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FAA Inconvenience

garymail

Active Member
Currently, the FADO (NM-09) requires builders to travel to the FSDO on a Tuesday or Thursday with an appointment to present a drivers license or other ID in order to obtain the repairman's certificate. I am lobbying for DAR's such as myself to certify the identity of the builder and save them the time and expense to travel to the FSDO on a work day, often from hundreds of miles away.

If you have been inconvenienced by this practice, please send me a short note, as I will include that in my presentation.

Also, I am lobbying the FAA to allow a CFI to share the cockpit during phase 1 flight testing, which hopefully will reduce the Amateur Built Airplane accident rate.

Please respond only to [email protected]

Fly Safe!

Gary Brown
ATP A&P IA CFI DAR
 
Repairmens Certificate

When I built my RV6 a representative from the FSDO did the inspection and processed the repairmen’s paper work without my having to travel to Kansas City.
I did have to wait 2 months for him to be able to do the inspection.

My wife’s RV 12 and our Hanger mates (3 aircraft) all required
+300 round trip for a 20 minutes interview and document check to receive the needed certificate since they used a DAR.
 
...Also, I am lobbying the FAA to allow a CFI to share the cockpit during phase 1 flight testing, which hopefully will reduce the Amateur Built Airplane accident rate...

This aspect of your quest is in conflict with the purpose of Phase 1 - Testing. Phase 1 is for the aircraft, not the pilot.

I'm likely to get some "feedback" on this point, but if you're learning your airplane, you're not conducting a test of the airplane or it's systems. Testing and training are two separate things.
 
I only live 15 miles from the OAK FISDO, but still, it took a couple of hours of time which were unnecessary.
It's as if the FAA trusts DARs to issue AW certs, but does not trust them to write a letter that says, "I spoke with Mr. Smith and believe he constructed over 51% of the aircraft, and has the knowledge to inspect it."
I can see how it might get trickier for partner builds, or those who bought a partially assembled kit.

Funny story: when I showed up to get my repairman's certificate, the inspector was accompanied by a new hire - the person who, a few months earlier, had been my DAR! He turned to the inspector, said, "oh yea, he's the builder". I put away my photos and logs, the inspector went away to type up the forms.I chatted with my former DAR.
 
LOR works!

I've been issuing a "letter of recommendation" for the repairman certificate for quite a few years now. So far most all FSDO inspectors issue the repairman certificate without question after receiving my letter. It seems to give them a "warm fuzzy" if they have a letter with some's signature on it.
 
This aspect of your quest is in conflict with the purpose of Phase 1 - Testing. Phase 1 is for the aircraft, not the pilot.

I'm likely to get some "feedback" on this point, but if you're learning your airplane, you're not conducting a test of the airplane or it's systems. Testing and training are two separate things.

There was a big discussion about this at Oshkosh (and here on VAF, too). Opinions were widely varied. I believe an idea was floated of allowing a second pilot (qualifications TBD, but higher) sometime after first flight, and then of allowing a second pilot (maybe even just rated and current in category) after a given number of hours and specific tasks. I don't think anything is set in stone yet.

Personally, I don't think instructing needs to be happening in Phase 1, and I don't think CFI should be a requirement if a second person is allowed in some portion of Phase 1. I do see merit in allowing a second rated pilot later in the test program to help with data collection and workload management, and as a safety pilot during certain avionics tests, but that shouldn't be happening in the first few hours of a test program.

(I also think the test program could be set up better than just "40 hours"--maybe something primarily task-based?--but that's a discussion for another time.)
 
(I also think the test program could be set up better than just "40 hours"--maybe something primarily task-based?--but that's a discussion for another time.)

Technically it IS task based. Unfortunately the "tasks" are not well defined.
The 40 hours is only a minimum time to accomplish the testing.

Again unfortunately, most people focus on the 40 hrs more than they do testing. That is a big part of the problem.
 
TESTING

The current requirements for EAB testing are absurd. The limitations on Experimental Exhibition have been liberalized considerably in recent years. When I was involved with Exp Exhibition the testing requirement was five hours.
If the airplane is working properly I can do all the testing I need to do in five hours. Anything else is just a waste of time and fuel.
If I test a well built EAB for five hours, thoroughly investigating the stall characteristics and testing to Vne or beyond, I have performed more through testing than the so called "test pilot" who is afraid to go anywhere near Vne, much less do a real stall.
When I was involved with the Sukhois I would do one hour of testing close to the airport. If everything went well I would gradually increase speeds to Vne, and stall the airplane in many different attitudes. G test to 11 G. The rest of the five hours was just normal aerobatics.
I know of cases going back nearly fifty years where an instructor tested an EAB for a couple hours and then trained the builder to fly the airplane.
More than fifty years ago a very experienced FSDO inspector told me: test the airplane thoroughly for 20 hours and then hook an electric drill to the tachometer and run it up to fifty hours(the requirement in that era)
 
Mel,
Has your letter of recommendation allowed anyone to obtain their repairman certificate without personally appearing at the FSDO? E.g., by mail?
 
If I test a well built EAB for five hours, thoroughly investigating the stall characteristics and testing to Vne or beyond, I have performed more through testing than the so called "test pilot" who is afraid to go anywhere near Vne, much less do a real stall.

Testing stall, and VNE is not complete testing. And I agree that most people do NOT test anywhere near what should be done.

Testing throughout the entire normal range of speeds and throughout all maneuvers to be executed, Vso, Vx, and Vy and all regimes at all speeds, weights, and c/g loadings in 5 hours?
You're certainly better than I am.
 
Mel,
Has your letter of recommendation allowed anyone to obtain their repairman certificate without personally appearing at the FSDO? E.g., by mail?

Yes, But this is not normal and is not IAW the regulations.
 
You guys think the visit to the FSDO for the Repairman Cert after a DAR completed the inspection was bad get this:

I waited 3 weeks for the FSDO to complete my inspection. During the inspection I had the paperwork to apply for the repairman certificate and I asked if I could at this point. The answer he gave was no. He told me I had to complete Phase I flight test (40 Hours) first. At this point I was just really happy to have a airworthiness cert so I let it go "you know don't **** the fed off" right?

Later for various personal reasons I was slow at getting the testing done and fast forward almost 10 months after the airworthiness inspection I was only at 30 hours and starting to get worried that with all the FAA delays I wouldn't either get the hours flown off in time to get an appointment schduled so I could do my conditional inspection. So I emailed the FSDO inspector and asked him again if I could get the paperworked started he asked me if I had completed phase I. I said no and he told me at that time I need to complete phase I first then give him a call schedule an appointment at FSDO with him where they would interview me on the proper maintenance on an engine during the condition inspection. He said be prepared to answer questions such as how to set the timing etc. I was pretty disappointed as my FSDO is 90 miles away and I would have to go during the workday. He also told me to bring my aircraft log books, operating limititations, and special airworthiness cert. My first reaction was who do you think did the engine timing in the first place? He even made coments like nice workmanship etc when he was doing the inspection.

Trying not to **** the guy off too much I asked if he could point me to the regulation that states that Phase I has to be complete. He said it was the "policy" of this office not to issue repairman cert until phase I because if the aircraft is lost during phase I it cannot be rebuilt and they will have a repairman certificate floating out there for an aircraft that can't be rebuilt. At this point I feel the FSDO is making this stuff up. I can't see how an aircraft in Phase I can't be rebuilt. I didn't want to push it so left it be and decided to take the high road get the hours flown off as fast as possible and get the appoint scheduled hopefully to make my conditional timeframe.

Curious as to if anyone else had this problem I called EAA and they said the FSDO is making the rules up on their own. The EAA rep nearly begged me to allow him to forward my inquirey to their government advocacy department to help. At this point I don't want to rattle the hornets nest it is just easier to fly the hours off and then hope I get the cert before my conditional is due but I saw this thread and thought my story was right on topic.
 
Builder inconvenience is not an excuse for the FAA to yield responsibility

I personally do not want the FAA to reduce the requirements in any way. These arguments are trivial compared to the requirements for the average builder to go through the process of building an airplane and the FAA must not let their requirements for assuring the qualifications of the person applying for a Repairman Certificate to slip any lower than they already are. If I had to go to Washington DC to get the certificate after spending 8 years building the plane I would have done it. The ability to do all work and inspections after I retired was a driving reason for building an experimental in the first place - having to drive some place and submit to an interview and document review is a painless requirement.

I'm sorry to be in conflict with you my fellow builders but I cannot agree with the proposition.

Bob Axsom
 
Oh, I'd be rattlin' !!!

Clueless Feds should get a swift smackdown IMHO!

Its like messing with Cops they can only make your life worse. If at all possible take the high road.

I personally do not want the FAA to reduce the requirements in any way. These arguments are trivial compared to the requirements for the average builder to go through the process of building an airplane and the FAA must not let their requirements for assuring the qualifications of the person applying for a Repairman Certificate to slip any lower than they already are. If I had to go to Washington DC to get the certificate after spending 8 years building the plane I would have done it. The ability to do all work and inspections after I retired was a driving reason for building an experimental in the first place - having to drive some place and submit to an interview and document review is a painless requirement.

I'm sorry to be in conflict with you my fellow builders but I cannot agree with the proposition.

Bob Axsom

In my case I think its a little absurd as the FAA inspector did my inspection saw my workmanship and talked with how I did things so why should have to fly off 40 hours and drive 90 miles so he can ask me the same question and look at the paperwork HE issued me. I can sort of get your point about DAR'd aircraft but not FAA FSDO inspected aircraft.
 
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you got it wrong

I do not espouse to change the phase 1 rules. I only espouse that it would air safety of a low time inexperienced pilot were to have an experienced CFI ride with him for the first few hours until the owner became comfortable with the aircraft!

At the airline where I worked, the new pilot spent the first 25 hours ( about 4 days) with a check captain until they felt comfortable with the aircraft. If the 121 rules mandate it for safety sake, why not the part 91?

fly Safe!

Gary
 
...Its like messing with Cops they can only make your life worse. If at all possible take the high road...

If the cops are doing something wrong, then they should be held accountable.

And if the EAA or AOPA is "begging" to for an opportunity to make examples of Feds behaving badly, then that's exactly what should happen. I don't know about you, but my dues are paid expressly for this purpose. I couldn't care less about the magazines... I want advocacy.
 
Are you advocating transition training in a pre-existing aircraft of known quality, or training in a new airplane of unknown quality?

I'll bet your airline did not put new pilots into test pilot situations. Remember that the same rules that apply to well tested kits like Vans also apply to something I built in my garage from 2 x4's.
 
...At the airline where I worked, the new pilot spent the first 25 hours ( about 4 days) with a check captain until they felt comfortable with the aircraft. If the 121 rules mandate it for safety sake, why not the part 91...

Because in the airline world, the aircraft is not under flight test. Remember, Phase 1 is the test and verification of a custom built, unique aircraft. It is NOT a time for the pilot to "get comfortable". The pilot in Phase 1 had better START OUT comfortable!
 
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