Experimental Amateur-Built Inspections: What to Expect

There aren’t a lot of pilots whom I know who enjoy checkrides. Oh sure, some say that they do, that they enjoy the process of learning something new and then proving that they know it. But most still have a little secret dread about an upcoming examination—if for no other reason than a failure can change their plans for the future.

The same can be said for homebuilders reaching the end of an aircraft project. They know that they have to pass an inspection, and for those who have never done it, the equivalency to a checkride is too hard to ignore. So let me tell you the first thing that I tell everyone for whom I am doing an airworthiness inspection as a Designated Airworthiness Representative (DAR) when I show up: “This is not a checkride!”

Sure, we are going to make sure that all your paperwork is up to snuff, and sure, we are going to have a look at all the work you have done for the past several years. But my goal as an inspector is to leave your hangar with you grinning from ear to ear with your new airworthiness certificate. If there are minor problems, we’ll fix them. If there are major problems, we’ll talk about them. But I am not holding any secret cards, I get nothing out of failing you, and the fact is, writing a denial letter is the beginning of a long process that none of us want to go through. So let’s just get down to it and talk about what inspections are about, and what they are like.

First, realize that an average condition inspection takes a very experienced mechanic the better part of a day on an aircraft with which they are familiar. Most people take at least a weekend if not a week, and some take a month. When we do your airworthiness inspection, we’re going to spend a couple of hours at it, and that should tell you something. The inspection is not a substitute for a condition inspection, and it will not be as thorough. The DAR (or FAA inspector) will not sign your logbook attesting to the fact that the aircraft is in a “condition for safe operation.” In fact, it is a requirement that the builder/owner signs such a statement before we even look at the plane. The owner is the one attesting to the “safe condition,” not the inspector. We’ll make a logbook entry that the aircraft “qualifies for an Airworthiness Certificate”—but that is not so much about the aircraft as it is meeting the (fairly minimal) requirements and that the paperwork is all complete.

Let’s pause a moment and talk about the terms “airworthy” and “airworthiness” (as in certificate). In the certified aircraft world, an aircraft is “airworthy” if it conforms to its type certificate—and that includes being in a condition for safe operation (although the term is rarely used for certified machines). Since Experimental/Amateur-Built (E-AB) aircraft do not have type certificates, they cannot ever be “airworthy” by that definition. But we can issue one an airworthiness certificate (a special one) because all manned flying machines in the U.S. have to have one to be legal to fly. The term “airworthiness” is an unfortunate coincidence with the term “airworthy”—nothing more. When an inspector follows the guidance (given in FAA document 8130.2) that requires them to inspect the aircraft to make sure that it is “airworthy,” they are really being asked to inspect it to make sure that it “qualifies for an Airworthiness Certificate.”

So, what does an E-AB aircraft have to do to qualify for an airworthiness certificate? Well, you have to fill out all the paperwork properly. You have to write a Program Letter to the FAA telling us what you want to do—specifically, in this case, that:

“In accordance with section 21.193, I request a Special Airworthiness Certificate for my aircraft for the purpose of operating amateur-built aircraft.”

Along with the Program Letter, you need to sign the Affidavit (Form 8130-12) that says that you built the aircraft for education and recreation—this is where you perjure yourself if you paid someone to build the airplane for you. You also have to prove that the airplane is registered (you have to have the Registration Certificate), you have to provide a three-view drawing, and you need to be able to show the inspector the weight and balance, a construction log (or some way to prove that you built it), and that you have properly marked the aircraft.

You will apply for the airworthiness certificate by logging in to the FAA’s Airworthiness Certification website (known as AWC) and entering all of the information that it asks for. Builders used to have to figure out how to fill in the actual application—the nice thing about AWC is that it does that for you, accurately, based on the answers you give it. Once you have filled out your application and selected either a FSDO inspector or DAR, you submit it. AWC will forward this into the machine, and it will eventually be assigned to your DAR or inspector for work.

The great thing about AWC is that once a DAR like myself gets the application, we can see all of the paperwork that we need to see before we come out for your inspection. If we see any problems, we work directly with you to correct them before we come out—it is very collaborative, not at all adversarial. We want to issue you an airworthiness certificate, and we’re not going to be tricky, or make you jump through hoops just to watch you do it. We probably make minor tweaks with the applicant in about 50% of the cases we work—it is just not a big deal. Once everything is set in AWC, we’ll set a date and time for your inspection.

When I show up for an inspection as DAR, I ask that the airplane be opened up “as for condition inspection.” The fact that the owner has to do such an inspection before I arrive makes that easy—I just tell them to leave the inspection covers and cowl off, along with any interior panels I need removed to see control connections. We will not ask for extensive disassembly, and many FAA inspectors, unfamiliar with light aircraft, will not even ask for that—they will show up, check your paperwork, see that the markings all match, and sign your airworthiness certificate. Those of us that have signed on as DARs generally are a bit more committed to checking the “killer items” for you as a second set of eyes.

What are the killer items? We want to prevent structural failure, loss of control, fires, and engine failures. To do this, we’re going to look over your primary structure and connections (such as nuts and bolts that we can easily see). In doing that, we’ll get a feel for your workmanship. We’re next going to check control continuity from the stick and pedals all the way to the control surfaces, looking for locknuts, safety wire, tight jam nuts … all the things that are needed to keep the flippers moving with the stick. Next, we’ll look over the fuel system to make sure it is up to snuff, well built, and has no leaks or loose fittings. Chafing is another thing we look for—all of this being to prevent fires. And then we’ll take a good look firewall-forward to add our eyes and experience to make sure controls work, exhausts are tight, fuel lines are secure, and there is a good chance that the engine will keep running. We’ll most likely ask that you show us that you’ve run the engine/airframe combination for at least one hour on the ground to make sure everything works.

Finally, we have to make sure that your aircraft meets the marking requirements. The N-number has to match 14 CFR 45 requirements, you have to have a Passenger Warning, you have to have a 2-inch high “Experimental” placard, and you have to have a data plate with Make, Model, and Serial number that EXACTLY matches the registration (and that means word order, capitalization, and punctuation. Paul F. Dye is not the same as Dye, Paul F. for instance). We also need to make sure that all controls are marked with what they are, and how they work. “Throttle,” “Open,” “Close” is an example. So is “Landing Light” with an “On” and an “Off.” We cannot assume that up is on and down is off—they must be labeled.

What are we not going to do? We’re not changing or checking your oil, not doing a compression check, not checking your timing. We’re not checking tire pressures, looking for cracks and tears everywhere (or anywhere) in the structure. We’re not going to snake a borescope anywhere—like you might do during your condition inspection. That is not the purpose of an airworthiness inspection for the purpose of issuing an airworthiness certificate.

You will—if you are using a well-respected DAR—be getting an experienced set of eyes and hands to go over your project one last time, but you should not be depending on them to catch every last problem or hidden defect. This is why we always recommend the use of EAA Technical Counselors and other experienced builders to go over your project several times. Each time, they will find something that you, they, or someone else missed. Risk mitigation is an iterative process.

I’ll leave you with this final example of the need for iteration. As a DAR, I can’t issue an airworthiness certificate for my own project—that would be a conflict of interest—so I had a friend from the FSDO agree to do the inspection on my recent project. Two days before the scheduled inspection, I went over the airplane with my DAR checklist and decided it was ready. The next day, my wife (who has helped build several planes and has her own ongoing project) took the same checklist and went over the airplane for a couple of hours. She found five squawks (all minor, but there, nevertheless) that I had missed. In going through her squawks, I found three more very minor ones on my own.

No one is perfect, no one is flawless—so get eyes on the project, and remember that your final inspection—with a DAR or FAA inspector is never going to catch everything—nor is it intended to. In the end, you are responsible for the condition of your aircraft—but smart builders take advantage of every bit of help they can get.