[gasman]

DEADLINE FOR 51% RULE COMMENTS IS MONDAY
Fight to preserve amateur-building movement continues
51% RuleThe privilege of the EAA community's amateur-building enthusiasts to build and fly their own aircraft - and for all of us to enjoy and marvel at the innovations that spring out of the homebuilt movement - is in jeopardy. We have a handful of days remaining in the public-comment period during which to urge the FAA not to encumber amateur builders with unwieldy, unwarranted, and unnecessary compliance requirements.

Anyone who intends to submit a comment on the FAA’s proposed changes to interpretation and enforcement of the “51% Rule” has until Monday, December 15, to do so as the FAA’s supplemental comment period draws to a close. (The FAA reopened the comment period in October after disclosing it had inadvertently removed reference materials for several days during the previous comment period.)

The FAA’s says its proposed changes would address activity occurring outside the current homebuilding regulations called out in FAA order 8130.2 - namely, excessive commercial assistance and “pro building” of amateur-built aircraft. However, as EAA’s comments submitted on September 30 contend, the proposed changes – including the cumbersome “20-20-11” requirement, would not only harm amateur-built aviation but they also would not adequately address the excessive commercial building.

EAA calls on the FAA to enforce the existing amateur-built aircraft rules that have served aviation and the homebuilt movement well for more than 50 years and not impose new, complicated requirements on homebuilders. We urge those of you yet to comment to act now before the December 15 deadline. For much more information on the issue, including how to submit a comment, visit www.EAA.org/govt/building.asp.

 

[ccarter]

My contribution to the 51% rule change

A copy of the letter I sent, my little contribution to the movement.

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Hello,

I would like to express my thoughts on the proposed changes to the 51% builder rule now being considered by the FAA.

I just recently finished construction of a Van's RV-7 kit plane. It was my first experimental project. I built almost completely alone over a period of 2 years. My intentions from the onset where to build a safe and reliable aircraft that had good performance and low cost of ownership. There is no better way to do that other than the experimental category in my opinion.

My building experience was indeed educational as well as recreational. In fact I would say the learning never ends as now I am successfully piloting my plane. I feel much more confident in my aircraft because I have combed over every inch of the airframe, torqued every bolt and bundled every wire. How many certified aircraft owners can make that claim? Most importantly, in those critical areas where design directly impacts an aircraft's safety and performance I entrusted that to the kit maker. Van's aircraft has a stellar reputation for the design performance of its kit planes which is one of the major reasons why I selected the RV-7.

As an example, critical design of the wing, directly impacting the airfoil, stall characteristics etc. is a portion of the kit itself and not the builder. The shape of each rib is critical to that wing and its safe ability to fly. Van's, in my case, has taken the responsibility for that wing and left other builder abrication tasks to the builder himself that are perhaps of less impact on the safety of flight. I can not imagine fabricating those ribs from a template and cutting them out by hand. In my view the Van's kit (as well as others I might imagine) has in fact made a "safer" aircraft by carefully identifying those areas in the overall kit construction and meeting the existing requirements of the 51% rule as they stand now. Of course there are other examples I could site but I believe the meaning is clear. The proposed change would place more "build from scratch" responsibility on the builder and increase the likelihood of subtle errors creeping into the kit aircraft itself. The statistical impact would be increased accident rates among experimental aircraft.

I see the problem as enforcement of the current rule. Changing a rule that is not being adequately enforced now only serves to place an even heavier burden on those who are in compliance.

"The innocent are usually the ones who suffer for the deeds of the guilty in a backwards society".

Bureaucracies tend to believe the solutions to problems are more bureaucracy. I disagree in this instance. To tighten a rule where the enforcement will not change, if that indeed is the situation, is ultimately choosing to do nothing about the problem.

I encourage the FAA to choose to enforce the exiting rule rather than tighten a rule where the enforcement appears inadequate.


Thank you,

 

[wvshooter]

51% rule

I am plans building a Mustang II which means I am not purchasing any of the kits offered by Mustang Aeronautics. I am however, going to be buying many individual parts from the company. Some for convenience and some for the reason Carter mentions above. (I will fab my own wing ribs however and have total confidence the results will be top grade) As others have stated elsewhere the problem with the 51% rule is the virtual total fabrication of a composite experimental by certain companies with little left for the builder to undertake. I think this is where the change will be comming. I would be surprised if FAA did anything to inhibit amateur building other than the composite thing mentioned above especially considering the need to encourage commerce during the recession.

And then again FAA could care less about economic impact. Whichever, making your own wing ribs can be fun.