Completing kits for others.

Tom-D said:
That in the end, would be determined by the DAR/FAA inspector. And they mostly will be swayed by the better quality work of a professional, in what ever endeavor they have been in evolved.
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This aircraft has been build by:
1 fuselage was assembled by an A&P.
2 The wiring was completed with help
3 the engine was installed and serviced by another A&P
4 The radios were installed and wired by a AV shop.
5 the canopy was build as requested by a canopy glass shop other than the kits plans.
6 the aircraft was painted and trimmed by a professional paint facility.
7 Seats were completed and installed by a custom upholstery shop.

does this aircraft qualify for the X/AB type certificate as per 21.191/21.193 ?
 
Tom-D said:
This aircraft has been build by:
1 fuselage was assembled by an A&P.
2 The wiring was completed with help
3 the engine was installed and serviced by another A&P
4 The radios were installed and wired by a AV shop.
5 the canopy was build as requested by a canopy glass shop other than the kits plans.
6 the aircraft was painted and trimmed by a professional paint facility.
7 Seats were completed and installed by a custom upholstery shop.

does this aircraft qualify for the X/AB type certificate as per 21.191/21.193 ?
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Not enough information provided.
How much of that was paid work? How much of the total work was paid work? How much of the plane was pre-assembled (as in a quick-build kit) before the build started?
 
Cap'n Jack said:
Not enough information provided.
How much of that was paid work? How much of the total work was paid work? How much of the plane was pre-assembled (as in a quick-build kit) before the build started?
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Have you ever seen these services completed with out compensation?
 
Cap'n Jack said:
Not enough information provided.
How much of that was paid work? How much of the total work was paid work? How much of the plane was pre-assembled (as in a quick-build kit) before the build started?
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What IF::: this was a plans built aircraft? all consumables bought by the owner.
 
Tom-D said:
Have you ever seen these services completed with out compensation?
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Personally? No.
But someone who is an A&P could help a friend with a build, under their supervision, without compensation, on their fuselage, as you yourself asserted. See, some of us do read your posts.
I could help a friend run the wiring under their supervision. I'd do it for free.
I suppose another A&P could do the engine install as well under supervision without compensation.
 
Tom-D said:
What IF::: this was a plans built aircraft? all consumables bought by the owner.
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Already answered....

Hiring help starts to look like the situation mentioned by Everskyward. I'll quote it again since you missed her post and citation:

Everskyward said:
Here is a FAQ from the EAA regarding the 51% rule.

https://www.eaa.org/en/eaa/aviation...ent-rule-on-amateur-built-homebuilt-airplanes

Q: I want to hire someone to finish the wings on my kit. Can I do that?

A: There is no specific prohibition in hiring someone to help with the construction of your aircraft. In fact, that is what you are doing when you purchase a kit; you are hiring someone to help you construct your aircraft. To be eligible for an amateur-built certificate, the “major portion” (at least 51 percent) of the tasks needed to make the aircraft airworthy must be completed by amateurs “solely for their own education or recreation.” So you may hire someone to finish the wings on your kit if you still have 51 percent or more of the tasks remaining to be completed by amateurs solely for their own education or recreation.

To assist builders with assuring that they have accomplished the required number of tasks, the FAA has provided a new checklist that enables builders to fill in an additional column for “commercial assistance” in addition to the kit provider column. This form helps a builder determine if the project would continue to comply with the amateur-built regulations if he or she hired someone to complete additional tasks originally evaluated by the FAA and kit manufacturer to be amateur-builder tasks.
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This check list she mentioned (https://www.faa.gov/aircraft/gen_av/ultralights/amateur_built/kits/media/am_blt_chklist_job_aid.pdf ) covers the scheme you propose, where paid help (this is commercial).
 
Cap'n Jack said:
Already answered....

Hiring help starts to look like the situation mentioned by Everskyward. I'll quote it again since you missed her post and citation:
This check list she mentioned (https://www.faa.gov/aircraft/gen_av/ultralights/amateur_built/kits/media/am_blt_chklist_job_aid.pdf ) covers the scheme you propose, where paid help (this is commercial).
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After being involved in X/AB building since the 90s that this topic we discuss is one of the areas that the FAA says one thing in an AC, then does another in the field.
 
Tom-D said:
After being involved in X/AB building since the 90s that this topic we discuss is one of the areas that the FAA says one thing in an AC, then does another in the field.
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I'm pretty sure the rules have evolved over the years.

The information posted by Ron Wattaja and Everskyward seem consistent with what I hear from the EAA and other sources, such as Kitplanes magazine.
 
Cap'n Jack said:
I'm pretty sure the rules have evolved over the years.

The information posted by Ron Wattaja and Everskyward seem consistent with what I hear from the EAA and other sources, such as Kitplanes magazine.
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Remember who has a CYA to contend with.
 
To answer your original question IMO, depending on the level of completion, you could potentially get a range from slightly more than the cost of a quick-build version of the kit to the going market rate for a flying example.

As for the legality of such a venture the opinions of us here on POA carry zero weight-- contact your FSDO and ask them.
 
Cubcrafters has a program where a buyer takes a vacation and hangs out with the CC crew for a week or so as they assemble some components of a Carbon Cub. Then the owner goes away while CC builds the new airplane and certifies it as amateur built. This is a fully approved program. The end result is probably a better airplane since it's built by professional aircraft builders in a factory environment. You E-AB experts should have fun talking about that one. :)
 
Stewartb said:
Cubcrafters has a program where a buyer takes a vacation and hangs out with the CC crew for a week or so as they assemble some components of a Carbon Cub. Then the owner goes away while CC builds the new airplane and certifies it as amateur built. This is a fully approved program. The end result is probably a better airplane since it's built by professional aircraft builders in a factory environment. You E-AB experts should have fun talking about that one. :)
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It doesn't matter what any of us so called experts thinks. If the FAA is OK with it then that's that. We can argue that these types of programs are thinly veiled attempts at skirting the standard certification process all day long but that won't change anything. Personally I don't care one way or the other. My RV-10 was slow build all the way because that's the way I wanted it. However, I don't begrudge guys who trade time for money and go the 2 week-to-taxi programs one bit. The only thing I care about is if someone does something that the FAA frowns upon that puts the current E-AB certification or operating rules at risk.
 
I agree, which is evident in my earlier posts that said to ASK YOUR DAR!
 
Yes, it does. Ask most FAA guys to get involved with an E-AB airplane and they'll tell you the FSDO doesn't do that. They'll probably give you a list or DARs. That's who does the inspection and provides the airworthiness certificate. That's 100% accurate in my case and for lots of other EX owners and builders I know.
 
Stewartb said:
Yes, it does. Ask most FAA guys to get involved with an E-AB airplane and they'll tell you the FSDO doesn't do that. They'll probably give you a list or DARs. That's who does the inspection and provides the airworthiness certificate. That's 100% accurate in my case and for lots of other EX owners and builders I know.
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My point is DARs don't make the rules. And while there are FSDOs and MIDOs who choose to be less than cooperative with airworthiness inspections, there are many that are. My FSDO did mine.
 
Checkout_my_Six said:
and there is a difference between conformity and airworthiness....right? :D
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It must conform to be considered airworthy... technicalities...

Where I work, conformity inspections are performed by inspectors from the quality department, and we've been doing one or two every month (on 57, 67 and 77 aircraft) for several years now.
 
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GlennAB1 said:
It must conform to be considered airworthy... technicalities...

Where I work, conformity inspections are performed by inspectors from the quality department, and we've been doing one or two every month (on 57, 67 and 77 aircraft) for several years now.
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There is an additional item required for airworthiness.....

Remember an EAB is not conforming to a TC like the aircraft you're referring to.
 
Checkout_my_Six said:
There is an additional item required for airworthiness.....

Remember an EAB is not conforming to a TC like the aircraft you're referring to.
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Yep. In fact E-AB aircraft are never "airworthy"--they are in a condition for safe operation, but no where is it ever stated they are airworthy despite the fact they are issued a special airworthiness certificate.
 
GlennAB1 said:
I never said airworthiness as only determined by conformity, conformity is only a part.

Yeah, but they all conform to a standard.
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Care to elaborate- what standard for E-AB?
 
Bottom line is tom believes that even though he would be getting paid he is an amateur. The rule is clear, if more than 51% of the tasks were done by someone getting paid, it is not E-AB. But since tom is an amateur, he doesn't have to follow the rules.
 
GlennAB1 said:
Refer to the EAA website and the page (FAQ) pertaining to conditional inspection, argue it with them.
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LOL-- I don't have to as I'm quite conversant on the applicable regs and procedures involving both E-AB certification and ongoing maintenance since I built, certified, fly, and maintain an E-AB aircraft and hold the repairman's certificate. So your statement pertaining to a "standard" holds no merit
 
tsts4 said:
LOL-- I don't have to as I'm quite conversant on the applicable regs and procedures involving both E-AB certification and ongoing maintenance since I built, certified, fly, and maintain an E-AB aircraft and hold the repairman's certificate. So your statement pertaining to a "standard" holds no merit
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And you are required to certify it to a standard annually.
 
GlennAB1 said:
And you are required to certify it to a standard annually.
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Nope-- just that's in a condition for safe operation. I do that by following the scope and detail of part 43 IAW my oplims but there's no standard to compare it to like in the standard type certificated world. Each E-AB is a one-off for certification purposes.
 
tsts4 said:
And? What does that have to with a "standard"? You do the condition inspection within the scope of part 43 but there's no standard to compare or adhere to.
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Call it what you want. I'll quote the FAA: "14 CFR Part 43 — Maintenance, Preventive
Maintenance, Rebuilding, and Alteration
This regulation represents the heart of aviation maintenance, and is the second of the “Big Three” regulations previously identified. The 13 rules and six appendices contained within part 43 provide the standard for maintaining all 185,000 civilian aircraft currently registered in the United States."
Page 12-9, here:
https://www.faa.gov/regulations_pol...craft/amt_handbook/media/FAA-8083-30_Ch12.pdf
 
GlennAB1 said:
Call it what you want. I'll quote the FAA: "14 CFR Part 43 — Maintenance, Preventive
Maintenance, Rebuilding, and Alteration
This regulation represents the heart of aviation maintenance, and is the second of the “Big Three” regulations previously identified. The 13 rules and six appendices contained within part 43 provide the standard for maintaining all 185,000 civilian aircraft currently registered in the United States."
Page 12-9, here:
https://www.faa.gov/regulations_pol...craft/amt_handbook/media/FAA-8083-30_Ch12.pdf
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Except part 43 doesn't apply to E-AB aircraft and following the scope and detail of part does not a standard make. Now since we're into semantics, yes I follow "standards" of maintenance practices such as fastener torque values,what should be inspected, so on and so forth, but I'm still not conforming to a "standard like a type certificate. IOW there's nothing stating what my RV10 configuration should be hence no airworthiness determination since there's no such thing as a standard RV10.
 
GlennAB1 said:
There's a difference between a 99% compete kit and 99% completed kit.

99% complete kit means the builder will have to supply 1% for complete airframe kit.

You're welcome;)
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I think I mis-worded my question. Lets say I (amature, in my garage) get the airframe complete, and on it's own three feet. Zero electrical, zero control cables/rigging, zero plumbing, zero instruments, nothing other than assembling the airframe. Nothing FWF, no interrior, no paint. What percentage would have been completed? If I hire someone to do the rest to complete it, will I have met the 51% rule?

The second part of my question was in reference to advertisement for kit built aircraft (insert kit of choice here) 99% completed, just needs fwf, and radios, yada yada.
 
unsafervguy said:
Bottom line is tom believes that even though he would be getting paid he is an amateur. The rule is clear, if more than 51% of the tasks were done by someone getting paid, it is not E-AB. But tom is an amateur
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FTFY because I am not considered a Commercial aircraft building facility. I do not manufacture parts for kits. I can add professional assistance, just as any other person.
 
bluerooster said:
I think I mis-worded my question. Lets say I (amature, in my garage) get the airframe complete, and on it's own three feet. Zero electrical, zero control cables/rigging, zero plumbing, zero instruments, nothing other than assembling the airframe. Nothing FWF, no interrior, no paint. What percentage would have been completed? If I hire someone to do the rest to complete it, will I have met the 51% rule?

The second part of my question was in reference to advertisement for kit built aircraft (insert kit of choice here) 99% completed, just needs fwf, and radios, yada yada.
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Two parts to your question,
Part one -- there is a percentage chart in the AC listed above, giving what the FAA thinks is a percentage for each item.
Part two-- I assume that you are thinking that there are partial build kits for sale listed as 99% completed. These can be sold in two ways. as an aircraft on a bill of sale form 8050-2, which tracks the kit serial number. or the second sold as parts, be careful this way, because the FAA will want to know which kit these parts came from or who built them.
 
A while back ( uncertain about time ) the FAA changed the format of the letter of limitations for X/AB aircraft, prior to this change the letter did not contain guidance as to what a Condition Inspection would contain. After the format changed they now say that the Conditional Inspection will contain the items in FAR 43-D as the minimum requirement.
 
Checkout_my_Six said:
Remember an EAB is not conforming to a TC like the aircraft you're referring to.
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But it must conform to its letter of limitations. which can contain items that the FAA believes pertinent.
 
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