Who gets the Repairmen's certificate

Discussion in 'Maintenance Bay' started by Tom-D, Dec 26, 2017.

  1. Tom-D

    Tom-D Taxi to Parking

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    We have a guy who has bought three different wrecks from salvage yards all were at one time complete flying aircraft.
    but have been deregistered and the N numbers reassigned
    he takes parts from all three and assembles an aircraft, does the new registrations per regs.
    he has built none of the assembles done none of the fabrication.

    can he legally apply for the repairman's certificate?
     
  2. NordicDave

    NordicDave Pre-takeoff checklist

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    Are these experimental airframes like Van's RV's or certified aircraft?

    If experimental... The FAA does not stipulate where the parts were bought for experimental, just that the builder assembles 51% of the plane themselves.

    If certified airframes... A person could put 3 wrecks into one good plane under supervision of an IA with amount of hours involved signed by the IA, could be applied to the minimum time required to obtain and Airframe Certification; following passing of the FAA exam. Airframe license as in the "A" in the A&P certification.
     
  3. Dana

    Dana Pre-takeoff checklist

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    He can't even apply for an airworthiness certificate, let alone the repairman. Throwing together already built parts of other aircraft is not sufficient to be seen as the 51% required for an E-AB certificate.
     
  4. Checkout_my_Six

    Checkout_my_Six Final Approach

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    no.....nada....nuth'n....he gets.

    unless he can buffalo a newbe PMI.
     
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  5. Capt. Geoffrey Thorpe

    Capt. Geoffrey Thorpe Final Approach

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    Well, if they were parts from certificated aircraft yuppie duppie:

    https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_20-27G.pdf

    "Use of Salvaged Assemblies from Type-Certificated Aircraft.
    The use of
    used or salvaged assemblies
    (for example, landing gear, horizontal stabilizer, and
    engine mount) from type-certificated aircra
    ft is permitted, as long as they are in a
    condition for safe operation. However—
    (1)
    You should contact your local FAA
    MIDO or FSDO prior to using a
    major assembly or subassembly, such as wings, fuselage, or tail assembly from a
    type-certificated aircraft. As an amateur
    builder, you should be awar
    e that when building
    your aircraft, the excessive use of majo
    r assemblies or subassemblies from type-
    certificated aircraft would most likely
    render it ineligible for certification under
    § 21.191(g).
    (2)
    You will not receive credit for work d
    one on, or the use of, salvaged major
    assemblies or subassemblies when determining whether your amateur-built aircraft has
    met the major portion requirement. This woul
    d include any “rebuilding” or “alteration”
    activities to return these compone
    nts to an airworthy condition.
    (3)
    All fabrication, installation, and assembly tasks on the Amateur-Built
    Aircraft Fabrication and
    Assembly Checklist (2009)
    that you’ve completed by the use of
    used or salvaged assemblies can only be annotated in the “Mfr Kit/Part/Component”
    column."

    Ifen someone bought parts from previously certificated as having been built by amateurs aircraft - it is perhaps a little grey?

    "Buying an Aircraft Built From
    a Partially Completed Aircraft Kit.
    If
    you buy an aircraft built from a partially comp
    leted kit, you should get all fabrication and
    assembly records, such as receipts for mate
    rials, the builder’s log, and aircraft, engine,
    propeller logbooks, and any other documentati
    on available (see paragraph 7h) from the
    previous owner. You should add the construction efforts of the previous amateur builders
    to your builder’s log to show the construction
    history of the kit. This information will
    help us to determine whether your complete
    d aircraft is eligib
    le for amateur-built
    certification"

    and
    "If you buy a
    partially built aircraft built from a plan,
    you should get all fabrication and assembly
    records, such as receipts for materials,
    the builder’s log, and
    aircraft, engine, and
    propeller logbooks, from the previous owner.
    You should add the construction efforts of
    the previous amateur builders to
    your builder’s log to show th
    e construction history of the
    aircraft. This information may help us to
    determine that your aircraft is eligible for
    amateur-built certification (see to para
    graph 8b(5) for more information)."


    The work can be done by "other amateurs" as long as the work was actually done by amateurs and not just "supervised" by an amateur. And, you would have to list all of the previous "amateurs" on the application for the airworthiness certificate.

    "You may receive
    commercial educational assistance in the fabric
    ation or assembly of specific parts and the
    completion of certain tasks or processes invo
    lved in the construction of your aircraft.
    The FAA may credit commercial educational assistance provided for educational
    purposes toward the major portion determina
    tion. However, commercial educational
    assistance cannot exceed a demonstration on
    how to perform the task. You, as the
    amateur builder, must still perfor
    m the task to receive credit."

    For the repairman's certificate the question would, I think depend on of you got a new data plate and airworthiness certificate that is unique and not from one of the donor aircraft.
    "The prim
    ary builder of your aircraft,
    even as the second builder, and can
    satisfactorily prove to us that you can determin
    e whether the aircraft
    is in a condition for
    safe operation.
    b.
    One of the builders of an amateur-built ai
    rcraft registered in a corporation’s
    name. The applicant should prove through us
    e of the builder’s log that they can
    determine whether the aircraft is
    in a condition for safe operation."
     
    Last edited: Dec 27, 2017
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  6. Tom-D

    Tom-D Taxi to Parking

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    All three aircraft were E/AB. of the same make and model.
     
  7. Tom-D

    Tom-D Taxi to Parking

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    As long as all parts were amateur built. Why isn't he good for E/AB certificate?
     
  8. Checkout_my_Six

    Checkout_my_Six Final Approach

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    to quote a famous doofus....."Let me be clear....he didn't build dat...."
     
  9. NordicDave

    NordicDave Pre-takeoff checklist

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    To be more clear... I wasn't implying putting 3 wrecks together gets you and Airframe License.

    The education requirement is 18 months on the job training with proper approvals or a year of formal education at an accredited school, which takes about a year; plus FAA exams. Double this for a full A&P certificate.

    Working on planes with the right FAA approved supervision, goes towards accomplishing the minimal time requirement.
     
  10. Tom-D

    Tom-D Taxi to Parking

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    How does this have any bearing on this subject, when all parts were E/AB and thus the aircraft built would be E/AB?
     
  11. NordicDave

    NordicDave Pre-takeoff checklist

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    Caps. Thorpe, The question was not "can I put 3 wrecks together and make a 'flight of the Phoenix' FAA approved aircraft"

    The question was can a person earn a repairmen certification by putting 3 planes together? The answer is yes, under the right supervision and fulfillment of the minimal training/time requirement. The plane DOES NOT NEED TO FLY or be airworthy, just reassembled to standards.

    The A&P school on my field takes apart and rebuilds 6 planes on their ramp every year. These planes are non-airworthy donations just for this purpose.
     
  12. Tom-D

    Tom-D Taxi to Parking

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    The aircraft must be 51% amateur built. it is not required to be built by one person.
     
  13. Tom-D

    Tom-D Taxi to Parking

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    To be clear, there is only 1 aircraft built from three others
     
  14. NordicDave

    NordicDave Pre-takeoff checklist

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    Tom, your assuming the OP was talking about Experimental; he does not state. My first reply was two parts, experimental or Certified. This thread has followed the certified option.
     
  15. Tom-D

    Tom-D Taxi to Parking

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    When dealing with certified aircraft, you can build an aircraft from junk parts, it is done every day. but you must have a data tag to register the aircraft, and the work must be accomplished by an A&P or under the supervision of one.
    In the First post I asked about a Repairman's certificate, making it a E/AB question. we don't have Repairman's certificates on Certified aircraft.
     
  16. Ravioli

    Ravioli En-Route

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    @NordicDave -- Tom IS the Original Poster. Sheesh. We can't argue with him about EVERYTHING can we?

    The N# vs Serial number discussion hasn't come up. Is the serial number of the finished plane fresh, or one of the previous three planes? That would have a lot to with the availability of a Repairman's certificate for it.

    My guess (newbie EX guy, purchased 3 years ago) is that the plane can be registered but the repairman's certificate would not likely be issued.
     
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  17. Tom-D

    Tom-D Taxi to Parking

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    That's for certain, you do not get an A&P certificate by building one aircraft.
     
  18. Tom-D

    Tom-D Taxi to Parking

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  19. Ravioli

    Ravioli En-Route

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    I don't believe Vans would issue a new serial number. So more murky stuff. But I also can't guess which of three they would keep it under.

    Having acquired one, and done their paperwork to be associated with the S/N on the plane when I had already purchased it gives me some insight into their process.

    Doubtful the repairman's certificate is in this guys future. But, heck, that just means an A&P does a Condition Inspection once a year. Mine have all cost <$1,000.00. (E-AB do not require IA) That, I think, is a good thing.

    Eyes on your maintenance work is as valuable as eyes on your pilot skills.
     
  20. Tom-D

    Tom-D Taxi to Parking

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    Let's assume that this aircraft in question is not a Van's.
    Let's say that it is a simple plans built rag and tube type.
    What would be the largest stumbling block in getting a repairman's certificate.
    These type of home builds have a generic looking data tag, bought at AS&S.
    I'm thinking in this case, with a new data tag, (with new data on it) he is home free with the R/C
    All parts are amateur built, he's good with the E/AB certificate.
    There is nothing I know of saying he has to build any of the parts.
    and he has been involved enough to say he built it.
     
  21. Dana

    Dana Pre-takeoff checklist

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    You didn't say that in your original post.
     
  22. wanttaja

    wanttaja Pattern Altitude

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    "Can" he receive a repairman certificate? Of course....if he encounters a compliant DAR.

    By AC 20-27G, he should't.

    “A determination of major portion will be made by evaluating the amount of work accomplished by the amateur builder(s) against the total amount of work necessary to complete the aircraft, excluding standard procured items.

    "Note: The major portion of the aircraft is defined as more than 50 percent of the fabrication and assembly tasks, commonly referred to as the “51-percent rule.” For example, an amateur-built kit found on the FAA List of Amateur-Built Aircraft Kits has 40 percent of the fabrication/assembly completed by the kit manufacturer. In order to be eligible for an experimental amateur-built airworthiness certificate and per the major portion rule, the fabrication and assembly tasks that may be contracted out (for hire) to another individual (or builder/commercial assistance center) needs to be less than 10 percent.”

    By your description, the owner hasn't done any of the fabrication tasks....hence, he doesn't meet the AC20-27 definition.

    Ron Wanttaja
     
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  23. wanttaja

    wanttaja Pattern Altitude

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    I'm actually looking at this right now. I can build a new Fly Baby (without an electrical system) cheaper than installing ADS-B in my current one, if I re-use things like the engine, wheels, welded bits, etc. Given my druthers, I'd just build a brand-new fuselage (of modified design) and install the current wings, tail, landing gear, and FWF. I'd be stripping off the fabric and performing some modifications to the re-used parts.

    The argument is, because I would build a fuselage from scratch, this would demonstrate my ability to fabricate major wood structural items and hence be capable of performing repairs on said structure.

    The repairman certificate is based on faith, in any case. It permits the holder to sign off the Conditional Inspection even on engines, which the possessor may not have done much more than hang the engine on the mount.

    Ron Wanttaja
     
  24. Direct C51

    Direct C51 Pre-takeoff checklist

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    First, let's clarify, Tom is talking about a "Repairman Experimental Aircraft Builder" certificate, not an A&P certificate based on hours worked rebuilding the airplane.

    Ron, I think you are just confused by his question, because I know that you know the regulations. Tom is talking about taking pieces from 3 E/AB airplanes, lets say fuselage of one, tail of another, and wings from a third, and bolting them all together. This will qualify as E/AB if those 3 components were built by amateur builders with the appropriate documentation. The owner doesn't have to do the fabrication tasks, as long as they were done by other amateurs. The 51% rule only has to do with qualifying for E/AB and has nothing to so with a repairman's certificate.
     
  25. Stewartb

    Stewartb En-Route

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    The experimental airworthiness inspection is the only time a DAR will set eyes on the project and at that point the airplane is finished. He has no way of knowing what "assemblies" you used or in most cases, where you got them.
     
  26. MauleSkinner

    MauleSkinner En-Route

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    I'm not sure you intended those two phrases to be connected, but does documentation exist to that effect?
     
  27. Bell206

    Bell206 Pre-takeoff checklist

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    The short answer, yes he can... provided he is the one listed on the airworthiness certificate application for that completed aircraft. Will he get it? That depends on who will be signing him off and how he responds during his interview. As stated above the key term is "primary builder." And that includes building from a kit, from salvage, or from whatever. I've seen it go every which way who gets a ticket and who doesn't.
     
  28. Tom-D

    Tom-D Taxi to Parking

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    What kind of documentation would you get when buying junked or salvaged aircraft parts.
     
  29. Tom-D

    Tom-D Taxi to Parking

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    EXACTLY !
    So, how then can the R/C be refused?
     
  30. Tom-D

    Tom-D Taxi to Parking

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    As I understand the rules you have two choices on how to do the paper work.
    1 keep the old data tag, and paper work, and call it a repair, this way you save the inspections involved with getting the new AWC. and the fly off time.
    2 use a new data tag make it as if you built the whole thing, do the inspections to obtain the new AWC, then fly off the time as a new build would be required to do.

    When it looks like a new aircraft and the paper work says you built it, the R/C would be most automatic.
     
  31. Tom-D

    Tom-D Taxi to Parking

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    Your AC is all about commercial assistance, and gives no advice on parts that were built by amateurs, and reused on E/AB aircraft.
    It concentrates on the 51% rule, which we already know is complied with in the case.
     
  32. MauleSkinner

    MauleSkinner En-Route

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    Exactly...how is it being determined that the parts are amateur-built?
     
  33. Tom-D

    Tom-D Taxi to Parking

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    Interesting conversation, thanks.
     
  34. Tom-D

    Tom-D Taxi to Parking

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    They are at one time all use on Legal E/AB aircraft. even if they were a kit aircraft the parts were assembled by amateurs. to qualify for the E/AB status the first time around. why would that change?
     
  35. MauleSkinner

    MauleSkinner En-Route

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    How do you know they had airworthiness certificates the first time around?
     
  36. Capt. Geoffrey Thorpe

    Capt. Geoffrey Thorpe Final Approach

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    First you need an airworthiness certificate. In theory, you are supposed to be able to document your work to show that the aircraft was sufficiently built by amateurs. Now, if you have a lazy ass inspector (which does happen), you may get away with a the stated lack of documentation. But, on the other hand, the inspector (and the FAA) can elect to tell you that you have a nice pile of scrap. It's not up to the FAA to prove that the aircraft wasn't built by amateurs, it's up to you to prove that it was.
    A prudent individual would discuss this whole idea with the FSDO/MIDO before plunking down hard earned cash on what could be no more than something to mount on a pole as a wind vane. And, over the course of that discussion, I suspect that any answers W.R.T. the repairman's certificate (which is the least of the things to be worried about) could be answered.

    "It is
    important to
    document the entire fabrication and asse
    mbly process from the beginning to
    the end, in a continuous and sequential manne
    r. This is because, at the time of
    certification, the FAA is required to ascertain
    whether the amateur builder(s) fabricated
    and assembled the major portion of the aircraft. Making this findi
    ng requires adequate,
    sufficient, and credible documentation. Th
    is documentation should clearly show who
    performed the task(s), when and where the ta
    sks were performed, depict the methods of
    construction and quality of workmanship, a
    nd document the use of commercial and
    non-commercial assistance."
     
  37. Capt. Geoffrey Thorpe

    Capt. Geoffrey Thorpe Final Approach

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    Simple. Each aircraft could have significant portions that were not built by amateurs. So, you use the commercially built wings from one, commercially built tail from the second, and the commercially built fuselage from the third and you end up with an assembly that does not any longer meet the so called 51% rule.
    Weather or not the FAA would let that slide is up to the FAA. And, anything that anyone says here is just speculation. So, it would seem to make sense to get the answer straight from one end or the other of the actual horse.
     
  38. Tom-D

    Tom-D Taxi to Parking

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    I would wager that when you use salvaged parts, there would be enough work done to document the required amount to satisfy any inspector.
     
  39. tsts4

    tsts4 Line Up and Wait

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    IMO it's possible. As we've discussed before, issuance of the repairman's certificate for an E-AB aircraft is not tied to the amount of work done by any individual as long as they are listed on the 8130-12 as a builder. The 51% rule only applies to the issuance of the AWC and has no connection to the repairman's cert. So if he is able to get get a new AWC for the plane, then seems to me the only hurdle would be convincing the FSDO inspector during his interview that he has the requisite knowledge to adequately perform all of the required inspections and maintenance tasks.
     
  40. Tom-D

    Tom-D Taxi to Parking

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    When the parts were commercially built how could it have been a legal E/AB?
    There is something I'm missing ?