Applying for repairman certificate for EAB partially built

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lsaway

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lsaway
I purchased an EAB airplane that is partially built. I intended to complete the project, but being able to do the Condition Inspection is high up on my desirability list. I know that the primary builder may apply for repairman certificate at the time the AWC is applied for. The EAA website states:

"What does "primary builder" mean?
FAA does not define this term. EAA considers the primary builder to the person who's signature is on Form 8130-6, block III attesting to the airworthiness of the amateur built aircraft..... However, there is no official FAA definition of "primary builder" so it will be up to the FAA inspector who accepts your application to determine if you meet the requirement or not. This is done through an interview process that includes a review of the aircraft construction records."

With this unfinished kit, the starting builder registered it years ago and is current. AWC has not yet been applied for. Since the starting builder is now the manufacturer on record, is it impossible to be the primary builder and obtain repairman certificate, regardless of what percentage of the work I completed?
 
You can be the primary builder. What the local FSDO will require is highly variable, but definitely have sufficient documentation to show that you did enough building yourself to have the skill to complete the condition inspection. None of the other paperwork really matters relative to the requirement for the repairman certificate other than maybe prompting the FSDO to be more picky.
 
What does the bill of sale say?

If you have (or can get) a bill of sale for a project with no mention of N-number, you can just get a new registration and then AWC in your name as the primary builder, the old one just expires.
 
The repairman’s certificate can be seperate from the aircraft registration. What the FSDO will be looking for is proof that you were involved enough with all aspects of the build in order to be able to maintain it., biggest sampling block according to my local guy are the ones that buy a brand new pre setup engine for their plane. They have no idea how to do things like overhaul the mags or even re-time them. They usually don’t pass on the first try. In your case it depends on how much is already done. If the plane is almost done it’s going to be hard to prove you built enough to know what you are doing. If it still has some airframe, engine, and panel work left you might have a chance.
 
My current plane started out as a kit that a previous owner had begun. Not to disparage anyone but some of his work wasn't up to par. There was some taking apart of what little work he had done and repairing or replacing the parts. Many of the replacement parts were scratch built using the plans although the parts could have been ordered. It was a wonderful learning experience to cut, bend, shape, deburr, and fit the parts & pieces together!

When I went to get my repairman's certificate I took my laptop and a copy of my builder's log file. We sat in a room and they looked through all my builder's logs and photos. They asked about parts, procedures, and had a few "how/why/what for" questions. I had a lot of evidence to detail the build.

It was easy for them to see that not only had I built it but that I had the skills to maintain it. IMHO, that is what they are mostly seeking to prove.
 
Around here, the FAA usually is pretty good about giving the repairman certificate to the guy who takes it through certification. There's no 51% rule or anything like that for this. Just the person who claims he's the principal builder.
 
Adding on...

Depends on the FSDO. I had a new at Sun-n-Fun do mine. He was totally clueless. I suspect he didn't know what any airplane was. Other people I have spoken with say it was a rubber stamp process. If you know other people who have gone through the process, I would check with them.

I say go in loaded for bear and hope for squirrel.
 
I've personally seen both extremes, and both have been within the same FSDO. One guy rebuilt a previously constructed and flying airplane and was able to convince the FSDO to give him a repairman certificate for his effort. In no way, shape, or form was he responsible for most of the construction but he had the thing far enough apart and made enough repairs to it to satisfy the interviewer. On the other hand, I also know of a guy who built his whole airplane (from a kit) and the FSDO denied him a repairman certificate. The claimed reason for denial was that there was inadequate documentation that the applicant was the builder.

I wouldn't sweat the situation you're in at this point. If there is a concern about earning the repairman's certificate a call to your FSDO may help you get going in the right direction.
 
I got my repairman cert after a pretty in-depth interview at FSDO. They asked questions it would have been hard to fake answers for if not VERY familiar with the plane. It was fun.
 
IIRC, anyone listed on the 8130-12, Eligibility Statement Amateur Built Aircraft, can apply for that aircraft’s repairman’s cert. For group builds, the person submitting the 8130-6 for the AWC isn’t always the most the qualified builder. Most typically though the builder submitting the 8130-6 is the same person who applies for the repairman’s cert. The fact it was a partially completed kit technically shouldn’t have any bearing unless there’s doubt you have the requisite knowledge to safely maintain the aircraft.

Like others have posted it’s mixed bag when it comes actually going through the application process. I know some that were in and out in under 30 minutes— basically just a paperwork drill. In my case it was a 1.5 hour ordeal. I was thoroughly grilled, mainly on my power plant knowledge. The inspector, who wasn’t the same one who did my AWC, nevertheless knew I had built the plane so I guess he figured I was more than qualified to maintain the airframe. As a result, even though I brought a copy of my builders log and other supporting documentation, he didn’t look at any of it outside of the actual application.
 
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Great info from everybody. So it sounds like the aircraft already having the first builder listed as manufacturer is not going to be a deal killer for getting repairman certificate. That is good news for me. The rest is up to the discretion of the FSDO in charge. I know I will still have to demonstrate my experience, ability, and knowledge, but at least it is still possible.
 
lsaway said:
Great info from everybody. So it sounds like the aircraft already having the first builder listed as manufacturer is not going to be a deal killer for getting repairman certificate. That is good news for me. The rest is up to the discretion of the FSDO in charge. I know I will still have to demonstrate my experience, ability, and knowledge, but at least it is still possible.
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Why are you listing the first builder as the manufacturer? You can list them on the 8130-12 but they aren’t the manufacturer. All you need from them is a bill of sale (and many times you can get one from the kit manufacturer) and their builder log to help show compliance with the 51% rule, but not having the log is not necessarily a showstopper.
 
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lsaway said:
Great info from everybody. So it sounds like the aircraft already having the first builder listed as manufacturer is not going to be a deal killer for getting repairman certificate. That is good news for me. The rest is up to the discretion of the FSDO in charge. I know I will still have to demonstrate my experience, ability, and knowledge, but at least it is still possible.
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Connect with your FSDO and DAR early into the process and get them onboard. Find out what their expectations are.

BTW ... welcome to homebuilding!
 
Capt. Geoffrey Thorpe said:
Nit: The repairman certificate lets you perform the condition inspection.
No knowledge check or certificate is required to maintain the aircraft.
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Bad wording on my part—point taken. To do the sign off, you’re supposed to have the requisite knowledge to do so, even if you aren’t wrenching on the plane. As you pointed out anyone, regardless of qualification can perform any maintenance on E-AB aircraft.
 
tsts4 said:
Why are you listing the first builder as the manufacturer? You can list them on the 8130-12 but they aren’t the manufacturer.
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He already registered the airplane. In the FAA database, the serial number is listing him as the manufacturer. That was my concern for obtaining the repairman cert.
 
lsaway said:
He already registered the airplane. In the FAA database, the serial number is listing him as the manufacturer. That was my concern for obtaining the repairman cert.
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it’s not an airplane-yet. You should be able to change it, or better yet you submit a new registration based upon a new serial number that you come up with.
 
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tsts4 said:
it’s not an airplane-yet. You should be able to change it, or better yet you submit a new registration based upon a new serial number that come up with.
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I had a situation similar to this on a previous purchase. The former owner had reserved an N number and sold me the kit as a plane (so marked on the paperwork - and I did not catch it at the time). It took a letter from the seller to the FAA to say that what I purchased was indeed an unfinished "kit" and not a "plane". The question for the OP ... what is written on the bill of sale? Did you purchase a kit or a plane?
 
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tsts4 said:
it’s not an airplane-yet. You should be able to change it, or better yet you submit a new registration based upon a new serial number that come up with.
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Bill of Sale from Kit manufacturer to original builder has the serial number. I'm new to homebuilding rules, but I know this creates more complications if I were to try and register it with a different serial number.
 
lsaway said:
Bill of Sale from Kit manufacturer to original builder has the serial number. I'm new to homebuilding rules, but I know this creates more complications if I were to try and register it with a different serial number.
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Contact the kit manufacturer and have them issue you a new bill of sale. In any event you set the serial number. You can use the one the kit manufacturer assigned, I did (actually my builder number which really isn’t the same as a serial number). But there’s nothing stopping you from rolling your own since you’re the one applying for the AWC, not the kit manufacturer,
 
Daleandee said:
The question for the OP ... what is written on the bill of sale? Did you purchase a kit or a plane?
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Standard FAA Bill of Sale with N number and serial number. When I bought it, he said to contact him if there is any other paperwork needed. I don't think there would be any problem getting a generic bill of sale for unfinished kit.
 
lsaway said:
Standard FAA Bill of Sale with N number and serial number. When I bought it, he said to contact him if there is any other paperwork needed. I don't think there would be any problem getting a generic bill of sale for unfinished kit.
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You can apply for your own N number ...
 
tsts4 said:
Contact the kit manufacturer and have them issue you a new bill of sale. In any event you set the serial number. You can use the one the kit manufacturer assigned, I did (actually my builder number which really isn’t the same as a serial number). But there’s nothing stopping you from rolling your own since you’re the one applying for the AWC, not the kit manufacturer,
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I probably don't need another bill of sale from manufacturer. Since I have consecutive bill of sales from the manufacturer to the first builder, then from him to me. I never considered that I don't have to use the serial number the kit manufacturer supplied. If this doesn't appear "shady" or violate any rules, it is something to consider. Since everybody is stating that it might still be possible to get repairman cert no matter who is listed as the manufacturer, I don't mind if the original builder is the manufacturer anyway. Are there any other benefits of being listed as the manufacturer opposed to just being a repairman?
 
Daleandee said:
You can apply for your own N number ...
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I was planning on doing an N number change anyway to a more personalized number I have on reserve. So, would a new N number with the original serial number and a new manufacturer be a conflict with the existing FAA records?
 
lsaway said:
I probably don't need another bill of sale from manufacturer. Since I have consecutive bill of sales from the manufacturer to the first builder, then from him to me. I never considered that I don't have to use the serial number the kit manufacturer supplied. If this doesn't appear "shady" or violate any rules, it is something to consider. Since everybody is stating that it might still be possible to get repairman cert no matter who is listed as the manufacturer, I don't mind if the original builder is the manufacturer anyway. Are there any other benefits of being listed as the manufacturer opposed to just being a repairman?
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Well, you need to have registration updated anyway as you’ll be the new owner assuming you want to keep the N-number the previous builder received— just as if you were buying a flying airplane. I don’t remember clearly, but I seem to recall that the name on the 8150 (registration application) and the 8130-6 needed to match. EAA has a kit with a checklist that spelled all of this out.
 
lsaway said:
I was planning on doing an N number change anyway to a more personalized number I have on reserve. So, would a new N number with the original serial number and a new manufacturer be a conflict with the existing FAA records?
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Dunno. One option would be to keep the serial number but on the new registration and the subsequent AWC instead of, for example calling it an RV-12 or Ch-750, or whatever it is, call it an Lsaway 12, or LsAway 750 or whatever you like. As the builder , you can call it whatever you want on the paperwork and give it whatever serial number you want. The kit manufacturer doesn’t get a vote in the process.
 
Bought my EAB partially built. Zero problem getting the AW and repairman cert at Oakland FSDO.

Frankly, the guy spent less than 2 minutes looking at my documentation. I had a whole speech prepared too, but never got to use it!
 
Both of my EAB’s were from second hand kits. The thing your Inspector is looking for is systems
lsaway said:
I probably don't need another bill of sale from manufacturer.
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In the RV world (point is, there's a long history of successful builds and registrations), what you do is send confirmation to Van's and have them change the builder number (the kit number) to your name, and at the appropriate time, they will send you a kit bill of sale. Seems to work very well registering the airplane. Might want to check into it.

Beyond that, unless you like the prior builder's N-number, there's no reason to "acquire" that N-number, because you'll be on the hook to renew it from time to time, even before the airplane needs to be registered, and that's just gonna cost you money.

So, I'd try and get out of the aircraft bill of sale business and get into the partial kit sale business, as long as the kit manufacturer will recognize your ownership.
 
lsaway said:
I was planning on doing an N number change anyway to a more personalized number I have on reserve. So, would a new N number with the original serial number and a new manufacturer be a conflict with the existing FAA records?
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Wasn't a problem for me. I simply reserved an N number and used it when registering the plane before the AW inspection.
 
lsaway said:
I don't mind if the original builder is the manufacturer anyway. Are there any other benefits of being listed as the manufacturer opposed to just being a repairman?
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The manufacturer should be the person who applies for the airworthiness certificate, i.e. you.

lsaway said:
I was planning on doing an N number change anyway to a more personalized number I have on reserve. So, would a new N number with the original serial number and a new manufacturer be a conflict with the existing FAA records?
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Get a new bill of sale that doesn't list the N-number and apply for a new registration yourself with your new N-number. Nothing in the FAA database ties a "Smith Bugsmasher 1234" that never received an AWC to a "lsaway Bugsmasher 1234", and you can pick whatever serial number you want, e.g. 001. If the kit maker supplies a serial or plans number you can use it if you want to, or not. In the case of my Hatz, the original builder used the plans number for both the serial number and the N-number (with his initials added), but that's not required. It is useful to use the kit maker's serial number though (and to get your name listed for that nunber in their records), to tie the plane to any SBs the kit maker may issue. The FAA doesn't care either way as long as the registration matches the AWC,
 
I've learned much from all the comments. I have been involved with standard category aircraft most of my life, but never had any experience with experimental aircraft. Since I first started, General Aviation has evolved to where standard category no longer fits my resources and lifestyle. For me, experimental is the way to reverse time a bit to the good old days of aviation.
 
Lndwarrior said:
Bought my EAB partially built. Zero problem getting the AW and repairman cert at Oakland FSDO.

Frankly, the guy spent less than 2 minutes looking at my documentation. I had a whole speech prepared too, but never got to use it!
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Maybe I should make a trip to Oklahoma FSDO and hope I get your same guy.
 
lsaway said:
Maybe I should make a trip to Oklahoma FSDO and hope I get your same guy.
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Won't help (unless you're in OK). Other than Sun-n-Fun or Oshkosh, you have to use the FSDO which serves the address where the plane is registered. At least that's what they told me.
 
donjohnston said:
Won't help (unless you're in OK). Other than Sun-n-Fun or Oshkosh, you have to use the FSDO which serves the address where the plane is registered. At least that's what they told me.
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A trip to Sun-n-Fun sounds good. I have always wanted to go. What is required to schedule it there?
 
kyleb said:
In the RV world (point is, there's a long history of successful builds and registrations), what you do is send confirmation to Van's and have them change the builder number (the kit number) to your name, and at the appropriate time, they will send you a kit bill of sale. Seems to work very well registering the airplane. Might want to check into it.
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I called the kit manufacturer today. They said they will only provide a bill of sale to the original purchaser, no exceptions. 1 option down
 
lsaway said:
I called the kit manufacturer today. They said they will only provide a bill of sale to the original purchaser, no exceptions. 1 option down
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No worries. Just use the bill of sale you got from the previous owner and submit your own registration. You don’t have to do it now, it just has to be done in plenty of time before you submit the AWC application. What you can do now, if you want is reserve an N-number you like. You can peruse the FAA database until you find one you like that isn’t taken and reserve it online.
 
flyingron said:
Around here, the FAA usually is pretty good about giving the repairman certificate to the guy who takes it through certification. There's no 51% rule or anything like that for this. Just the person who claims he's the principal builder.
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This is the only answer. The RC can be submitted by anyone involved, primary builder is nothing more than a vote. The DAR (lol no fsdo is gonna inspect an eab) will take the paperwork and sign and submit without a second thought.
 
pfarber said:
This is the only answer. The RC can be submitted by anyone involved, primary builder is nothing more than a vote. The DAR (lol no fsdo is gonna inspect an eab) will take the paperwork and sign and submit without a second thought.
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The Washington DC FSDO did my AWC inspection on my E-AB ai4craft, but that was back in 2015. These days (post-COVID) a DAR might be your only option but I’d still ask the FSDO (if you are close by) if they’ll do it as the inspection would be free— your taxpayer dollars at work. Also DARs really don’t have a role in the repairman’s cert process. I guess that can help you fill out the application and they can submit a letter of recommendation but the applicant still has to work with a FSDO to receive the cert.
 
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My DAR told me that the DAR’s have no function with the application of the repairman’s cert. When I asked he said “Contact the FSDO. We don’t have anything to do with that.” Now he was an old DAR so maybe it changed and he didn’t want any part of it.
 
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