Building an airplane is a long and complicated task. Years of effort come down to the final step where you are anxiously awaiting the signoff from your local Designated Airworthiness Representative (DAR). It doesn’t seem too hard to fill out a few forms, write a letter, and check your plane over one more time. What could possibly go wrong? Apparently a lot, based on my recent experience. To help you avoid the common problems I often see, let’s go over the process of preparing for the DAR visit.
The EAA has a packet designed to help the builder through the registration and airworthiness process. I urge everyone to join EAA and then take advantage of their extensive resources to aid you in this process. I have one warning, however. Lately, some of the forms in the EAA packet have expired, so double-check the form dates before you fill them out. Out-of-date forms will be rejected by the FAA. I have already reported this to EAA, so I am sure they will take care of this right away. When in doubt you can always get the most current forms from the FAA website.
Whatever you list on your registration is what you will need to match everywhere else. Be sure to have this in front of you as you complete the other forms and your data plate.
You must have your permanent registration in hand before the DAR can begin the airworthiness certificate process. Be sure to apply for your registration at least two months before you think you will need it. The process usually goes faster than that, but it can drag on in some cases. Your DAR has no ability to assist with registration issues because that is handled by a completely separate division of the FAA.
The old cartoon caption, “No job is finished until the paperwork is done,” is particularly apt when it comes to getting your plane released for flight by the FAA. There are several forms to consider, so we’ll go through them one-by-one.
On Form 8130-12, as with the other forms, enter the owner’s name just as it appears on the registration. Model, serial number, and registration number should also match the registration exactly. List yourself under builders and include others who made major contributions. Type N/A on the commercial assistance line if that is true. Otherwise, expect to complete a detailed evaluation of the work you did with your DAR.
The first form you will need to deal with is the Eligibility Statement Amateur-Built Aircraft Form 8130-12. Be sure to look in the upper right corner of the form, which begins on page 2 after the instructions, for the expiration date. As we went to press, the expiration date on the form was 9/30/2017, which is around the same time that many of you will be reading this, so check the date on your copy of the form carefully.
The form begins by asking for the name and address of the registered owner. The name you put on this form should match exactly what you have on your registration in the box titled Issued To. This may be different than the name in the box labeled Manufacturer and Manufacturer’s Designation of Aircraft.Please use the Issued To name.
In Section II fill in the model, serial number, and registration number exactly as it appears on your registration. If the model as it appears on your registration is “Van’s RV-8A,” then that exact thing must appear on this form. Do not abbreviate it to RV-8A, for example.
In Section III use the same name exactly as it appears in Section I.
In Section IV if the notary acknowledgement is on a separate page, put “see attached” in this box.
The airworthiness certificate process begins with a program letter, which is simply a letter to the FAA asking them to issue you a special airworthiness certificate. In this letter, you will describe your airplane and the location where it will be available for inspection. You will also “request” a flight test area, which is generally not subject to your wishes but is predetermined based on the airport you will be using for your Phase I flight testing. The EAA has a model program letter in its packet, but you will need to get the exact language and the flight test area from your DAR. Instead of spending time with the EAA form, simply contact your DAR and ask for a sample letter. When completing your program letter, be sure to list the builder, registration number, serial number, and model exactly as they appear on your registration. Always remember that the builder name and the owner name may be different. Whenever it asks for builder, use the name shown in the Manufacturer box on your registration.
Be sure to fill in Section I exactly as the information is shown on your registration form. Note that the builder name is the name from the Manufacturer box on the registration.
Application for Airworthiness Certificate
The Application, Form 8130-6, seems to be the most troublesome. This form is available online from the FAA website as a PDF file that can be completed on your computer. This is much preferred to having you fill it out by hand. Just be sure to use the most current form.
This form must be exactly correct or it will get rejected, either by the DAR or his or her supervisor at the FAA. In Section I things seem pretty straightforward, but people do get the builder’s name and model number wrong from time to time. Be sure the aircraft builder’s name is the same as the name listed in the Manufacturer box on your registration. This is not necessarily the same as the owner’s name. The model and serial number must also match the registration. Do not guess or try to remember this. Get your registration in front of you and copy the information exactly.
You have some boxes to check in Section II of Form 8130-6: Special Airworthiness Certificate, Experimental, and Amateur-Built.
In Section II you have two boxes to check. Check Box 4 where it says “Experimental,” and then check Box 2 to the right where it says “Amateur Built.”
In Section III, Box A asks for your name. This is the owner’s name as it appears in the Issued To box on your registration. This is usually shown last name first, but the most important thing is to have it exactly match whatever is on your registration.
In B there are four boxes. Only check the box marked Airworthiness Directives. Put N/A in the text windows of the other boxes and leave them unchecked. In the text section of the A/W box, you will need to list the number and dates of the most current biweekly airworthiness directives notice. Go to the FAA regulatory guidance library, and then click on “Small Aircraft, Rotorcraft, Gliders, Balloons, and Airships.” This will give you any ADs that have appeared in the last two weeks. The number you need to enter on the form will look like this: 2017-10, 5/1/2017-5/14/2017. That description goes in the text box under Airworthiness Directives. Of course, the assumption is that you have searched for ADs related to any certificated or TSO’d parts you may have on your airplane, and that you have checked the biweekly report for anything new.
In Section III of Form 8130-6, be sure to use the Issued To name from your registration in Part A (Registered Owner Name). In Part B check the Airworthiness Directives box and put the number and date of the most current Small Aircraft Biweekly Report in the text section. Put N/A in the other boxes as shown. In Part C check the box and write 0 in the hours boxes. Date the application as shown, and again list the owner’s name and title.
But ADs don’t apply to Experimental/Amateur-Built aircraft, you say. Well that may be true, more or less, but the FAA still wants to know if there are any outstanding ADs on any parts of your plane, and if there are, what you have done about them. Your condition inspection says that the airplane is in a condition for safe operation, so the logic is that a part with an uncorrected AD is not safe for operation. You are not necessarily required to comply with the AD in the same way a certificated aircraft would, but you are required to ensure that your plane is in a safe condition by some reasonable means.
Part C of Section III should be checked and the airframe hours entered in both boxes. Presumably this is zero for a new plane. In other cases, such as applying for a renewal, the hours will reflect the actual time.
Part D of this section contains the date of the application that should be entered in this format: day (two digits)/month (three letters)/year (four digits). For example, 17 May 2017. The name following should be the name listed on the registration under Issued To, plus the title, owner, or other appropriate title if the owner is not an individual. Lastly, you will sign your name.
There are no entries required in Section IV, but in Section V you should list the date of the inspection in the same format as before. Your DAR will fill in the rest of this section.
On the last page, you have some more work to do. In Section VIII, check boxes A, B, C, D, F, and J. In the text window for J enter “21.191(g).” This is the section of the federal aviation regulations that deals with airworthiness for Experimental/Amateur-Built aircraft. You are now finished with this form.
A fire-resistant data plate must be installed on the airframe showing the builder, the model number, and the serial number. Many data plates will list other information, but that information is not required. The important thing is to get the required information right. The builder name must match the Manufacturer box from your registration exactly as it is shown. The model number and serial number must also match the registration exactly. The data plate must be permanently affixed to the airplane, usually near the tail on either side with metal rivets. The important thing is to make sure the information on the data plate matches the registration exactly. Many builders have had their airworthiness certificates delayed while they waited to get their data plates remade. Be precise. Check twice, then order once.
Weight & Balance
You must weigh your plane and complete your weight and balance calculations for your own use and to show the DAR. Your calculations should show the forward-most CG loading, the maximum loading, and a typical loading for the flying you expect to do. You will also need to list your CG limits and gross weight, which should be the gross weight and limits recommended by the kit or plans manufacturer. To be sure, you are not bound by their recommendation, but you should only deviate from it for a very good reason, none of which comes to mind. Be sure to have a copy that the DAR can keep.
You must include what is called a 3-view drawing or photos showing the same with your application. These are usually easily obtainable from the kit maker or plans designer. If not, the builder group for your particular type of airplane is usually a good resource. The drawing or photos must show a front, side, and top view of the plane. The drawing does not need to have dimensions. If you can’t find any drawings, photos will do. Just be careful when trying to get a top-view photo. We don’t want you to fall off the roof of your hangar.
The builder’s log is your record of the construction process. There is no set format for this, but all agree that a good selection of photos is the best evidence of your involvement in the building process. Be sure to have a few photos that include you. Written records of what you did and when you did it are also good evidence of your efforts, as are records of any EAA technical counselor visits. Photos on your computer or tablet are fine for this purpose, but do try to have them organized and edited for redundant photos before the DAR shows up.
If you have built from plans or an approved kit and not used any commercial assistance except for instructional purposes, the builder’s log will be sufficient evidence of your compliance with the majority Amateur-Built requirement (51% rule). If your kit is not on the approved list or you did use commercial assistance, your DAR will need to do a detailed evaluation of your work to determine its eligibility for Amateur-Built status.
You need an airframe (aircraft) logbook and an engine logbook to keep track of your maintenance. A propeller logbook is also nice to have, but some people simply make prop maintenance entries in the aircraft logbook. Many prop manufacturers will include a prop logbook with their new prop. All logbooks should be filled out with the relevant information about the aircraft and engine or prop as applicable.
You must have a condition inspection entry in your aircraft logbook before the DAR can sign you off. Here is the required entry: “I certify that this aircraft has been inspected on [insert date] in accordance with the scope and detail of 14 CFR part 43, appendix D; and was found to be in a condition for safe operation.” After this you need to list your name, certificate number, and type of certificate held, and then sign your name. Since you do not yet have your repairman’s certificate, you will use your pilot’s license (certificate) number. Your type of pilot’s license will be the type of certificate held. Once you get your repairman’s certificate you will use that number and description.
If you will be conducting your Phase I out of a Class D airport, you will need to have your transponder certified, proof of which should also be in your logbook. If you do not have an electrical system, you are exempt from this requirement. A pitot/static certification is not required unless you plan to fly IFR. In any case it is not required for Phase I. However, it is highly recommended for everyone, even VFR pilots, at least this one time.
Please note that you as the builder are responsible for conducting a thorough condition inspection, not the DAR.
When the DAR is finished with everything, he or she will make an entry in your logbook referencing the airworthiness certificate just issued to you. At that point, you will be officially out of the building phase and into Phase I flight testing.
Secure all spark plug wires and sensor leads with cushioned Adel clamps. It is better if they are kept separate as shown here.
Preparing Your Plane
Your plane must be complete and ready to fly before the DAR arrives. That means you would be willing to get in and fly it after replacing the inspection covers. If your plane isn’t complete to that point, you are not ready for the DAR. That means the plane has been weighed, the fuel system has been tested, the avionics have been tested, the engine monitoring system has been tested with the operating limits set, and the engine has been run at least for a few minutes. If any of these steps remain undone, you need to take care to get them done before the DAR visit.
As part of your inspection, you will need to present evidence of a fuel system test. This does not have to be anything elaborate. Simply a sheet of paper with the recorded fuel flow will do. If you have a photo of the test being performed, that would be nice, but it is not required. The EAA has a fuel system test form that you can use. If you are unsure about how to test your fuel system, there is an EAA webinar that goes into the process in depth. There is also an article that covers the topic in the December 2012 issue of KITPLANES. Last but not least, the FAA covers fuel system testing in its advisory circular AC 90-89B, which is available online. Your DAR is required to ask for evidence of this test, so be prepared.
Be sure to check your fuel flow and record the results so you can show it to your DAR. This is now required, not to mention a good idea.
The DAR must see your engine run. Be sure that you can start your engine easily and that there is enough fuel in the tanks to do so. Also, be sure that your battery is fully charged. Often builders will forget this as they have been testing and programming their EFIS and avionics. If your airplane won’t start, you will not get your signoff and airworthiness certificate.
Beyond these requirements there is no universal agreement within the FAA as to how thorough a DAR inspection should be. Some do almost no physical inspection, simply limiting themselves to a review of the paperwork. Others will get more involved in the nuts and bolts of your airplane. In any case, do not count on the DAR to find any problems that may exist with the construction of your airplane. That is your job. Here are some things you should look at to be sure your plane is ready to fly.
Use Torque Seal to mark control rod jam nuts and hose fittings after you tighten them as a reminder of what has been completed and what has not.
• Be sure all nuts and bolts are tight, properly torqued, and have at least one, but not more than four, threads showing. Fasteners that need cotter pins or safety wire should have those installed; same for turnbuckles on control cables. Jam nuts at control rods are a special area of concern. It is easy to forget to tighten these, so I recommend that builders mark them with Torque Seal after they are tightened. That makes inspection very easy. The same marking works well for fuel and oil line fittings.
• In the cockpit, switches, breakers, fuel valve, and controls should be well marked if their intended use is not obvious and conventional. Be sure that controls work smoothly and move through their full range of travel with some cushion. In other words, the item being controlled should reach its limits of travel before the control does.
Check to be sure all cotter pins and safety wire are in place before your DAR inspection. Some places such as this are easy to miss.
• In the engine compartment, watch out for wires and SCAT ducts that are too close to exhaust pipes or are not well-secured. Correct any places where wires could chafe against other parts, especially the engine mount. Be sure that any openings in the firewall are sealed with a 2000-degree-rated sealant. That does not include red RTV.
• Make your plane look like it is ready to fly. Or maybe to put it another way, make your plane look like you are ready to sell it, and a buyer is on the way. Tidy up the area around the plane to present an appearance of order. This will give the DAR confidence that the things he or she will be looking at, and the things he or she can’t see, will be properly done. In short, make it easy for them to say yes.
It is not the DAR’s job to enforce best practices on your project. But he or she should try to catch any problems that will make the plane unsafe to fly now or in the near future. Take advantage of the many resources available, such as back issues of this magazine and your EAA technical counselor, to get things right on your project. Good luck on your big day.