Who gets the Repairmen's certificate

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

  1. tsts4

    tsts4 Line Up and Wait

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    It's possible. Both AC 20-27G and Order 8130.2J allow it, but both admonish that excessive use could render the project ineligible for certification under 21. 191(g). The Amateur-Built Aircraft Fabrication and Assembly Checklist provides the framework to determine the impact of using such assemblies.

    IOW use too much and you end up violating the 51% rule.
     
  2. Tom-D

    Tom-D Taxi to Parking

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    On simple rag and tube plans built aircraft as quoted in my previous post, it would be very remote that a commercial builder would even exist.
    even if the previous builder did have an expert weld up the tube assemblies that is allowed. That scenario given would be so remote that the inspector wouldn't even suspect it.
     
  3. tsts4

    tsts4 Line Up and Wait

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    Well that's an honor system issue more than anything IMO and applies to the AWC anyways. The FSDO inspector who did my AWC inspection was a turbine airframe guy who only gave my plane a cursory inspection. I could have assembled it out of used pinball machine parts and he wouldn't have batted an eye. My repairman's cert interview, on the other-hand was a bit of ball buster -- no way to hide any deficiencies on my part. Of course I know of guys who had the opposite experience -- ball buster AWC inspections followed by basically pencil whipped repairman cert interviews.
     
  4. Tom-D

    Tom-D Taxi to Parking

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    why would you want to hide any thing when every thing you did was legal?
    when asked if you welded the tubular structure, simply say no, it was done by a pro for safety sake. those types of processes are allowed to be done by professionals.
     
  5. tsts4

    tsts4 Line Up and Wait

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    Sigh. I wouldn't and didn't. I was just using that example to describe the difference in thoroughness of my repairman's interview vs my plane's AWC inspection. The point is there are parts of the process that are potentially more reliant on the honor system than others.

    In your original scenario I think the long pole in the tent is getting the AWC. Get that and IMO the only thing standing in the builder's way of getting the repairman's cert would be a knowledge deficiency that's exposed during the interview.
     
    Last edited: Dec 27, 2017
  6. Tom-D

    Tom-D Taxi to Parking

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    IMHO I believe it is a lot easier to be legal, than you'd have us believe.
     
  7. tsts4

    tsts4 Line Up and Wait

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    Hmmm-- never said it's hard to stay legal and didn't mean to imply otherwise. My apologies if it came across that way. However, being non-compliant (ie not legal) is not synonymous with deceit or subterfuge. I was just making an observation based upon your example in post #42 (see below):
    Anyway, we are diverging from your original question which is interesting to me and I would like to hear the outcome of such an endeavor.
     
  8. Capt. Geoffrey Thorpe

    Capt. Geoffrey Thorpe Final Approach

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    Lettuce assume that each of your 3 aircraft are 51% amateur and 49% commercial (per the checklist). Each is a legal E-AB. Which parts/assemblies are which? Different peeps can farm out different stuff. How can you document that your frankenplane is made of at least 51% amateur parts/assemblies and not made of too many of the bits that were commercially sourced?

    Do you believe that the FAA is going to want what they say they want? Or do you have some inside information that tells you that you can get away with not meeting the standards as spelled out in the advisory circular?
     
  9. donjohnston

    donjohnston Pre-takeoff checklist

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    Because the AWC inspection and the interview for the R/C are two separate and unrelated events by (usually) different people.

    All the DAR cares about is whether the aircraft is "airworthy". Period, end of story. They could care less if you mined the ore and made you own bolts.

    The FAA inspector (or whatever they are called) are the ones who will determine whether you are the builder and if you know enough (and can prove) about the construction of the aircraft to receive the R/C.

    And after talking to many people who have received their R/C, there is no rhyme or reason as to how that determination is made.
     
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  10. wanttaja

    wanttaja Pattern Altitude

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    Yes, you've got the right of it, here. However, #1 won't do what I want to do...if I "repair" the current airplane, then the airplane has an engine-driven electrical system and thus I have to install ADS-B. Taking route #2, I won't have to, assuming I remove the generator prior to transferring the engine to the new airplane.

    Also, with route #2, I should be able to receive the Repairman Certificate. It's getting tougher to find A&Ps to do the Condition Inspection.

    Ron Wanttaja
     
  11. Tom-D

    Tom-D Taxi to Parking

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    You are correct choice #1 will not get you the repairman's certificate. but remember no matter how much you rebuild or change, it still amounts to a repair to the aircraft. And may require a new letter of limitation. and all the paper that goes with it.

    #2 you are building a new aircraft, simple as that.
     
  12. GlennAB1

    GlennAB1 Ejection Handle Pulled

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    What are alterations?
     
  13. Tom-D

    Tom-D Taxi to Parking

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    Rather obvious to most.
     
  14. GlennAB1

    GlennAB1 Ejection Handle Pulled

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    But not you. The word "change" can be found in FAA description of major alterations, but not major repairs.
     
  15. unsafervguy

    unsafervguy Cleared for Takeoff

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    this is really easy on paper, but could be hard to determine in reality.
    1. if the franken plane uses the paperwork from one of the original planes, then it is a repair and the new owner will not get the repairmans cert.
    2. if the plane is being submitted for a new A/W then it has to show that it meets the requirements for EAB and the owner needs to show that the parts that were used were AB or the percentages meet the 51 percent rule. if the DAR or FAA determine that the parts used were built under commercial assist and the aircraft will not met the 51 percent rule then the A/W should be denied. if the Aircraft is determined to be EAB and the A/W issued, then the inspector will then determine if the assembler of parts has the knowledge to maintain the aircraft and will or will not issue the RC based on his/her determination. the biggest thing that needs to be done doing this type thing is document it all. the original documents from each of the three airframes should be obtained. without them, proving that it meets the EAB requirements could be difficult.

    bob
     
  16. Dana

    Dana Pre-takeoff checklist

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    Absent all three original build logs, how can you prove the parts were in fact amateur built?

    Taken to the extreme, what if it's only parts from one aircraft (rebuilding a deregistered wreck)? How is that different?

    Much of it might be how good you are at saying to the DAR, "It's a new build," with a straight face.
     
  17. Tom-D

    Tom-D Taxi to Parking

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    How does one determine what is a major repair on a EXP aircraft When FAR 43 does not apply. :) You really missed the point on that one.
     
  18. Capt. Geoffrey Thorpe

    Capt. Geoffrey Thorpe Final Approach

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    The op-lims do.
     
  19. Tom-D

    Tom-D Taxi to Parking

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    I fact it would be a new build, When you have no traceability on any thing all the parts to make up the aircraft, you would be required to start from scratch with the paper work.

    When you build A Volmer sea plane, you use the wings and flight controls from a Champ. and it is considered a new build, Why would this be any different? Plus a R/C is issued to the builder.
     
  20. Tom-D

    Tom-D Taxi to Parking

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    Just in as far as what the inspections will include.
    Not in as far as what would be a major or minor repair.

    The Letter of limitation will say the FAR 43-D will be included as the yearly condition. but that is all the letter will include.

    show me a Regulation that requires any EXP aircraft to gain authority to repair it on a 337?
     
  21. Capt. Geoffrey Thorpe

    Capt. Geoffrey Thorpe Final Approach

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    Who said anything about a 337? You can't do a 337 for repairs or alterations on an experimental aircraft - they don't apply.

    The op=lims include lots of stuff beyond just inspecting per append. D.

    The op-lims have a very long paragraph about what to do in the event of a major change as defined per part 21. What exactly you have to do depends on when the op-lims were issued - i has changed several times over the years. But, for the most part, if your "repair" is going to have an appreciable effect on the weight, balance, structural strength, reliability, operational characteristics, or other characteristics affecting the airworthiness then you gotta go back to square 1.
     
  22. Ravioli

    Ravioli En-Route

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    Mostly agree, except to say it is back to Phase I and usually not for the same direction.
     
  23. bflynn

    bflynn En-Route

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    Come on, silly argument. The DAR will never issue an airworthiness cert because you'll never be able to adequately show that you're complying with the 51% rule. Therefore there will never be a repairman's cert.

    To do that, you'd have to track down the 3 individual builders and get THEIR documentation that it was amateur built. E-AB does not state that YOU must build it, only that it was AB. But you do need to show very good familiarity with each aspect of the aircraft. IF you had built an airplane of the same type, could prove that you know the type inside and out and IF you could track down the original builder logs from the 3 aircraft, then MAYBE you'd have a really bad chance at getting the airframe certified. But I would not place any amount of money on it.
     
  24. Tom-D

    Tom-D Taxi to Parking

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    In plans built aircraft there really is no 51% rule. it is all done by the builder. 51% only applies to kit built aircraft.

    Think about it, why did the FAA require the aircraft to be built 51% by the amateur ?

    It sure wasn't due to the fisher products, their kits are nothing but raw materials.
     
    Last edited: Dec 28, 2017
  25. Tom-D

    Tom-D Taxi to Parking

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    Do you really believe that anyone could use salvaged parts. re-work as required, and not know enough to satisfy the FAA
     
  26. bflynn

    bflynn En-Route

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    The situation stated in the OP is not talking about plans built. Even if the 3 A/C were plans built, you'd still have to get the builder's logs to show it. The 51% rule would apply to the assembler of the new Frankenplane A/C. My thought is the DAR is going to balk at it because it falls under the "You were stupid enough to approve what" question if the new A/C has an incident.
     
  27. bflynn

    bflynn En-Route

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    It would depend on what you're putting together. Fuselage from one plane, wings from another and engine from a third...Not so huge. You put the wings on, hook up aileron controls and a pitot tube and you have an airframe that you largely know nothing about.

    I've got a fair mechanical background from the Navy - TM (now machinist mate) and I was a QA inspector on a nuclear submarine. I could probably manage the above, but there's no way I'd know what was inside the rest of the airframe.
     
  28. Tom-D

    Tom-D Taxi to Parking

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    Done as a new build why would they question the build process?
    I'd wager if the builder had pictures of the restoration process, showing the parts as they were cleaned, painted etc. It would be a easy do.
     
  29. bflynn

    bflynn En-Route

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    Because to get a E-AB cert, you have to demonstrate that the build process was actually AB? What am I missing?
     
  30. Ravioli

    Ravioli En-Route

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    I think @Tom-D's plan would work if they put in a bunch of crappy looking rivets and shoddy looking wire wrap.

    Then they could say to the DAR, "how could of this been done by anyone other than an amateur?"
     
  31. Tom-D

    Tom-D Taxi to Parking

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    I'd bet that any parts coming out of a scrap yard is going to need a lot more than just putting together.
     
  32. Tom-D

    Tom-D Taxi to Parking

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    All the parts used in the rebuild would be rather easy to identify as home built. It would be rather easy to see they aren't Cessna parts .
     
  33. Tom-D

    Tom-D Taxi to Parking

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    That's too damn true to be funny. :)
     
  34. Tom-D

    Tom-D Taxi to Parking

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    My thoughts on this so far.

    If the 3 aircraft in question were a Vans type kit, I really doubt that the bolt up of the major components would work, specially coming out of a scrap yard. and if the aircraft had a kit serial number you are going to need that serial number and go with the rebuild of that serial number, with a new registration, and all that entails.

    If these aircraft were of the rag and tube type such as a j-3 look alike, it may, if the rework of the parts is good enough to appear to be new build.
    And to make it look like a new build it would require new covers. paint. glass, all that stuff. And to install all that I believe the builder would gain the knowledge to pass the FAA questions to get the RC.
     
  35. GlennAB1

    GlennAB1 Ejection Handle Pulled

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    My experience with airliner parts coming from a scrap yard is that you usually have to make a repair when installing them because holes don't line up.
     
  36. Capt. Geoffrey Thorpe

    Capt. Geoffrey Thorpe Final Approach

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    Where is the FAA document that says that?
     
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  37. Stewartb

    Stewartb En-Route

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    How many of you guys have actually built an exp and gone through the inspection process?
     
  38. Checkout_my_Six

    Checkout_my_Six Final Approach

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    I bet Tom has....multiple times. :D
     
  39. tinerj

    tinerj Cleared for Takeoff

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    Ten guys can help build a E/HB and each one do less than 51% of the work. Only one can be designated the "builder", but that petson can get the repairman's certificate for that plane and can do the condition inspection.
     
  40. Tom-D

    Tom-D Taxi to Parking

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    A Murphy rebel, 1 war bird corsair, and a Fisher celebrity. and a restoration of a VariEZ.

    plus 17 total restorations of certified