture.
    2. The aircraft is fixed wing and either unpowered or powered by reciprocating
    3. The aircraft has a current annual inspection (14 CFR 91.409) at the time of
    application for original issuance.
    4. The aircraft must be in condition for safe operation (14 CFR 91.328) for
    5. Aircraft which holds or has held an Airworthiness Certificate in another Category
    defined by 14 CFR 23.3

  34. scott fohrman says:

    Oops.. now I am getting caught up in my own web… the above is 21.184, not 21.24. But same answer, the weight limitation only applies for new primary category aircraft produced under a PC, not a ANV.

  35. Planeguy says:


    Your the man.


  36. Terry Bowden says:

    I am curious.. what happens when it’s time to sell a PNC airplane? Does the proposed rule require all non certified alterations to be removed or at least disclosed to the buyer? So what about the fifth or sixth buyer down the line? Not all the prior aircraft owners who are likely to participate are sure to be as talented and conscientious as your average RV craftsman/homebuilder. There are an awful lot of armchair engineers and redneck mechanics out there. Let’s consider that somewhere down the line (assuming no crash has occurred) somebody will want to take the airplane back to Standard Category. Where does the A&P I.A. find all of the data necessary to determine which items are standard and which are not. That is if the alteration is visible or detectable by the typical inspection done at annual. From my experience as a Vintage DER, I have noted I.A.’s are already struggling to make such distinctions when undocumented repairs and modifications are present. I can only see that this issue becoming more chaotic if this proposal passes. The flood of “anything goes” aircraft design and “shoot from the hip” maintenance practices will certainly cause an errosion of safety.

  37. scott fohrman says:

    Because it is intuitive that ANV (or PNC or whatever) aircraft would worth a whole lot less than one in standard category, the ARC rec envisioned that most owners would convert their aircraft back to standard category before they sell them to avoid taking a bath on the price.
    In fact we were banking on this as part of the safety argument as it would be to an owners financial detriment to alter an aircraft to such an extent that it could not easily be converted back to standard category upon sale. Therefore we are giving people a finical incentive to keep their airplanes close to type design as opposed to threatening them with legal action. I think this is a much more effective tact.
    Under the ANV rec, it would be legal to sell an airplane in the ANV category, just, well stupid to do so.
    However I am troubled by your Redneck mechanic argument. Honestly, I have seen way more dangerous DERs than I have seen issues with mechanics – In fact most good innovation we see comes from hard working mechanics, owners and builders of experimentals. We are trying to encourage that spirit of individual inventiveness with the ANV rec and spread it to the world of standard category. In fact, if you are argument were true, we would see experimental aircraft falling out of the sky because of the issues that you speak of – nothing could be farther from the truth. We would also see issues in the decade old Canadian owner MX class – yet in most years that class has proven safer than standard category.
    The big thing here Terry is that we have to trust people to do the right thing. And remember there is always a choice here. I am sure there will be people that would never consider buying an aircraft that was PNC category for the reasons you state – that’s is a valid decision. However I will bet that there would be just as many that would be happy to own an aircraft where it was not painful to comply with regulations more appropriate to an airliner than a privately operated vehicle.

    • Brent Taylor says:

      Per your comment above; “In fact we were banking on this as part of the safety argument as it would be to an owners financial detriment to alter an aircraft to such an extent that it could not easily be converted back to standard category upon sale. Therefore we are giving people a finical incentive to keep their airplanes close to type design as opposed to threatening them with legal action.” let’s take a look at some of the comments on this blog from those that are all in on the PNC proposal;

      “I could put some cool avionics in my Cessna just like the RV guys do!”
      “I want to put a Dynon in a 45 year old Bonanza”
      “Sounds like a great plan. Tear out all the steam gauges in a 172 and put a non tso garmin or dynan in for $3000 perfect! Then put a IO360 into the 172? Perfect.”
      “I can see Dynon avionics, autopilot, LED lights, solid state electronic ignitions. Safer and more-modern airplanes. Oh, the possibilities!”
      Second, they probably don’t want to find themselves in the news when some highly modified version of one of their products decides to come unglued.
      “Why limit to small/non-turbine? The experimental category currently contains things like the Epic LT, a 300+ kt pressurized turboprop with 6 seats. How does an airplane like a TBM700 not fit with the private flying concept as well as the Epic if the owner so chose and assumed the risk of reduced valuation?”
      “Funny I just said to my friend, it really stinks that I can’t put cool stuff like skyview in my 56 172.”
      “….by allowing you to convert it to something like a second-hand homebuilt. That means you could upgrade a tired old 70′s-era 172 with things like a glass cockpit, autopilot, electronic ignition, and a new interior (and also run on mogas) without having to go through mounds of paperwork and STCs, and do so at a fraction of the cost.”
      “As the owner / restorer of a vintage twin I find the PNC a cause of insomnia. To think that my plane could once agin be as great as it was the year it was conceived is a powerful notion. Diesel power plants, glass cockpits, advanced flight guidance, automatic climate control…”

      So which is it going to be, “keep their airplanes close to type design” in which case what’s the point of the PNC at all, or allow unfettered and unlimited modification per the comments highlighted above ??
      If the later, how will the PNC regs assure conformity to the approved type certificate, let alone airworthiness, with just an annual inspection?? Have the ARC members that drafted this proposal thought to insert/provide any help, support and liability protection to IA’s attempting a return aircraft (as modified above) to standard airworthiness, or will they leave IA’s swinging in the wind and on there own in this matter?

    • Terry Bowden says:

      Hello Scott,
      I am sorry, I must apologize to my Redneck friends, who are some of the most conscientious and honorable folks on earth. I should have used a different word in describing the incompetence we all have seen throughout aviation. I’ve known shoddy mechanics and shoddy DERs. I have also known shoddy individuals who are aviation rulemaking committee members. All of those types are the ones we cannot “trust.. to do the right thing”.

      Aviation professionals who lead our industry should strive for safety to the best of our ability. Nobody is perfect. But one should never knowingly compromise when it comes to risks. That is why I have to speak up when I see proposals such as this. I cannot support taking something already proven safe and compromising it for the sake of money or un-approved but sexy/tricky gadgetry. It does not compute with me.

      It is also why I take my DER responsibilities more than seriously. If you are insinuating that I fall in the category of a dangerous DER, then I take personal offense. Aviation is my livelihood. I recognize daily that precious human lives are at stake with each signature I provide, whether it be as an A&P or a DER. Safety is always paramount to me. Safety in engineering designs cannot be based on a warm and fuzzy feel that we “trust people to do the right thing”. A design is either safe and compliant with the airworthiness requirements or not.

    • Carl Hopkins says:

      “Because it is intuitive that ANV (or PNC or whatever) aircraft would worth a whole lot less than one in standard category”.

      So my 1977 Arrow with all steam gauges and original ADF and King 170B radios is worth more than the same plane with a Dynon or Garmin “experimental” full glass suite installed by my avionics shop? I don’t think so!

      • scott fohrman says:


        I think it would be, simply because of the restrictions the ANV would come with (which are basically the same op limits as experimental AB) – but who knows what the future may bring.
        So nicely equipped aircraft might be worth more.

        It would be kind of interesting if ANVs wound up being worth more. I bet you would see the manufacturers clamoring to get the 20 year rule removed then!

        • Carl Hopkins says:

          What op limits in experimental AB are there? Day or night VFR or IFR at least anywhere in the US.

          I think the manufactures (Piper, Cessna, Cirrus, etc.) are missing the boat if they oppose this. The best thing for them is more pilots. But at $500,000 and up for a new plane we aren’t going to get many new pilots. But take an old plane for under $50,ooo, update it for under $25,000 and there are a lot more people who will buy into that. And eventually they will upgrade to new.

          And the first thing I think most people will do is to install “experimental” avionics which will also likely make those planes safer.

  38. scott fohrman says:


    I think it is fair to say that we feel differently about this and I will not attempt to sway your opinion.

    But, I honestly hope that there comes a time where all of the people you quoted above can alter their aircraft just like they say they want to. People should be able to treat their aircraft like any other privately owned vehicle in terms of MX and changes. GA is dying my friend – if we don’t do something radically different and make this sport more attractive to normal people, GA is going to worthless as a boarhog (Pardon my redneck)

  39. scott fohrman says:


    I certainly was not insinuating anything about you personally, just as I assume that you were not toward me either. We all friends here….

  40. Scott. Fohrman says:

    Sorry Brent, typing on my iPhone and I think getting too old to see the dang thing!

  41. Terry Bowden says:

    Carl brings up an interesting point which touches on my previous comment about sexy/tricky gadgetry. These Garmin/Dynon/JPI/Electronic International/and many other electronic instruments are wonderful. Many have are eligible as primary instruments to totally replace original steam gauges on many airplanes. But they can also be a source of misleading information to the pilot if not implemented correctly in consideration of the airworthiness requirements.

    All of their bells and whistles are there for an intended purpose. Most newer systems have capability to alter limits, cautions, and warnings to fit the specific application. Many times, I have seen circumstantial applications with multiple STCs and other 337 modifications that complicate or blur the lines when trying to assure installation within the airworthiness requirements. When approved under an STC or after careful review by an engineer/ DER, these systems certainly would improve the value of an aircraft. But without assurance by an experienced engineer to the airworthiness requirements, mistakes can creep into an aircraft in such a way as to render it not only less valuable, but as an accident waiting to happen.

    Look at airspeed limits for example. I have seen airplanes with various modifications affecting aerodynamics such as VGs, spoilers, flap modifications, gross weight changes, horsepower changes, propeller changes, just to mention a few. Each may have their own substantiation for higher or lower V-speed limitss. But when different V-speeds are specified for one airplane as a result of to more than one or two combined mods, the issue becomes complicated and warrants thorough examination. This is true, not only for airspeeds, but engine temperature limits, and other parameters important for safe operation. With respect to the aural and visual cautions/warnings of some of these systems, a mechanic would not have to be “shoddy” to be un-qualified to weigh all of the factors necessary to assure a glass panel compliant with the airworthiness requirements.

    The existing FAA process for approval of such equipment is not perfect, but an FAA design approval does give the flying public reasonable assurance that the pertinent factors have been addressed to keep airplanes safe. How much assurance exists with the proposed PNC scenarios?

    • Bill Berson says:

      The passenger must determine his level of comfort the same as any other aircraft that is issued a Special Airworthiness Certificate. The aircraft must be placarded and the pilot is required to tell the passenger that the aircraft no longer is maintained with the assurance of the Type certificate.
      The special operating rules and requirements to protect the public is listed on page 318. It includes 8 items, such as item 8 which addresses phase 1 flight testing for major changes.

    • TedK says:

      Terry – the proposal is not a carte blanche for modifications without oversight. Note that the FAA can require Phase One testing to assure that any combinations of modifications is acceptable.

  42. Kayak Jack says:

    Scotty Fohrman observes, “It would be kind of interesting if ANVs wound up being worth more. I bet you would see the manufacturers clamoring to get the 20 year rule removed then!”

    This would be a really good outcome. It could advance General Aviation, partially remove FAA, and set back attorneys. I may believe in Santa clause again!

  43. Brent Taylor says:

    Scott F.
    As you there, of the 123 individuals making up the ARC that drafted this PNC idea, how many are A&P’s and IA’s ? After all they (A&P’s IA’s) have a large stake in this PNC proposal.
    I know there had to be some, just wondering what the percentage (hence representation) there was from the maintenance community.

    • scott fohrman says:

      I myself am an A&P IA, as was Ric Peri from AEA, but I would have to say not many others were. The vast majority were certification engineers from different OEMs.

      A large percentage were aircraft owners, which helped as they had felt the “pain” of having to buy parts etc for their own aircraft. Many expressed after the final vote that they would love to convert over if the FAA does not rewrite the idea into something unworkable.

      But….I am not sure I accept the premise that A&Ps have a larger stake in this then anyone else in the GA community. Really what the ANV rec boils down to is that if the owner of a standard category aircraft is willing to accept the same operating limits as an Experimental AB, then he/she should also be allowed the same privileges. (i.e. parts, alterations, owner MX etc) It really is about fairness – we don’t limit these privileges to the builder of an EAB, the 2nd, 3rd, 4th etc owners get the same (save for a repairman’s certificate). So, of a 2nd owner of any EAB can get this, why can’t the owner of a standard category aircraft do the same? We think that all owners should have the same opportunity, hence the ANV rec.

      So, I just don’t see how we as A&Ps have any more stake in this than anyone else. There are plenty of us that are happy to work on Experimental airplanes and I am sure the same will be true of ANVs. Plus – it is hard to have a hard stake in something that is inherently optional, there is nothing in the rec that forces or compels anyone to do anything. No one will force a mechanic to work on an ANV, No one can force an IA to sign to convert one back to standard, heck no one can force an owner to designate his aircraft as Non Commercial use. Its all optional, but I suspect that people are intrigued by the prospect. If you like the idea, please post, let the EAA know you want the option.

      • Brent Taylor says:

        ” I am not sure I accept the premise that A&Ps have a larger stake in this then anyone else in the GA community”

        “I just don’t see how we as A&Ps have any more stake in this than anyone else.”

        Wonder if other A&P’s/IA ‘s reading this blog feel the same ?? As for me, those two statements say it all “my friend” !!

        • scott fohrman says:


          In all seriousness, what all does “it” say? Why would A&Ps have a larger say or stake in allowing people to save money and hassle in operating their aircraft? I would think this would be something that everyone in GA should have equal input on.

          I am happy to answer any question you have regarding the ARC or the ANV rec – but I am far from a mind reader, so help me out here.

        • Bill Berson says:

          I am an A&P I.A. And also I am an airplane owner that sees private aviation slowly dying.
          In my opinion, all private airplanes (non-commercial) should be exempt from the requirements for annual inspections by an I.A. The maintenance rules for store bought private airplanes should be exactly the same as EA-B.

  44. John Worsley says:

    The idea that there may be problems associated with buying/selling a PNC airplane has some validity. However, the current rules don’t completely protect buyers from incompetent work. When you buy a used plane, you have no way of knowing what a previous owner may have done to the plane without logging it. So you still have to trust that people will do the right thing.

  45. Mike Brown says:

    I wonder if there isn’t a way to separate the issue of airframe/powerplant modifications from avionics replacements? They’re being discussed here as if they’re all one issue, but I see a major difference between the comments on how neat it would be to update the panel in an old 172 with those warning about the dangers of combining aerodynamic mods or unprofessional maintenance techniques. I would welcome a change giving me the ability to replace a radio myself (as a ham operator of 40+ experience, I think I can handle that), and I wouldn’t be bothered if I couldn’t change an engine (which I couldn’t do myself, anyway).

    It seems to me that replacing a radio with a much less expensive, and much more capable, non-certified version has considerably less impact on safety than changing an engine or adding a STOL kit. If the radio quits, you’re no worse off than if a gold-plated certified radio quit. You’re not going fall out of the sky, and you should have backups (I wouldn’t think of flying without a handheld under the seat, having had my share of failure of certified coms).

  46. Planeguy says:


    Rumor has it that the FAA is not interested and there for not pursuing implementation of the PNC! Say it’s not so? What exactly is the FAA required to produce under there presidential mandate? Will there be a PNC next year?

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