Hello all,

I hope this hasn't been discussed previously; I've done a search and came up with very little. I've seen posts where someone would mention they would like to re-certify to experimental, but no one has detailed the procedure.
I have a 75 7GCBC that will likely need a rebuild in a couple years... I love the plane and I would like to incorporate some mods to make it suit my style better. I don't want to go down the STC route as it's cost prohibitive and the mods are very limited for this type. I've asked around and the answer I get from most is that it cannot be done... unless I certify it under Exhibition Experimental... I have no desire to do that. I would think that if I were rebuilding the plane anyway, why not go exp, right?
Any thoughts and or experiences?

Thanks!

Your best bet is to go talk to the FAA in the form of your local FSDO.

In the distant past, the FAA permitted a few certified airplanes to be converted from standard airworthiness to Experimental-Amateurbuilt. That simply never happens nowadays, for a couple of reasons.

First, the E-AB category is intended to offer educational and learning opportunities to the builder. Simply changing airworthiness certificates, then modifying a few things really doesn't fit. In fact, the title: Amateur Built pretty much says it all.

Second, the E-AB category, to ensure the criteria are met, requires that you build 51 % of the aircraft. ANd, that doesn't mean you bolt a bunch of certified parts together....it means you BUILD a substantial part of the airplane. It's pretty hard to get 51 % credit by modifying a standard category airplane.

There are other "flavors" of Experimental aircraft, but they tend to be pretty limiting:

Experimental Airshow and Exhibition: This is the category that many airshow performer's hot rod aerobatic airplanes operate in, as well as some warbirds. The category requires that at the start of each year, you provide the FAA with a list of "airshows and exhibitions" you will show the airplane at this next year. That is the only flying you're allowed to do, with the exception of "routine recurrency" flying. Frankly, a number of the folks operating in this category do a lot of "routine recurrency" flying.....

For reference, there is a Cessna 170 for sale on Barnstormers in this category (added a turbocharged engine) that's been for sale at a rock bottom price for months now. That category isn't very desireable.

Experimental Flight Test: This category is used by developers of mods or new aircraft types. Typically you'll have a specific area within which you're allowed to fly hte airplane, but not outside that area. No passengers, unless they are required crew. And, these certifications almost always come with a time limit, at the end of which the airplane has to be either certified with the mods, or converted back to compliance with its TC.

Frankly, you'll be better off to sell that airplane and buy one that's already modified, or bite the bullet and modify (via stc) the one you have.

MTV

MTV,

Thank you for your input and quick reply, I very much appreciate it.
I will be at the FSDO in a couple weeks, so I will take that opportunity to talk to someone about it.
Funny that I've built a 51% kit and I've also helped restore a couple airplanes from the ground up... I thought the restorations were much bigger work that the kit... and I certainly learned more as well... I just need to sell the FSDO on this concept!

My little airplane (63 P172D) is probably one of the more highly modified certificated airplanes around, and it's all been done either through STC or 337 field approvals. There are so many existing STCs out there, and if your IA has a good relationship with the FAA, it's just not that hard to get the 337s done. Here's my list (some obviously are just accessories not needing any approvals); the previous owners converted the engine to Lycoming 360A1A (Avcon conversion); installed Madras droop wingtips, modern Cessna wheel pants, extended dorsal fin, and new windshield; repainted aircraft in modern layout; and refurbished interior with new upholstery and carpets:

Aeroflash wingtip strobes
Airspeed indicator replaced
Alpha Systems angle of attack indicator with heated probe
Alternator conversion
Altimeter replaced
Altitude encoder replaced
APU receptacle
Artex 406Mhz ELT
Attitude gyro replaced with modern style
Avionics cooling fan
Avionics master switch
BAS retracting/locking shoulder harnesses
Directional gyro replaced with modern style
Engine replaced, custom built to certified standards by Aircraft Cylinders & Engines, Inc., Greeley, CO
FAA-approved fire extinguisher
Fuses converted to circuit breakers, custom circuit breaker subpanel
Garmin 430W GPS
Garmin 96C handheld GPS
Gregoire leather-covers for both control yokes, includes PTT buttons
Heated pitot tube
Insight G3 engine analyzer
Kennon custom covers for windshield, cowl, prop, spinner, pitot tube, AOA probe
Kennon custom cowl plugs
Kennon custom window reflective covers
Kennon custom wing covers/spoilers
King ADF (used)
Knots 2 U flap gap seals
KWJ Engineering CO detector
Mirror to view back seat
Narco navcom
Narco transponder
New headliner
Oregon Aero comfort modifications to pilot seat
Pitot-static system re-plumbed and certified IFR
PreciseFlight HID landing/taxi lights
PreciseFlight Pulse-light system (flashes both landing/taxi lights)
PreciseFlite 2-place “back pack” oxygen system, including pulse-oximeter
PS Engineering 6000B audio panel/intercom with marker beacon receiver
Reiff engine heater with oil cooler heater
Rosen sun visors
Skytec light weight starter
Soros Ventube improved ventilation intakes and exhaust vents
Steve’s aluminum gascolator
Whelen anti-collision red/white strobe

In addition, the panel was re-oriented to a modern “six pack” arrangement when the gyros were replaced.

I also asked about going experimental, when we encountered delays in an early mod, but my IA's answer was simple: "It can't be done." We haven't had that problem since, because all delays have been only a few weeks at most, and with a little planning, they've been included in the time to do the annual.

Cary

The first thing to do “halfsnap” is to go the FAA web site and down load Advisory Circular “AC No: 20-27G” Certification and Operation of Amateur-Built Aircraft and read it cover to cover. Especially page 12 section “8” paragraph “e” “Converting a Type-Certificated Aircraft to an Armature-Built Aircraft. In short is says “No Way” because Certified aircraft already have a process to make modifications called STC’s and Field approvals using the 337 process. Sounds OK but we all know its BS and expensive.


BUT, there is a way and they, the FAA have given it to us. In the past it was a subjective decision of the person inspecting the aircraft to say if you did 51% if the work or not. Today in order to make it a simple black or white decision you must fill out Appendix “8” the “Armature-Built Aircraft fabrication and Assembly Checklist (2009)”. This is an in-depth check list as to who built what. Well if you show that you completed 51% of the supervision and assembly of the aircraft you win.


This is a simplification of the process but it’s the facts as of today. So do your homework.

Good Luck


Rick

Rick,

Thank you... I will definitely have myself a little study session with AC20-27 and go from there.

Sergio

mtv wrote:........
Second, the E-AB category, to ensure the criteria are met, requires that you build 51 % of the aircraft. ANd, that doesn't mean you bolt a bunch of certified parts together....it means you BUILD a substantial part of the airplane. It's pretty hard to get 51 % credit by modifying a standard category airplane.....

This is a bullshit rule IMHO. A good example of how it is selectively applied is the "2 weeks to taxi" program offered by Glastar. There is no way that a guy can "build" an airplane from scratch & have it in a ready-to-taxi condition in 2 weeks. First of all, you're assembling pre-fabricated parts. Secondly, the Glastar employees are doing a good part of the work. I was told that you build one wing rig, they then sign you off as the builder of all the ribs. This is legit?
The same thing goes for all the hired gun builders who are putting together RV's for which the buyer then gets the repairman certificate. And don't tell me it doesn't go on, I know of at least one builder doing exactly that.
Rebuilding (for example) a tripacer from the ground up into a V6 STOL, a Bushmaster, or just a modified-wing 2-seat-plus-big-baggage bushbird is just as much or more work than building a kit. A guy I now just finished building a Carbon Cub in 3-1/2 months (with a hired A&P helping him)- got it signed off as an E-AB & got the repairmen certificate, no problem.
If the FAA is gonna create, interpret, or enforce a rule prohibiting or penalizing the use of parts off a certificated airplane, they should do the same right across the board regarding ANY prefabricated parts AND any labor used other than the guy listed on the repairman certificate. Or better yet, just relax & let people do what they will-- as long as the finished product is airworthy & clearly identified as an experimental, just what's the problem?

hotrod150 wrote:

mtv wrote:........
Second, the E-AB category, to ensure the criteria are met, requires that you build 51 % of the aircraft. ANd, that doesn't mean you bolt a bunch of certified parts together....it means you BUILD a substantial part of the airplane. It's pretty hard to get 51 % credit by modifying a standard category airplane.....

This is a bullshit rule IMHO. A good example of how it is selectively applied is the "2 weeks to taxi" program offered by Glastar. There is no way that a guy can "build" an airplane from scratch & have it in a ready-to-taxi condition in 2 weeks. First of all, you're assembling pre-fabricated parts. Secondly, the Glastar employees are doing a good part of the work. I was told that you build one wing rig, they then sign you off as the builder of all the ribs. This is legit?
The same thing goes for all the hired gun builders who are putting together RV's for which the buyer then gets the repairman certificate. And don't tell me it doesn't go on, I know of at least one builder doing exactly that.
Rebuilding (for example) a tripacer from the ground up into a V6 STOL, a Bushmaster, or just a modified-wing 2-seat-plus-big-baggage bushbird is just as much or more work than building a kit. A guy I now just finished building a Carbon Cub in 3-1/2 months (with a hired A&P helping him)- got it signed off as an E-AB & got the repairmen certificate, no problem.
If the FAA is gonna create, interpret, or enforce a rule prohibiting or penalizing the use of parts off a certificated airplane, they should do the same right across the board regarding ANY prefabricated parts AND any labor used other than the guy listed on the repairman certificate. Or better yet, just relax & let people do what they will-- as long as the finished product is airworthy & clearly identified as an experimental, just what's the problem?

51% does not mean 51% of the aircraft build time wise, or even that you as an individual built 51% of the components. It means you participated in 51% of the "tasks" involved. As an example, it is possible to complete one wing rib and gain 100% of the skills required to build them all. The rest of the ribs then would be only repetition. The education that you gained in this meets the purpose that defines the EAB class. It was built for the individuals "education and/or recreation" but a certified aircraft wing that was built for the purpose of commercial sale does not, regardless how detailed or lengthy the rebuild. The other group that built for "recreation" qualifies for EAB also, they built for the "recreational" value of building and flying it. This type builder is more commonly referred to as a "homebuilder" and is considered by many as more true to the roots of EAB but both qualify and either can pay someone to help since much of the work requires two. How could one person run both the rivet gun and the bucking bar on a wing or fuselage, it's not possible. Nothing disqualifies an A/P as the build partner but is not OK for him to build it for you.
For any certified aircraft that was originally built by a manufacturer for the purpose of resale, it automatically would fail the test of "built for the purpose of education or recreation". If there is a line to be drawn between the two classes, it has to be there or there cannot be two separate classes. Otherwise every (certified) plane ever built could become an exception to the rule once someone does an extensive rebuild.

dirtstrip wrote:...51% does not mean 51% of the aircraft build time wise, or even that you as an individual built 51% of the components. It means you participated in 51% of the "tasks" involved. As an example, it is possible to complete one wing rib and gain 100% of the skills required to build them all. The rest of the ribs then would be only repetition. The education that you gained in this meets the purpose that defines the EAB class. .....

I hear from you're saying but I still think it's BS. If a guy rebuilds (for example) a Pacer wing, extends the flap, moves the aileron outboard, & extends the spar/ adds wing ribs as required, he has obviously learned the skill required to build a wing. But yet he is prohibited from doing that & calling it an exp. If he just buys a set of spars ribs & fittings from Univair, Dakota Cub, or whoever & does the same thing-- that's just fine. But other than the name on the parts, isn't it pretty much the same thing?
I guess in addition to the experimental classification(s), what we need is an "owner maintenance" category like Canada has.

hotrod150 wrote:

dirtstrip wrote:...51% does not mean 51% of the aircraft build time wise, or even that you as an individual built 51% of the components. It means you participated in 51% of the "tasks" involved. As an example, it is possible to complete one wing rib and gain 100% of the skills required to build them all. The rest of the ribs then would be only repetition. The education that you gained in this meets the purpose that defines the EAB class. .....

I hear from you're saying but I still think it's BS. If a guy rebuilds (for example) a Pacer wing, extends the flap, moves the aileron outboard, & extends the spar/ adds wing ribs as required, he has obviously learned the skill required to build a wing. But yet he is prohibited from doing that & calling it an exp. If he just buys a set of spars ribs & fittings from Univair, Dakota Cub, or whoever & does the same thing-- that's just fine. But other than the name on the parts, isn't it pretty much the same thing?
I guess in addition to the experimental classification(s), what we need is an "owner maintenance" category like Canada has.

No, that doesn't work either. If you buy new ribs from Dakota or Univair, you still do not get to count rib fabrication as part of the 51 %. So you get no credit for any of the ribs.

The problem is, the line was a little fuzzy, and some folks were jumping across it into EAB without any real "building" on their part. So, the line needed to be better defined. Now it is, and many don't like it. Nevertheless, that's what happens when people jump through loopholes....the loopholes get closed.

And, EAB is, in my opinion, a VERY special category. It should be held to a pretty strict standard in my opinion. There are some tremendous examples of craftsmanship out there.

Finally, EAB doesn't say that one individual has to do 51% of the work. I can buy a partially built aircraft, or have someone else assist in construction, and it still MAY count.

MTV

Hot rod 150, I see your point also but where then would be the line between classes? Simply put for a certified aircraft the all important nameplate defines the certified origin of everything attached to it. The aircraft was brought into this world by a manufacturer who did it for the purpose of making money and you can't change that part to "for the purpose of education or recreation". You can rebuild everything behind it but it is still from a certified design which has commercial origin. You can modify the design enough during the rebuild that it can no longer be recogizable as the certified aircraft it was created to be, but it also cannot be Experimental Amateur class because the purpose of the original was for commercial sale, not education or recreation regardless of effort to meet or exceed the 51% rule. The purpose for creation test needs to be met too, not just the 51% part. So an extensively modified aircraft built from a certified origin ends up caught somewhere between the two classes of certified and Experimental Amateur Built and that class will likely be Experimental Exhibition.

What you are proposing is like trying to change your parentage, it can't be done. But I have raised teenagers and they would have agreed with you, that rule is bullshit.

I can certainly see the wisdom to the rule. You should not be allowed to take any engineered and time tested certificated aircraft parts and use them on a amateur built aircraft. You should be permit ed to buy hardware aluminum not meeting any specifications awning fabric with no specifications an engine from what ever and build a plane get it licensed and give some one a ride. Now that I think of it, seems like bullshit.

bush master wrote:.....You should be permited to buy hardware aluminum not meeting any specifications awning fabric with no specifications an engine from what ever and build a plane get it licensed and give some one a ride. Now that I think of it, seems like bullshit.

Yes even bicycle parts are allowed and the names of two within that founding group are Wilbur and Orville. The original freedom to do that still exists but there are also time tested and proven designs within the Experimental Amateur Built class. These are not all that qualify of course, and if you want factory help that is available to builders too, within limits.

http://www.faa.gov/aircraft/gen_av/ultr ... nket_list/

Not listed are the qualifying customer assist programs that start with these kits and professional assistance can be had at some of the kit plane factories or at factory build centers. The assist programs get evaluated also. This is how I built my plane. A Dream Tundra

[quote="halfsnap"]Hello all,

I hope this hasn't been discussed previously; I've done a search and came up with very little. I've seen posts where someone would mention they would like to re-certify to experimental, but no one has detailed the procedure.
I have a 75 7GCBC that will likely need a rebuild in a couple years... I love the plane and I would like to incorporate some mods to make it suit my style better. I don't want to go down the STC route as it's cost prohibitive and the mods are very limited for this type. I've asked around and the answer I get from most is that it cannot be done... unless I certify it under Exhibition Experimental... I have no desire to do that. I would think that if I were rebuilding the plane anyway, why not go exp, right?
Any thoughts and or experiences?

Thanks!

I would not recommend going to the FAA FSDO because most of them are under staffed and don't have the time to deal with this! You need to find a DAR- Maintenance that are qualified for this re-certification listed under the state they are located at, found on the FAA website. They are the one's that usually inspect and sign off the deferent types of classes of Experimental aircraft. They can give sound advice on what you can and can't do. My advice before you talk anybody, ask yourself what are you trying to accomplish with this airplane, Speed, stol, aerobatics, etc..It's a lot of work to redesign an airplane, I have been through it. In my opinion its easier and takes lot less time to built most kit airplanes if you can find one you like, or except the airplane you have under it's certification. Good Luck with it!
Mountainflier

Mountainflier is right. As much as I disagree with the regulation it would be easier to change the tides than the rules. It would be easiest to rebuild your plane and add the approved mods that you want or build a experimental plane that will definitely met the amateur built rules. I have been thru this process several times. That being said the owner of the Wilga Beast seems to be ok with Experimental Exhibition, think he said he has a 600 mile radius.

As stated, go to a DAR that will be signing it off, Do not waste time at the FSDO. You have zero chance of getting the answer you want to hear at the FSDO but the DAR might have a way to do it.

The main point I'm getting is that "the FSDO is not there to help".... lol, I should have known that!
I will seek out the help of a DAR... as far as what I want to do with the plane, that's a good question... the first thing, would be for it to shed about 100Lb... Impossible on certified parts, unless there's an STC for a Catto prop, Dynon glass and a longer legged aluminum gear that's not $5k. As for the 51% rule... I'm thinking pure BS... just my opinion as I learn more about it.
Thanks again for all the advice

And, by the way, DARs "consult" for a fee. If you don't know what you want to do, a DAR will help you lighten up alright....your wallet. They don't work for free.

But, as noted, if you really want to go down this road, bring cash.

MTV

dirtstrip wrote:.... Simply put for a certified aircraft the all important nameplate defines the certified origin of everything attached to it. The aircraft was brought into this world by a manufacturer who did it for the purpose of making money and you can't change that part to "for the purpose of education or recreation". .........

I believe Cub Crafters has an S-LSA certificated version of the Carbon Cub. The guy at my airport who built one from a CC kit certified it as an AB-E, NOT an E-LSA. Seems like Cub Crafters brought the Carbon Cub into the world to (as you put it) make a profit .Judging from the price tag for ready-to-fly, or even for a kit, they accomplished that.Now what's the difference between assembling a CC kit, or rebuilding an older airplane- Pacer, SC, whatever? If anything, rebuilding the older airplane (esp with a bunch of mods) is more work.
So what's the difference between buying a CC wing & assembling it, or a Piper wing & re-assembling it? Looks like rule-wise, CC's OK for exp & Piper ain't. Practically speaking- very little difference at all.

Completely different animal. The EAB and E-LSA operate under completely different rules. They do not meet the same requirement as Experimental Amateur Built. It is right to say the Light Sport Aircraft built by the manufacturer is certified but not experimental. No changes are allowed. The same plane can be built by an individual with a identical kit purchased from the factory but is still more restrictive than EAB. It is experimental but there are additional rules and limitations within the class.

I don't have first hand experience in this discussion of E-LSA and LSA

So I will add this to the confusion.

http://www.kitplanes.com/sportplanes/0505-3740.pdf