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E-AB build documenation and stipulations for heavily pre-fabbed kits

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mcurcio1989

Well-Known Member
Joined
Mar 15, 2013
Messages
178
Location
Toledo
I am building an Aventura 2 amphibian. This design of the airframe is very very similar to a Sea rey but with the ultralight style wings (bent tubes not ribs). All of the tubing comes pre-bent and in many cases pre-drilled. I'll de-burr the holes and file and smooth edges before installing parts and sometimes enlarge a hole or drill a hole once the part is lined up. There are a couple hundred of these planes out there and obviously there are loads of planes built with ultralight style construction (bent tubing bolted together with plastic fittings etc.) Quicksilver would be a good comparison. I assume that due to the low build time on the quicksilver planes that like mine, there is really not a lot of fabrication left to the builder. So how does this work for the 51% rule. Reading through the list in Appendix 8 of AC 20-27G, assembly holds basically the same amount of weight as fabrication so I see how they meet the 51% rule with the minor fabrication doen. So what has me scratching my head is the table on p15 of that advisory circular. It states that if

"You assembled your aircraft from a kit composed of completely finished, prefabricated components, parts, or precut or predrilled materials, and using these materials means you did not fabricate and assemble the major portion of the aircraft" than you are not eligible for E-AB.

While of course technically you meet the 51% rule it seems that kits like this (there are loads out there) are really dancing on a fine line and a picky DAR may really give you trouble. Of course that said, there are loads of planes like this out there and this construction / design does not really lend itself to a whole lot of fabrication requirements for the builder anyways. My interpretation of the quote above is that they are trying to avoid people taking advantage of the system and will frown upon building a kit from mostly prefabbed parts where the majority of your 51+% came from assembly.

With all that said I am trying to make sure that I have all of the appropriate documentation - build logs and pictures. Question is how much does the DAR usually look at this stuff. Is it a quick glance or do they nit pick through it? Also what type of pictures do you need - Should I be taking a picture of every part on the checklist before and after is has been fabbed (as necessary) and assembled to the airframe?
 
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