Bob White wrote:

On Mon, 1 May 2006 19:56:43 -0700
"Joe Hull" <joeh@pilgrimtech.com> wrote:

I think the A&P may be a problem also.  I need one because I didn't
build the airplane.  He sounded OK when I first talked to him, but more
recently he's been talking about checking to make sure the plane was
built to plans and stuff.  I think he's supposed to check the brakes,
make sure the flaps aren't falling off, etc.  I think his implication
is that the original builder could modify anything he wanted to, but
that I can't.  This view seems to me to go beyond the roll of the A&P
as I understand it.  I may have to find another one that understands
experimentals.

Bob, I hate to say it but I think your DAR is right on the A&P. Since you
aren't the original "Manufacturer" you can't hold a "repairman's
certificate" for your plane. I asked my DAR what would happen if I wanted to
buy an old Long-EZ and restore it. He said I could do the work but I'd have
to get an A&P to sign it off. So, you can still do the work but you have to
find an A&P that is will to inspect your work and sign off in your Airplane
Log.
Joe Hull
Cozy Mk-IV #991 (In Phase1 Flight Test - 10.9 hrs flown) Redmond (Seattle), Washington

Hi Joe,

Getting the repairman's certificate is definitely out.  I've known that
since purchasing the plane.  The A&P was making noises to the effect
that I couldn't modify the plane since I wasn't the original builder.
If he's concerned about the mods and won't sign off, that's one issue,
but AFAIK, I can make any mods I want as long as an A&P signs off.

Bob W.

Here are a few observations & comments, some of which can be backed up with a visit to the EAA website & some of which are direct personal experience.

1. The repairman's ticket is at the whim of the FAA. You can build 100% of the airframe, mine the ore, etc & if you can't convince the FAA that you can competently maintain the plane, they don't have to issue the ticket. There are also documented cases where the FAA knew that the a/w cert applicant only built the last 5-10% of the plane (rest was amateur built, of course) & the FAA still issued the repair ticket based on their confidence in the applicant's ability. Most, if not all of this is documented on the EAA web site.

2. The DAR's & a/p's are incorrect about alterations to an already-licensed homebuilt. Anyone, or anything, can work on, modify, rebuild etc a homebuilt. Return to service requirements basically depend on when the a/w cert was issued but never repeat never involve an a/p unless you desire it. For a/w certs issued in the 'old days' you must call the FAA, they do a (minimal) re-inspection & issue a new a/w cert. In the not-so-old days (but before 911), certs were issued with language that allowed a log entry documenting the change & putting the a/c back in phase 1 test for 5 hrs in the original test area defined when the a/w cert was issued. After 5 hrs test time, a log entry returns the plane to normal service. No officials of any sort are involved. Post 911 a/w certs add a restriction that you must notify the FAA of your intent to return to phase 1 & get their new ok on the proposed test area. All else is as the not-so-old days. A/p involvement need not occur until the next annual condition inspection and that is only to do the inspection, not sign off any mods. I've been down all three routes with various homebuilts, none of which I built. To re-state: The only thing you need an a/p or DAR for is signing off a condition inspection; your dog can change an engine & convert to tailwheel if you can teach him how & convince him to do it & as long as you follow the directions in your particular a/w cert, you can return the plane to service legally.

3. Removing a dataplate & disassembly/reassembly to get your name on the a/c as builder is specifically prohibited, but it has happened.

Now, I can't guarantee that your particular FSDO actually understands their own rules....

Hope this info will make your modification life easier....

Charlie




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