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  #31  
Old 07-16-2008, 03:02 PM
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scard scard is offline
 
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Yeah, the changes are sad, but change is change sometimes (only after we, myself included, are done lobbying and complaining)... Did you submit a letter many months ago when the comments were solicited? I did.

I'm envisioning a new market and some new ingenuity needed for cheap simple tools to make it possible for the individual to easily stamp and form parts such as bulkheads and ribs. Obviously the kit manufacturer will have to design with the new rules in mind.

You can pick up a 20 ton press for dirt cheap at Harbor Freight, with a little bit of pneumatics it can work at the press of a button. Then we just need to produce a set of cheap dies that wear ok for two or three airframes. Ok, it isn't having it all delivered to you from Vans right off of their gazillion dollar cnc punch press, but it also isn't like having to hammer each rib from scratch.

Unfortunately it seems as if we're going to have to go back a little bit in order to move forward. There is always a way, and it will still be super fun! That is about all the optimism I can muster for you right now .
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Last edited by scard : 07-16-2008 at 03:06 PM.
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  #32  
Old 07-16-2008, 03:02 PM
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Brantel Brantel is offline
 
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Man this will change the face of the market for new QB designs. Van's SB's just ain't that far off with all the darn "Make From's". How do you justify 20%? By weight, total time spent building, size of the parts ??????

This has to be a love/hate scenerio for Van. This almost guarantee's him strong future kit sales on existing kits but on the other hand will truly tie his hands on future development.

This is a major step backwards and for nothing. How would you like to be Van who has spent a lifetime developing processes, tooling and a design around being able to provide a kit builder with a kit that can be assembled without a million dollars worth of mills, lathes, presses, brakes, shears, special jigs, tooling ect.
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Last edited by Brantel : 07-16-2008 at 03:09 PM.
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  #33  
Old 07-16-2008, 03:14 PM
rrd1_99 rrd1_99 is offline
 
Join Date: Jun 2008
Location: La Grande OR
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Default Ok, here come the flames!

Let me preface this with the fact that I am certainly not a fan of more regulation, more bureaucracy, more tax dollars wasted, and so forth. I also don't regularly trust the "wisdom" of our government agencies and policies. But I fail to see why we should be in such an uproar over this probable regulation change.

It is obvious, both from the FAA statement regarding the need for clarification and from the actual proposal that this is a crackdown (shakedown) on businesses and individuals that have been flatly DEFYING current regulations in order to sell more kits (make more money). Don't get me wrong, profit is not a dirty word. But I have to obey both federal and state regulations every day in my job whether or not I agree with them. I could certainly make more money if I chose to disregard those regulations and then use the argument that "It ain't hurtin' nobody!"

Paying someone to show you how to build an airplane does not seem to be a violation of either the old regulations or the new clarifications. Paying someone to build an airplane for you and hand you the paperwork to sign that says you built it IS a violation of both. Frankly, most of us are well aware of places/people who effectively offer to build a kit for you, hand you the paperwork to sign that says you built it, collect their $$, and call it "builder assistance". As Van has suggested all along, these folks have been pushing the limits, and by supporting them and/or turning our heads we have now attracted the attention of those who are in charge of regulating those limits.

Is it inherently safer for an experienced builder to assemble a kit than someone who can't fix a lawnmower. Yes, obviously. But it certainly doesn't meet the spirit of the regulations that have for decades allowed individuals to build and fly their own airplanes with the FAA's blessing. We haven't been up in arms over those regulations and their intent for the last 50 years, why are we now choking on the fact that they will be enforced?

As for this "20% of the fabrication" issue, I am sure a little ingenuity by kit manufacturers will result in no real undue hardship on anyone. Some clarification of whether this is by parts count or physical dimension or weight might help, but it doesn't sound unreasonable to me to expect a builder to actually build parts. Cutting two inches off a length of aluminum angle and drilling holes in it counts as fabrication.

I know this may not set well, and maybe I am looking at this wrong. I'm ready, hit me with it!

Roger
-9A QB
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  #34  
Old 07-16-2008, 03:30 PM
PJSeipel PJSeipel is offline
 
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Default Fabrication

Flame me if you will, but how many people actually took the time to sit down and read the draft FAA documents, and how many are commenting solely based on the EAA press release?

The fabrication piece actually looks a whole lot worse than it probably is, at least for the slow-builders. If you review the checklist and look at say, fabricate the wing ribs:
Sure, Van's gets credit for forming them, heat treating them, and drilling the pilot holes, but I fluted them, deburred them, match drilled them, drilled holes for wiring, primed them, etc. Since each point on the checklist can be divided into tenths, I give Van's .4 as the manufacturer and me .6 under fabrication for the wing ribs. I'm well on my way to 20% fabrication.
Sure it's subjective depending on who's evaluating the kit, but if I deburred, drilled, fluted, cut, modified that part in any way, shape, or form before assembling it to the aircraft, then I participated in the fabrication of that part and deserve some of the credit. And since Van's only pressed a button then they did less of the work than I did.

Where I see this having an effect is on the quick-built and builder assist industries. On a slow built, I did those fabrication tasks on each and every wing rib. On the quick-built, it's not so clear cut because the factory did it for many of them.

PJ Seipel
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  #35  
Old 07-16-2008, 03:42 PM
rv9builder rv9builder is offline
 
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Quote:
Originally Posted by PJSeipel View Post
Since each point on the checklist can be divided into tenths, I give Van's .4 as the manufacturer and me .6 under fabrication for the wing ribs. I'm well on my way to 20% fabrication.
PJ, can you tell us where it says this? Many of us (myself included) haven't had time to read through everything yet.

Thank you,
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  #36  
Old 07-16-2008, 03:49 PM
RV8N RV8N is offline
 
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Default It's called "ENFORCEMENT"

[quote=rrd1_99]It is obvious, both from the FAA statement regarding the need for clarification and from the actual proposal that this is a crackdown (shakedown) on businesses and individuals that have been flatly DEFYING current regulations in order to sell more kits (make more money).../QUOTE]

I agree that people are abusing the system and I agree that something needs to change. BUT... you can change the rules to anything you like, if you don't enforce the rules, it don't mean squat.

The feds are will have to enforce the rules for it to make a difference. So why don't the just enforce the current rules? That would sure be simpler than all this fuss with interpretting new rules that are suppose to accomplish the same thing as the old rules.

Karl

Now in Sandpoint, ID :-)
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  #37  
Old 07-16-2008, 04:00 PM
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rocketbob rocketbob is offline
 
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OK, so lets say the new regs get passed, and it clearly doesn't benefit us. The only people these rules benefit is the bureaucracy of the FAA. Great, so now they have some precedent to start making some more changes. What's next? Limits on speed, number of seats, horsepower? Don't think it can happen? Think again. Its been thrown around in FAA circles.

The thing that gets me is how the various letter groups have gotten themselves in bed with the FAA and try to make you think they've accomplished something. If these new rules go into effect, the EAA hasn't done a thing IMO. These changes should be fought.
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  #38  
Old 07-16-2008, 04:04 PM
rrd1_99 rrd1_99 is offline
 
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Default Karl is absolutely right

Couldn't agree with you more. Your comparison to gun control issues is right on the money. But I can see where the "old" regs left a significant gray area that was exploited by some, with full knowledge they were operating outside the intent and spirit of the law. It appears to me that the new proposals are little more than a clarification of the intent and purpose of the original regulations.

Roger
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  #39  
Old 07-16-2008, 04:14 PM
PJSeipel PJSeipel is offline
 
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Quote:
Originally Posted by rv9builder View Post
PJ, can you tell us where it says this? Many of us (myself included) haven't had time to read through everything yet.

Thank you,
Sure, check out: http://www.faa.gov/aircraft/draft_do...yChecklist.pdf

and then read the notes at the bottom. Here's part of it, sorry I don't know how to make it bigger:



They need to do a much better job of defining "fabrication" in my opinion.
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  #40  
Old 07-16-2008, 04:23 PM
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Ironflight Ironflight is offline
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Quote:
Originally Posted by RV8N View Post
I agree that people are abusing the system and I agree that something needs to change. BUT... you can change the rules to anything you like, if you don't enforce the rules, it don't mean squat.

The feds are will have to enforce the rules for it to make a difference. So why don't the just enforce the current rules? That would sure be simpler than all this fuss with interpretting new rules that are suppose to accomplish the same thing as the old rules.

Karl

In both principle and belief, I am 100% in agreement with you Karl - enforce the rules you have, don't make new ones! Unfortunately, in this particular case, that ship has sailed. As I postulated earlier, the FAA has already decided that the rules have changed. Complaining about that won't help. We can only look forward - how do e comment on the proposals to make things best for us in the future....and then how do we make sure that those rules are enforced?

I also like PJ's interpretation of fabrication - if we can get the authorities to see it that way, then there will be little change for the real homebuilders.

Paul
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