New draft revision of AC 65-23B (repairman cert. procedures)

[rmartingt]

Apparently the FAA has put out a draft version of AC 65-23B, which deals with issuing repairman's certificates to builders.

As far as I can tell, the biggest changes are:

1. Paragraph added requiring that applicants demonstrate the "requisite skill"

2. Creation of a "gold seal" on the repairman's cert. for builders who meet a list of criteria, including but not limited to:

• Comprehensive builder's log
• Documentation of modifications
• At least 3 tech consultation visits
• In process inspections
• Pre-cover inspections
• Inclusion of features like AOA, shoulder harnessees, clearly marked controls, etc.
• Post-build inspections (like the ones used for the APP)
• Aircraft-specific condition inspection checklist
• Flight manual
• Aircraft-specific checklists
• A detailed flight test plan
• Flight advisor consults
• Additional instruction
• Detailed testing notes, etc.

Honestly I'm not concerned about the "gold seal" myself. I'm not a good record-keeper, and if they're looking for day-by-day build logs and itemized receipts, I'm SOL.

I'm considering comments on other parts of this.

Edit: adding link: https://www.faa.gov/aircraft/draft_d...Coord_Copy.pdf

[n82rb]

What a stupid idea. Typical faa. What purpose dose that serve. The purpose of a repairmans cert is to show you have the
knowledge and skills To perform the condition inspection.

How about a diamond seal if you have great penmanship with your log entries.

Bob burns
Rv-4 n82rb

[bret]

Is there a documented problem with the way we are doing our condition inspections, what warranted this change-draft?

[1001001]

Originally Posted by rmartingt

Apparently the FAA has put out a draft version of AC 65-23B, which deals with issuing repairman's certificates to builders.

As far as I can tell, the biggest changes are:

1. Paragraph added requiring that applicants demonstrate the "requisite skill"

.

What is the "requisite skill?" Kissing up to the certificating authority?

On a serious note, where are these skills defined, what are the criteria by which they are judged, who has the authority to pass judgment on them, how will that judgment be recorded, can it be appealed, etc. etc. ad nauseam. Wishy washy language like this eventually serves only to increase the subjectivity of the issuance rather than increase safety. Without specific guidance, every issuing authority will have different and probably conflicting guidelines. Sounds like a step backward.

As for the "gold seal" what will it get you? Certainly it won't give you the authority to inspect other airframes... So what possible benefit could it be?

[az_gila]

The draft document page is here, scroll to the bottom of the page -

https://www.faa.gov/aircraft/draft_docs/afs_ac/

It's also interesting that the "Gold Seal" bit goes out of the area of construction and into the area of flight test. Is that relevant on the "Repair" certificate? -

The intent for the addition of the gold seal to an existing Repairman Certificate is to recognize the repairman of an experimental amateur-built aircraft that provides more details and incorporates additional safe practices during the construction, certification, and testing of an amateur-built aircraft.

My guess is that they want the "Gold Seal" bit to identify kit built planes that adhere closely to the kit makers plans, with all deviations fully documented. It could be used in the future by builders to improve resale value.

[rmartingt]

Originally Posted by 1001001

What is the "requisite skill?" Kissing up to the certificating authority?

Apparently, this:

Originally Posted by FAA

REQUISITE SKILL. The FAA will consider applicants to have the requisite skill to determine whether the aircraft is in a condition for safe operation when at least one of the conditions below applies:

1. The Airworthiness inspector has knowledge that the individual builder constructed the aircraft. The inspector may accept information from another Airworthiness inspector involved in the original aircraft certification and familiar with the builder?s expertise.

Note: AC 20-27 notes that amateur builders have adopted the practice of calling upon a person having expertise with aircraft construction techniques, such as Experimental Aircraft Association (EAA) technical counselors, to inspect components and conduct other inspections as necessary. This practice has been highly successful in ensuring construction integrity. Therefore, FAA inspectors may use EAA technical counselors as resources in verifying the builder?s expertise.

2. The applicant presents satisfactory evidence, such as the aircraft construction logbook.

3. The applicant proves to the inspector?s satisfaction an ability to perform condition inspections and an ability to determine whether or not the aircraft is in a condition for safe operation.

I think this is just codifying what the inspector is already (supposed to be) doing today.

As for the "gold seal" what will it get you? Certainly it won't give you the authority to inspect other airframes... So what possible benefit could it be?

That's a really good question. Bragging rights when selling? I have no idea

I'd rather see the FAA concentrate on developing a way for making the certificate transferable to new owners/other builders/ etc. in the event the original holder passes, and developing some kind of middle-ground way for owners of certified airplanes to work on (only) their own aircraft without having to go the full A&P route (which covers a lot of ground not relevant to a light aircraft owner).

[az_gila]

Reading the previous post I am remided of the FAA structure.

Aircraft certification comes from the MIDO group, while the Repairman Certificates come from FSDO.

That would explain the reference to "The inspector may accept information from another Airworthiness inspector involved in the original aircraft certification and familiar with the builder’s expertise."

However, a MIDO person looking at the finished plane in a ready-to-fly state probably won't have much info on the builder's expertise.


Reading more... and shades of the 70's when FAA pre-cover inspections were the norm -

10.1.6 Pre-Cover Inspections. Documentation of pre-cover inspections must be presented to the FAA for inclusion in the FAA aircraft certification file. Documentation needs to indicate pre-cover inspections by knowledgeable persons such as FAA inspectors, EAA technical counselors, or certificated mechanics. All pre-cover inspection documentation needs to include dates and names of all person(s) involved.

I wonder how the local MIDO operations would respond to calls for pre-cover inspections?

Reading even more...

At this time AC 20-27 calls for the inspector to determine that you built the plane, with a builder's log only being one possible version of proof.

These are the listed forms of evidence -

Examples of documentation and methods that can be used include the following:

(1) The Amateur-Built Aircraft Fabrication and Assembly Checklist (2009);
(2) Comprehensive builder’s logs in any format, to include photographs of all the steps included in each of the listed tasks in the Amateur-Builder Aircraft Fabrication and Assembly Checklist (2009), materials and techniques used in construction, as well as dates, locations, and detailed descriptions;
(3) Photographs/video/DVD;
(4) Drawings and engineering specifications;
(5) Kit manufacturer’s data, when necessary;
(6) Relevant documentation (for example, plans) and references (for example, handbooks) used;
(7) Documentation concerning any commercial assistance used, including receipts;
(8) Documentation concerning any non-commercial assistance used;
(9) Part inventories and histories;
(10) Receipts and catalogs; and
(11) Logbook entries.

The new text appears to be standardizing on more specific forms of documentation.

[1001001]

Well if it represents a written standardization that is a good thing in my opinion. I wonder if this is in response to any specific situations. We have all read posts here and elsewhere about scary conditions that should have precluded issuance of an airworthiness certificate and should have been found during a reasonable AW inspection.

[DanH]

Originally Posted by az_gila

The intent for the addition of the gold seal to an existing Repairman Certificate is to recognize the repairman of an experimental amateur-built aircraft that provides more details and incorporates additional safe practices during the construction, certification, and testing of an amateur-built aircraft.

Special recognition...a pat on the back. Attaboy!