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  #91  
Old 07-22-2008, 11:41 AM
PropellerHead's Avatar
PropellerHead PropellerHead is offline
 
Join Date: May 2008
Location: Pisctaway, NJ - USA
Posts: 105
Default Regulation Constipation

Quote:
Originally Posted by Jconard View Post
The ability of a federal agency to fabricate new law from whole cloth is limited, but their ability to clarify and refine the enforcement of existing law is granted wide deference, hence clarifications and enforcement decisions rather that entirely new law.
But did they fabricate 20% or more of that law?
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Tooling Up for an RV-10 build.
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Last edited by PropellerHead : 07-22-2008 at 12:07 PM.
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  #92  
Old 07-22-2008, 12:48 PM
JHines JHines is offline
 
Join Date: Jul 2007
Location: Rock Hill, SC
Posts: 390
Default

Quote:
Originally Posted by frazitl View Post
What are we going to do about it? The proposed new rules I mean. Maybe it's time to start a new thread so those that want to can continue this discussion on how big bad government is the root of all evil (I agree by the way).

What I'd like to discuss is how are we going to respond to the proposed new rule? Haven't seen much discussion of this yet, and to me, this is where we need to put our energies...

Besides building of course,
In my experience the best thing to do is to get out all our howling and teeth-gnashing and appeals to the constitution out on this forum or over several beers.

Then, every person who's affected by this should respond through the designated comment channel back to AIR-200, with a well-reasoned, calm statement.

At this point they are not going to back down on having new rules. BUT, government agencies CAN be responsive to arguments that a proposed order will be burdensome or difficult to administer, and will listen to reasonable alternatives.

For example, I would like to point out how difficult it is going to be to submit a "kit w/modifications" for approval under the 51% rule BEFORE construction, when the builder isn't even sure what the changes might be.
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Charlotte, NC
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  #93  
Old 07-22-2008, 05:22 PM
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frazitl frazitl is offline
 
Join Date: Jan 2005
Location: Las Vegas, NV
Posts: 488
Talking Now we're talking!

For the FAA to reasonably deal with pre-approval for modifications to a 51% approved kit, they will need to define a "threshold" below which a builder won't loose their pre-approved 51% status. Otherwise the whole process is brought to it's (our) knees. Having to submit to FAA for approval plans for a change is bad enough. Having all such plans in place BEFORE the fact is impossible in an "experimental / amateur built" model.

My proposal would be to allow without prior approval any change that does not decrease the builders fabrication or assembly contribution to the build. So far, ALL of my changes to my 7A QB kit have added a LOT of both...

As written, they are creating a certified like web of terror (OK, maybe I digress a little... ).
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  #94  
Old 07-22-2008, 06:46 PM
rfinch rfinch is offline
 
Join Date: Nov 2007
Location: Davis, CA
Posts: 157
Default Phil Gramm was right...

...you guys are the biggest bunch of whiners I've seen. Thought VAF was moderated but I've seen no moderation on this thread.

Here's some clues:
  1. The FAA is not evil incarnate
  2. Government is not invariably incompetent, nor business a model of efficiency
  3. The proposed rule change--which I guess hardly anybody has read--serves to clear up and reinforce the current Amateur building rule.

Moderate this! But at the same time, could you moderate all the tirades here? Or at least, as someone else proposed, start a new thread that will discuss the topic in a reasoned manner. For, or against, or more nuanced, but always reasonable.
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Last edited by Ironflight : 07-22-2008 at 07:11 PM. Reason: Removed family-unfriendly reference/language
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  #95  
Old 07-22-2008, 07:44 PM
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rocketbob rocketbob is offline
 
Join Date: Jun 2006
Location: 8I3
Posts: 3,643
Default

Quote:
Originally Posted by rfinch View Post
...you guys are the biggest bunch of whiners I've seen. Thought VAF was moderated but I've seen no moderation on this thread.

Here's some clues:
  1. The FAA is not evil incarnate
  2. Government is not invariably incompetent, nor business a model of efficiency
  3. The proposed rule change--which I guess hardly anybody has read--serves to clear up and reinforce the current Amateur building rule.

Moderate this! But at the same time, could you moderate all the tirades here? Or at least, as someone else proposed, start a new thread that will discuss the topic in a reasoned manner. For, or against, or more nuanced, but always reasonable.
I got a chuckle out of this one...
1. Do you know who Bob Hoover is?
2. Have you ever heard the name Katrina?
3. "Hi. We're from the government, and we're here to help."

On a more serious note, some discussions I've had with the EAA folks indicate they are going to push back hard on the 20% rule because the rule is completely unworkable. I suppose the EAA is whiny too then...
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Last edited by rocketbob : 07-22-2008 at 10:50 PM.
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  #96  
Old 07-22-2008, 09:49 PM
JimLogajan JimLogajan is offline
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Join Date: Jul 2006
Location: Dexter, OR
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Default

Quote:
Originally Posted by rfinch View Post
The proposed rule change--which I guess hardly anybody has read--serves to clear up and reinforce the current Amateur building rule.
Actually I've studied the PDFs that contain the proposed changes - I downloaded them 6 days ago. I'd be interested to know if you have located answers to the following:
  • Fabrication is not clearly defined because raw material is not clearly defined. E.g. Would rivets be considered raw material or assembled items?
  • The method I should use to determine the percentage that is fabricated is not defined. E.g. Under "Fabricate wing covering or skin" - assuming that flat aluminum sheets are considered "raw" material, how would I allocate the percentage of that fabrication task to measuring and marking, to drilling, to bending, to cutting to shape, to countersinking, to de-burring, and to priming? For any given chosen metric, say hours worked, energy expended, mass of items, count of items, task count, volume of items, or length(s) of items, wouldn't I have to be informed by the kit manufacturer how many of said metric it used to perform its portion of the fabrication in order for me to provide an honest estimate of the percent that I fabricated?
  • The proposed checklist is airplane-centric; do you see any way it can provide guidance to homebuilders constructing gliders, rotorcraft, airships, or balloons, for example? What's a DAR to do?
  • Did you see in the checklist that it contains scores of tasks of completely different degrees of difficulty all of which are assigned equal weight? E.g. Assembling propeller to the engine counts the same as fabricating an engine cowling? (This can be a good thing or a bad thing, depending on why the builder is building. In some cases it is good that an assembly task weights the same as fabrication - in other cases it is grossly unfair.)
  • Did you notice that aspects that previously were never included are now counted against you if you choose to farm them out? E.g. Various control panel electrical system tasks?
  • Do you see anywhere in the checklist instructions on what I should do if some items are not applicable (e.g. The plane I am building has no composite cores in the wings(!), or no flaps, or no aileron trim, or I do not need to fabricate any tools or fixtures, or....)? Notice that "Note 1" of the checklist says the totals must add up to 187! Do you think that if anyone in the FAA had actually done a proper critical/sanity review of the checklist procedure prior to publishing it that it would have been published with such a note?

The proposed changes are not, in my humble opinion, clarifications but are rather a new set of rules. And poorly thought through - in my humble opinion of course.
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  #97  
Old 07-23-2008, 03:08 AM
PJSeipel PJSeipel is offline
 
Join Date: Jan 2005
Location: Albany, GA for the moment
Posts: 294
Default

Quote:
Originally Posted by JimLogajan View Post
  • Fabrication is not clearly defined because raw material is not clearly defined. E.g. Would rivets be considered raw material or assembled items?
  • The method I should use to determine the percentage that is fabricated is not defined. E.g. Under "Fabricate wing covering or skin" - assuming that flat aluminum sheets are considered "raw" material, how would I allocate the percentage of that fabrication task to measuring and marking, to drilling, to bending, to cutting to shape, to countersinking, to de-burring, and to priming? For any given chosen metric, say hours worked, energy expended, mass of items, count of items, task count, volume of items, or length(s) of items, wouldn't I have to be informed by the kit manufacturer how many of said metric it used to perform its portion of the fabrication in order for me to provide an honest estimate of the percent that I fabricated?
  • The proposed checklist is airplane-centric; do you see any way it can provide guidance to homebuilders constructing gliders, rotorcraft, airships, or balloons, for example? What's a DAR to do?
  • Did you see in the checklist that it contains scores of tasks of completely different degrees of difficulty all of which are assigned equal weight? E.g. Assembling propeller to the engine counts the same as fabricating an engine cowling? (This can be a good thing or a bad thing, depending on why the builder is building. In some cases it is good that an assembly task weights the same as fabrication - in other cases it is grossly unfair.)
  • Did you notice that aspects that previously were never included are now counted against you if you choose to farm them out? E.g. Various control panel electrical system tasks?
  • Do you see anywhere in the checklist instructions on what I should do if some items are not applicable (e.g. The plane I am building has no composite cores in the wings(!), or no flaps, or no aileron trim, or I do not need to fabricate any tools or fixtures, or....)? Notice that "Note 1" of the checklist says the totals must add up to 187! Do you think that if anyone in the FAA had actually done a proper critical/sanity review of the checklist procedure prior to publishing it that it would have been published with such a note?
If it's any help, I sent in a list of comments very similar to your list, and including a few others, after I had read all of the documents. I recommend that you and others do the same. We've only got 30 days. If we don't point out the mistakes now, we've got no right to complain about it later.

PJ Seipel
RV-10 #40032
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  #98  
Old 07-23-2008, 07:09 AM
tomcostanza tomcostanza is offline
 
Join Date: Jul 2005
Posts: 292
Default What does The Man have to say?

Van's website seems quiet on this announcement. Does anyone know if the company has anything to say publicly?
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  #99  
Old 07-23-2008, 12:06 PM
JimLogajan JimLogajan is offline
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Join Date: Jul 2006
Location: Dexter, OR
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Default

Quote:
Originally Posted by PJSeipel View Post
If it's any help, I sent in a list of comments very similar to your list, and including a few others, after I had read all of the documents. I recommend that you and others do the same. We've only got 30 days. If we don't point out the mistakes now, we've got no right to complain about it later.

PJ Seipel
RV-10 #40032
I do intend to submit comments similar to what I posted - what I wrote needs to be cleaned up in several ways before I submit it to the FAA. The only thing I'd add is that one should always be diplomatic (I'd never submit a comment to the FAA telling them I thought they hadn't thought their proposal through, for example! And the "tone" I'd try to impart would be non-confrontational.)
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  #100  
Old 07-23-2008, 02:33 PM
Steve Brown Steve Brown is offline
 
Join Date: Oct 2007
Location: Alviso, CA
Posts: 405
Default Some of us don't like the whole big picture

Quote:
Originally Posted by rfinch View Post
.......
  1. The FAA is not evil incarnate.........................
We're starting from the premise that the whole system is screwed up and needs to be fixed, otherwise GA IS going to die.

As far as your #1, I got my dad a T-short that read:

FAA mission statement
"We're not happy until you're not happy"
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