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What does FAA require you to do early on?

AndyWAUS

Member
I'm in the middle of the RV-10 empennage kit. I noticed many people here keep detailed build logs and many also registered an N-number. I have done none of these things. My only build log is the date I write down on every page of the Vans plans when I complete the page. Should I be worried and change my ways? I thought I would worry about FAA closer to the end of the project. Is there a cheat sheet for new builders explaining what is the minimum required paperwork a builder should produce?

Thank you!
 
The only thing you really need to do at this stage is document what you are doing to make it clear you are doing the work. Take photos and keep them in a file, keep a notebook or diary, keep a blog. Do something that serves two very important purposes...

1 - it shows the FAA that you did the work and this was amateur built.
2 - photos serve as a reminder to you of what you did, when, and why. When it comes time to inspect, update, or fix something, that reference can be helpful.

I use the EAA blog because it is free and easy to use. It works nicely for photos and for notes to myself of what I did and what I need to do.

As far as tail numbers are concerned, there is no need to do it until you are ready to fly. Lots of people, including me, simply get excited about what they will call this huge pile of parts when it is completed and start reserving numbers when they think of a good one that is available.
 
Builder log

My opinion, but if I were buying an experimental, a builder log would get almost as close an examination as the airplane. A well documented log should help resale value. However, I'm very OCD. :D My blog is below.
Not required, but I also recommend at least three EAA Tech Counselor visits. Preferably by different TCs. One before closing the first empennage component. One before closing wings and tanks. One at canoe stage. One before DAR inspection.
 
Build log

I believe what your doing is good, I would just add to the date the time spent of the task. That is what I did when I built my RV7A. It is good to show how long you spent doing the work. No need to rewrite the task. It is just to show the FAA what you did, so that you can receive your Repairman Cert.. Do take pictures with you in them as you are working on things. It is proof that you did the work.
 
I kept a log, wrote on the plans, and took photos. When the DAR came out I had brought a computer to the hangar with the photos. The DAR just looked at the photos (try to get some with you in the picture). As mentioned above, you can reserve an N number cheaply ($5 or $10 per year) if you see one you like. I recommend not registering until a few months before final inspection - in some states that may trigger property taxes earlier than need be.
 
Thank you folks! Let me clarify the question a little bit. I know many people enjoy blogging and vlogging every detail of their build. I'm not one of them. There are many people much more qualified than I am to educate the world about building planes, and I'm not looking to join this cohort. So really I'd like to keep logging to a minimum - the less meta-work I do the more time I have for doing actual work. I went through FAA and EAA (thank you Sean) and found that requirements are very loosely defined. It's good to know that "time spent building" is not mandatory - I purposely avoid tracking hours. But also the EAA interpretation is outdated and IMHO misleading.

On the page about builders log, the EAA says "FAA guidance (FAA Order 8130.2F, Chg. 4) recommends that pictures be included in your builder records. Lots of pictures are a plus, especially pictures showing you actually working on the project."

In fact, FAA order 8130.2F has been superseded long time ago, and the current version is 8130.2J, but also the FAA order mentions no such thing about photos. The only place the word "photo" appears in a relevant context in the order says "Examples of documentation include ... A comprehensive builder’s log that includes items such as drawings, engineering specifications, plans, references, handbooks, kit manufacturer’s data, photographs, video, documentation of commercial assistance, yada-yada". So per FAA, photographs are listed next to video and kit manufacturer's data, and emphasizing photos is just EAA's creative interpretation of the letter.

I understand that people are talking from their positive experience obtaining airworthiness and repairman certificates, and I appreciate that. Keeping an extensive log with photos or videos of myself building would be on a safe side and will satisfy FAA. But given that I've already build a chunk of the empennage with no logs, I need to find out what is the bare minimum the FAA needs. My understanding is they don't need the "Amateur-Built Fabrication and Assembly Checklist" because Van's RV-10 is listed in their list of kits which satisfy the 50%+ rule, but please let me know if anyone has experience FAA asking for the checklist. I have also sent emails to my FSDO and MIDO with a question regarding how verbose the builder's log needs to be. I will write back to this thread if/when the FAA responds.
 
Just copy the builder's manual, and date(/initial if you want) when each item is completed on the copy. Take some photos every now and then, include yourself in a few.

'Tain't that hard.

BTW, the empennage is very small fraction of the build. If you have few or no or shabby records from that, I doubt it would even be noticed by a DAR. Just fix your process problem, and build on. (Or try to recreate some of them by noting approximate dates tasks were completed in your copy of the builder's manual, per above).
 
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You can reserve a N number at anytime. It will cost you a few dollars every year to retain the number. But it is not necessary, and you can start the registration process ~6 months before your airworthiness inspection.
 
Your logbook is more for you than the FAA. You’d be surprised at how much you forget. e.g., did I spray zinc chromate under there, or something else, or nothing? And most important: if you decide to skip a step, for whatever reason, write that down and circle it in red, so you don’t forget to come back to it.
 
Just copy the builder's manual, and date(/initial if you want) when each item is completed on the copy. Take some photos every now and then, include yourself in a few.

'Tain't that hard.

Now that makes more sense. Thank you!
I actually got a call back from FSDO and asked them the question. The FAA person told me the same info - they would like to see a few pictures of me building it to confirm that I was the builder. But it doesn't have to be every day of building, just a few milestones will suffice. Beyond that recommendation they don't prescribe a format of the build log, so whatever suits best. I explained what I'm doing with dating the build manual pages and he said it's fine. When I apply for airworthiness certificate, there will also be an interview-like process focused on safety of the airplane. This can be done either with a DAR or FAA MIDO. MIDO is free.

An interesting thing I didn't know (in context of repairman certificate) - the manufacturer of the airplane is going to be me, not Van's Aircraft. So I can actually call it whatever I want - Andy's Aircraft BP-5037 if I like. And then I can only service this one aircraft. I can service it even if I sell it. But I can't service another RV-10, because it's not Andy's Aircraft BP-5037. (maybe you all know this already)
 
Your logbook is more for you than the FAA. You’d be surprised at how much you forget. e.g., did I spray zinc chromate under there, or something else, or nothing? And most important: if you decide to skip a step, for whatever reason, write that down and circle it in red, so you don’t forget to come back to it.

For this purpose I use the plans book itself. I mark each step as I go with checkmarks and comments. Probably not the best way to search for and retrieve information, but it works for now. Sometimes I will skip a page and move ahead with a different piece with the intent to come back later - for example, when I'm waiting for a dry day to spray primer - then I mark each incomplete step and then come back, complete and mark them off.
 
I have a related question that the OP might also be interested in, hope it's ok to ask here.

At what point do you need to involve the FAA (IE: DAR) in the build in terms of inspections? Are there specifics things you should not do before an inspection occurs, etc.?
 
:eek:
An interesting thing I didn't know (in context of repairman certificate) - the manufacturer of the airplane is going to be me, not Van's Aircraft. So I can actually call it whatever I want - Andy's Aircraft BP-5037 if I like. And then I can only service this one aircraft. I can service it even if I sell it. But I can't service another RV-10, because it's not Andy's Aircraft BP-5037. (maybe you all know this already)

Some clarification: Anyone may work or ‘service’ any EAB aircraft. The repairman certificate will allow you to sign off the required annual condition inspection, and, as you noted, only on your specific airplane.
 
I have a related question that the OP might also be interested in, hope it's ok to ask here.

At what point do you need to involve the FAA (IE: DAR) in the build in terms of inspections? Are there specifics things you should not do before an inspection occurs, etc.?

Really, only when you are very close to finished. But some may have longish scheduling times. When you do make contact, ask the DAR for specific guidance, e.g., cowling off (probably yes), inspection panels off?, transponder inspection in hand (should be no, but some fsdos think the answer is yes), etc. You must have the faa registration in-hand. Ask him about logbooks, photos, etc. BTW, most FSDO/MIDO guys will issue the repairman certificate on the inspection visit; most DARs cannot, it will take a trip (currently due to covid a remote call) to the fsdo.
 
Interview the DAR

When the time came about a year ago to get my airworthiness certification, I had to interview several DAR's to find one that could come in a reasonable time frame. I had to scratch one who insisted I fill out the long form to prove I did 51% of the construction, even though the model was on the FAA list of approved kits. He did not care.
 
When I read these posts, I always feel fortunate that my local FSDO does EAB inspections around here. I think writing a date, with your initials on the newer Vans plans at each step, along with some pictures to prove that you actually participated in the build (if you want a Repairman Certificate), is enough. To be honest, my inspector never actually looked at my home-made build logs, or pictures I took (on the first one), of any of my three airplanes I’ve built. I had EAA Tech Counselor reports at maybe three phases during each build, which they were interested in. If you are using a DAR, they are probably more detailed in their review, but my experience has been that if you have your FAA paperwork in order - registration, logbooks, condition inspection sign off (by you) - and they feel confident you built the airplane, then you shouldn’t have anything to worry about.
 
When the time came about a year ago to get my airworthiness certification, I had to interview several DAR's to find one that could come in a reasonable time frame. I had to scratch one who insisted I fill out the long form to prove I did 51% of the construction, even though the model was on the FAA list of approved kits. He did not care.

This is odd - I asked FAA this very question today and they confirmed the form (I think you refer to the Amateur-Built Fabrication and Assembly Checklist) is not needed for kit planes from the FAA list. By the way they don’t call it certified or approved and specifically ask to not represent it as such. It’s just “evaluated”. But Vans should have a copy of the checklist they submitted and a letter of eligibility from FAA and I believe they can share them with the public.

Good thing about DARs is you can hire the one who is reasonable. :)
 
I haven't really seen it mentioned but you eluded to it with your comment.
A log book, pictures or blog is mostly for getting your Repairman's certificate.
I don't think the DAR really cares who built it. After you get the plane flying then it is time to call the FAA and schedule a visit to get your Repairman's.
They want proof that you are the person that built the plane. A Repairman's would not be issue to a person that did not build the plane.
I have heard that the proof can be many different things including a verbal interview to see if you know what you are talking about.
However every FSDO and every inspector interprets the rules different so it is best to have your bases covered with good documentation. (pictures of you smiling while holding a rivet gun) ((and maybe a bandaid or two))
 
This is odd - I asked FAA this very question today and they confirmed the form (I think you refer to the Amateur-Built Fabrication and Assembly Checklist) is not needed for kit planes from the FAA list. By the way they don’t call it certified or approved and specifically ask to not represent it as such. It’s just “evaluated”. But Vans should have a copy of the checklist they submitted and a letter of eligibility from FAA and I believe they can share them with the public.
Good thing about DARs is you can hire the one who is reasonable. :)

The checklist MUST be used if you have made modifications to the kit or if you had ANY paid assistance.
 
I got a call back from FAA MIDO, and they confirmed the things others have said on the thread. For the airworthiness certificate perspective, they are only concerned about the 51% rule, and as long as the kit is in the list of FAA evaluated kits, you don't need anything. Plan pages marked with dates of completion is more than enough as a builder log.

They also said no FAA engagement is needed until the airplane is ready for inspection. When ready, submit the application through the AWC tool on the faa.gov website and they will tell the wait time for MIDO. If the wait is too long then choose a DAR.
 
I got a call back from FAA MIDO, and they confirmed the things others have said on the thread. For the airworthiness certificate perspective, they are only concerned about the 51% rule, and as long as the kit is in the list of FAA evaluated kits, you don't need anything. Plan pages marked with dates of completion is more than enough as a builder log.

They also said no FAA engagement is needed until the airplane is ready for inspection. When ready, submit the application through the AWC tool on the faa.gov website and they will tell the wait time for MIDO. If the wait is too long then choose a DAR.

Good on ya for thinking ahead and putting a good process in place, but don't stress over things. If you're only on the empennage kit, you've got boatloads of time to learn about all of the registration and inspection steps. Just keep decent records and notes and photos, and focus on building. It's a marathon, not a sprint. Enjoy the journey :)
 
Modifications such as....?

Primarily we're are looking at major modifications that change the configuration of the aircraft or ones that would reduce the percentage of the builder.

IMO, the latter is a "no brainer" because, as we all know, any modification increases the work done by the builder.
 
A log book, pictures or blog is mostly for getting your Repairman's certificate. I don't think the DAR really cares who built it.

Not sure where you got that idea. The DAR (or FAA inspector) definitely DOES care who built the aircraft. Proof of compliance with the major portion requirement (aka the "51% rule") for an amateur-built airworthiness certificate is required before the certificate can be issued. The build records, along with the verbal interview at the time of the final inspection, are used to make the determination that the aircraft meets the requirement. If the build records and/or the interview ends up being insufficient in the inspector's judgement, the inspector has the option of employing the checklist. Of course such a situation is very rare, but it can happen.

And yes, the build records are also used when applying for the repairman certificate, but that's not their primary purpose.
 
Hi Joe,
I should spend some time researching this before replying but short on time.
I ASSUMED that amateur built means any amateur. Not necessarily the one registering the plane. So as long as it is not >50% professionally built it was good. Remembering back 7 years I don't remember the conversation coming up with the DAR about who built my plane. I am sure a DAR would be quick to pick up on it during conversation about the build and then require documentation if required.

I will spend some time looking for documents supporting us both. please list if you know where I can find it.

Second thought, what about the Young Eagles build or partner builds?

Title 14, Code of Federal Regulations (14 CFR), part 21, section 21.191(g), defines an amateur-built aircraft as an aircraft "the major portion of which has been fabricated and assembled by person(s) who undertook the construction project solely for their own education or recreation."
 
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Primarily we're are looking at major modifications that change the configuration of the aircraft or ones that would reduce the percentage of the builder.

IMO, the latter is a "no brainer" because, as we all know, any modification increases the work done by the builder.

Thanks for pointing this out. The language really didn't make any sense to me. I'm making some modifications to my RV-10, including a BRS parachute system. As an example, installing just that parachute system adds about 100 hours to the build time, according to the manufacturer. As a result, I will be 100 MORE hours on the good side of 51%. How a builder modification would decrease a builder under 51% makes no sense to me, given mods ADD time versus stock plans. I'm glad you are as confused about the language as I am, and you are the expert.
 
Hi Joe,
I should spend some time researching this before replying but short on time.
I ASSUMED that amateur built means any amateur. Not necessarily the one registering the plane.

I think we are on the same page. When you said the DAR doesn't care who built the plane, I took the "who" to mean if it was an amateur or a paid professional. You are correct in that the DAR or inspector is only looking to verify that amateur builders performed the major portion of the tasks, whether the applicant was involved or not. But the build records are HOW we determine that the amateur-built requirements are met. So we definitely ARE interested in the build records. Thus, I was referring to your statement that the build records are primarily used when applying for the repairman certificate. That is not the case. The build records are very important at the time of certification. This is especially true in those cases where the applicant may have obtained a partially-completed project.
 
I use the website webuildplanes.com It’s super easy to use from my phone, I just snap a picture on my phone as I’m working and write down what task I completed and how many hours I worked on it.
 
My opinion, but if I were buying an experimental, a builder log would get almost as close an examination as the airplane. A well documented log should help resale value. However, I'm very OCD. :D My blog is below.
Not required, but I also recommend at least three EAA Tech Counselor visits. Preferably by different TCs. One before closing the first empennage component. One before closing wings and tanks. One at canoe stage. One before DAR inspection.

Man thats the best information ever, and I just took a look at your build. From one OCD to the next very nice job!
 
This makes me wonder if or how secure the EAA builder logs are. I've been doing a paper build log at the same time but that obviously won't have photos.

Just sent an email off to the EAA support site to see how they back up the builder log sites.

I don't know of any easy way to back it up on a computer or spare drive.

Anyone know??
 
EAA Backup

The EAA builder site has a way to download your entries to an excel document. I haven't done mine as yet so I don't know that much about it. The download tab is under "My Account". As an excel document, I doubt your pictures are included, but I keep copies of mine on both my phone, desktop and cloud backups so I'm good with that.

Edit: Out of curiosity, I just downloaded my project and thumbnails of the pics are included as well. I'm no expert in Excel, so I don't know if you can upsize them back to the original size or not.
 
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I use a Google Spreadsheet with one row for each building session. Date, what I did, hours broken out by major section (empennage, wings, etc.), any Service Bulletins included in the work, and links to any pictures I took.

I also have other pages in the spreadsheet where I list deferred steps, budgets for avionics and other purchases, a circuit list, a fuse list, electrical load analysis, connector list showing all pinouts, and other information about the build that I might find useful later.

Happy to share a read-only link to it if anyone’s curious about how it’s laid out. Just PM me with your Google account name.
 
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