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FAA says I can't do maintenance, etc

V

VETE76

Well Known Member
It has taken 10 months to get my repairman certificate from the FAA. Its an interesting story but I don't have the time to write it. No none would believe it any way.
He, (faa) came to my hanger to look at my RV7. Wanting me to prove I built it on my own. He never looked at any pictures from my build log, nor did he look at the build log.
Boy could he recite the regs, word for word! He was about 30 yrs old. Was an A&P. Then he asked me if I knew what I could and couldn't do on my RV. I told him. WRONG! You can change oil, tires and clean the windshield, the repairman cert. allows you to only do the yearly conditional inspection. You can not repair anything you find wrong! Is this guy full of engine oil? putting it nicely! I told him I was taking off the propeller to try a different one, he said I couldn't. Unless I was a certified FAA approved mechanic. A&P etc.
 
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Did that one guy "say" or did he put it in writing? If they issued the same repairman cert that we all have without a whole bunch of "other" paperwork, I would say you have the appropriate credentials that you were seeking and to just proceed as you know to be correct.
 
The easy peasy way to stump any FSDO inspector is to respond with "show me the FAR where it says I can't do <whatever>." and keep a copy of the FARs handy.
 
Your inspector was mistaken. Read 65.104(c).

§65.103 Repairman certificate: Privileges and limitations.
(a) A certificated repairman may perform or supervise the maintenance, preventive maintenance, or alteration of aircraft or aircraft components appropriate to the job for which the repairman was employed and certificated, but only in connection with duties for the certificate holder by whom the repairman was employed and recommended.

(b) A certificated repairman may not perform or supervise duties under the repairman certificate unless the repairman understands the current instructions of the certificate holder by whom the repairman is employed and the manufacturer's instructions for continued airworthiness relating to the specific operations concerned.

(c) This section does not apply to the holder of a repairman certificate (light-sport aircraft) while that repairman is performing work under that certificate.

[Doc. No. 18241, 45 FR 46738, July 10, 1980, as amended by Amdt. 65-45, 69 FR 44879, July 27, 2004]

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§65.104 Repairman certificate—experimental aircraft builder—Eligibility, privileges and limitations.
(a) To be eligible for a repairman certificate (experimental aircraft builder), an individual must—

(1) Be at least 18 years of age;

(2) Be the primary builder of the aircraft to which the privileges of the certificate are applicable;

(3) Show to the satisfaction of the Administrator that the individual has the requisite skill to determine whether the aircraft is in a condition for safe operations; and

(4) Be a citizen of the United States or an individual citizen of a foreign country who has lawfully been admitted for permanent residence in the United States.

(b) The holder of a repairman certificate (experimental aircraft builder) may perform condition inspections on the aircraft constructed by the holder in accordance with the operating limitations of that aircraft.

(c) Section 65.103 does not apply to the holder of a repairman certificate (experimental aircraft builder) while performing under that certificate.
 
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rocketbob said:
The easy peasy way to stump any FSDO inspector is to respond with "show me the FAR where it says I can't do <whatever>." and keep a copy of the FARs handy.
Click to expand...

And in the context of this discussion (what work you can and can't do on you r RV-7), when he turns to FAR 43, have him first read part B of 43.1 which says...

"(b) This part does not apply to?

(1) Any aircraft for which the FAA has issued an experimental certificate, unless the FAA has previously issued a different kind of airworthiness certificate for that aircraft; or"

So, anything he would refer to in 43 (it regulates who can do what on certificated aircraft). does not apply.

Bottom line...

Anyone, can do any work (whether they should is a whole other discussion) on an aircraft with an experimental airworthiness certificate. The repairman's certificate only authorizes you to do the annual condition inspection.
 
Mike H said:
Your inspector was mistaken. Read 65.104(c). however If you did not build the aircraft then you cannot legally perform maintenance other than preventive maintenance specified in FAR 43.3(g).
Click to expand...

This is not correct.
See my previous post.
 
Yes....I forgot that that 43.1(b)(1) excludes all EAB aircraft for maintenance, alterations and repair.
 
rocketbob said:
The easy peasy way to stump any FSDO inspector is to respond with "show me the FAR where it says I can't do <whatever>." and keep a copy of the FARs handy.
Click to expand...

i asked and he said part 65 and he even emailed it to me. i dont see the same thing he saw.
 
He is WRONG!

VETE76 said:
i asked and he said part 65 and he even emailed it to me. i dont see the same thing he saw.
Click to expand...

It sounds like he is referring to 65.103. Have him read 65.104(c) which says that 65.103 does not apply.....
 
faa

Regardless of his being the repairman supervisor he still has a boss. Typically these guys rotate through assignments within the FBO. You could wait until a more educated person is assigned or go to his boss.
 
Why waste your time with any further interaction with this guy or his boss or anybody else at FAA? You have your repariman certificate, now go about your business conducting all aircraft maintenance/repair that is necessary and that you are comfortable performing.
 
erich weaver said:
Why waste your time with any further interaction with this guy or his boss or anybody else at FAA? You have your repariman certificate, now go about your business conducting all aircraft maintenance/repair that is necessary and that you are comfortable performing.
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I dismissed him 1 min after he left my hanger.
 
One does not need the repairman certificate to perform maintenance and/or repair to an experimental amateur-built aircraft.
The repairman certificate is only required to sign off the condition inspection.
 
Mel said:
One does not need the repairman certificate to perform maintenance and/or repair to an experimental amateur-built aircraft.
The repairman certificate is only required to sign off the condition inspection.
Click to expand...

******
This is a very different "twist" than I had understood it over these past 30 yrs. I always thought you had to have the Rep Cert to do the work. Good to know for sure and makes sense.
 
So now this guy is off to misinform the *next* applicant.

Somebody should at least notify his boss, anonymously if necessary, that he's spreading blatantly wrong information to his customers (the public).
 
Somebody should buy him an all-expense-paid round trip to Airventure this year with the requirement that he be a daily FAA speaker in the forums. His topic, of course, would be what you can and cannot do as owner of an EAB airplane with a Repairman's Certificate. Now that would be an education!
 
rv7boy said:
Somebody should buy him an all-expense-paid round trip to Airventure this year with the requirement that he be a daily FAA speaker in the forums. His topic, of course, would be what you can and cannot do as owner of an EAB airplane with a Repairman's Certificate. Now that would be an education!
Click to expand...

Outstanding thought! I like it!
 
If only......

We could insure that he would show. Ill throw in the first $100 to the pot for his ticket and expenses. I'll bet the EAA would comp him a ticket and provide a guide for opportunities for improvement.
 
Please do the next guy a favor!

PLEASE contact the FSDO.....stop the pain for the next guy:( there is nothing they can do to you and trust me.....theyWILL inform the inspector!!!:cool:
 
Skykingbob said:
PLEASE contact the FSDO.....stop the pain for the next guy:( there is nothing they can do to you and trust me.....theyWILL inform the inspector!!!:cool:
Click to expand...

Bob, it sounds as though you know for a fact that the FSDO will coordinate with and convey the correct information to this inspector once a call is made. Because many of us are clueless about the inner workings of the FAA (myself included), and some of us have even had the opposite experience (again, myself included), would you mind sharing how you know they'll do the right thing in this instance?
 
The wonderful collaboration of this forum is exactly this... we share the good and the bad to help others or get help from others. Please either report him to his supervisor (and he does have must share his/her name if requested since he is Federal employee) or share his name on the forum. I'm not sure if sharing his name is within the guidelines of this public forum but others should know what to expect.

Thanks for sharing your experience.
 
The last words

Vete 76

I always have the last two words with my wife or the FAA ( MOT in my case..)

Wife: Yes Dear..

MOT: Yes Sir..

Then keep on doing exactly what I was doing in the first place...:D

They think they're in control and I'm happy....

Good Luck with Godzilla..

Bruno
 
Skykingbob said:
PLEASE contact the FSDO.....stop the pain for the next guy:( there is nothing they can do to you and trust me.....theyWILL inform the inspector!!!:cool:
Click to expand...

I sent him an email asking him to please explain what he was trying to tell me in more detail in case I was misunderstanding him. I told him he had me thoroughly confused by the time he left. I will let you know.
fred
 
Option

Fred,
You could invite him back out to your hanger and remove that prop like you said you wanted to do and let him write you up. Then you could reinstall that prop, get in the airplane, and fly it in front of him. When you land, and the authorities put you in the county jail, you could write to us and let us know how it goes and then we could all post how he was wrong. That would be kinda fun, at least from here. :)

Seriously, I would take the short and simple route, use Mel's advise and politely have him read that reg Mel listed. Its pretty simple and to the point.

cj
 
rvbuilder2002 said:
And in the context of this discussion (what work you can and can't do on you r RV-7), when he turns to FAR 43, have him first read part B of 43.1 which says...

"(b) This part does not apply to?

(1) Any aircraft for which the FAA has issued an experimental certificate, unless the FAA has previously issued a different kind of airworthiness certificate for that aircraft; or"

So, anything he would refer to in 43 (it regulates who can do what on certificated aircraft). does not apply.

Bottom line...

Anyone, can do any work (whether they should is a whole other discussion) on an aircraft with an experimental airworthiness certificate. The repairman's certificate only authorizes you to do the annual condition inspection.
Click to expand...

I can sort-of see where a new FAA inspector could get tripped up here. If he's not familiar with EAB and he's only read the reg that pertains to the Repairman's Certificate, then it does appear that the only thing the repairman can do is the condition inspection. Which is correct, the only privilege the repairman's certificate gives you is the condition inspection. Your inspector clearly does not know what Scott said here, which is that you don't need any type of certificate to do maintenance, repair or alteration of an experimental aircraft. Which is pretty obvious, since anyone with a pulse can legally build one, and I'll bet he'll feel really stupid when someone finally points that out.
 
FAA

The geographical dividing line for FSDO's, at least the ones in upstate Ny, are along county lines. The dividing line between Albany and Rochester FSDO is the Onondaga/Madison county line. The OP lists a Syracuse address, but I believe he listed a private airport near Chittenango for aircraft home base. The airport location appears to be in Albany FSDO.
May years ago I had considerable personal experience with both FSDO's. Rochester was superb, Albany not quite as good.
I took my first Part 135 PIC checkride with the manager of the Rochester FSDO. he had a reputation for being very demanding. I should have failed the checkride, instead he gave me an incomplete and had me come back a few days later and repeat just one non precision approach.
A few months prior I had taken my instrument and multi check rides on two consecutive days with a Rochester FSDO Inspector and passed both.
I also was working as an apprentice mechanic for an FBO in the Rochester FSDO area and met both ops and Maintenance inspectors on a regular basis.
The principal maintenance inspector did the condition inspection on my EAB on two occasions.(pre repairman program). After the first inspection he handed me a small form that authorized me to take the A&P tests. I did not ask for this, he simply did it. Technically he should have issued only the Airframe portion.
This was the era when the FAA Inspectors were truly there to help. Today things have gone about as far as possible in the opposite direction.
 
FAA

Prior to the time in my previous post, I became acquainted with a gentleman from a different FSDO in the Northeast. Although this person is long gone, I will not name the FADO out of respect for him. he was a neighbor for several years. I was building my first EAB and he was also build an EAB.
I did no have a phone at the time and I would show up at his house unannounced. We would go down in his basement where his airplane project was and sit and talk airplanes, sometimes for several hours.
I was in my early 20's, he was probably mid 50's, a very experienced pilot. He always treated me as an equal. It was many years later that I found that he was manager of the FSDO(then GADO) office.
He was the one who volunteered-the (then) 50 hour test requirement is nonsense. Test the airplane thoroughly for 20 hours. If there are no problems, hook up a drill motor to the recording tach and run it to 50 hours.
I took his advice. I always tell people that the FAA recommended two pilots to help me complete phase one. Their names were Mr. Black and Mr. Decker. Although I never met either of them, they helped me completer 50 hours of testing in just two weeks. They always left the airplane full of fuel and the windshield clean.
A true story from the 60's.
 
FAA

While this has been an interesting discussion, if nothing was provided in writing to the OP, it is a non issue. Pretend it did not happen and move on. I have been working on EAB for over 50 years, MANY encounters with the FAA, airshows and competition events. never had an issue with the FAA about maintenance or paperwork issues on EAB. Certified aircraft, an entirely different story. FAA ramp check, the FAA was looking at a pilots shoulder strap that looked like it had been chewed in half by a rodent. FAA very timidly asked me what I thought he should do. I said I think you should ground the airplane. I then added, "you know if I grounded the airplane for that I would probably get fired". He grounded the airplane. The only time in three years that I couldn't stop laughing when I called my boss.
For about 1 1/2 years I parked one building away from the FAA FSDO office. A very entertaining and educational period of time.
 
VETE76 said:
I sent him an email asking him to please explain what he was trying to tell me in more detail in case I was misunderstanding him. I told him he had me thoroughly confused by the time he left. I will let you know.
fred
Click to expand...

You know, the complete illogicality of his statements *ought* to hit him square in the face when he thinks about it:

Only an A&P can do work on an EAB (including, presumably, all the things done at an annual inspection), but then said A&P would let his work be signed off by someone with "only" a Repairman's Certificate at annual?

What would possibly be the point of there even *being* such a thing as a Repairman's Certificate, then?
 
Trust me! He is in a position to know what the FAA will do.

krw5927 said:
Bob, it sounds as though you know for a fact that the FSDO will coordinate with and convey the correct information to this inspector once a call is made. Because many of us are clueless about the inner workings of the FAA (myself included), and some of us have even had the opposite experience (again, myself included), would you mind sharing how you know they'll do the right thing in this instance?
Click to expand...
 
FAA

VETE76

Please call EAA headquarters. And let them know the situation so they can deal with it Also. This help us all in long run. There's a lot of fruit cakes in this world. :D
920 426 4800
800 564 6322
Bill J
 
VETE76 said:
It has taken 10 months to get my repairman certificate from the FAA. Its an interesting story but I don't have the time to write it. No none would believe it any way.
He, (faa) came to my hanger to look at my RV7. Wanting me to prove I built it on my own. He never looked at any pictures from my build log, nor did he look at the build log.
Boy could he recite the regs, word for word! He was about 30 yrs old. Was an A&P. Then he asked me if I knew what I could and couldn't do on my RV. I told him. WRONG! You can change oil, tires and clean the windshield, the repairman cert. allows you to only do the yearly conditional inspection. You can not repair anything you find wrong! Is this guy full of engine oil? putting it nicely! I told him I was taking off the propeller to try a different one, he said I couldn't. Unless I was a certified FAA approved mechanic. A&P etc.
Click to expand...

When I took my paperwork to the Dallas FSDO to get my repairman's certificate, the gentleman who did my paperwork said that this would allow me to do the annual inspection on any RV-8. I asked him to confirm what he said, and he did just that. I went home and red the regs to make sure that this wasn't correct but never called him back on it.

BTW, when the certificate didn't arrive in the 90-day window, I called him back. He said the paperwork got "lost" and had to be resubmitted. I got the certificate 10 days later.

-John
 
My gripe:

Recently I went to take an instrument checkride in my RV-7A. I called the DPE one month prior and asked what his policy was regarding giving a checkride in an experimental. He told me that if I was willing to fly it, he was willing to give me a checkride stating that DPE's are given some latitude to decide whether to give a ride in a homebuilt.

Fast forward to my checkride: When I showed up at my exam, I informed him that I built my RV-7A myself after he asked if I bought it completed or partially built. I pulled out all of my logbooks including my avionics logs which showed that all of my required checks were up to date (transponder, pitot/static, ELT). He focused on my ELT check and didn't like the way I entered the ELT check in the avionics log. We spent roughly 20 minutes with him griping about the wording. He called a friend of his who is with the FAA in the avionics area and when on the phone with him said "I have a 'handyman' here who changed the batteries in his ELT" and then went on to further discuss the situation with him over the phone in my presence. After he hung up, he sat back with his arms folded across his chest and said he wouldn't fly in this airplane because it wasn't legal. He said the only way I could change the batteries in my ELT was if I had a repairman's certificate. I then informed him that since I had built the airplane myself, I did indeed have a repairman's certificate and produced it for his inspection. He then started in questioning me about CFR Part 23 indicating his disdain that I built and flew a homebuilt yet I wasn't conversant in Part 23.

My whole point in this is that after being addressed condescendingly as a "handyman" with his friend from the FAA, it became apparent that there is a subculture of disdain for homebuilders since we don't really follow all of the same rules as the certified aircraft with respect to maintenance. I'm not trying to paint all FAA employees with the same brush but this guy came into the exam with a large chip on his shoulder. If he didn't want to fly in a homebuilt, that's his prerogative but he was a jerk!

I have written to the local FSDO yet. I'm wondering if EAA has any input. Sorry for the venting.
 
Fast forward to my checkride: When I showed up at my exam, I informed him that I built my RV-7A myself after he asked if I bought it completed or partially built. I pulled out all of my logbooks including my avionics logs which showed that all of my required checks were up to date (transponder, pitot/static, ELT). He focused on my ELT check and didn't like the way I entered the ELT check in the avionics log. We spent roughly 20 minutes with him griping about the wording. He called a friend of his who is with the FAA in the avionics area and when on the phone with him said "I have a 'handyman' here who changed the batteries in his ELT" and then went on to further discuss the situation with him over the phone in my presence. After he hung up, he sat back with his arms folded across his chest and said he wouldn't fly in this airplane because it wasn't legal. He said the only way I could change the batteries in my ELT was if I had a repairman's certificate. I then informed him that since I had built the airplane myself, I did indeed have a repairman's certificate and produced it for his inspection. He then started in questioning me about CFR Part 23 indicating his disdain that I built and flew a homebuilt yet I wasn't conversant in Part 23.

My whole point in this is that after being addressed condescendingly as a "handyman" with his friend from the FAA, it became apparent that there is a subculture of disdain for homebuilders since we don't really follow all of the same rules as the certified aircraft with respect to maintenance. I'm not trying to paint all FAA employees with the same brush but this guy came into the exam with a large chip on his shoulder. If he didn't want to fly in a homebuilt, that's his prerogative but he was a jerk!

I have written to the local FSDO yet. I'm wondering if EAA has any input. Sorry for the venting.[/QUOTE]

THIS ISNT MY 1ST Ecounter with the FAA. 1984 we built a rally ultralight the 2 seater version. we had to get the FAA to inspect it, as the dar wasnt in the works yet. he looked at it and all he could say at first was, "this just doesn't look like a REAL airplane!! wen he was finished he handed us the air worthyness cert saying as we took it from his hand, "yep, it passed, but it just doesnt look like a real airplane" but its legal. be carefull and enjoy! Mr Lyngel, Rochester fsdo, a real nice and fuuny gentleman! they aren't all bad!
 
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VETE76 said:
I sent him an email asking him to please explain what he was trying to tell me in more detail in case I was misunderstanding him. I told him he had me thoroughly confused by the time he left. I will let you know.
fred
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Well i told u i would post his reply, it has been just about 4 weeks now......you guessed it, i haven't heard a word. oh by the way, i just did my inspection myself on my own airplane.
fred
 
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