New FAA Policy on Amateur Building Released

[Low Pass]

Originally Posted by Dgamble

.....Who has the deeper pockets for lobbyists? Who has the ear of the local Senators? Who has access to influentional FAA bureaucrats?

Hint: It's not Van's.

Excellent point. Thx

[DanH]

<<Hint: It's not Van's>>

Well, not entirely true. Want to compete with Van? Under the new rules, forget it. Van has a nice list of grandfathered kits. Your new kit will require customers to fabricate 20% from scratch.

[Dgamble]

Originally Posted by DanH

<<Hint: It's not Van's>>

Well, not entirely true. Want to compete with Van? Under the new rules, forget it. Van has a nice list of grandfathered kits. Your new kit will require customers to fabricate 20% from scratch.

LOL, that's a good point! I imagine Lancair wouldn't be overly bereft either. Although.... I wonder if cutting and laying glass is "fabrication." See how this stuff gets tricky in a hurry? And you have to pay lawyers and bureaucrats to figure it all out, and more lawyers to appeal their decisions.

[tomwebster]

Why can't I just buy my scratch fabricated parts
from a small cottage industry?
Tom

[rocketbob]

Bad, bad, bad.

No other way to put it.

Certainly this will have a stifling effect on any new kits brought to the market, since they won't be able to compete with existing kits...

The whole premise on why they wanted to revise the amateur-built rules (to prevent hired guns from building planes) is stupid... it caused absolutely no one any harm. I say let hired guns build, the more the better.

I guess everyone in the future will get stuck building brand-V airplanes, unless you enjoy scratch-building...

[DanH]

<<The whole premise on why they wanted to revise the amateur-built rules (to prevent hired guns from building planes) is stupid... it caused absolutely no one any harm. I say let hired guns build, the more the better.>>

It really didn't cause anyone any harm, and in truth the FAA hasn't pursued them. Think about it. If the FAA wanted to clamp down on pro-builders, you would have seen grounded airplanes all over the place. The old "don't crash in my schoolyard" thing has been SOP a long time....don't embarrass us and we'll leave you alone.

The embarrassment started with the rise of factory builder assist centers. Two weeks to taxi? Yeah, right. If a builder spends two weeks, 7 days a week, 10 hours a day, his own little hands worked 140 hours. The rest was rules-twisting. The straw that broke the camel's back was a factory assist center for a jet kit.

Standard smart bureaucratic politics; (1) divide and conquer, and (2) put in a juicy bone for the biggest players so they will get on board. Van's doesn't have a builder-assist center, and all his kits are grandfathered or LSA. Meanwhile, the competition gets a huge profit center kicked out from under them.

[Peterk]

Gary,

Concerning the modification of an ELSA that has been certified. My understanding from the EAA is that similar to an AMBLT you can modify an ELSA once certified simply because there is nothing that says you cannot. In other words, with your airworthiness cert comes a certificate of operating limitations for your aircraft. Within that you may be instructed to test fly any modifications that you make and log such. Of course you would not be allowed to leave the parameters of the LSA guidelines. An example may be to place a 496 in place of the 296...after certification.

Again...I don't see this in writing anywhere but would certainly appreciate your thoughts and anyone elses'.

THx

Pete

[JimLogajan]

The EAA article includes a link to a text-only web page that contains only part of the proposed changes. I did a bit of searching and found the following FAA web page that contains links to three PDF documents containing the entirety of the proposed changes and (more importantly) an e-mail address where comments may be directed:

http://www.faa.gov/aircraft/draft_do...?Doc_Type=Pubs

Hopefully this will help.

[Noah]

Those of you who have followed Van's publications on this issue will recall that he argued that the fabrication of a component is composed of many steps in going from raw material to an airworthy part.

His contention was that the CNC stamping, punching of matched-holes for assembly, and other "factory labor" represent a very small part of the overall labor required to build a component. He also argued that it is not economical for a homebuilder to own the equipment required to consistently and economically produce these components, and that the homebuilder's labor, which includes drilling, dimpling, deburring, prep, assembly, and painting require MUCH more labor than the raw production (stamping) of the part from raw stock. He also argued that for the FACTORY to perform all of this extra labor would make parts prohibitively expensive (Cessna). He argued that the 51% rule should apply to the LABOR in producing a part, a little bit of labor from the factory, but MOST from the homebuilder. He proposed a chart showing labor percentages from the homebuilder and the factory, all tallied up to see whether the homebuilder met the 51% or not.

His argument made a lot of sense to me.

The thing most apparent to me in reading about the new requirement for 20% of parts to be fabricated FROM RAW MATERIAL or STOCK means that Van's argument somehow fell on deaf ears.

To me, this is the biggest failing of the FAA proposal, and I think we need to mobilize to provide comment to this effect. Think about it, if Vans takes 39 seconds to produce a wing rib, and you take 2 hours to make it airworthy, haven't you done more than 51%? This is the argument that needs to be made, IMHO.

Yes I realize that the existing RV kits will be grandfathered. But the development of future kits could be a dark one if this interpretation, and if the 20% "fabricated from raw stock" is allowed to stand.

[RV8N]

Originally Posted by Low Pass

The hired guns are working with the existing regulations. If they're not, bust them. Don't "clarify" the regulations just because the system is actually thriving and it may be threatening the authority of a federal agency...

I have to agree with Bryan. The current regulations haven't been enforced. We don't need new rules, we need to enforce the rules we already have.

This is very analogous to gun control. Many gun laws are ignored and not enforced but the gun control lobby wants lots of new laws to control those horrible guns. How about enforcing the existing laws? Ever think of that?

Karl

Now in Sandpoint, ID