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Repairman Certificate Issues related to 51% rule?!

BobbyLucas

Well Known Member
So a Van's Rep is telling people that "you need to prove the the FAA that you built 51% of the aircraft to get your airman repairman certificate."

I believe this to be 100% incorrect. The 51% rule is for the EAB airworthiness certification of the aircraft and has nothing to do with the repairman certificate.

Here is what the FAA says in AC 20-27G section 17: "You can get a [repairman] certificate if you are — a. The primary builder of your aircraft, even as the second builder, and can satisfactorily prove to us that you can determine whether the aircraft is in a condition for safe operation." I don't know how you prove it to them, but it's not that you built 51% of the plane.

I had a potential buyer who was concerned about meeting the 51% rule if he bought my partially complete empennage kit and then also did the quickbuild wings and fuse. I explained that the 51% rule only meant that 51% of the plane had to be built by amateurs and that he could buy a 99% complete plane built by 100 amateurs and still have it certified EAB, QB or not. I also explained the repairman cert as above.

The buyer then said he wanted to talk to Van's and after doing so he decided to pass and forwarded me the email with the quote above. I don't know if the misinformation was why he decided to pass on my kit as the Van's rep also tried to talk him out of buying any partial kit for other reasons(edit: which is fine). Still upsets me though (edit: the misinformation part). :mad:
 
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That is how I read it, just looked at it. I am relatively new to EAB. I have seen numerous posting on here warning about 51% and repairmen cert (along with registration problems) when folks purchase partial kits on here.
 
Bobby?s right....

Bobby, you are correct. I know of (2) recent cases where the project was 90% finished, and the end-builder received the repairman certificate. Paperwork was all in order. Just the facts here, not going to drift off-topic on quality, builder experience, etc.
 
Maybe we should be asking if someone who didn't build 51% of the aircraft should get a repairman certificate for that aircraft?
 
Since the OP didn't post the entire e-mail we don't really know what the context of "tried to talk him out of it" is.

It was likely the same context as THIS DOCUMENT FROM VANS WEB SITE.

Keep in mind that Van's stays in business buy selling kits. As part of that, second (third, forth, even fifth, etc.) hand kits have always been fully supported. In the process of doing that, tech. support regularly has to help customers clean up the mess that the new owner unknowingly bought. It is for that reason that any second hand kit purchase query to Van's will always receive cautionary advise.

As far as a requirement that 51% of the build be done to meet requirements for issuance of a repairman's certificate... I agree, it is not a requirement. But, since there is no absolute spec., FSDO's around the country (and even individual ASI's) have regularly imposed their own personal interpretation on what the definition of "demonstrating sufficient knowledge of the airplane" entails" is.
There are countless people that have been denied when most of us would feel they were fully entitled to receive one.
 
No

Maybe we should be asking if someone who didn't build 51% of the aircraft should get a repairman certificate for that aircraft?

No. Off post drift, and no need to pontificate. The rule (repairman certificate) is stated, so that is what the OP is Discussing. No ?if?s,? ?should-be?s,? etc.
 
Since the OP didn't post the entire e-mail we don't really know what the context of "tried to talk him out of it" is.

It was likely the same context as THIS DOCUMENT FROM VANS WEB SITE.

Keep in mind that Van's stays in business buy selling kits. As part of that, second (third, forth, even fifth, etc.) hand kits have always been fully supported. In the process of doing that, tech. support regularly has to help customers clean up the mess that the new owner unknowingly bought. It is for that reason that any second hand kit purchase query to Van's will always receive cautionary advise.

As far as a requirement that 51% of the build be done to meet requirements for issuance of a repairman's certificate... I agree, it is not a requirement. But, since there is no absolute spec., FSDO's around the country (and even individual ASI's) have regularly imposed their own personal interpretation on what the definition of "demonstrating sufficient knowledge of the airplane" entails" is.
There are countless people that have been denied when most of us would feel they were fully entitled to receive one.

I take no issue with Van's discouraging buying used kits - I totally get that. And the other things he mentioned are valid personal opinions, some of which I share - no issue there. If those reasons are why the buyer passed, no problem. What I take issue with is presenting a false statement as fact. 51% is not an FAA requirement for issuing an EAB repairman's certificate. Spreading false information does a disservice to the entire community. Note - I am NOT saying he did it knowingly at all, I'm sure a lot of people are confused in that area.
 
Maybe we should be asking if someone who didn't build 51% of the aircraft should get a repairman certificate for that aircraft?

The percentage that the person built should have very little to do with it IMO. I understand the thinking is that what a person has done ought to correlate in some way with what they know.

But if I think if we were to use the percent of work a person did on the airframe as the only metric in determining whether or not a repairman cert is issued, we will most certainly end up with cases where people who are perfectly capable of maintaining their aircraft are denied and worse yet, people who really shouldn't be maintaining their aircraft are issued certs.

I'm also not saying the system we have now is perfect. But using an arbitrary number of tasks completed during the build as the determining factor for qualification would be a mistake IMO.
 
No. Off post drift, and no need to pontificate. The rule (repairman certificate) is stated, so that is what the OP is Discussing. No “if’s,” “should-be’s,” etc.

Since this is clearly a question of interpretation the intent of the rule is absolutely part of the discussion ;)
 
If the 51% rule applied to the repairman certificate, no one could get it if they had multiple builders. The 51% rule is that the majority of the aircraft must be built by "amateurs"!

The requirements for the repairman certificate is that the applicant must be listed as a primary builder on the registration application, and he/she must prove that they have enough knowledge about the build to competently accomplish the condition inspection.
 
If the 51% rule applied to the repairman certificate, no one could get it if they had multiple builders. The 51% rule is that the majority of the aircraft must be built by "amateurs"!

The requirements for the repairman certificate is that the applicant must be listed as a primary builder on the registration application, and he/she must prove that they have enough knowledge about the build to competently accomplish the condition inspection.

Exactly. One question though, in what way is the applicant asked to prove they have the knowledge; a test, an informal interview? Doesn't sound like there's a standard. Or is it just assumed unless there's a red flag in the paperwork?
 
Exactly. One question though, in what way is the applicant asked to prove they have the knowledge; a test, an informal interview? Doesn't sound like there's a standard. Or is it just assumed unless there's a red flag in the paperwork?

There is no "standard". This is determined by an informal interview with a FSDO inspector.
 
There is no "standard". This is determined by an informal interview with a FSDO inspector.

Yep. I was grilled on aircraft syetms, primarily the engine, for over an hour by my FSDO inspector when I appiled for my repairman's certifiacte. On the other end of the spectrum I know of others that just had to show up and submit the appilication with little to no discussion whatsoever.
 
There has been a few "builder assist" programs that abused the Repairman certificate. Basically it was 99% built by "assistance" and the buyer was builder, manufacture, repairman. This was a work around certified aircraft production and selling completed planes. NOTE NOT ALL BUILDER ASSISTANCE IS A WORK AROUND...

The INTENT and SPIRIT of the amateur built aircraft category was and is LEARNING.... If I was FAA inspector interviewing the "builder" of an RV and they could not explain the basics of riveting, FWF, fuel system, electrical system, flight instruments, brakes, fiberglass.... what ever is relevant, I WOULD DOUBT THEY QUALIFY AS BUILDER and REPAIRMAN. It would be hard to learn much doing 1% of the build.

Based on the fact the QB kits are 51% legal and are structurally very complete, there is a lot of emphasis on finishing, FWF, systems.... I would agree with that. However if you get a kit that is complete and you pop rivet on the data tag, I don't think you qualify.... based on the intent and spirit. What are you going to say if the FED asks you, "How much of this did you build and prove it..." you might be in trouble.
 
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There is no "standard". This is determined by an informal interview with a FSDO inspector.

And the more evidence you can bring to that interview, the better. I showed up with two armloads of binders full of parts receipts, drawings, 5 binders of builders log with more than 2000 pictures and they still worked me over for about an hour and a half before accepting that I knew the plane inside and out. They would ask me something like "How did you install the cabin heat?" and I would pull the appropriate buildlog entries and photos to show it - or the injectors, or the throttle linkage, ELT installation, trim tab, etc etc.

It doesn't take long for them to figure out if you know the airplane well or not - but it does take a while to cover all the relevant PARTS of the airplane that you need to know in order to get the repairman certificate.

My experience was at the Lubbock, TX FSDO, it was pleasant enough but long and full of delays while they looked up relevant paperwork.
 
For my latest project I emailed the FSDO inspector a link to my online build log a few days before the "interview". As a backup I took a single binder with a hard copy of the log to the interview which consisted of making sure the paperwork was correct. The only comment was "That aircraft involved a lot of work". Sending the web link ahead of time really expedited the process and turned it into a 15 minute paperwork exercise.
 
I just had a camera record and upload video automatically whenever we were in the shop working .. just sent the FSDO a link to the videos .. done!
 
Ditto what Sam said. About a week prior to my interview with the FSDO, sent the inspector a link to my builder's blog. The day of the "interview" I showed up with two thick binders .... one being my builder's log documenting the activity of each work session and the other thick binder contained well over 200 photos of the build progress ... with me in every photo performing various tasks.

As we were walking into the meeting room, I casually asked the inspector if he had visited my builder's blog and was told "yes" .... and he said "there is no doubt in my mind, you built the airplane". He followed up that statement by saying he could tell I built the airplane because I was wearing different T shirts in the photos as he scanned from day to day on the blog.

He kinda laughed, then mentioned how some guys try bring in a few photos posing as if they are doing various assembly tasks and saying they built the airplane .... but are wearing the same shirt in every photo.

During the interview, my builder's log and photo album was paged through and questions were asked ... but I did not feel as though I was being grilled.

The takeaway ... having a builders blog with lots of photos of you doing the work is a good thing. At the very least, keep a detailed builders log documenting each work session's activities and during the build, take lots of photos of yourself actually doing the work (and don't wear the same shirt daily LOL).
 
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