For years various people have said "Dwight, you should get your A&P", and while I agreed (in theory) I had no idea how to pursue it given my background. You see, the experimental work doesn’t .. technically .. count toward A&P experience because the FAA can’t assume that the work was done to aircraft standards, and there was no experienced certificated individual overseeing and approving the work.

However, a particular friend (Ryan) kept pushing and nagging and we finally called the local Greensboro FSDO to get their reaction. It was immediate outright rejection, thus confirming the view that it was an impossible task.

Bear in mind, absolutely everyone I talked with said that this was an impossible lift. That given the current rules laid down by the FAA there was no way for me to leverage my experimental experience and get an A&P certificate. I must have been told this by a half-dozen different experienced people, including experienced A&P/IAs. I actually assumed they were right, however, at this point I was in a stubborn frame of mind. Knowing that every FSDO is different I thought that I’d try one more.

Orlando FSDO

Every FSDO is different, each with their own area of oversight and often their individualized approach to interpretation and administration of the rules. As with any complex set of rules, there are "edge cases" and often complex interactions between the rules that require careful consideration and interpretation. Because of this, what one FSDO would consider unreasonable or impossible another FSDO might view as acceptable. This is why after being dissed by the Greensboro FSDO I thought it was worth a call to another FSDO, and fairly randomly picked Orlando.

Cheryl King

I called the Orlando FSDO and got routed to Cheryl King, a FAA Maintenance inspector. She was more open to working with me. That was on June 10, 2020, and was when this whole saga actually begin.

During that initial call I outlined my situation, my years of building the RV-7, the work done on the Citabria with the oversight of Tom Malechuk, the multiple years of assisting on the annual of the RV, the work helping restore the Citabria which was another effort overseen by Malechuk, and many other activities which allowed me to build experience. Cheryl agreed that it wasn’t the most common path to an A&P, but it wasn’t out of the question.

She directed me to write up all my wrench-turning experience, including what was done, what tools/techniques were used, and to submit that to her for review. She continually stressed that the goal was to document 30 months of work. The challenge for me is that my work was not done as a full-time activity, and was spread over literally about 18 years at that point in time. She suggested that I get the various A&Ps I’d worked with to confirm the work, but in some cases the people with whom I worked were simply unavailable to me any longer.

Documenting Experience

I did get multiple A&Ps I know to write letters recommending that I be signed off to get the A&P, and I believe that helped. But in the long run the FAA required specific experience be documented (30 months!) and that was the bar I had to get over.

I wrote up my experience, and even with each item noted fairly briefly it came to 10 pages. I submitted that as well as the letters of recommendation, and waited to hear back from Cheryl. As you might imagine, she is extremely busy and it took some time for my submission to make it to the top of her work queue. The response was that what I submitted was good, but she needed more.

There was ambiguity in my mind about what was needed …​. exactly. So it took a good bit of back-and-forth emailing to come around to the point where I could give her what she needed to justify signing off an 8610 for me. In fact, more than once I concluded that I had hit a wall, and coming up with enough to justify the sign-off was simply impossible.

Whenever I hit that point, and I did so multiple times, Cheryl would write back something like "We are not going to give up on this.", and encouraged me to try again. While I kept feeling like I had hit an insurmountable roadblock more than once, she continued to push to get what she needed to give me the opportunity to earn my A&P certificate.

I’m going to pause here to point out that she is an FAA employee. She is one of "the FEDs". Those people who we always assume are out to nail us for some small transgression, and who the the natural enemy of the average pilot. She went far above what she was required to do, and made an effort way beyond what would be expected. I was absolutely floored by how much she cared, and how much she wanted to make this work out …​ though she had to do so within the rules. Amazing.

The final push came when she suggested I sit down with one of the A&Ps with whom I had worked and detail everything we had done together. Ryan Evans and I did that and the resulting document came to about 6 pages. It was exactly what Cheryl needed, with one small editorial request made by her. She wanted us to add an introductory statement which would indicate the time frame over which this work had been performed, and it should total 30 months.

Endgame

But …​ you knew there had to be a "but" here, right? But at that time I had only known Ryan for 24 months. I refused to lie, and told her the truth about that. We did add the statement, but it was 6 months shy of 30. I suggested that there were two options.

Option one was that she take the 24 months with Ryan, and making assumptions about the veracity of the previous 18 years of off-and-on work, elect to credit me with a minimum of 30 months. Option two was for me to simply continue to do work with Ryan for another 6 months, then re-apply then. I was clear that I was happy to go with either option, that I was in no hurry, and that it was entirely up to her.

Her response was "Then we will go with it". I needed to re-submit an updated 8610 form, had to shoehorn a lot of experience into the tiny boxes on the 8610 form, had to send a picture of my driver’s license, and ultimately had to have a FaceTime meeting with Cheryl. I swear, when she came on the video she had a bigger grin on her face than I did. I received my signed 8610 form on Feb 3, 2021. The next step was to head off to Baker’s to actually get the three written exams, the oral exam, and the practical exam out of the way. But that is another story.

When this was all done I did call Cheryl’s managers. Both her direct supervisor and the overall manager of the FSDO. I know people mostly call when things go wrong, but I wanted to call because something went right. They loved hearing that Cheryl had gone above-and-beyond, and commented that my feedback was coming at a particularly good time …​. yearly review time! Awesome.