100 hour inspection question

[Ralgha]

A non-profit corporation owns 7 airplanes, which members of the corportation may fly (it's a flying club). The club allows any member who is a CFI to provide instruction in the airplanes to other members with the following rules:

• The CFI must present copies of their certifications, medical, etc. to the board of directors, which are then on file.
  
• The CFI must hold their own CFI insurance.
  
• The CFI must submit an application to the board, and then be interviewed by the board.
  
• The CFI must submit to two check flights with board members.
  
• After all this, the CFI is approved to provide instruction in the airplanes for a period of one year, after which the CFI must be re-approved by the board.

Now the question. Would/could this be interpreted as a situation where a 100-hour inspection is required? The CFI is not employed by the corp., but it still seems a little gray to me because of the approval process.

 

[deadstick]

No.

I say this because the the member-CFI can "provide instruction in the airplanes to other members." This is giving the owner of the plane (although 1 of many) dual.

Now, with that said, the member-CFI CANNOT give dual to a non-member because then the CFI is providing both the service and the aircraft.

 

[avbug]

Is there a reason why you would not want to be doing 100 hour inspections?

Don't say cost...that would be a stupid answer.

I won't begin to list the number of things I've found on 100 hour and progressive inspections that will kill you.

Waiting for the annual, if you're going to be flying the airplane for any number of hours of consequence, is stupid.

Do the 100 hour inspections, be happy, stay alive.

It will cost you far less in the long run.

 

[vclean]

Sounds similiar to a FBO type operation. A FBO cannot provide flight instruction in an aircraft out of 100hr, but may rent it. Since this is a corporation (non-profit or not) and the CFI is a member (employee?), receiving compensation for his/her services, then a 100hr is required.

BTW, it seems like an overly complicated process to instruct there. Two checkrides? Board approval? Hopefully you get a rental discount for the trouble.

 

[pilotman2105]

I currently serve on the board of our flying club of ~250 members. We have been addressing the same issue. Technically a 100-hour would not be required since both people in the aircraft are members. In essence, whoever is receiving the dual is providing the aircraft because they technically own it (or part of it).

However, avbug brings up a valid point. We do 100-hour inspections on our aircraft simply because they fly enough where a 100-hour increases safety. Our club has in-house maintenance, and the 100-hour inspectoins at times prove to be slightly more expensive and more of a burden on our maintenance. However, this is much better than the alternative of loosing an aircraft.

Ralgha, thank you for in the insight on the CFI issue however. We currently do not let our CFI members give dual for insurance reasons. Perhaps we may use some of those methods you have used in your club to make that a reality.

Thanks!

 

[Ralgha]

First to address Avbug's concerns:

We do both 100 and 50 hour inspections on the airplanes, however they are not "official" 100 hour inspections. They are not signed off as per the FARs, but they cover the same material (please don't ask my why, I'm not the one in charge of maintenance). Currently, the airplanes are allowed to overfly the 100 hour limit (by more than the 10% rule), though it's discouraged it does happen occasionally, but if the 100 hour inspections would be required then this would need to stop, obviously.

Moving on to comments about owners, it is called a club, however each member is not part owner of the airplanes. The club is incorporated (non-profit), and the corporation owns the airplanes. It is not written anywhere in our resolutions, etc., that members have any ownership of corporate property. If the corporation is dissolved, members get none of the remaining assets. Members do not hold shares, or anything like it. So, while both the student and CFI are members, neither is an owner.

These rules to allow members to instruct in our airplanes was just recently passed by our board, previously all instruction was contracted with an FBO (and still is). No members have yet begun to instruct, so we haven't violated anything yet even if it does turn out to require the inspections in this case.

Finally, to address the comment about overly complicated process:
Find me another place that can match our rates (wet, with very good condition airplanes). This is why we have high requirements, it keeps insurance costs down and safety up.

C152: $35/hr
C172: $52/hr
C172RG: $64/hr

 

[avbug]

They are not signed off as per the FARs, but they cover the same material

If inspections are being performed on those aircraft and appropriate logbook endorsements are not being made, then your aircraft are legally unairworthy; the airworthiness certificate has been invalidated in accordance with line 6 of that certificate.

A 100 hour inspection is identical to an annual inspection in detail and scope.

If a 100 hour inspection is being performed, then it should, and MUST, be logged. There is no reason to not log it as such if it's being performed.

Changing the oil and checking the plugs is not a 100 hour inspection. Again, a 100 hour inspection is identical to an annual inspection.

I see no way in your description of this operation that one could justify providing instruction without requiring a 100 hour inspection.

Further, I believe you'll find that your insurance carrier will want to see the same.

 

[Ralgha]

The inspections are logged correctly for what they are. They are not logged as the 100-hour that is required by the FARs, they are logged however other maintenance is. The IA who works on the airplanes is extremely concious of getting the paperwork correct. I'm not worried that what is being done is being logged incorrectly, I'm worried that the current situation might require the official 100-hour inspection.