Question: Can experience gained building an Experimental, Amateur-Built aircraft count toward the practical experience requirements required for an airframe or powerplant license?
Answer: The FAA requires at least 18 months of practical experience for one rating (airframe or powerplant) or 30 months for both ratings. Based on a 40-hour workweek, that equals 2,880 hours of experience for one rating and 4,800 hours for both ratings. The time need not be full time or in consecutive months. FAA Handbook 8900.1, Volume 5, Chapter 5, Section 2, paragraph 5-1135 states that "work gained on an experimental amateur built aircraft should be evaluated on its own merits to determine whether it fulfills the experience requirements". Therefore, you must be able to document the time spent and experience gained in building and maintaining an Experimental, Amateur-Built aircraft. Since it is required that you maintain a builders log in order to receive an Experimental, Amateur-Built airworthiness certificate, you may use the log as documentation of meeting the A & P Experience requirements. There is no required format of a builders log. We suggest a three ring binder be used to keep a running log of the date, time and what was accomplished. As the log is entirely up to the builder to keep, it would not be a bad idea to have it validated from time to time by a friendly A & P with an entry such as "I have reviewed the work hours and the log of the work and found them to be correct. Signed John Smith, A & P, etc." Another way to validate the log is to have it notarized and taken to the FAA inspector.
From FAA Handbook 8900.1, Volume 5, Chapter 5, Section 2:.
5-1135 EXPERIENCE REQUIREMENTS. Section 65.77 requires the applicant to have documented practical experience in maintaining airframes and/or powerplants. At least 18 months of practical experience is required for the appropriate rating requested. For a certificate with both ratings, the requirement is for at least 30 months experience concurrently performing the duties appropriate to both ratings. If the 30 months concurrently performing the duties appropriate to both ratings has not been met, then calculate each rating separately using the 18-month requirement for each.
A. The practical experience must provide the applicant with basic knowledge of and skills with the procedures, practices, materials, tools, machine tools, and equipment used in aircraft construction, alteration, maintenance, and inspection.
B. With exception to the JSAMTCC A&P certification program experience gained from the military, work as an airframe or powerplant mechanic or work on an experimental amateur-built aircraft will be evaluated on its own merits to determine whether it fulfills the experience requirements. When evaluating military experience, aviation safety inspector’s (ASI) and ASTs are not to accept military occupational specialty (MOS) or Air Force Specialty Codes (AFSC) “carte blanche” as qualifications to accepting experience of § 65.77. Even though the MOS suggest authorization for either the airframe, powerplant, or both the A&P certificates, the inspector will only endorse FAA Form 8610-2, Airman Certificate and/or Rating Application, after ensuring, by a thorough interview and detailed review of records, that the person qualifies under § 65.77.
C. An applicant is not expected to be highly proficient in overhauls, major repairs, or major alterations in the minimum 18 months experience.
D. Powerplant tests will include questions and projects on propellers that must be completed successfully regardless of the applicant’s experience.
E. In evaluating documented part-time practical aviation mechanic experience, an equivalent of 18 months (or 30 months) based on a standard 40-hour workweek is acceptable. The months need not be consecutive. A standard workweek has 8 hours per day for 5 days per week, thus totaling 40 hours per week and approximately 160 hours per month.
F. For foreign applicants located in the United States, all of the requirements for a citizen of the United States apply. This includes applicants who come to the United States just to take the mechanic test. For those located outside the United States, refer to volume 5, chapter 5, section 3. The following are types of documents that will be acceptable to establish the required record of time and experience:
1) A detailed original statement from a foreign airworthiness authority of the country in which the experience was gained.
2) A detailed statement from an advisor of the International Civil Aviation Organization (ICAO) that will validate the applicant’s experience.
3) If the foreign civil authority refuses to provide this information, the inspector will take appropriate action to determine that the experience is valid.
NOTE: Appropriate action is whatever the inspector deems appropriate to determine that the experience is valid, i.e., review supporting documentation presented to satisfy authorization, without expending an excessive amount of time or resources on behalf of the applicant.
4) Foreign military experience is considered acceptable experience toward authorization to take the knowledge test based on the context of § 65.77. The applicant must present verifiable documentation from the foreign military or government substantiating the military work experience. Review the current version of AC 65-11, Airframe and Power Plant Mechanics Certification Information, for guidance.
NOTE: If the applicant shows only foreign military work experience on aircraft that are not manufactured to U.S. standards, that is not an issue; the experience still has to meet the requirements of § 65.77.
G. Applicants who have not graduated from an FAA-approved AMTS or JSAMTCC A&P certification program must present documents from an employer, co-worker, or other sources satisfactory to the Administrator to establish the required record of time and experience.
1) Applicants will document a proportionate amount of experience directly applicable to the certificate and ratings sought. The applicant must have verifiable experience in 50 percent of the subject areas listed for the rating sought (see 14 CFR part 147, appendices B, C, and D) in order to be eligible.
2) The FAA inspector must evaluate the documents submitted to determine the applicants’ eligibility for a test authorization.
3) There is no expiration for this eligibility.
H. Applicants who have not graduated from an FAA-approved AMTS or JSAMTCC A&P certification program and are applying based on military experience must prove that their military aviation experience, gained in 50 percent of subject areas, meets the requirements of part 147.
1) To help speed the review process, the applicant may supply the following documentation to the FAA:
a) A positive form of picture identification, such as a driver’s license, passport, or military I.D.
b) A properly completed Form DD-214, which lists the total time in service and the MOS codes the applicant was assigned (for current MOS codes, see Figure 5-135).
c) A letter from the applicant’s executive officer, maintenance officer, or classification officer that certifies the applicant’s length of military service, the amount of time the applicant worked in each MOS, the make and model of aircraft and/or engine on which the applicant acquired the practical experience, and where the experience was obtained.
d) Training records showing the type of aviation schools the applicant attended and/or a record of on-the-job training. Active duty Air Force, selective guard, and reserve are eligible for a transcript.
2) Time spent in training or in a MOS for supervision and/or inspection will not be counted toward the 18 or 30 months of practical experience required in § 65.77. Only actual hands-on experience is acceptable.
3) The JSAMTCC A&P certification program permits military applicants to be granted authorization to take the Airframe and Powerplant (A&P) Knowledge Test upon presentation of a military Certificate of Eligibility (see Figure 5-137), and a Certification Performance of Job Tasks form (see Figure 5-136).
4) As required by the JSAMTCC A&P certification program process, military technicians will be provided with an individual FAA Certification Performance of Job Tasks by their branch of service. Upon the completion of the program and validation of all signed tasks, an official Certificate of Eligibility will be issued by the participant’s branch of service along with a signed copy of the FAA Certification Performance of Job Tasks.
5) Sample copies of the FAA Certification and Performance of Job Task and the Certificate of Eligibility are located in Figures 5-136 and 5-137, respectively. On the certificate, the seal affixed in the lower right corner is gold in color and carries a raised embossed stamp from the applicant’s training organization.
6) The military experience must be directly applicable to the certificate and ratings sought.
7) There is no expiration for this eligibility.
8) Applicants must be advised that the authorization to test is only valid for testing by Designated Mechanic Examiners (DME) who exercise privileges within the geographic area served by the FSDO where the authorization is granted. Should the applicant wish to test with a DME in another district, additional FAA approval will be required. The DME must gain permission from their FSDO/international field office by any written means to conduct a test for an applicant authorized in block 5 from an inspector from another geographical location.
Falsification of Logbook Entries
FAR 65.20(a)(2) governs the falsification of logbook entries and states:
(a) No person may make or cause to be made –
(2) Any fraudulent or intentionally false entry in a log book, record, or report that is required to be kept, made or used, to show compliance with any requirement for any certificate rating under this part.
(b) The commission by any person of this act prohibited under (a) of this section is a basis for suspending or revoking any or ground instructor certificate or rating held by that person.
AC65-2D Airframe & Powerplant Mechanics Certification Guide