Most people reading the story of a hapless American with his Cub in Europe expect the conclusion to be one of challenging customs and procedures coupled with the majesty of European beauty. After all, that makes us Americans feel good about flying in the USA, and it also makes those of us who spend inordinate sums to vacation in Venice and Paris feel good about it, too. Even locals in Europe might like idea, being that it’s a gentle and public nudge for regulators to chill out, and a blessing upon the crowded soil for which most Europeans deal with. When it comes to maintenance in Germany, I sadly cannot ingratiate the masses with the aforementioned satisfaction.
Most would classify Germany as a world leader in mechanical activities, bred from the stereotypical German engineer. While I can completely attest to the soundness of German manufacturing, the same opinion cannot be shared when it comes to maintaining American aircraft originally assembled in the 1940s.
Engineers thrive on tolerances. If something cannot assuredly be confirmed as being to a particular tolerance, then the answer is to overhaul or replace it, not necessarily to do more research, or practice the complex art of troubleshooting. The pinnacle of this kind of thinking is the fact that German-registered aircraft must have piston engines overhauled at TBO. It is not a recommendation; it is a requirement. Furthermore, the disease of premature overhaul that is prevalent in America (using basic mechanical faults as excuses to needlessly major an engine) is much more common in Germany, such that I am told that many more are overhauled before TBO.
A logical question becomes, “who does the overhaul in Germany?” Unlike the USA, any old A&P cannot sign off on a major overhaul for a German aircraft. Even though major repairs to an engine are permitted, technically so that the case can be split, an A&P cannot sign off the work as a major overhaul, even if all of the associated work of an overhaul was done. The engine would still need to be overhauled at the appointed TBO. This is done by a certified aircraft piston engine overhaul shop, for which I am told via hangar talk that there are only two options left in Germany. To make matters worse, the German government reportedly clamped down on a situation where a certified shop had subcontracted work, invalidating many customers’ overhauls as being illegal. To add insult to injury, that not only disemboweled the repair station, it also resulted in violations for hapless owners of said “overhauled” engines.
Overhauls are no laughing matter, and like most regulations in Germany that are restrictive by American standards, Germans like to immediately point out the benefits of such regulatory overreach. I personally think it is a coping mechanism out of a fatalistic belief that there is no hope of ever relaxing such harsh requirements. Sure, engines overhauled in Germany going to be of better craftsmanship than a typical field overhaul in rural backwoods America by a small shop. However, of what benefit is it to spend 300% more to achieve 15% quality increase, or to have the aircraft out of service for months while on a waiting list, or worse, to push the limits of safety out of fear of impending unaffordable costs? It is one thing to debate cost versus quality, there is another of who can or will do the work if options are nearly nonexistent.
I walked in a repair station in Germany inquiring about an avionics check. The person at the front desk asked what make and model of aircraft, for which I replied “Piper PA-11.” After a few phone calls to the back, I was told “Sorry, we cannot work on that aircraft. We’re not certified for it.” “Excuse me? What do you mean certified? You don’t have any A&Ps working today?” “No, we have a mechanic certified for the PA-11, we just don’t hold the certification as a repair station.” “What? You have to have make and model for both the mechanic and repair station? This has nothing to do with the PA-11. I want you to check a piece of avionics, not repair, just check it.” “Sorry, we can’t work on it.”
I eventually reached out to a fellow American to receive my biennial flight review, for which I really felt I could get some instruction this time, as he would know my perspective, and what things to look out for in German airspace. Because we would technically be a bit overweight in my airplane, which is an enormous deal here, I rented an N-registered Cessna 172 (costing hundreds more). Ironically, this poor CFI had to get a European CFI designation to satisfy German law. A US CFI cannot practice with American pilots in Germany without an equivalent European CFI license. After he got that, he was told he needed to join an “Approved Training Organization” to render his services, as opposed to freelance instruction as we are accustomed to in the USA.
Having digressed, on the BFR, we landed in Worms, Germany so the CFI could introduce me to a repair station that he felt would be a good resource in case I needed it. I stood by attempting to understand the ensuing conversation with my limited German, and came away with the impression that it didn’t go well. “So, I guess he doesn’t have the certification for a PA-11?” “No, that’s not the problem. He just doesn’t want to work on your airplane.”
So what is the owner of an N-registered airplane in Germany to do? For the Germans that own N-registered planes (yes, there are some, mostly due to the non-existence of German type certificates for the model), there are a smattering of FAA-certified A&Ps with inspection authorization here in Germany, with the caveat that they are Germans as well. This works well to satisfy US law, except the problem is, they are still German.
Its not news that Germans are precise and exacting. Various Americans that have attempted aviation in Europe have emailed me their stories in the last few months, as have I interacted with regular Germans flying German aircraft, both of which are depressing and frustrating stories that end with total resignation, empty wallets, and few hours flown. It is culturally normal here during an inspection to expect to find a long list of things to replace, whether common sense or practicality requires it or not. Whether making the decision under US or European regulation, the personality of the inspector shines through, and I have come to understand that an inspector determines his or her prowess based on how many things can be deemed deficient. A fellow Cub owner had to replace a slew of gaskets on his engine, including the oil kidney gasket, which is not a minor undertaking, effectively for prevention. I howled at how silly it was, and the owner of the airplane was glad that he got off with “so few things” to have to do. For a nation that has mastered emotional compartmentalization and mathematical rigidity, I found it hard to believe that this aircraft owner’s prefrontal cortex was functioning as he defended preventative gasket replacement.
I am an avid reader of the school of thought that the psychology of 100 hour and annual inspections is not rooted in science or comprehensive mechanical analysis. 100 hours is a nice base 10 round number, and one year is a common fixation in our minds. One pilot flies 400 hours in a year, and another 10, and an annual inspection somehow suits both? Or, in talking with an FBO owner in the USA who operates and overhauls his own flight school aircraft, I learned that engines majored at TBO that are flown daily show minimal wear, compared to rarely used aircraft that corrode at significantly faster rates. How could the same TBO work equally for both environments? Before coming to Europe, I thought that the state of maintenance in the United States needed a serious overhaul for GA aircraft, a product of needless regulatory overreach and a disconnect from sensible decision making based on actual mechanical information. I had simply no idea that things could get so astronomically worse so that I would gladly buy a box of chocolates and bouquet of flowers for the next FAA employee that I meet.
It would be disingenuous to fail to consider the positive side of maintenance in Germany. I had one occasion where the German approach smashed that of the United States. For small Continental engines in the USA, exhaust repair issues seem to be the domain of finding “some guy” to weld the muffler that an A&P is satisfied to supervise, or sending it in for overhaul to a shop in another state. When phoning just about any American overhaul shop, there is nothing but a wide range of when they will get around to it, and a huge price sticker, with little other than “send it in and we’ll see what happens.” Small repairs or total overhauls are all treated as overhauls, and I grimace at unnecessary work. New pipes welded on are a risk of misalignment; I’d rather have the problem specifically fixed, without creating new ones. Well, here in Germany, I phoned a welder with more certifications than a simple-minded American could count, and he quoted a precise cost, requiring a precise amount of time, and he would arrive at 10AM on a coming day, for which he pulled up within 60 seconds of the allotted time and the work was done with precision, near perfection, and no problems.
My positive experience is telling as to what Germans are striving for: a system operated so perfectly that faults and problems disappear. That is evident driving on the autobahn, as I routinely exceed 120mph in my finely crafted German automobile, and the numbers support my emotional experience: German cars and roads are safer than anywhere else in the world.
The same cannot be said of aviation. When requirements are so excessive and burdensome that they make access to aviation resources difficult, when regulation becomes a game of “gotcha” instead of serving public safety, and when rules are so complex violation is inevitable, it serves two outcomes: reducing general aviation activity, and encouraging a fatalistic approach for those that remain. Both of those backfire on public safety, as the death spiral of reduced aviation activity increases costs and kills innovation. It is obvious that fatalistic views in light of burdensome regulation isn’t helping anyone.