ChiefPilot

Well Known Member
Assuming the actual builder of an E-AB holds the repairman certificate and has access to the appropriate equipment, can they perform their own pitot/static and transponder tests to satisfy FAR 91.411 and 91.413?

Has anyone done this?
 
Assuming the actual builder of an E-AB holds the repairman certificate and has access to the appropriate equipment, can they perform their own pitot/static and transponder tests to satisfy FAR 91.411 and 91.413?

Has anyone done this?

You may get different opinions, but the answer is no you cannot.
 
You may get different opinions, but the answer is no you cannot.

Can you expand on why? The only possible limitation I can find is in part 43 appendix E, which may limit altimeter accuracy tests. I could find no limitations on performing the transponder tests called out in part 43 appendix F.
 
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Copied/pasted from my FAQ page on my site (more stuff like this there for your enjoyment):
http://www.expaircraft.com/faq.htm

Who can perform these inspections?

With few exceptions, only an FAA Certified Repair Station (CRS) with the appropriate ratings may perform the inspections required by CFR 91.411 and 91.413.


Can a builder with a repairman certificate for the aircraft he built perform his own altimeter, static or transponder certifications?

The FAR’s authorize the "manufacturer" of the aircraft to conduct the tests However, the builder of an amateur-built aircraft does not meet the FAA’s definition of a manufacturer. The FAA, in Order 8130.2, defines a manufacturer as a Production Approval Holder (PAH). Some examples of a PAH would be the holder of a Production Certificate (PC), a Parts Manufacturing Authority (PMA), and Technical Standards Order Authorization (TSOA). An amateur builder does not fit this definition. Thus, the amateur-builder cannot perform the transponder and pitot/static tests on his/her homebuilt.
 
Last edited:
Copied/pasted from my FAQ page on my site (more stuff like this there for your enjoyment):
http://www.expaircraft.com/faq.htm

Who can perform these inspections?

With few exceptions, only an FAA Certified Repair Station (CRS) with the appropriate ratings may perform the inspections required by CFR 91.411 and 91.413.


Can a builder with a repairman certificate for the aircraft he built perform his own altimeter, static or transponder certifications?

The FAR?s authorize the "manufacturer" of the aircraft to conduct the tests However, the builder of an amateur-built aircraft does not meet the FAA?s definition of a manufacturer. The FAA, in Order 8130.2, defines a manufacturer as a Production Approval Holder (PAH). Some examples of a PAH would be the holder of a Production Certificate (PC), a Parts Manufacturing Authority (PMA), and Technical Standards Order Authorization (TSOA). An amateur builder does not fit this definition. Thus, the amateur-builder cannot perform the transponder and pitot/static tests on his/her homebuilt.

And yet, our aircraft registration and data plates list us as manufacturer, plain as day.
 
And yet, our aircraft registration and data plates list us as manufacturer, plain as day.

What can I say. One of the first things the FAA tells us in Oklahoma City is, "We don't answer 'why' questions."

Bottom line, what Walt says is true. It has been tested.
 
Yes it's true

Yes, we are the manufacturer. But keep in mind that the transponder and pitot static checks are especially important for when we are flying in controlled airspace and/or in IMC conditions. The transponder is used by ATC for identification and separation, and is becoming even more important with ADSB.

There is a fallacy in the static system test that I have a problem with, though and that is it is only a leak check. It really doesn't mean it is accurate during flight conditions. An improperly stalled static system can cause the airspeed to be off by a large error, and that affects the altimeter as well. During Phase I testing I always test that the altimeter is reading correctly during flight conditions by making low approaches that are done VFR to verify it looks correct. Low passes down the runway at various speeds can confirm the accuracy as well, with the correct baro setting. Or, setting the altimeter for Zero and then flying down the runway at 20-4- feet will give you a quick idea of the error, if any.

Most of the kit manufacturer's have done some kind of testing and tell you where to put the static port for the best results. However, not all manufacturers do and therein lies the potential problem. We are sharing airspace with those airplanes that have an error in them. So, just because the ADSB points out traffic at 2 o'clock and 500' below you---don't believe it until you have seen it with your eyeballs.

Vic
 
besides...

the cost of buying, and keeping in calibration, the needed test equipment really makes this a non-starter for a casual (biennial) user.
 
My local avionics shop/ FAA repair station had to purchase a new ADSB transponder test set. The cost was in the $25k neighborhood. This cost does not get added to any txponder certification as everyone in the business still needs to be price competive with the competition.