I think most owners are aware of the items in Appendix "A" of FAR43, however most are probably not aware of the FAA letter FAA Interpretation from the Chief Counsel's office, the interesting paragraph (page 2 second paragraph, in its entirety)

Many preventive maintenance tasks are listed in 14 C.F.R. part 43, appendix A, paragraph(c). The paragraph sets forth in 32 numbered sub paragraphs items the FAA has determined to be preventive maintenance. Even though the introductory text of sub paragraph(c) states that "[p]reventive maintenance is limited to the following work...." (emphasis added), in view of the broader definition of preventive maintenance in section 1.1, we believe that such limitation 'is not controlling. Similarly, for the same reason, we also believe that the following sentence in Advisory Circular 43-12A, Preventive Maintenance (which was referenced in Mr. Hernandez's letter), is overly restrictive. That sentence, found in Paragraph 3(b)(1), states: "If a task or maintenance function does not appear in the list, it is not preventive maintenance." As with the other paragraphs of Appendix A (i.e., on major repairs and major alterations), the lists are better viewed as examples of the tasks in each category - they cannot be considered all - inclusive. There are, no doubt, many "simple or minor preservation operations [tasks]" and many "replacement[s] of small standard parts not involving complex assembly operations "performed daily, especially on small general aviation aircraft, that the agency would consider to be preventive maintenance, though they are not included in the 32 listed items. It is our understanding that Flight Standards 'Aircraft Maintenance Division is planning to clarify this issue in a future revision to the AC.

{bold/underline emphasis is mine} Reading appendix A item 1 the FAA says that I can perform "Removal, installation, and repair of landing gear tires"  and Item 4 "Service landing gear wheel bearings, such as cleaning and greasing." I don't know how many people here have replaced their main landing gear tires or removed the bearings (inner and outer) for cleaning and regreasing however on my airplane in order to accomplish this task I must disassemble the brake caliper to release the wheel from the aircraft, and in my case the brake pads aren't riveted to the backing plates, they are connected via "button" and simply snap into place, plus to seperate the wheel halves I have to remove the brake disc/rotor as it is held in place with the same bolts that hold the wheel halves together. So based upon the interpretation in the FAA's letter I believe I am comfortably within the guidelines of replacing the brake pads and the brake disc when replacing a landing gear tires. Since the FAA has already said I can do the tires and every GA aircraft with disc brakes would have to be disassembled I would thing the FAA would have consider this to be an owner performable maintenance item. Oh and completing the job I have to safety wire the bolts on the caliper which is item 5 on the list "Replacing defective safety wiring or cotter keys" Am I off the mark on this one?  I don't think so, I already working with the sub assembly that the FAA has already deemed to be a maintenance item, I'm just adding the stuff I have to remove to get to the maintenance item.

Let us assume I have the knowledge to do the work I'm looking to perform competently, eg taught, shown, performed the work previously under the supervision of an A&P etc...  So am I reading the FAA interpretation of the rules correctly in that replacing the brake pads would fall under owner allowed maintenance?  I would think so. Removing the brake caliper completely would be a no no as hydraulic lines are expressly forbidden and the brakes are hydraulically operated.  I'm sure you can make an argument that the FAA was referring to high pressure hydraulic lines, eg those operating gear retraction pistons, but I can see opening the the hydraulic line would introduce air that would have to be bled out, and although I'm capable of doing it, I would think this would not fall under the maintenance guidelines.

Let us assume I have the knowledge to do the work I'm looking to perform competently, eg taught, shown, performed the work previously under the supervision of an A&P etc...  So am I reading the FAA interpretation of the rules correctly in that replacing the brake pads would fall under owner allowed maintenance?  I would think so. Removing the brake caliper completely would be a no no as hydraulic lines are expressly forbidden and the brakes are hydraulically operated.  I'm sure you can make an argument that the FAA was referring to high pressure hydraulic lines, eg those operating gear retraction pistons, but I can see opening the the hydraulic line would introduce air that would have to be bled out, and although I'm capable of doing it, I would think this would not fall under the maintenance guidelines.

Except on my Grumman Tiger, you can change the brake pads without disconnecting the brake lines.  This is why the FAA took the view that something which is legal preventive maintenance on one plane might not be on another.  One has to examine the entire process to make the determination.

Except on my Grumman Tiger, you can change the brake pads without disconnecting the brake lines.  This is why the FAA took the view that something which is legal preventive maintenance on one plane might not be on another.  One has to examine the entire process to make the determination.

didn't say I had to disconnect the calipers (although I have under the A&P's supervision to rebuild them), I just said that removing it would be a no no without proper "supervision" Other than trying to be dissuaded, I think the example I provided certainly falls under the guidelines of owner preventative maintenance.

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