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Rebuilding a factory A/C as a homebuilt?

I have been asked to broker a Tecnam P2002 Sierra. It started life as a factory aircraft. It then had the wings and empennage removed (and replaced perhaps) and a substantial Garmin panel upgrade. Then is was registered in Spain in as a homebuilt with a restricted normal category certificate of airworthiness. This would seem to operate as a permit, which is signed by the owner once every two years to extend its validity.

I’ve sold 50+ aircraft but this has me perplexed. The owner said there is no build book as it were, as this was not required in Spain. The owner said he spoke to the IAA here and they had no issue with it going on an ILAS permit as a homebuilt. I am just wondering if anyone else has seen this scenario before? It would seem to me to be a mine field, as once you had a deal agreed to sell it the potential buyer will start coming across more and more hurdles to change the registry. Maybe I am overplaying the differences due to my unfamiliarity with the situation. Perhaps this is common all over Europe and I just haven’t seen it!



U206F, J3 Sea, PA32R & others

I don’t have a useful answer to your main Q William, but your comment

“as once you had a deal agreed to sell it the potential buyer will start coming across more and more hurdles to change the registry”

resonates with numerous “for sale” scenarios I have peripherally been “near” to. It is a common thing for a buyer to want to move to a different registry and to try to make the seller enter into some sort of warranty. One must resist this no matter what, because a registry move is an absolute classic can of worms, and that’s even on a certified plane, never mind one like this with a dodgy registration history. IMHO one has to sell it 100% “as seen” – like a Ford Escort without an MOT

@Coolhand and @Aart might know about this, being Spanish based. There are other Spanish pilots here too.

Shoreham EGKA, United Kingdom

I once sold a Cessna 140 project plane here in France. I was surprised to see it show up on the French “amateur built” register a few years later, so I guess it can happen.

In the US, on FAA register, you just go to “Experimental” and that’s it.


I’ve heard of it happening in France where the UFM-10 Samba has been registered as a homebuilt after being factory built. In my experience selling permit, homebuilt and microlight aircraft is a different job to selling group A stuff, and its a lot more work. I am only doing it as its a based at same field as my Twin Com.

Peter strikes a valid point about selling aircraft and the buyers making their problems, your problems. I fell for that once but that was nearly ten years ago. When someone says to me “I need to install a 406mhz ELT, an 8.33Mhz radio and a mode S transponder” I wish them all the best with their plans for the aircraft but remind them it is an airworthy G/EI reg (whatever) aircraft as determined by a licensed engineer, and it is exactly as advertised. Its a schoolboy error to take someone else’s problems and make them your own. All part of the sparring match that selling things becomes. People throw out these little jabs to see what sort of level of experience the seller has.

U206F, J3 Sea, PA32R & others

I’ve seen two instances of similar stuff on FAA register: one is a Culver Cadet (an FAA certified plane) that was rebuilt with a owner built steel tube (versus wood) fuselage, O-200 engine and other mods. It was registered as Experimental Amateur Built. The second is a Bücker Jungmann that would normally be FAA registered as Experimental Exhibition, but which was so extensively redone (with parts from several factory built aircraft, new construction amateur built wings and different engine) that it also ended up as Experimental Amateur Built. In the US this happens when the Designated Airworthiness Representative writes up the paperwork that way, presumably after talking with somebody at FAA to get their additional buy in. Its desirable to most owners and buyers that the plane be in E-AB category.

The notion that one can just take a plane into experimental category in FAA is incorrect. It’s virtually impossible to put a certified aircraft in the FAA register as experimental. At least in any useful way. Many have tried, because it would simplify maintenance, but the only viable long term solution is the Operating Amateur Built category, and for that 51% need to be made or assembled by you. I have made comments under each.

§21.191 Experimental certificates.
Experimental certificates are issued for the following purposes:

(a) Research and development. Testing new aircraft design concepts, new aircraft equipment, new aircraft installations, new aircraft operating techniques, or new uses for aircraft.

This is time limited to maybe 1 or 2 years. After that you can re-apply to have it extended, but they will very rarely extend more than once. So not a viable solution.

(b) Showing compliance with regulations. Conducting flight tests and other operations to show compliance with the airworthiness regulations including flights to show compliance for issuance of type and supplemental type certificates, flights to substantiate major design changes, and flights to show compliance with the function and reliability requirements of the regulations.

Same thing, time limited and result based.

(c) Crew training. Training of the applicant’s flight crews.

Clearly not applicable.

(d) Exhibition. Exhibiting the aircraft’s flight capabilities, performance, or unusual characteristics at air shows, motion picture, television, and similar productions, and the maintenance of exhibition flight proficiency, including (for persons exhibiting aircraft) flying to and from such air shows and productions.

A possibility, but you have restrictions. No passengers, and can only fly to and from exhibitions or air shows.

(e) Air racing. Participating in air races, including (for such participants) practicing for such air races and flying to and from racing events.

Same as above.

(f) Market surveys. Use of aircraft for purposes of conducting market surveys, sales demonstrations, and customer crew training only as provided in §21.195.

Again, time limited.

(g) Operating amateur-built aircraft. Operating an aircraft the major portion of which has been fabricated and assembled by persons who undertook the construction project solely for their own education or recreation.

The only real option, but you need to comply with 51% rule.

(h) Operating primary kit-built aircraft. Operating a primary category aircraft that meets the criteria of §21.24(a)(1) that was assembled by a person from a kit manufactured by the holder of a production certificate for that kit, without the supervision and quality control of the production certificate holder under §21.184(a).

Not applicable.

Where you see FAA certified aircraft put into FAA Experimental Exhibiton by private owners, it is most often because they are special use aircraft in some sense. I know of two Extra 300s and a single seat factory built Pitts like that, all aerobatic aircraft. I haven’t seen the operating limitations for any of those, but FWIW the owners do not restrict operations in any sense that I’ve noticed.

One of my FAA certified aircraft was put into Experimental Exhibition or Restricted many years ago, in the mid-70s, and used with a smoke system to do a display routine, oil tank located in the cockpit. Then it was sold to a guy who owned it for a long time, and only after he’d bought it and flown it a couple of years did he find out that it’d been taken out of standard airworthiness and never returned. I have the ensuing and somewhat frantic written correspondence with the FAA, which seems to indicate that the new owner refused to admit that the situation existed, so the FAA just ‘fixed’ the paperwork. Anyway it’s OK now, per the CD which I studied pre-purchase. Things were probably done differently in the pre-Internet age

(Maybe the second paragraph above is actually on topic, more or less, and for the rest I apologize)

Last Edited by Silvaire at 24 Jan 17:20

If an aircraft is not eligible for a standard CofA e.g ex-military, annexed with no type certificate holder etc, most countries will have a sub-ICAO option of a permit to fly.
This will often be subject to different restrictions compared to an amateur-built aircraft.

To register as amateur built, you will usually have to show evidence that it was genuinely and substantially amateur built.

It’s hard to think how an essentially factory built, certified aircraft from a current manufacturer could fit into either category.

It would be interesting to know how it is described and approved on its current registration.

KHWD- Hayward California; EGTN Enstone Oxfordshire, United States

A lot of people have looked into putting their certified plane onto a “homebuilt” (term used loosely) regime – for obvious reasons.

And the national CAAs hate people doing that, for obvious reasons Hence you cannot normally do it.

The US Exp regime allows it for various specialised purposes e.g. flight testing uncertified avionics (had a thread on this before – the IFD540 tests) but a US Exp aircraft cannot be usefully based in Europe except in Germany and some 3rd World areas (had many threads on this too ). And Euro-reg homebuilts cannot generally be based in Europe outside their country of registry (some exceptions, also many threads on this but I know for a fact that many owners don’t know this)

The whole thing is a minefield, and that’s before you talk about something from Spain, with its record of completely undisputed title to land and houses built on it

Shoreham EGKA, United Kingdom


You need to talk to ILAS, I doubt there will be smooth path to getting an IAA permit unless either
(i) there is a well documented history showing this aircraft was 51%+ amateur built (not apparently applicable) or
(ii) is is a classic/orphan non-certified type such as the Jodels etc. (not apparently applicable).

Some folks who imported a PH-registered non-amateur-built Zenair fell into a similar predicament to the one you describe, when attempting to obtain a permit to fly for EI-registration.

Good luck.

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