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Data Plate - Did the FAA mess up?

eavila1

Well Known Member
Friend
I registered my RV-9 a few months back and the Registration has my full name and address etc as the owner , but they put the manufacturer as Vans Aircraft Inc. They also have Vans Aircraft as the Kit manufacturer which is correct.

I sent a request into the FAA immediately to look at this and make a correction if needed. No response.

So my dilemma is I need to engrave my data plate for a pending soon to come inspection. I'm the manufacturer. But I don't want it to not match my registration.

Pipe in all you seasoned DAR's...... What shall I do? Am I the one with the wrong thinking? Is Make the same thing as Manufacturer?
 
you are the manufacturer
no need to list kit provider
a dar will respond if it is necessary to correct
 
Yes - sadly, you’re going to have to correct this with Aircraft Registration, and they are NOT in a very helpful mood right now for some reason. If you go back and look at all the paperwork you submitted, you might find a clue in why it got done that way - but regardless, the Registration and Dataplate must match, and while it could slow down your inspection, its easier to fix it now than later.
 
Just a thought. The manufacturer can be listed as a company as far as I recall. Your registration shows “VANS ACFT INC” as the manufacturer. Maybe form a corporation with that name and stick with the registration and avoid months getting this changed?
 
Just a thought. The manufacturer can be listed as a company as far as I recall. Your registration shows “VANS ACFT INC” as the manufacturer. Maybe form a corporation with that name and stick with the registration and avoid months getting this changed?
I think that "Van's" may have a word to say about that solution.
 
I think that "Van's" may have a word to say about that solution.
Maybe, but it's already on the registration and there's not much they could do about it. They don't have a registered trademark and there's nothing that prevents someone from forming a company with a similar sounding name in a different state, especially if they're not using the name to make money. It's a lot simpler than delaying the project many months or longer to deal with bureaucratic black box just to fix a clerical error.
 
You may want to enlist a title service to get this squared away quickly. I have used Insured Aircraft Title Service in OKC on numerous occasions for Aircraft transfer and registration. They usually get the job done in a day. Last time I used them for registration it was $65. They can also provide any historical paperwork that was filed with the FAA over the years.
 
Personally, I think the "manufacturer" should be listed as "Amateur Construction".

I actually went thru a similar experience with my repair station; the FAA wanted me to keep a "capabilities" list of airframes I was authorized to work on. That turned into learning/WTF moment for my inspector when I told him each EAB aircraft has a different manufacturer, which would mean a capability list of hundreds of pages, and manual revision approvals would be required for each one.
He quickly dropped the requirement to list airframes in my repair manual.
 
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I registered my RV-9 a few months back and the Registration has my full name and address etc as the owner , but they put the manufacturer as Vans Aircraft Inc. They also have Vans Aircraft as the Kit manufacturer which is correct.

I sent a request into the FAA immediately to look at this and make a correction if needed. No response.

So my dilemma is I need to engrave my data plate for a pending soon to come inspection. I'm the manufacturer. But I don't want it to not match my registration.

Pipe in all you seasoned DAR's...... What shall I do? Am I the one with the wrong thinking? Is Make the same thing as Manufacturer?
The first question is what did you put in the box on form 8050-1, the one labelled "Aircraft Manufacturer and Model"?
 
Some people, in my opinion, have too much information on their data plate. Of course you can do that if you want, but all that is required is three basic things, which I have done on mine, inexpensively:

 
Some people, in my opinion, have too much information on their data plate. Of course you can do that if you want, but all that is required is three basic things, which I have done on mine, inexpensively:
Yep, Make, Model, and Serial Number. But the important thing is that they must match the registration exactly!
 
The first question is what did you put in the box on form 8050-1, the one labelled "Aircraft Manufacturer and Model"?
ugh yeah I went back and looked and I put Vans Aircraft thinking it was asking for the kit manufacturer for that box on the form. It seemed too repetitive to place my name again as owner a few boxes below that on 8050-1. Well my DAR hasn't said anything yet and I'm thinking I need to bring his attention to it?

I realized what I'd done when finally looking at the data plate 3 item requirement where the builder is the manufacturer.
 
Yes - sadly, you’re going to have to correct this with Aircraft Registration, and they are NOT in a very helpful mood right now for some reason. If you go back and look at all the paperwork you submitted, you might find a clue in why it got done that way - but regardless, the Registration and Dataplate must match, and while it could slow down your inspection, its easier to fix it now than later.
It looks as if the person looking back at me in the mirror hosed this up. Live and learn
 
You may want to enlist a title service to get this squared away quickly. I have used Insured Aircraft Title Service in OKC on numerous occasions for Aircraft transfer and registration. They usually get the job done in a day. Last time I used them for registration it was $65. They can also provide any historical paperwork that was filed with the FAA over the years.
Jake can you send me their contact info and Name. I googled but three or four come up. Potentially wanting to use the one you mentioned if it will save me time and bureaucratic hassle
 
Wow!! The stars are aligning. I waited for 45 minutes on the FAA toll free number and got the right person.

Turns out I correctly filled out my affidavit as the builder. So she said they coded it wrong and is fixing it today and sending out a new registration. Will email me the temporary for my DAR inspection. Not counting my chickens quite yet until I get the email/temp new registration but looks as if issue resolved.

Also it pays to be nice to get things done. I'm learning. A little luck too. Triple check your paperwork and even then sometimes people make mistakes
 
From the NOW YOU TELL ME Department.(Note I am not a DAR or FAA inspector so this is my experience and opinion.) One comment I saw that hit a nerve is FAA not knowing their own guidelines and being inconsistent. Personally it would both me, if I built it, I want my name as manufacture on registration and data base.

KIT manufacture line is a newish things (may be decades but was not always a thing before Kit planes ruled over Part 23).

Kit ManufacturerVANS AIRCRAFT INCKit ModelRV-X

Make/Manufacture put your name, Last First MI (no punctuation)
Model: RV-X (don't put "Vans RV-X" or anything but model, is my advice, but do as you like. Look at the CVS list of all registrations and sort. You will see variations, but I looked at the most common simple way, makes sense to me, Model RV-X. In my case my Airworthiness is blank since plane has not been inspected yet or flown. That is where the engine and other information goes.

"AIRWORTHNESS " from your DAE / FAA inspector, fills out more info on your plane. MAKE SURE they fill it out right, with correct everything including manufacture, because they could change it (may be?). Do not just ASSUME they (FAA/DAR) did PPW right. Some newish FAA guy, maintenance side of FSDO, junior, so they send him on these field trips, may not get it right. I also know of one 2 yrs ago and they did no real in-depth inspection, just PPW. A senor FAA guy may not get it right, humans make mistakes. Make sure they get your engine and other data filled out. Again not sure if they still do all that. I know LSA is apparently different.

LSA IS DIFFERENT: I did some work, inspections, pre-sale, looking at a RV-12iS, a E-LSA version. The aircraft owner was correct. The manufacture is Van's Aircraft. I questioned that being he built it. That is they way they do it with Light Sport Aircraft. I do not know if they now have extended that to EAB but I can tell you I registered my new project last year and it shows my name as manufacture.

HIGHTLY RECOMMEND EAA's Kit Plane Package with all kinds of good info on doing your PPW and your Airworthiness inspection. I recommend you get someone experienced person (may be a EAA Tech Council) to look at it. Also READ the instructions.

TIP : 1st registration by builder need Van's Bill O Sale, which you must request from Van's (MAKE COPIES*). You also need your proof of ownership, meaning your receipts buying kit. If bought from another person you have to have their receipts, a paper trail of ownership pre registration. Send in with your application, BE SURE TO PAY THE FEE correctly. If you had a reserved N-Number it is less than if not. MAKE COPIES is important. FAA wants originals, but the STATE TAX collector may write you and say HEY I SEE YOU HAVE A PLANE, please pay us with-in 30 days of the letter date (which is already a week old). They will ask for same PPW you sent FAA. So COPIES!!! Also have some for your records, just as a back up. I won't get into state TAX, but that is a whole deal. PM me if you like, but it is state to state.

Good news is YOU are the owner... that is the main thing.
 

Make/Manufacture put your name, Last First MI (no punctuation)
You can put anything you want, but most use their name. HOWEVER, it need not be Last First MI...mine is First MI Last, e.g.

HIGHTLY RECOMMEND EAA's Kit Plane Package with all kinds of good info on doing your PPW and your Airworthiness inspection. I recommend you get someone experienced person (may be a EAA Tech Council) to look at it. Also READ the instructions.
Absolutely! Learn from the thousands who have gone before you, no need to flounder around and rediscover ways to F this up. Get the kit.

TIP : 1st registration by builder need Van's Bill O Sale, which you must request from Van's (MAKE COPIES*). You also need your proof of ownership, meaning your receipts buying kit. If bought from another person you have to have their receipts, a paper trail of ownership pre registration. Send in with your application,
You do NOT, AFAIK and it wasn't required when I registered mine, need to send in copies of receipts. What you DO need to send them is the affidavit of ownership, form 8050-88. Keep the receipts, sure, but what the FAA wants is the notarized affidavit, not the receipts. But *this is all explained in the EAA Kit*.
 
Manufacturer: you (builder)
Model: rv-xx
(Vans doesn’t control engine/ avionics/mods/electrical/prop/weight-balance and there is no POH until you test and create one) (for the DAR “you” declare the aircraft is safe for flight)
 
You can put anything you want, but most use their name. HOWEVER, it need not be Last First MI...mine is First MI Last, e.g.


Absolutely! Learn from the thousands who have gone before you, no need to flounder around and rediscover ways to F this up. Get the kit.


You do NOT, AFAIK and it wasn't required when I registered mine, need to send in copies of receipts. What you DO need to send them is the affidavit of ownership, form 8050-88. Keep the receipts, sure, but what the FAA wants is the notarized affidavit, not the receipts. But *this is all explained in the EAA Kit*.
yep the notorized affidavit is what saved me.
 
You can put anything you want, but most use their name. HOWEVER, it need not be Last First MI...mine is First MI Last, e.g.


Absolutely! Learn from the thousands who have gone before you, no need to flounder around and rediscover ways to F this up. Get the kit.


You do NOT, AFAIK and it wasn't required when I registered mine, need to send in copies of receipts. What you DO need to send them is the affidavit of ownership, form 8050-88. Keep the receipts, sure, but what the FAA wants is the notarized affidavit, not the receipts. But *this is all explained in the EAA Kit*.
I follow the FAA form instruction and EAA's recommendations. Just what worked for me.

Yes, Form 8050-1 Aircraft Registration Application; Van's Aircraft provides a Bill of Sale (FAA Form 8050-2) for their kits a must if you built it*; Affidavit of ownership FAA.AC Form 8050-88 which must be signed in front of a notary public, plus $5 Check or money order payable to the Federal Aviation Administration for FAA assigned N-number, custom N-number requires I recall a whopping plus $10 more.

My points make COPIES of originals (but send inked originals) and get the Cert Kit from EAA for $20 ($18 for EAA members).

EAA Amateur-Built Certification Kit
 
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for the DAR “you” declare the aircraft is safe for flight
After a MOSAIC-induced dive into the minutiae, I was surprised to learn that the DAR also has significant personal responsibilities on that front.

Issuance of the initial AWC to a newly constructed EAB (for example) requires the FAA or its designee to identify potential safety hazards (8230.2L 2-3.d), and to physically inspect the aircraft to verify that the aircraft is airworthy (2-3.f.10). The DAR can only issue an AWC if he or she specifically finds, among other things, that the aircraft is airworthy (2-3.h.1).
 
After a MOSAIC-induced dive into the minutiae, I was surprised to learn that the DAR also has significant personal responsibilities on that front.

Issuance of the initial AWC to a newly constructed EAB (for example) requires the FAA or its designee to identify potential safety hazards (8230.2L 2-3.d), and to physically inspect the aircraft to verify that the aircraft is airworthy (2-3.f.10). The DAR can only issue an AWC if he or she specifically finds, among other things, that the aircraft is airworthy (2-3.h.1).
In my experience, most FAA inspectors are great at nitpicking paperwork but lack actual aircraft skills (as in never worked on one).
 
In the context of aircraft registration, the FAA says it is.
On my Special Airworthiness Certification there is “Builder” (manufacturer box has N/A).
On my registration it is “Manufacturer“.
On my limitations it is “Make”.
On my Data Plate it is “Manufactured By”
 
On my Special Airworthiness Certification there is “Builder” (manufacturer box has N/A).
On my registration it is “Manufacturer“.
On my limitations it is “Make”.
On my Data Plate it is “Manufactured By”
Exactly my point
Among the different divisions of the FAA, Make and Manufacturer are used synonymously.
 
Remember to ask about Repairman's Certification documentation. The DAR provides a document. Another opportunity to get things mixed up. FAA went around internally on mine and I assume they got it right. They sent me the cert and it has Lucy's N-number.
 
Update: just in case people need to hear a success story with FAA. I was emailed my corrected temporary registration that now has my name as the manufacturer rather than Vans. This was corrected and done in a matter of days. She said a new hard copy is being mailed. Way to go FAA and to this particular employee who takes pride in just being competent and efficient.

Woohoo inspection set for next week. Now to double and triple check everything until then
 
Yep, Make, Model, and Serial Number. But the important thing is that they must match the registration exactly!
Perhaps not exactly. I had some issues with this. My registration listed the model as "RV-12IS" all caps. My bill of sale from Van's had the model as "RV-12iS" with a lower case "i". So, when all of the paperwork and a photo of my data plate (with RV-12IS) matching the registration exactly was submitted through AWC online there was an issue with the data plate. I had to have a new one made with a lower case "i". Drilled the rivets and attached the new one to the fuselage. Too bad I couldn't get a plate that was the same size so I have 3 holes that had to be filled with rivets as the new plate is smaller. All of this had to be done very quickly and the plate sent overnight as I already had my inspection scheduled. I just wanted to get it flying and did not fight over it. The DAR was somewhat shocked also and tried to argue my case to no avail. It was a lower case somewhere in the system and the FAA said the registration will always be all caps. My Airworthiness Certificate has a lower case "I". It is the newer computer printed one with at Operational Limitations attached. Not hand written like in the past.

Henry
 
Perhaps not exactly. I had some issues with this. My registration listed the model as "RV-12IS" all caps. My bill of sale from Van's had the model as "RV-12iS" with a lower case "i". So, when all of the paperwork and a photo of my data plate (with RV-12IS) matching the registration exactly was submitted through AWC online there was an issue with the data plate. I had to have a new one made with a lower case "i". Drilled the rivets and attached the new one to the fuselage. Too bad I couldn't get a plate that was the same size so I have 3 holes that had to be filled with rivets as the new plate is smaller. All of this had to be done very quickly and the plate sent overnight as I already had my inspection scheduled. I just wanted to get it flying and did not fight over it. The DAR was somewhat shocked also and tried to argue my case to no avail. It was a lower case somewhere in the system and the FAA said the registration will always be all caps. My Airworthiness Certificate has a lower case "I". It is the newer computer printed one with at Operational Limitations attached. Not hand written like in the past.

Henry
There is nothing the system does to cross check documents before the DAR has even done your inspection and issued the airworthiness certificate.
I have a feeling it was actually the managing specialist of the DAR that looked through the documents and decided that your data plate should be changed.
When a DAR goes through training, it is emphasized very strongly that the information depicted on the data plate has to match the information on the 80 50–3 registration card exactly. Right down to any punctuation, hyphens etc..

In the end, though, you have to just do what you’re being told. Even if it is not correct.
 
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Looking for some help in understanding this from those familiar with the inner workings.

Starting point: ACs are not regulations per se, but are authoritative for interpretation as official guidance.

The document posted appears to be not an AC, but an FAA Order, which I thought was mandatory to comply with for the FAA, and helpful but not binding for the public. Wouldn't then all registrations etc. need to, or at least be allowed to, comply with the definitions in the order?

Not trying to pick a fight, just trying to understand why following the order isn't the acceptable answer. Mods please delete or move if problematic.
 
Looking for some help in understanding this from those familiar with the inner workings.

Starting point: ACs are not regulations per se, but are authoritative for interpretation as official guidance.

The document posted appears to be not an AC, but an FAA Order, which I thought was mandatory to comply with for the FAA, and helpful but not binding for the public. Wouldn't then all registrations etc. need to, or at least be allowed to, comply with the definitions in the order?

Not trying to pick a fight, just trying to understand why following the order isn't the acceptable answer. Mods please delete or move if problematic.
Mel and Walt, look at their signatures. OK. Yes AC are more advisory not binding (but they are note below). Of course there are debates, because internet and:

1) FAA on occasions does not understand or is consistent with their own "Orders". FAA Inspectors (and DAR's) follow these Orders fairly well, but stuff happens. Things are indeed subject to (legal) interpretation. So debate might be educational, or find an error regardless of who made it. FAA can make mistakes. :rolleyes:
2) Yes AC's although not binding, informational, educational, clarification, CAN BE interpreted as law in Court. There are infamous cases of pilots violated for not following an AC or AIM missive, or shock of shock actually violated following an AC. :oops: Catch 22. Bottom line AC's, AIM are "official", recognized by authority.​
3) AIM is not regulatory like an AC, but both are "Regulatory in Nature". Meaning it is written down and they kind-a, wanna, u2, follow it (unless they don't). I know of violations of a pilot for not following an AC or AIM recommendation. Although not regulatory you will be slapped hard. Judges put a weight into these Docs.​
4) The only person'(s) opinion that matters is "The Administrator" and their Lawyer's and Federal Judges in DC. The FAA's own Lawyer's and Fed Judges at times disagree with how FAA interprets their own regulations, orders, etc. So they get their hand slapped, which sometimes causes a kerfuffle for GA, Airlines and Manufactures.​
5) Data Base, records, are handled by bureaucrats (not meant as a pejorative) in Oklahoma, entering the paper work they are given (I say with sympathy). They don't make the rules, just manage the records. If something is glaring I am fairly sure they flag it. Subtitle nuances, issues like this is not their concern, responsibility. Garbage in garbage out. I am sure they have QC, error checking, checklist, trained, but... Overall I think OK records does a great job.​

In the end no one is going to get hurt but someone's feelings may be, which I understand. You spend many years and dollars building a plane, flying it, you want your name as manufacture. All I know, I got my name as manufacture on an RV-7 a year ago or so. The friends RV-12iS registered before min by a year or so, an E-LSA does not show him as builder. Looking at that ORDER after talking to local FAA (had to go through 2 Inspectors to find one who knew what was up) that is correct. So no argument. "I was only following orders". I prefer the Sergeant Hans Schultz defense: "I know nothing! I see nothing! Nothing!".
 
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Mel and Walt, look at their signatures. OK. Yes AC are more advisory not binding (but they are note below). Of course there are debates, because internet and:

1) FAA on occasions does not understand or is consistent with their own "Orders". FAA Inspectors (and DAR's) follow these Orders fairly well, but stuff happens. Things are indeed subject to (legal) interpretation. So debate might be educational, or find an error regardless of who made it. FAA can make mistakes. :rolleyes:
2) Yes AC's although not binding, informational, educational, clarification, CAN BE interpreted as law in Court. There are infamous cases of pilots violated for not following an AC or AIM missive, or shock of shock actually violated following an AC. :oops: Catch 22. Bottom line AC's, AIM are "official", recognized by authority.​
3) AIM is not regulatory like an AC, but both are "Regulatory in Nature". Meaning it is written down and they kind-a, wanna, u2, follow it (unless they don't). I know of violations of a pilot for not following an AC or AIM recommendation. Although not regulatory you will be slapped hard. Judges put a weight into these Docs.​
4) The only person'(s) opinion that matters is "The Administrator" and their Lawyer's and Federal Judges in DC. The FAA's own Lawyer's and Fed Judges at times disagree with how FAA interprets their own regulations, orders, etc. So they get their hand slapped, which sometimes causes a kerfuffle for GA, Airlines and Manufactures.​
5) Data Base, records, are handled by bureaucrats (not meant as a pejorative) in Oklahoma, entering the paper work they are given (I say with sympathy). They don't make the rules, just manage the records. If something is glaring I am fairly sure they flag it. Subtitle nuances, issues like this is not their concern, responsibility. Garbage in garbage out. I am sure they have QC, error checking, checklist, trained, but... Overall I think OK records does a great job.​

In the end no one is going to get hurt but someone's feelings may be, which I understand. You spend many years and dollars building a plane, flying it, you want your name as manufacture. All I know, I got my name as manufacture on an RV-7 a year ago or so. The friends RV-12iS registered before min by a year or so, an E-LSA does not show him as builder. Looking at that ORDER after talking to local FAA (had to go through 2 Inspectors to find one who knew what was up) that is correct. So no argument. "I was only following orders". I prefer the Sergeant Hans Schultz defense: "I know nothing! I see nothing! Nothing!".
Thank you, very informative, I appreciate the insight particularly inside the FAA & DAR system how things are handled. Thanks for humoring the dumb question, I have lots of those.....
 
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Jake can you send me their contact info and Name. I googled but three or four come up. Potentially wanting to use the one you mentioned if it will save me time and bureaucratic hassle
I'm so glad you got it resolved with a call to the FAA. It's hard to get a hold of them but when you do they're pretty helpful. I was going to send you a PM to tell you you didn't need a title company for that because I just finished writing this post on another forum regarding CARES and title companies and the FAA registration CD when I found your thread. If you didn't get though by phone I was going to tell you to try contacting them through CARES.

Not 100% related but useful info none the less:


"You got me thinking about this now because I just bought a plane recently and instinctively did what I always do, I requested a title search from one of the companies that has been doing this forever.

So after reading this thread I went to CARES and downloaded their info 2 ways. Individually for registration and airworthy documents, and also using the DOWNLOAD ALL REGISTRATION HISTORY DOCUMENTS.

Both downloads had the same information, so at least their system is working correctly there. Then I clicked on REQUEST A COMPLETE COPY and it opened to the typical CD request page. That's where I noticed that it has the page count of items so I went back to the downloaded files and the ones sent from the title search company and they're all the same.

So with this information I believe that :

1- paying a title company search is wasting money because they apparently just go to CARES and get what you can get online
2- paying the $10 for the CD is also a waste of money because you can get the same paperwork instantly on CARES.

So that clears up any doubt regarding using a title company vs ordering a CD vs CARES, for this type of paperwork search.

Now regarding "1. cares.faa.gov is not representative of everything on file..." part, it seems to be everything they have on file, but it doesn't help with the fact that some paperwork isn't at the FAA or in some logbooks because humans store, hide, or destroy some paperwork, so we still have to do those in depth pre-buy inspections.

My experience with the last 4 pre-buys I did since my search began about 6 months ago for my next new-to-me plane, is for another time, but please, to all who read this, do a really good pre-buy with a very knowledgeable mechanic with experience in the model you're buying. Don't settle for using any mechanic !
 
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