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Dear Edde,
Per AC 20-139A, FAA Pub 8130.2(D) and FAR
21.191(g), for qualifying to Register and becoming a Repairman: The link
says:
The fabrication and assembly operation listed in
FAA Form 8000-38 are the ONLY things FAA inspectors are concerned with when
determining the status of your amateur-built experimental aircraft. If you
have been 'involved in performing' ANY of these operations, you earned gained
credit for having performed that operation and toward establishing amateur-built
status for your plane.
There are 119 fabrication and assembly operations
for a standard fixed wing aircraft, and you'd need to be 'involved in' 60
of them. That qualifies you as a Repairman for that plane, and for to
register it. Hours or effort has nothing to do with it, says
FAA.
If your kit is already
Registered, the next step is 'Certification', i.e. Airworthiness. See FAA
Advisory Circular 20-27F (dtd 9/26/03 ... so far)
The FAA is adding a lot of 'clarification' to their
rules pertaining to kits, and for some reason these are more demanding for
kits than those for Certifying a plans-built. One would think the opposite
should be true. Further, they seem to be applying requirements published
in just the last three or four years to as-yet-incomplete-kits which may be
twenty years old or so ... confusing ' grandfather'... and lateralling it
over to FAA DAR inspectors, who the builder pays, thereby creating a
conflict of interest. So, everybody's trying to make it work, and we
just have to do the best we can, especially when buying and completing an
older partially built kit.
Additional or contrary comments are
invited.
T.
EAA 5572, tech Counslr/Flt. Advsr.
...working to certify L235 kit
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----- Original Message -----
Sent: Friday, July 23, 2004 10:44
PM
Subject: [LML] Epic aircraft
I wonder if some of you got the
announcement from Epic aircraft that they flew their first prototype
recently. The CEO is Rick Schrameck (my memory says - he's one of us,
right?) Anyway, the price of the plane is $1.1 million but it will initially
be certified in the "amateur built category". I thought the rules were
simply: You build 51% of the plane and you get to fly in the
'experimental class'. And you can sell the plane too. If you don't
build the plane, you buy a 'certified' model.
If Rick is building planes for
sale, he's the same as Piper and Cessna, and should be playing
by the same rules. Similarly for the 'builder assist' guys out
there: If you're building the IVs for other owners who have not put
anywhere near 51% of the effort (who's kidding who here) then there's going to
be trouble at some point.
Maybe Epic's got it all worked
out. But this is no joke. There are an awful lot of IVs going down
and it's only a matter of time before someone takes out a school bus loaded
with kids. The paperwork better be squeaky clean, or, not only will
there be hell to pay, but our category could be at risk.
Maybe I'm wrong, but I'm thinking
that some guys (that are circumventing what I understand to be the spirit of
the amateur built class, and probably not even on this list) are putting our
existence at risk.
I look forward to having my mind
put at ease...
Ed de Chazal
Lowly 360 driver (and
builder)
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