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Repairman's certificate for a used kit

Vol88

Active Member
This short video in the latest FAAST Blast addresses the importance of the previous builders' logs and how to determine eligibility for the Repairman's certificate. It was of interest to me because I am the third builder of my RV10 kit.

It's worth watching if you are - or are considering - finishing someone else's kit. It's not a showstopper, but it is worth knowing in advance.

https://www.youtube.com/watch?v=QUnkCtEHaBo&list=PL5vHkqHi51DS-zCdCFOUyVzUgYlF_0qXK
 
This short video in the latest FAAST Blast addresses the importance of the previous builders' logs and how to determine eligibility for the Repairman's certificate. It was of interest to me because I am the third builder of my RV10 kit.
It's worth watching if you are - or are considering - finishing someone else's kit. It's not a showstopper, but it is worth knowing in advance.
https://www.youtube.com/watch?v=QUnkCtEHaBo&list=PL5vHkqHi51DS-zCdCFOUyVzUgYlF_0qXK

I just watched this video and the gentleman is wrong on 1 point. To qualify for the repairman certificate the applicant must be listed as A primary builder but he/she does NOT have to build 51% of the aircraft.

Example: 12 people build an amateur-built aircraft. No one builder has built 51% of the aircraft, but one of the builders is eligible for the repairman certificate.

The one builder designated for the repairman certificate must be a primary builder and show that he/she can competently perform the condition inspection.

§65.104 states that the applicant must be the primary builder. It says nothing about "Major Portion" or "51%".

The 51% rule only applies to the qualification of the aircraft as being eligible as Experimental Amateur-Built aircraft. i.e. §21.191(g).
 
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From the FAA...

This interpretation is far different from most have understood to this point.

Since the video was ostensibly produced by the FAA, and is brand new, are they saying they are now issuing a new interpretation? If so, this could affect a whole lot of builders.
 
Clear as mud

So is this one of the differences I read about occasionally where interpretations of the FARs vary from FSDO to FSDO?

In this case, this FSDO FAASTeam Program Manager has apparently read 65.104(a)(2) ("Be the primary builder...") to mean the person who built more than 50% of the 51% - which comes to 25.5%.

AC20-27G doesn't provide anything more specific than "The primary builder of your aircraft, even as the second builder..." or "One of the builders of an amateur-built aircraft registered in a corporation's name." (p. 31)
 
Guys, Mel is completely and accurately correct in terms of what the regs say.

I have ben to numerous FAST and Wings briefings by FA field inspectors who have very little knowledge of the Experimental rules (remember it is a tiny percentage of what they do). The best guys are willing to say “I don’t know, I have to look that up” - but a very large number don’t want to admit they don’t know, so they make something up. It is frustrating to sit and hold still when they do that - I usually start asking questions that guide them to the truth (if I can).

Know the regs, have them handy, and when an FAA inspector says something that you KNOW is wrong, pull them out and ask questions about how you could be interpreting it differently....most of them will come around.

If you really get stuck, the EAA Government Affairs guys are there to help!

Paul
 
I wish there was some variance to the Repairman Certificate rules. My early RV6A rebuild/restoration has been quite extensive including all aspects of building the plane from a kit. All new systems including electrical, fuel system, structural, engine overhaul, paint, canopy and reassembly of the plane. I have a log of all the work completed and feel with all the work I have done I should qualify for doing my own condition inspections. Maybe EAA could lobby for some adjustment to the rules.
 
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