E-mail address

Thanks for posting this, Doug. Watch out if you simply click on the link in the PDF to send E-mail to Miguel Vasconcelos - it has a typo. The correct address is as printed: [email protected]
 
Trying to help

I want to send a note to the FAA and alcon helping "our cause" but I am new to the rules and not sure what to write.

"Amature / experimental" airplane construction seems to be treated much differently than building a kit car or chopper motorcycle. I see the need for inspections and test period but, the 51% rule seems arbitrary and capricious on the part of the FAA.

I Plan to own and fly a Vans RV-4. I would love to buy it from a bussiness that would custom build one for me. The same way Orange county choppers builds motorcycles on TV. I know its illeagle to do that VS a buyer beware purchase of a Used bird that I will have to pay A&P mechanics to modify.

What is the true spirit and intent of the 51% rule. Seems to be to protect the establsihed aircraft manufacturers. Is it possible to have it resended?

Perhaps one of the old hands can draft then post a note that I can Email and snail mail off to those folks who will decide this. Love how this post has interested person I can Email when i have the best words penned.

Thanks, Dan
 
I think it's well written and fair.

It protects and rewards those who have earnestly learned new skills and knowlege, and rewards them with the right fly their aircraft within a complex highly regulated airspace system.

It similarly protects above builders from losing their priveldges due to the actions of well funded persons trying to get a new high performance aircraft without paying the price of a certified aircraft.

As usual, it only takes few to ruin a good thing for everyone and this regulation seems to offer excellelant protection for the experimental aircraft community.

Writing the FAA to petition a more lenient stance will enhance profits for Vans and the like and increase the chance ALL OF US will lose the privledge of experimental flight.

I, for one, will write the FAA and support their position as it is in my best interest.

Consider carefully what you wish for.

Flame away. I built my own airplane.

Bob
 
Too deep for me

It is obvious I simply do not know enough about the rules our what is at stake to submit my comments to the FAA.

I'm a 50 year old man that has dreamed of flying his whole life. Working the war in Kosovo got me enough cash to fianlly buy a cessna 152. The struggle to earn whatever it takes to fly is not lost on me. The temendous dedication it takes to build an airplane is amazing and way beyond me for the forseeable future.

The dream of owning an super duper RV 4 and having the cash to fuel it keeps me going through these 98 hour work weeks.

I am so grateful for the guidance of this group to insure I do the right things the right way. Thanks for enduirng my inappropriate thoughts. remember my first post about external drop tanks for extra fuel on RV-51s :eek:

Thank you, Dan
 
Rocketboy said:
I think it's well written and fair.

It protects and rewards those who have earnestly learned new skills and knowlege, and rewards them with the right fly their aircraft within a complex highly regulated airspace system.

It similarly protects above builders from losing their priveldges due to the actions of well funded persons trying to get a new high performance aircraft without paying the price of a certified aircraft.

As usual, it only takes few to ruin a good thing for everyone and this regulation seems to offer excellelant protection for the experimental aircraft community.

Writing the FAA to petition a more lenient stance will enhance profits for Vans and the like and increase the chance ALL OF US will lose the privledge of experimental flight.

I, for one, will write the FAA and support their position as it is in my best interest.

Consider carefully what you wish for.

Flame away. I built my own airplane.

Bob
Click to expand...

Well written and fair? Where do you find the "well written" part when everyone from a wannabe builder (me) to the top kit manufacturer is asking for an interpretation of "fabrication"? I also do not believe that the great majority of us are asking for lenience... nor supporting the actions of the "we build it for you" shops. We are asking for a reasonable sculpting of the rules to support the actions and methods used for many years by the majority of builders out there. I believe that allowing the kit manufacturer to fabricate the parts we assemble is not diminishing the education or recreation gained, and undoubtedly provides for greater parts quality control and consistency - resulting in a safer end product.

Depending on the interpretation of this vague "fabrication" rule... there is a great possibility that the end result will be less ability for many of us to build and fly our dreams.

I am not sure why you are worried about Van's making a profit. I had the opportunity to visit the factory last week. I have to tell you I didn't see a lot of expensive cars in the parking lot. What I found was a bunch of hard working individuals from Tom Green on down... happily producing a product that they have a passion and love for. Grass roots America.

And while I am happy for you that you built and have your own plane... your post sure echos of what we call the IGM attitude. I got mine...

While you challenge others to flame you... my intention is not that... but hopefully to provide some balance to your post to many of the folks who have not had the time to research this as much as myself and others have. While I would encourage them to research and form their own opinions... I do exercise the liberty to express mine.

The FAA needs to provide a better explanation of "Fabrication"... and further it is my strongest recommendation that "fabrication" not be separately tallied from assembly. I am not advocating loosening of the standards to allow professional assembly shops to be tallied under the 51% requirement. I would encourage the FAA to instead concentrate on better documentation by the inspecting official and taking a stronger stance against the few bad apples.

Respectfully disagreeing and responding.

DJ
 
The Webster definition of "fabricate" is CONSTRUCT-MANUFACTURE-INVENT-CREATE.

If the term were applied to the total project and not just individual parts, I do not see a problem. The FAA needs to define just what it is they mean by fabricate and also not get too hung up with labor verses fabrication. If they don't nail it down some inspectors will interpret "fabricate" to mean building your own foundry to make the aluminum needed for various parts and a milling machine to create fasteners.

That will be the gist of my comment concerning the proposal.
 
Phyrcooler said:
And while I am happy for you that you built and have your own plane... your post sure echos of what we call the IGM attitude. I got mine...

DJ
Click to expand...

WHAT!! I built mine with my own hands with no help from anyone. After spending thousands of hours building it, I don't want it grounded because a few thousand lame wannabes violate the law to have their airplanes built by hired guns. HOMEBUILT AIRPLANES ARE FOR HOMEBULIDERS.

So WHAT EXACTLY is wrong with that?

And where do you get off with this IGM foolishness?

Bob
 
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I did not rear anything about somebody taking over a project, many have both unfinished project in varying stages people sold there projects for many reasons health divorce financial etc, how will the FAA look at that since some are beyond QB stage or beyond the 51%

ken in maine
 
Didn't take long at all

for this thread to begin the deterioration into a flame war.

Not having studied either the current regs, nor the proposed new ones, nor the EAA or Vans responses, I take no side yet. But here's a thought I've not seen expressed.

As I understand the current regs have their roots from the 1950s, when amateur built aircraft were legally recognized and started in the USA. At that time there were no kits! You got some plans and had to fabricate everything from raw materials.

Things changed and now we have the spectrum from plans-built to Quick Build kits with one-week learn-to-build classes that you leave with a finished empennage. Then add in pre-fabbed wire harnesses, fuel lines, perfect-molded fiberglass, built-to-order panels, engines set up and even broken in for you. Yes, there's a big secondary market supporting "amateur" built with all manner of manufactured short cuts.

The FAA has also noticed this. Let's forget the obvious pro-builders for a moment. What about the amateur builders who do more check writing than fabricating and building? The proposed regs look to guide our hobby back to the original intent first. Then deal with the pro builders.

Sure, the FAA should define "fabrication", yada yada. But they don't deserve the libel and vituperation expressed in this and other forums. Then what about handling the pro-builders? I believe that's a legitimate business but it should be far more regulated than truly amateur build aircraft.
 
link to the rules needed please.

I'm an attorney. Can someone please send me a link to the proposed rules - saves time searching. I would like to take a look at the entire proposed rules just to see if there are any 'holes' we can widen.
 
Plane krazy said:
I did not rear anything about somebody taking over a project, many have both unfinished project in varying stages people sold there projects for many reasons health divorce financial etc, how will the FAA look at that since some are beyond QB stage or beyond the 51%

ken in maine
Click to expand...
Ken, There is nothing in the new proposal that changes the fact that the aircraft is to be "amateur-built". Just as before, it does not mean one person. Any number of persons can be amateur builders on one project. A project can be passed down several times so long as all of the builders are amateur builders.
 
Buggsy2 said:
What about the amateur builders who do more check writing than fabricating and building?
Click to expand...

It sounds like you're under estimating the amount of work required to take a quick build kit and make it fly. Sure the wings are mostly done and a good portion of the fuselage. If the builder then buys a completed panel and engine/prop there is still quite a bit of work remaining to make that plane fly, and that builder is living by both the letter and intent of the current 51% rules.

Not trying to flame you or sound testy, that's not the purpose of this post. However I must say your statement quoted above sounds a bit flipant.

In my opinion the new proposed rules do nothing to prevent the violation of the current rules. By adding in new vague requirements it merely makes it more difficult for those who are living by the letter and intent of the law. Those who have found a way to circument the current rules will find ways to get around the new ones.

Just my 2 cents.
 
I agree that it's the "fabrication" language that is the scariest. I've said before, the components that come from Van's are produced on CNC machines. An operator loads a sheet of aluminum into the machine, and presses a button. He/she just "fabricated" that part "from raw stock". If I pressed that same button, I would have "fabricated the component from raw stock". How does that solve the problem of commercial builders producing amateur experimental planes? How would it add to my "education or recreation"? If I wanted to skirt the law, why couldn't I just hire someone else to "fabricate from raw stock" my portion of the kit? According to the proposed changes, if I did 100% of the assembly (not a trivial task on a slow-build kit), and 19% of the fabrication, I would not be elligible for an airworthiness certificate. That's nonsense. When my plane is finished, I will have set every rivet, torqued every bolt, and soldered every wire in the airframe and engine. But I may not have "fabricated" 20% of the parts. Now if the 20% fabrication means 20% of everything necessary to take a part from raw stock to an installable part, MAYBE I would agree. Even after Van's sells me a part, I still have to drill, deburr, flute, and in my case, prime that part. If that counts as part of the 20% I might agree. But we still don't know what "fabricate" means, and we still don't know what "20%" means.

Like some gun control laws, when some people break the law, the government mentality is to pass more laws. Those new laws may do nothing to hinder the law breakers. They only make it harder for the law abiders to stay within the law. The existing rules would work just fine if the FAA would ENFORCE them.

My appologies if I sound like a Ron Paul ad.

Clear skies,
 
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jtrusso said:
It sounds like you're under estimating the amount of work required to take a quick build kit and make it fly.
Click to expand...
Yes, I was exaggerating to make the point that maybe the FAA thinks even well intentioned amateurs are getting near the 49/51 border and is trying to head off crossing it. It's still a puzzle to me: starting with a QB which I know is OK, but then going to an emp-building workshop, then having panels, etc build for me; at what time do I cross the line? Seems to me the FAA is trying to clear that up. Then they can deal with the pro-building issue.
In my opinion the new proposed rules do nothing to prevent the violation of the current rules.
Click to expand...
OK. But the FAA had a reason for what they did. What was it? Well, maybe I'll read the docs this weekend and be better informed.
 
tomcostanza said:
I agree that it's the "fabrication" language that is the scariest. I've said before, the components that come from Van's are produced on CNC machines. An operator loads a sheet of aluminum into the machine, and presses a button. He/she just "fabricated" that part "from raw stock". If I pressed that same button, I would have "fabricated the component from raw stock".
Click to expand...
Hmm. We need a bunch of the Oregon RV builders who will volunteer to go down to Vans, and out of the goodness of their heart, and just for their own education, push that button on the CNC machine. That way those parts would be fabricated by amateurs. :)
 
Kevin Horton said:
Hmm. We need a bunch of the Oregon RV builders who will volunteer to go down to Vans, and out of the goodness of their heart, and just for their own education, push that button on the CNC machine. That way those parts would be fabricated by amateurs. :)
Click to expand...

That is a great idea! :D
 
Call me naieve but in my opinion we do not want a strict definition of the term fabricate.

When all is said and done the system will still require our existing Army of DARs to inspect the plane and paperwork and make a determination as they always have. Seems to me the more nebulous the word fabrication the more leeway the DAR has. It is not in the interest of DARs in general to start en masse refusing to certify aircraft that meet the spirit and intent of the regulations as opposed to strict detailed criteria.

The FSDOs currently do not have the manpower, interest, budget, desire, nor political pressure to get deeply involved in regulating and directly inspecting homebuilts. It is in our best interest to keep it that way.

At the end of the day I predict nothing will have changed other than the government form number on the paperwork we will fill out.
 
Looks easy

Buggsy2 said:
... It's still a puzzle to me: starting with a QB which I know is OK, but then going to an emp-building workshop, then having panels, etc build for me; at what time do I cross the line? ...
Click to expand...
QB+builder workshop+pre-built panel - Just toss the parts into the garage and out comes an aircraft! Looks easy!

I sure like Kevin's idea! :)
 
I think some guys at the FAA have ARM's that are due to reset and they are just looking to "fabricate" some OT.:rolleyes:
 
Most of the parts in the Van's kits are partially completed and still need a certain amount of fabrication such as finished hole size, dimpling, cleaning and bending. The FAA needs to recognize this and include it in it's interpretation of fabrication along with the assembly of sub parts to complete the sub assemblies.

I believe the FAA needs to address the infractions of the rules violated by hired guns building planes for profit. This is not in the spirit of amature building and does not help further our "HOBBY". Blowing off the rules in the name of building safer airplanes just doesn't cut it with me. If you don't think you can build a safe plane, either get the proper training or find another hobby.

JMHO

Roberta
 
N395V said:
Call me naieve but in my opinion we do not want a strict definition of the term fabricate.

When all is said and done the system will still require our existing Army of DARs to inspect the plane and paperwork and make a determination as they always have. Seems to me the more nebulous the word fabrication the more leeway the DAR has. It is not in the interest of DARs in general to start en masse refusing to certify aircraft that meet the spirit and intent of the regulations as opposed to strict detailed criteria.

The FSDOs currently do not have the manpower, interest, budget, desire, nor political pressure to get deeply involved in regulating and directly inspecting homebuilts. It is in our best interest to keep it that way.

At the end of the day I predict nothing will have changed other than the government form number on the paperwork we will fill out.
Click to expand...


I agree. The FAA had no interest in doing my AW inspection and had no interest in interviewing me for my Repairman certificate or looking at my builder's log. They did make me change some of my date formats on the paperwork.
 
They have it right...

I personally support what the FAA is doing as I believe Experimental "Amateur Built" is being abused by far too many people to ignore and it is these people that are ruining it for everyone.

Some people here compare to building a car or a chopper. The fact is they are totally dissimilar. You can buy a kit from Vans to build a well proven, aerobatic, IFR aircraft for less than half the price of a certified plane and you can maintain it yourself.

Perhaps success of experimental designs is the biggest issue but we are at the point where there is significant motivation to do this appart from "recreation".
In contrast very few people build cars or choppers. However, a very large percentage of people in the market for new aircraft are building or paying someone else to build for them. I fully support the notion that builders be transparent with who built their aircraft and how much they paid for, as well as how much they did themselves.

The fact is that existing legislation allows for building as a hobby – not flying as a hobby. There is no sense to abusing the FAA for upholding the rules and making it more difficult for people to abuse the system.

One so called “kit” manufacturer has a “two week to taxi” program… In my view that is not homebuilding and the fact that they promote such a thing shows disregard for the spirit of the legislation at the very least. Even using the FAA form and taking pictures as said builder tightens bolts on ailerons “rigging them” would not convince many people the aircraft has been built for recreation. I would be convinced the builder had cash, little time and wanted to fly a nice new shiny aircraft and avoid paying a licensed engineer to maintain it.

Please if you are a person that does not have the time, skills or desire to build an aircraft, but still want to fly one, go and find a friendly builder who has one for sale. Hopefully he has flown for a few years and enjoyed his plane/worked out the bugs in it for you. Enjoy flying it, take it to a LAME to get it fixed but don’t pay someone else to build for you or buy from someone who makes a habit of building planes for others. The law simply does not allow it.

Richard

RV-7A finishing.
 
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