Can a Certified Aircraft be Taken to Experimental
- Thread starter Eddie Foy
- Start date
Dan Gervae
FRIEND
Upper Peninsula of Michigan
https://www.pilotsofamerica.com/community/threads/changing-to-experimental.90820/
not in in such a way that makes it worthwhile.
not in in such a way that makes it worthwhile.
CamTom12
Registered User
Huntsville, AL
For Experimental AB, no. You have to be able to apply the 51% rule checklist to your work (with proof). Anything salvaged from another airplane does not count towards that total.
See here, 2nd from last question: https://www.eaa.org/eaa/aircraft-building/building-your-aircraft/getting-started/the-51-percent-rule
I don’t know how to go Experimental Exhibition, though it doesn’t look too hard. I’d guess the difficulty level might depend on your FSDO though.
http://www.v8seabee.com/faqs/united-states.html
See here, 2nd from last question: https://www.eaa.org/eaa/aircraft-building/building-your-aircraft/getting-started/the-51-percent-rule
I don’t know how to go Experimental Exhibition, though it doesn’t look too hard. I’d guess the difficulty level might depend on your FSDO though.
http://www.v8seabee.com/faqs/united-states.html
Yes, you can go from Standard to Experimental. The real question would be what purpose of Experimental. 14 CFR 21.191 has 9 different purposes for Experimental certificates. Recognize that 91.319 limits the use of an aircraft with an Experimental Certificate to only operations for the purpose for which the certificate was issued.
You can’t take an airplane from Standard to Experimental Amateur Built. Any work done on components from previously certified aircraft can not be used to meet the “major portion” requirement for Amateur built. Given that, your options are pretty much limited to R&D, Exhibition, or Show Compliance. R&D, Show Compliance, Market Survey, Crew Training certificates can only be issued for a maximum of one year, so you would need to decertify each year. Exhibition and Racing are the only ones that can be permanent certificates.
Another issue will be maintenance. 43.1 says Part 43 doesn’t apply to Experimental aircraft, but goes on to say if an aircraft holds an Experimental but previously held another type of certificate (Standard or Restricted) it needs to be maintained per Part 43, which then means you need an A&P to work on it, and alterations will most likely need to be done using approved data and you still need to have 337 forms filed.
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Mauleguy
MEMBER
Lots of experimental Cubs out there built with certified parts in places. It is easy to comply with the 51% rule if you build it up from the ground up in my opinion. Get the form and figure out ahead of time all the things you are going to get credit for and see where you fall in the percentage then figure out what else you might take on to get the percentage up to 51. Almost every experimental cub built is not built by the owner/builder using bare 4130 tubing, most people don't make there own ribs and all the other wing parts needed to construct a wing.
The OP wasn’t talking about building a new airplane, the question was can a Standard category airplane be changed to an Experimental category.
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I've built a certified -12 from the ground up using a replacement airframe (nothing fit) and a basket full of disassembled wing parts. I've also built a 51% kit that came with a completed airframe, tail feathers, and fully assembled wings. Do your own math. How a guy configures his "kit" is up to him as long as the 51% worksheet comes out in his favor and the DAR signs off on it.
RaisedByWolves
FRIEND
Tx
Where does it say you can’t use parts that were never certified? Like a wrecked piper fuselage?
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You can use those parts, but you can’t take any credit towards the major portion. If you use the Piper fuselage as in your example, FAA looks at any work done on that fuselage as Part 43 maintenance, not building the new airplane.
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Carey Gray
Registered User
Thun Field, Washington
You can take your certified aircraft, crush it, roll it into a ball and throw it away, legally.
But you can't assume whatever the financial hit may be, make it an experimental and take care of the maintenance. It could be argued that aviation would be better/safer if you could. The FAA, in my humble opinion, has no idea what they're looking at.
But you can't assume whatever the financial hit may be, make it an experimental and take care of the maintenance. It could be argued that aviation would be better/safer if you could. The FAA, in my humble opinion, has no idea what they're looking at.
For the guys who've never been through the process, there's no DAR inspection until the plane is completed. Nobody knows or cares what you're doing until the day you request an airworthiness certificate. At that point the DAR visits to look the plane and paperwork over. They'd have no way of telling whose airframe or wings were used and I doubt they care as long as the 51% worksheet is believable and the math works.
Here's the 51% worksheet. Run the numbers. If you buy an FAA approved 51% kit the kit maker's 49% contribution is predetermined and filled out. You can skew those numbers by doing addition fabrication and modification. The same can be done if you start with certified parts.
https://www.faa.gov/aircraft/gen_av/ultralights/amateur_built/kits/media/AmBuiltFabAssyCklistFW.pdf
Here's the 51% worksheet. Run the numbers. If you buy an FAA approved 51% kit the kit maker's 49% contribution is predetermined and filled out. You can skew those numbers by doing addition fabrication and modification. The same can be done if you start with certified parts.
https://www.faa.gov/aircraft/gen_av/ultralights/amateur_built/kits/media/AmBuiltFabAssyCklistFW.pdf
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Eddie Foy
MEMBER
South Florida
Too much work!8)
RaisedByWolves
FRIEND
Tx
Could you use univair pma’d parts to count towards the 51%? If you were to buy new parts from univair and build the wings?
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Dan Gervae
FRIEND
Upper Peninsula of Michigan
I'd say you can do it if you want...Why not?.....You could build the whole thing following Piper Drawings and make mods as you see fit. I bet it would be the expensive way to go though rather than buying a non-PMA'd fuselage from Javron or one of the others.
You would get credit for the assembly, but not the fabrication. See the checklist that was linked in someone’s previous post.
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jnorris
MEMBER
Wisconsin
You can try that if you want, but be careful what DAR you decide to work with. Some of us know what questions to ask, how to look at photos, and can tell the difference. (In other words, don't bring it to me!)
But that discussion is not what the original poster asked. The question, as I understood it, was can you take an existing standard category airplane and make it experimental. No mention of building (or even repairing). The answer is "yes", but the airplane you end up with is not very useful. AND, as someone else mentioned, you still would have to use all the maintenance practices called out in Part 43, so you gain nothing by converting to experimental.
The building issue has been discussed ad-infinitum on this and other forums. The same people post the same opinions every time, and nobody's mind is ever changed. My only advice is, don't spend your money until you KNOW that you will get the certificate you want. And don't take any FAA representative or DAR's word on anything, even if you get it in writing. Personnel at FISDs and MIDOs change, and FAA policy changes, and what might be doable when you start might not be doable by the time you finish. Err on the side of caution.
CamTom12
Registered User
Huntsville, AL
This might be viewed differently to some. Take Draco the Wilga for example. Might still follow Part 43, but Mike’s got an airplane he couldn’t build in the certified world.
Eddie Foy
MEMBER
South Florida
Patey took his Wilga into Experimental Exhibition. This discussion was meant to address going into E-AB.
CamTom12
Registered User
Huntsville, AL
You didn’t specify, and if you did then I missed it.
There’s like 9 different kinds of experimental according to the FAA.
Besides, my point above was that Experimental-Exhibition can have value to people. Meant in response to the guy I quoted.
mike mcs repair
Registered User
chugiak AK
I think what the FAA DOES, compared to what is written, is different... policy type stuff...
They don't want to be bothered anymore for field approvals and such... and I think they are happy to have you go experimental and not have to mess with you anymore....
skywagon8a
MEMBER
SE Mass MA6
[h=2]Can a Certified Aircraft be Taken to Experimental[/h]
Eddie, This is the first indication that you meant E-AB. As others have noted there are a lot of different Experimental categories for almost an unlimited number of purposes. You are not the only one who seems to think that all Experimentals are the same. Far from it.
Eddie Foy
MEMBER
South Florida
I do not think all experimentals are the same. My original question was not specific enough. Mea Culpa!
Your reply implies I'm suggesting bending the rules. To the contrary, I'm suggesting guys learn the rules.
jnorris
MEMBER
Wisconsin
A very good plan indeed. I always encourage people to learn, and follow, the rules. In the long run, it's better for all of us. But I also wanted to point out that the rules and policies, not to mention FAA personnel, change over time, and what might have been legal, or easy, in the past may not be so easy anymore. And also take into consideration the variation between different FAA offices. What one office is fine with, another office might not want to touch with a 10 foot pole. They're all supposed to be playing by the same rules and policies, but there is often enough ambiguity in those rules and policies to allow a much different response from one office as compared to another.
For example, the office I work through is VERY fussy about the "exhibition" part of experimental exhibition. They want to see a valid purpose for "exhibiting the aircraft’s flight capabilities, performance, or unusual characteristics at air shows, fly-ins, and similar events." (Quote taken from FAA Order 8130.2J) Something like Draco would have a very valid exhibition purpose. Someone building a Super Cub clone would have to convince the inspector just exactly what the airplane is "exhibiting".
And the DAR doesn't make the final determination. If the DAR and the FAA office is operating per the published guidance, the DAR must send the application up the chain to be approved by his or her managing office before proceeding with the inspection and issuance of the certificate. So the applicant must first convince the DAR that the application is appropriate, then the applicant and the DAR must convince the supervising office that the application passes the smell test.
Just want to make everyone aware of how the process works, and that there is more than one possible outcome if you make an application. Keep good records, and make sure you have your ducks in a row before you call the DAR or FAA office.
That’s why the devil is in the details, specifically, the program letter needs to support the “purpose” for which you are applying for the certificate.
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