Repairman certificate

[crawford]

Can an individual that purchases a kit built aircraft from someone, get a repairman certificate to do his own annual and repairs?

[Marc Zeitlin]

Can an individual that purchases a kit built aircraft from someone, get a repairman certificate to do his own annual and repairs?If an RC has ever been issued for an EAB aircraft, then the answer is no, as only ONE RC can ever be issued for a give aircraft. But if you purchase a partially built kit/project that has never had an RC issued and can demonstrate knowledge of the aircraft to the DAR/FAA, then they can issue an RC for that aircraft to you.

The RC (or an A&P - no IA necessary) is ONLY necessary to sign off the Condition Inspection - other than that, ANYONE can do ANY work on ANY EAB aircraft.

[cub builder]

Can an individual that purchases a kit built aircraft from someone, get a repairman certificate to do his own annual and repairs? As long as no repairman certificate has been issued for that aircraft AND you can convince your local FSDO that you have sufficient knowledge of the construction of said aircraft to properly maintain it, you can get the repaimans certificate. It's easy if you are buying an unfinished aircraft because you can take photos of yourself working on the unfinished aircraft, which is usually the "proof" FSDO wants to see. It's more challenging if you are buying a completed flying aircraft, but can be done. When I built my SuperCub, I purposely did not get the Repairman Certificate since I can maintain it under my A&P license. That leaves the next owner eligible to get the repairmans certificate if he can convince FSDO he has sufficient knowledge. -Cub Builder

[ulpilot]

How does one find out if a repairman certificate as been issued for a particular homebuilt? The original builder of mine is deceased, and I am the 3rd owner.

[Dana]

What do the logbooks show? If the original builder signed off his own annuals, then he must have had the certificate (and it will show the number). If an A&P signed off the annuals, he probably didn't (though why he wouldn't, I can't imagine).

[Anymouse]

But if you purchase a partially built kit/project that has never had an RC issued and can demonstrate knowledge of the aircraft to the DAR/FAA, then they can issue an RC for that aircraft to you.

Here's a slightly different scenario. A few years ago I purchased an aircraft that was pretty much a basket case. It's been stripped to the frame and I'm hoping to finish re-building it in the next year or two. No Repairman Certificate has been issued. Assuming I provide documentation of this project, can I apply for and receive a Repairman Certificate?

[Marc Zeitlin]

Here's a slightly different scenario. A few years ago I purchased an aircraft that was pretty much a basket case. It's been stripped to the frame and I'm hoping to finish re-building it in the next year or two. No Repairman Certificate has been issued. Assuming I provide documentation of this project, can I apply for and receive a Repairman Certificate?I assume you're discussing an EAB aircraft here. If no RC has ever been issued for it, then yes - you can apply for one. If you can show to the FAA's satisfaction that you are knowledgeable enough (where who knows what "enough" is defined as in the FAA's world) then there's no reason they shouldn't issue you an RC. I will say, though, that people get fixated on getting the RC for and EAB aircraft, and it's really just NOT that important (and I say that as an A&P that will have signed off 14 CI's this year, and 30 over the past three). The ONLY thing the RC lets you do is sign off the CI, and that's just not a huge part of the maintenance or care of the aircraft, and not a huge part of the cost, either. All I'm saying is that don't let whether or not you can get the RC on a particular aircraft be the determining factor in whether you take on the project or not - if it's the plane for you, then do it, whether or not you can get the RC for it.My $0.02.

[cub builder]

I assume you're discussing an EAB aircraft here. If no RC has ever been issued for it, then yes - you can apply for one. If you can show to the FAA's satisfaction that you are knowledgeable enough (where who knows what "enough" is defined as in the FAA's world) then there's no reason they shouldn't issue you an RC. I will say, though, that people get fixated on getting the RC for and EAB aircraft, and it's really just NOT that important (and I say that as an A&P that will have signed off 14 CI's this year, and 30 over the past three). The ONLY thing the RC lets you do is sign off the CI, and that's just not a huge part of the maintenance or care of the aircraft, and not a huge part of the cost, either. All I'm saying is that don't let whether or not you can get the RC on a particular aircraft be the determining factor in whether you take on the project or not - if it's the plane for you, then do it, whether or not you can get the RC for it.My $0.02.

The knowledge level applied to get your RC for this aircraft should be the same as that of the original builder. Photo document the aircraft while torn down to it's smallest pieces. Make sure you have several photos that include YOU working on it while in it's smallest pieces, and during all phases of the rebuild. That SHOULD satisfy an airworthiness inspector that you have sufficient knowledge to tear the aircraft down to it's smallest pieces, inspect it, and rebuild it. That should suffice.

For the original builder, the Airworthiness Inspector usually requires that there be at least one photograph of you working on the aircraft at some point before it is ready to fly. If you exceed that level of documentation, you should be fine.

-Cub Builder

[martymayes]

Having requisite knowledge of the aircraft is only part of the puzzle.

The FAA 8900.1 inspector handbook, http://fsims.faa.gov/PICDetail.aspx?docId=8900.1,Vol.5,Ch5,Sec5 , says only the primary builder is eligible for a repairman certificate.

Under the paragraph of eligibility it makes qualifying statements to define primary builder. For example, it says an individual working alone must build the major portion of the aircraft. If built by a group, only one person of the group is eligible for a repairman certificate.

The FAA inspector handbook makes no reference to "rebuilding" an E/AB aircraft. If you use the original dataplate, it usually has the primary builder's name engraved and reference to the primary builder in the documents. I think one would have to qualify for a repairman certificate in the same manner as the original builder. My advice would be work with an FAA ASI to ascertain a rebuild will qualify one as eligible for a repairman certificate before making formal application. Making false testimony to the FAA carries an unpleasant penalty.

[cub builder]

Having requisite knowledge of the aircraft is only part of the puzzle.

The FAA inspector handbook makes no reference to "rebuilding" an E/AB aircraft. If you use the original dataplate, it usually has the primary builder's name engraved and reference to the primary builder in the documents. I think one would have to qualify for a repairman certificate in the same manner as the original builder. My advice would be work with an FAA ASI to ascertain a rebuild will qualify one as eligible for a repairman certificate before making formal application. Making false testimony to the FAA carries an unpleasant penalty.

Good points Marty. As always, you should have a discussion with an inspector at your local FSDO before you spend your $$.

Often times it's a crap shoot of who you get at FSDO as to whether you can get things done or not, but that's the FAA we live with. If you know a particular inspector at your local FSDO that has a reputation for working with builders and pilots to accomplish things, it's best to start with that particular Inspector. If his answer is that you can't do it, then there's your answer. One thing I've found with the good folks at FSDO is that nearly every FAR is subject to local interpretation and the handbooks are further subject to interpretation by the individual inspectors. Sometimes that's a good thing, and sometimes it's not. I've had experiences both ways with FSDO.

-Cub Builder

[Anymouse]

Thanks Marc, Cub and Marty!

Unfortunately, I find myself in the same place: Go check the FSDO!

The good news is that getting a Repairman Cert is not a big deal for me. I already have one for my Tango, so I know the limitations and sole privilege. It would be nice if I can get one, but the decision to buy this project was not made on that hope.

I'll probably document as normal and if I decide to try the RC thing, all I'll have to do is fill out the paperwork and then see what the FSDO says.

[cub builder]

There is an article in the current issue of KitPlanes that may be useful in discussion. Under "Ask the DAR", he says you must be listed as a builder on form 8130-12 to be eligible for a Repairmans Certificate. So the question to your local FSDO Airworthiness Inspector would be to ask if under your circumstances whether you would be allowed to file an amended form 8130-13. My guess is that the answer is likely to be no, but you won't know unless you ask.

-Cub Builder

[Marc Zeitlin]

There is an article in the current issue of KitPlanes that may be useful in discussion. Under "Ask the DAR", he says you must be listed as a builder on form 8130-12 to be eligible for a Repairmans Certificate. So the question to your local FSDO Airworthiness Inspector would be to ask if under your circumstances whether you would be allowed to file an amended form 8130-13. My guess is that the answer is likely to be no, but you won't know unless you ask.

-Cub BuilderInteresting. I could find no documentation that supports this contention. Not to say that it doesn't make some sense, since 8130-12 does say to list ALL builders. So if the 8130-12 had already been filed, then it would seem that an amended one would be useful to ensure that the new builder's name is on it.

The EAA states, at:

https://www.eaa.org/en/eaa/aviation-communities-and-interests/homebuilt-aircraft-and-homebuilt-aircraft-kits/frequently-asked-questions/how-to-get-your-repairman-certificate

that THEY consider the primary builder to be:

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.

So there's another form that the person applying for the RC would have to ensure has their name on it.

[1600vw]

Interesting. I could find no documentation that supports this contention. Not to say that it doesn't make some sense, since 8130-12 does say to list ALL builders. So if the 8130-12 had already been filed, then it would seem that an amended one would be useful to ensure that the new builder's name is on it.

The EAA states, at:

https://www.eaa.org/en/eaa/aviation-communities-and-interests/homebuilt-aircraft-and-homebuilt-aircraft-kits/frequently-asked-questions/how-to-get-your-repairman-certificate

that THEY consider the primary builder to be:

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.

So there's another form that the person applying for the RC would have to ensure has their name on it.



I know of a man who purchased a project that was almost done. He wanted pics of him building this project for just the reason stated here. So he could get this RC. He went to the local building supply center and purchased some wood.

He took this wood and started building his airplane. Took pics to show he did the work then scrapped the whole deal. He now has pics showing him building what looks like his airplane. He got the RC for this. Not the best way to do it but how he did it. Now I am not saying do this. But how this man did it.

[Byron J. Covey]

I know of a man who purchased a project that was almost done. He wanted pics of him building this project for just the reason stated here. So he could get this RC. He went to the local building supply center and purchased some wood.

He took this wood and started building his airplane. Took pics to show he did the work then scrapped the whole deal. He now has pics showing him building what looks like his airplane. He got the RC for this. Not the best way to do it but how he did it. Now I am not saying do this. But how this man did it.

A fine example of a man without honor. Just what we need in the EAA and sport aviation.


BJC

[1600vw]

A fine example of a man without honor. Just what we need in the EAA and sport aviation.


BJC



I find this kinda funny. For many know this man and he is respected by many. He has won awards for his builds and the airplane I speak of won some awards not long ago.

It would be nice to see this man sometimes and drop in on him. But I am never in his neck of the woods. Someday I may travel to see him again. A very very nice man and would help anyone that he could. My hat does go off to this man.

This airplane was sold sometime ago and now has changed hands a few times. Its maintained by an A&P today, not that it matters.

[martymayes]

I know of a man who purchased a project that was almost done. He wanted pics of him building this project for just the reason stated here. So he could get this RC. He went to the local building supply center and purchased some wood.

He took this wood and started building his airplane. Took pics to show he did the work then scrapped the whole deal. He now has pics showing him building what looks like his airplane. He got the RC for this. Not the best way to do it but how he did it. Now I am not saying do this. But how this man did it.

Pics of him building the project are not required in order to obtain a repairman certificate - there is not a single FAA pub that requires it. Instead of using all that money, energy and effort to create an unnecessary hoax, he could have been well on his way to building another airplane.

[Byron J. Covey]

I find this kinda funny. For many know this man and he is respected by many. He has won awards for his builds and the airplane I speak of won some awards not long ago.

It would be nice to see this man sometimes and drop in on him. But I am never in his neck of the woods. Someday I may travel to see him again. A very very nice man and would help anyone that he could. My hat does go off to this man.

This airplane was sold sometime ago and now has changed hands a few times. Its maintained by an A&P today, not that it matters.

So you condone his dishonesty because he is an excellent craftsman?


BJC

PS. I, too, know some highly skilled people (thinking of business men here, not homebuilders) who are dishonest. I can appreciate their skill, but I do not respect them.

[1600vw]

So you condone his dishonesty because he is an excellent craftsman?


BJC

PS. I, too, know some highly skilled people (thinking of business men here, not homebuilders) who are dishonest. I can appreciate their skill, but I do not respect them.



I did not say anything for what business is it of mine? This was a fuselage only. He built every other part. So really he never needed to do this but he did anyway. Really nothing dishonest. I know of a man who built over seven flying airplanes all built from hardware store wood, or wood purchased from your local lumbar yard. Who is to say he did not use this fuselage and not the one that was built by the other builder, whom also happened to be one who has won awards for his builds. This was his last build and never got it past the fuselage stage.

I never said one way or the other if I condone this or don't condone this. But what does that matter? When did I become the Aviation police. Above my pay grade.

[Auburntsts]

Interesting. I could find no documentation that supports this contention. Not to say that it doesn't make some sense, since 8130-12 does say to list ALL builders. So if the 8130-12 had already been filed, then it would seem that an amended one would be useful to ensure that the new builder's name is on it.

The EAA states, at:

https://www.eaa.org/en/eaa/aviation-communities-and-interests/homebuilt-aircraft-and-homebuilt-aircraft-kits/frequently-asked-questions/how-to-get-your-repairman-certificate

that THEY consider the primary builder to be:

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.

So there's another form that the person applying for the RC would have to ensure has their name on it.


Yeah but on the 8710-1, application for airman's certificate, you have to list the project as justification for issuance. Kind of hard to do that if you aren't listed as a builder. Having said that, there's no specified amount of work that the applicant has to do on the project -- set one rivet and technically you qualify as far as the application is concerned. The big question is does the applicant have the requisite knowledge to maintain the aircraft. For most of us we gain that knowledge via the build. However, for others, they come into the project with that knowledge.

In my case, even though the FSDO (Washington) knew I was the builder, because I had a different inspector for my repairman's cert interview, I was grilled on my overall maintenance knowledge. He really wasn't concerned with the airframe because he knew I built it. His focus was FWF. I was prepared and passed the interview but it wasn't a cake walk.

[Marc Zeitlin]

Yeah but on the 8710-1, application for airman's certificate, you have to list the project as justification for issuance. Kind of hard to do that if you aren't listed as a builder.Pretty sure you mean 8610-1 (which is the one you use for the RC application). But yes - you're correct - if you're getting the RC for a particular plane, that would be the one you'd have to list on that form as the "Record of Experience". And then there would certainly be a discontinuity if you weren't listed on the 8130-12 (but again, they'd have to cross-check).

So it seems as though, to make things right with no chance of paperwork issues, there have to be three forms that all agree - the 8130-12 (list all builders), the 8130-6 (who says it's ready for an AC) and the 8610-1 (the actual application for the RC). Although I suppose, if there are multiple builders, one could argue that the EAA's position isn't totally accurate since builder "A" could say it's ready for an AC while builder "B" gets the RC.

Angels dancing on the head of a pin, at this point...


Having said that, there's no specified amount of work that the applicant has to do on the project -- set one rivet and technically you qualify as far as the application is concerned. The big question is does the applicant have the requisite knowledge to maintain the aircraft. For most of us we gain that knowledge via the build. However, for others, they come into the project with that knowledge.Agreed.


In my case, even though the FSDO (Washington) knew I was the builder, because I had a different inspector for my repairman's cert interview, I was grilled on my overall maintenance knowledge. He really wasn't concerned with the airframe because he knew I built it. His focus was FWF. I was prepared and passed the interview but it wasn't a cake walk.Which just goes to show you that the FSDO's are all different, and change over time. I don't think that I was even asked any questions about the plane when my RC was issued - maybe a couple of minor ones, but nothing resembling a "grilling". They figured if I built it (which I had well documented) that I knew something about it. But obviously, YMMV, as every FSDO has their own interpretation of the rules.

[Auburntsts]

Oops - you're right it was the 8610 but the dash 2 not the dash 1 for me. I agree with you overall. The point is all of the paperwork has to match. Also agree 100% on the differences between FSDOs. My guy really wanted to make sure I understood how to maintain the engine and its systems since he had no idea as to my expertise as that is not truly discernable by inspection. For the same reason he didn't care about my builder's log.

[martymayes]

I think both of these cases follow the 8900.1 handbook guidance I posted earlier very closely. There is more than one path for the inspector to follow when issuing a repairman certificate. For example, documentation and/or asking the applicant to demonstrate he has the necessary skills to perform condition inspections and an ability to determine whether or not the aircraft is in a condition for safe operation.


In my case, even though the FSDO (Washington) knew I was the builder, because I had a different inspector for my repairman's cert interview, I was grilled on my overall maintenance knowledge. He really wasn't concerned with the airframe because he knew I built it. His focus was FWF. I was prepared and passed the interview but it wasn't a cake walk.

Sounds like you had to prove to the satisfaction of the inspector that you had the requisite skills. Completely in line with the guidance.




Which just goes to show you that the FSDO's are all different, and change over time. I don't think that I was even asked any questions about the plane when my RC was issued - maybe a couple of minor ones, but nothing resembling a "grilling". They figured if I built it (which I had well documented) that I knew something about it. But obviously, YMMV, as every FSDO has their own interpretation of the rules.

Sounds like the documentation was adequate to prove to the satisfaction of the inspector. Or, if you held an A&P certificate at the time you applied for a repairman certificate, I would certainly think that would be adequate to show you have the requisite skills to perform inspections. After all, A&P's are trained on how to inspect aircraft. Again, completely in line with the guidance.

I like the fact that an inspector's guidance is not rigid. One might not feel that way during the process but having been tested by the FAA many times over the years I have found if you are prepared and have the requisite knowledge, the process is painless. Prepare for the worst and celebrate when it's not.

[Marc Zeitlin]

Or, if you held an A&P certificate at the time you applied for a repairman certificate, I would certainly think that would be adequate to show you have the requisite skills to perform inspections. After all, A&P's are trained on how to inspect aircraft. Again, completely in line with the guidance.I don't disagree, but I got the A&P 12 years later :-).

...Prepare for the worst and celebrate when it's not.And this is about the best advice for being happy in ANYTHING :-). Low expectations.

[Anymouse]

...if you held an A&P certificate at the time you applied for a repairman certificate, I would certainly think that would be adequate to show you have the requisite skills to perform inspections. After all, A&P's are trained on how to inspect aircraft. Again, completely in line with the guidance.

Not disagreeing with you at all here, but I just have to wonder why an A&P would bother with getting a Repairman Certificate. The only benefit would be an extra piece of plastic to keep up with.

[Dana]

He said he got the A&P 12 years later...

But some A&Ps go ahead and get the repairman certificate anyway. The idea is that if their is ever an incident related to the aircraft's condition and the FAA pursues certificate action against whoever signed it off, it will be against his repairman certificate, not the more valuable A&P certificate.

[martymayes]

Not disagreeing with you at all here, but I just have to wonder why an A&P would bother with getting a Repairman Certificate. The only benefit would be an extra piece of plastic to keep up with.

I would apply for a repairman certificate for any aircraft I built. You are correct, not needed but I would do it just because I can.