I vs. We

Questions and answers regarding owner-produced parts


Along with the pilot shortage and mechanic shortage, there is also a parts shortage that plagues the general aviation industry. Because supply and demand are out of balance, the cost of new and used parts seem to increase every day.

Older fleets
First, we have an old fleet. The average general aviation single-engine airplane is approximately 32 years old. The average age of GA multi-engine reciprocating aircraft is close to 27 years old. The average age for the turbine-powered, multi-engine propeller-driven aircraft average around 19 years of age. So, due to long-term wear and tear, the demand for replacement parts and large sub-assemblies is much greater today than it was even 10 years ago.

Better maintenance
The second reason is our General Aviation fleet has been well-maintained over the years. So well in fact, the average GA aircraft with a mid-time engine and decent avionics has appreciated to two or three times its original purchase price and is still climbing. Yet even in that land of many zeros, the older aircraft are still substantially lower in price than the cost of brand-new aircraft with similar performance numbers and equipment. Still, the value of older aircraft in good shape are proven investments that over time have beaten the Dow Jones average. As a result, we have an economic imperative on the part of the owners to keep older aircraft in flying condition — which increases the demand for replacement parts.

Increased production costs
Today, aircraft manufacturers are not producing makes and models of aircraft in the same quantity they made back in the 1970’s. Hence, the production runs for parts are not as frequent and not as many parts are produced. In addition, it is not cost-effective for a manufacturer to make a lot of parts even if the unit price for each part is out of this world as taxes on maintaining a large inventory of parts would eat all of the profits. This low parts production keeps the supply of replacement parts low.
Also, some aircraft manufacturers would prefer that their older makes and models made a million years ago would quietly disappear from the aircraft registry. This retroactive birth control on the part of the manufacturers may not seem to make any sense until you look at aircraft market dynamics of creating demand and reducing costs. First, each older aircraft that is no longer in service creates a demand for a new, more expensive aircraft to take its place. Second, despite some tort claim relief granted to GA manufacturers in the early 1990’s, the fewer older aircraft there are in service, the manufacturers of those aircraft enjoy reduced overall liability claims and decreasing continuing airworthiness responsibilities.
So how are we going to maintain these older aircraft with an ever dwindling parts supply when Part 21, Section 21.303 Replacement and Modification of Parts requires us to use the Parts Manufactured Approval (PMA) parts on a type certificated product? Well, the same rule grants four exemptions to the PMA requirement. You can use:
1. Parts produced under a type or production certificate such as a Piper, Cessna, or Mooney produced part.
2. An owner- or operator-produced part to maintain or alter their own product.
3. Parts produced under a Technical Standard Order (TSO).
4. A standard aviation part such as fasteners, washers, or safety wire.

General privileges and limitations
Before I segue into the subject of "owner-produced parts" as called out in Section 21.303, which is the purpose of this article, I would like to create a small uproar with this statement:
"FAA Airframe and Powerplant rated mechanics can maintain, repair, and modify parts, but they cannot make a brand-new part and call it a repair."
Before you accuse me of losing neurons by the minute, check out Section 65.81 General Privileges and Limitations. The section talks to maintenance, preventive maintenance, and alterations; but not to manufacturing of parts. Nor is it implied privilege in Part 65, because Part 21, Section 21.303 says "NO PERSON" may make a REPLACEMENT part for a TC product unless that person has a PMA, etc."

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