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Thread: Professional builder /builder assist

  1. #41
    Bearhawk Builder's Avatar
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    I understand the checklist points system and have used it several times. Anyone who has built a plane from an approved kit knows there is something wonky with the two week program of the big guys, no way 51% of the tasks can be accomplished in two weeks. So why does the FAA 'work' with the big guys on this and we get scolded for even thinking about it? Serious question for DGA. What am I missing? The fact that this discrepancy exists makes some guys just fly under the radar and do what they want. It seems to come down to the willingness of the DAR being used to interpret rules since they are the only FAA reps we ever interact with.
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  2. #42
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    Quote Originally Posted by Bearhawk Builder View Post
    ..... Anyone who has built a plane from an approved kit knows there is something wonky with the two week program of the big guys, no way 51% of the tasks can be accomplished in two weeks. So why does the FAA 'work' with the big guys on this .......
    A certain kit manufacturer's "two weeks to taxi" comes to mind.
    I'm pretty sure the airplane owners come out of that with a repairman's certificate in hand.
    I don't have a problem with getting qualified airplane builders to do the work,
    I just don't think the owner should get the repairman's certificate for basically just footing the bill.
    Cessna Skywagon-- accept no substitute!
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  3. #43

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    Quote Originally Posted by Bearhawk Builder View Post
    no way 51% of the tasks can be accomplished in two weeks.
    A home builder may fabricate every rib by hand. A participant in the CubCrafters factory assist program presses a button to start the CNC router and all the ribs are cut while the "builder" does something else. Each rib still has to be pressed though and the day spent doing that seemed to be the longest.

    The factory assist build is carefully choreographed so the the "builder" is at the CNC router to start cutting the next batch of parts as soon as the raw stock is mounted on the table. Who made those parts - the builder, the person who mounted the raw stock, the person who programmed the CNC router, someone else?

    As I said in an earlier post I would like to have done much more of the work myself. Perhaps the biggest disappointment was that I didn't do any fabric work except to cut the pieces from the roll. I had also hoped to fabricate at least some of the wiring harnesses. Had to wait till I got home to do that.

    The ultimate build experience would be to do the first week build and then have all the parts shipped as a kit. EX kit builders don't press any ribs, don't build the ailerons and flaps, don't fabricate any of the carbon parts, don't lay up the tail feathers and fuselage in the welding jigs, etc etc.

    At CubCrafters the same factory production line is used for "factory assist" and standard cert aircraft. The factory assist builder's parts feed that production line in the same way factory built parts would.

    A factory assist build is certainly not the same experience as a kit build or plans build. I'm glad the factory assist option was available.
    Last edited by frequent_flyer; 08-05-2021 at 11:09 AM. Reason: changed NC mill to CNC router
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  4. #44
    stewartb's Avatar
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    It isn’t about 51% of the tasks. The rule requires 51% of the points.
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  5. #45
    Steve Pierce's Avatar
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    And I can tell you most of those Cub Crafters owners do not get the repairman's certificate. I do the inspection on a lot of those airplanes.
    Steve Pierce

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  6. #46

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    Quote Originally Posted by stewartb View Post
    It isn’t about 51% of the tasks. The rule requires 51% of the points.
    A distinction without a difference? Page 1 of the checklist form says - "(each task equals one point)"
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  7. #47
    stewartb's Avatar
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    I should have said labor. Can you say that you did 51% of the labor to build your Carbon Cub? Of course not, but you’re named as the builder, right?

  8. #48
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    Quote Originally Posted by stewartb View Post
    I should have said labor. Can you say that you did 51% of the labor to build your Carbon Cub? Of course not, but you’re named as the builder, right?
    I see that on my project from the other angle (scratch built): according to the checklist, I already have more than 60% in points. But I don't think I'm half done.
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  9. #49

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    Quote Originally Posted by Bearhawk Builder View Post
    I understand the checklist points system and have used it several times. Anyone who has built a plane from an approved kit knows there is something wonky with the two week program of the big guys, no way 51% of the tasks can be accomplished in two weeks. So why does the FAA 'work' with the big guys on this and we get scolded for even thinking about it? Serious question for DGA. What am I missing? The fact that this discrepancy exists makes some guys just fly under the radar and do what they want. It seems to come down to the willingness of the DAR being used to interpret rules since they are the only FAA reps we ever interact with.
    Couldn’t agree more. The rules (whatever they are) should be applied across the board to all builders.


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  10. #50
    stewartb's Avatar
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    With all due respect it seems the inconsistency is on the DAR side. If Cubcrafters and other manufacturers have established builder assist programs that are accepted and/or approved for 51% construction? I'd think other DARs should be learning from it. It isn't that the rules are different, the application of the rules is.

  11. #51
    Steve Pierce's Avatar
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    It isn't about building an airplane, it is about building an airplane for hire within the rules.
    Steve Pierce

    Everybody is ignorant, only on different subjects.
    Will Rogers
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  12. #52
    stewartb's Avatar
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    When I first contacted my DAR we talked about professional assistance. He encouraged me to use it. He didn't expect any private guy with a full time career to know everything or be good at everything that building an airplane requires. In the end some pro assistance makes for a better, safer airplane. That seems like a good idea.

    Is the market value of an FX airplane better than an EX when equally equipped with equal hours?
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  13. #53
    Steve Pierce's Avatar
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    From my experience the FX brings more than the EX equivalent. Found the battery cables wire tied to the torque tube on an EX and the DAR missed it. Felt weird to me when manipulating the controls.

    Did you get the repairman certificate for your airplane?
    Steve Pierce

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  14. #54
    stewartb's Avatar
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    Yes, and the interview process was pretty darn thorough. I think they were trying to weed out guys who don’t know the airplane. Turns out one of the FSDO guys was building an RV. It was fun comparing notes.

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    My builder assist program was all of you on sc.org as well as many good seminars and you tube. I managed to build the airplane and troubleshoot issues, perform maintenance, fabricate, cover, paint….it might not win a Lindy, but It’s a nice, safe, well built airplane and I built it…I painted it, I did everything. Thanks to sc.org for all the good help. Starting a build thread here was the best thing I could have done…my DAR is a member and he followed along the entire build…that made it pretty nice. What I’m saying is Thank You guys! Thank you very much….and I’m sure others learned along the way just by following.

  16. #56
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    I might take a little exception to the comment "He didn't expect any private guy with a full time career to know everything or be good at everything that building an airplane requires. In the end some pro assistance makes for a better, safer airplane. That seems like a good idea.". I took the same approach as Dan did above. I also had friends at the airport that would come by and check out the build. I always offered the 'look it over' and if you see anything tell me! A good friend of mine is an A&P (not active anymore) and gave me a nice compliment;"I'd fly anything you build".

    So I think you can get the same, possible better, plane from a amature build. But not everyone has the time, desire, patience to learn and problem solve to build and finish a kit plane.

    But to Steve's experience, a DAR can't see everything and I know of a few homebuilt's at the field I wouldn't ride in.

    My DAR inspection was straight forward as was the application for the repairman.

    I think all builder assist programs are great! What a good way to have people learn more about internal workings of their plane, be engaged, and promote GA.
    Last edited by aeroaddict; 08-06-2021 at 09:14 AM.
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  17. #57

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    Everyone is certainly entitled to their own opinion regarding builder assist programs and proving who does what percentage of this and that and what task took “X” amount of time, etc. etc., but it sounds like a lot of people are mixing apples and oranges with regards to how they think about this and who should be granted the repairman’s certificate. I’ll go back to my original argument in that none of this makes a difference and certainly doesn’t make for a safer aircraft. That repairman’s certificate only grants you permission to sign that logbook/condition inspection once per year. It has absolutely nothing to do with working on/maintaining that aircraft. I kind think of it like a physical. Your Dr. does a quick exam on you once a year, but it’s up to you to keep yourself healthy for the rest of the year. That physical, just like the annual condition inspection, is just a snapshot in time. It’s only valid for that one brief moment when your Dr. or A&P is checking things out. It’s totally up to you to maintain yourself….or in this case you’re airplane, for the rest of the year. I try to look at things from a common sense point of view rather than who made up some rule. Should some people probably not even be changing the oil in their airplane much less maintaining it all year?….absolutely!….but than there’s certainly other’s who may not possess the repairman’s certificate that are more than qualified to sign their logbook once a year for the condition inspection. Just my opinion….which isn’t worth much.
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  18. #58

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    I agree that there is great benefit to having someone more knowledgeable look over a project. That's why there is the EAA Tech Counselor program. We no longer do inspections other than the final inspection for certification, and we are not supposed to have the applicant open more than what we feel necessary to make a safe for flight determination. Remember that the builder needs sign for the same as a condition inspection before the DAR shows up to do the certification, and the DAR is accepting that inspection to a large degree.

    As for the quick builds - 2 weeks to fly, or whatever, I've never been involved with them, but I do use the checklist religiously if it is a kit that isn't on the kit list, or any time "commercial assistance" is used. Everyone needs to understand the purpose of Experimental Amateur Built. It is to allow someone to build an aircraft for education and entertainment, and then allow them to fly that aircraft. It is NOT intended to allow someone to go out and pay someone to built a non-certified aircraft for them, and does not fit the intent of 14 CFR 21.191(g). If you want to pay someone to build an aircraft for you, there is no real "purpose" that covers that within 21.191, so about the only option would be "Exhibition" with the appropriate operating limitations. How places like CubCrafters and the DAR that works with them gets away with it, I have no idea. Have the exploited the checklist to it's fullest, or are they fraudulently filling out things that were paid for and attributing them to the owner builder? I have no idea. The checklist is pretty liberal in what credit is given for, so they may actually be in compliance.
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  19. #59
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    Quote Originally Posted by frequent_flyer View Post
    Edited - Build log and checklist were not submitted by email. The inspector pulled them from the FAA aircraft records. I only had to submit the application and a signed copy of the "bill of rights"
    There's no way your construction records (aka "builder's log") were pulled from FAA records. Construction records are not submitted to the FAA. They are reviewed by the inspector (DAR or FAA) during the airworthiness inspection, and should be reviewed again by the FSDO inspector during the repairman certificate interview.

    If a fabrication/assembly checklist was required for the inspection, and was completed, that could be found in the FAA records. However, the checklist in and of itself does not directly impact the issue of the repairman certificate. The checklist only impacts the issuance of the airworthiness certificate. The FSDO inspector is still supposed to verify that the repairman certificate applicant is the "primary" builder of the aircraft. There are some cases where the applicant is NOT the primary builder, although these cases are somewhat rare. But that's what the interview process is supposed to establish.
    Joe

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  20. #60

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    Quote Originally Posted by jnorris View Post
    There's no way your construction records (aka "builder's log") were pulled from FAA records. Construction records are not submitted to the FAA.
    This is a direct quote from the FAA inspector's email exchanged during my application for the repairman certificate -

    "I was able to see the build log and eligibility statement on line, so we are good to go there."

    What on line source do you suppose this FAA inspector would have been able to access? How do you know what documentation the inspection DAR submitted to FAA?
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  21. #61

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    Quote Originally Posted by jnorris View Post
    The FSDO inspector is still supposed to verify that the repairman certificate applicant is the "primary" builder of the aircraft. There are some cases where the applicant is NOT the primary builder, although these cases are somewhat rare. But that's what the interview process is supposed to establish.
    The requirements for issuance of "Certificate Repairman for Experimental Amateur Aircraft" are documented in 8900.1 Vol 5, Chapter 5, Section 5. One of the ways of satisfying the requirements is specified in par 2 which states:

    "The applicant presents satisfactory evidence, such as the aircraft construction logbook.". There is no interview specified or required.

    An alternate way of satisfying the requirements is to comply with para 3 which states:

    "The applicant proves to the satisfaction of the inspector an ability to perform condition inspections and an ability to determine whether or not the aircraft is in a condition for safe operation."

    An interview may well be appropriate for an applicant wishing to qualify under the requirement of para 3.

    I see no reason to make up requirements for qualifying for a repairman certificate when FAA has clearly documented what the requirements actually are.

  22. #62

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    Quote Originally Posted by frequent_flyer View Post
    This is a direct quote from the FAA inspector's email exchanged during my application for the repairman certificate -

    "I was able to see the build log and eligibility statement on line, so we are good to go there."

    What on line source do you suppose this FAA inspector would have been able to access? How do you know what documentation the inspection DAR submitted to FAA?
    The only way a build log would be in the FAA records is if you provided a copy to the DAR and he submitted it with the certification paperwork prior to the AWC process. Since AWC, the only way it would be there is if the applicant uploaded it into the AWC Portal. Even if I had submitted a copy of the builders log with my certification paperwork, my Managing Specialist would have stripped it out and not sent it to Oklahoma City. Oder 8130.2J has a list of what paperwork is to be submitted to the Registry, and the build log is NOT specified. Most FSDOS will not send anything to AFS-750 unless it is required.
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  23. #63

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    Quote Originally Posted by frequent_flyer View Post
    The requirements for issuance of "Certificate Repairman for Experimental Amateur Aircraft" are documented in 8900.1 Vol 5, Chapter 5, Section 5. One of the ways of satisfying the requirements is specified in par 2 which states:

    "The applicant presents satisfactory evidence, such as the aircraft construction logbook.". There is no interview specified or required.

    An alternate way of satisfying the requirements is to comply with para 3 which states:

    "The applicant proves to the satisfaction of the inspector an ability to perform condition inspections and an ability to determine whether or not the aircraft is in a condition for safe operation."

    An interview may well be appropriate for an applicant wishing to qualify under the requirement of para 3.

    I see no reason to make up requirements for qualifying for a repairman certificate when FAA has clearly documented what the requirements actually are.
    You must not have dealt with FAA very much, Each FSDO and each Inspector within each FSDO seems to make up their own rules! Sometimes you go along to get along, sometimes you take them to task and use their own rules, Orders and Advisory Circulars against them. Pick your battles wisely!

  24. #64

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    Quote Originally Posted by dgapilot View Post
    The only way a build log would be in the FAA records is if the DAR submitted it with the certification paperwork prior to the AWC process. Since AWC, the only way it would be there is if the applicant uploaded it into the AWC Portal. Even if I had submitted a copy of the builders log with my certification paperwork, my Managing Specialist would have stripped it out and not sent it to Oklahoma City. Oder 8130.2J has a list of what paperwork is to be submitted to the Registry, and the build log is NOT specified.
    I expected to have to submit the build log to the FSDO inspector. He did not require it and he said why he did not require it. I corrected my post because the statement that I had submitted my build log by email was not correct.

    Maybe one day I'll request the records to see what is actually there.
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  25. #65

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    Quote Originally Posted by dgapilot View Post
    You must not have dealt with FAA very much, Each FSDO and each Inspector within each FSDO seems to make up their own rules! Sometimes you go along to get along, sometimes you take them to task and use their own rules, Orders and Advisory Circulars against them. Pick your battles wisely!
    There was no battle. I had read the rules before I applied. The inspector was familiar with, and followed, the same rules. It was a painless process.

    I have had some interaction with FAA both as a pilot and in my professional involvement with aircraft systems development and certification. I'm now retired but it was my understanding that FAA was trying to move a bit closer to standardization between different regions and offices.

  26. #66
    stewartb's Avatar
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    The FX program is interesting. I doubt the average FX buyer is qualified to hold a repairman's certificate if based solely on their participation in the FX process. The way an FX gets built is very different from spending a couple of years putting a plane together like most E-AB builders do.

  27. #67

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    Quote Originally Posted by stewartb View Post
    The FX program is interesting. I doubt the average FX buyer is qualified to hold a repairman's certificate if based solely on their participation in the FX process. The way an FX gets built is very different from spending a couple of years putting a plane together like most E-AB builders do.
    CubCrafters agrees that the average FX builder is not qualified for a repairman certificate. They actively discourage people from applying and they offer no assistance to those who do wish to apply.

  28. #68
    aeroaddict's Avatar
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    Are you speaking for CC when you say "CubCrafters agrees that the average FX builder is not qualified for a repairman certificate". How would CC know that?

    So the
    average FX builder spends time building a complete airplane with the builder assist program (a process approved by the FAA), applies and recieves airworthiness, but is not qualified for a repairman certificate?

  29. #69

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    Quote Originally Posted by aeroaddict View Post
    Are you speaking for CC when you say "CubCrafters agrees that the average FX builder is not qualified for a repairman certificate". How would CC know that?
    Here is the article that gave rise to that comment - https://www.kitplanes.com/cubcrafters-ex-3-fx-3/
    Look for comments by Lervold.

    My comment was also based on interactions with CubCrafters personnel and with the DAR who issued my airworthiness certificate.

    Earlier in this thread I provided a reference to the FAA requirements for a repairman certificate. Anyone who meets those requirements is qualified.

    It is my personal opinion that, if a person had no other experience of aircraft maintenance or inspection, the FX build program would not result in their being competent to maintain or inspect their newly built FX-3.

    I do not represent, or speak for, CubCrafters.
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  30. #70
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    Thanks. I'm surprised that CC would even make a statement one way or the other (legal reasons) and surprised that the (CC) DAR would voice an opinion.

    My experience was just the opposite (EX-2), the DAR was professional and experienced. But I will say I had my 'ducks in a row' and was ready. In regards to the Repairmans Cert, again it was rather a boring experience.

    I would not discourage anyone from learning more about thier (expensive) plane and becoming a Repairman. In my own case, there are a bunch of great knowledgeable people around the airport willing to offer help or advice; some are A&P's/IA's, and some are not.
    Last edited by aeroaddict; 08-19-2021 at 08:11 AM.

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    Quote Originally Posted by skywagon8a View Post
    dgapilot is absolutely correct on this subject. Every other year (except this year) the IAs need to meet with the FAA in March to renew their authorizations. Often the FAA legal department will make a presentation. After sitting through this presentation, it is a wonder every IA in the room doesn't stand up, throw his ticket on the table and walk out. Lawyers and sue happy people have made the profession in which most of us involved do it for the love of aviation, a very litigious occupation. It is not unusual for an unlicensed aircraft owner to accomplish something "not according to Hoyle" on his airplane. Then he presents it to the mechanic expecting the mechanic to bless it. Hopefully the mechanic finds it. Sometimes it doesn't make it's presence known until it breaks creating legal problems for the mechanic. It just is not something a mechanic should be expected to sign away his life savings upon.
    A mechanic who owns nothing is not a target therefore a lawyer will never sue them...cant get blood out of a turnip. No money payout, no reason for a lawyer to get involved. JMHO. Tim
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  32. #72

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    Quote Originally Posted by astjp2 View Post
    A mechanic who owns nothing is not a target therefore a lawyer will never sue them...cant get blood out of a turnip. No money payout, no reason for a lawyer to get involved. JMHO. Tim
    That's been my logic for some 50 years now.
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  33. #73
    wireweinie's Avatar
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    Quote Originally Posted by dgapilot View Post
    That's been my logic for some 50 years now.
    Mine, too. Unfortunately this hasn't been a voluntary situation. Maybe one day I'll own enough to get sued.

    Web
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  34. #74
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    Quote Originally Posted by aeroaddict View Post
    Thanks. I'm surprised that CC would even make a statement one way or the other (legal reasons) and surprised that the (CC) DAR would voice an opinion.

    My experience was just the opposite (EX-2), the DAR was professional and experienced. But I will say I had my 'ducks in a row' and was ready. In regards to the Repairmans Cert, again it was rather a boring experience.

    I would not discourage anyone from learning more about thier (expensive) plane and becoming a Repairman. In my own case, there and a bunch of great knowledgeable people around the airport willing to offer help or advice; some are A&P's/IA's, and some are not.
    Big difference between building an FX at the factory and an EX on your own. A lot of the FX owners sent a representative to do their build and have no desire to do their own maintenance and inspections. I work on a lot of them and they are not your average Super Cub owner.
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  35. #75
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    "they are not your average Super Cub owner." So are you saying a CC meets the definition of a Super Cub? Just kidding of course as these planes and pilots have taken a beating sometimes here on the forums.

    I assume by your statement that the owners just want the EAB category. There are some advantages of course but if they don't maintain the plane, then why?

    Good news is, it's business for you.

  36. #76
    Steve Pierce's Avatar
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    That is the only way to get a new FX3. It is not type certified and Cub Crafters does not have a production certificate so these guys want a new FX3 they or their agent must spend a week meeting the requirements and another week on final assembly and paperwork. On the other hand an EX builder builds, covers and paints the airplane. They should know the plane inside and out.
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  37. #77
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    Plenty of EXs get built by professional builders. I’m sure the same is true for Javron, Backcountry, etc. The demand for experimental Cubs is strong.

    The market is interesting. My nephew bought what I’d consider is the best standard category Cub I’ve seen sold in a long time. Recent restoration, new wings, 100 hour motor, pod, etc. He paid about half of what guys are paying for used Carbon Cubs.
    Last edited by stewartb; 08-19-2021 at 08:59 AM.
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  38. #78
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    Quote Originally Posted by aeroaddict View Post
    .... the owners just want the EAB category. There are some advantages of course but if they don't maintain the plane, then why? ....
    I can think of a couple reasons:
    first of all, no need to confirm to a type certificate--
    install whatever tires, high compression pistons, 4 into 1 exhaust, etc you want. No (expensive) STC required.
    Secondly, no IA required for annual inspection-- an A&P can do the yearly condition inspection.
    Cessna Skywagon-- accept no substitute!
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  39. #79

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    Nov 2014
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    I've experienced both types of building on my project so far - I started out with a week at Javron and then have done the rest on my "own" (I use quotes because I'm pretty sure sc.org could apply for the repairman's certificate). The builder assist week was invaluable to kick start the process. However, I'm finding that as the build has progressed, I've had to go back and properly learn what I did earlier (e.g. what type of rivets were those? what size? why? etc). I am glad I did it this way, and I wouldn't do it any other way. However, for me, if I did builder assist the whole way through, 1) I'd probably be flying by now; and 2) I would have large gaps in my understanding of plane construction.

  40. #80
    jnorris's Avatar
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    Quote Originally Posted by Sam D View Post
    However, for me, if I did builder assist the whole way through, 1) I'd probably be flying by now; and 2) I would have large gaps in my understanding of plane construction.
    And you'd have a larger hole in your wallet where some money used to be! As always, building an airplane is the act of trading time for money (and vice versa). If you have more money you can spend less time (by paying for a quick-build kit and/or using some builder assist), and if you want to save money you'll have to spend less time by doing more of the build yourself.
    Joe

    Fortis Fortuna Adiuvat
    Likes Bill Rusk, Sam D liked this post

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