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Thread: Call to Action - Changes to amateur-built certification

  1. #1
    jnorris's Avatar
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    Call to Action - Changes to amateur-built certification

    The homebuilder community needs your help! The FAA has proposed changes to the Experimental Amateur Built rules that EAA believes will negatively impact the homebuilt movement.

    We need you to do two things:

    1. Comment on the FAA's proposed changes;
    2. Spread the word - tell other builders and get them to comment.

    The FAA's stated goal is to better control commercial activities that reduce the amateur builder's actual involvement in the project to less than the "major portion" (51%) required by the regulation (Ref: FAR 21.191(g) ).

    EAA is concerned that the proposed changes place significant burdens on those who are building within the letter and spirit of the regulations while doing little to address excessive commercial assistance and "pro building".

    Comments must be submitted by September 30, 2008. The main points that need to be communicated to the FAA are these:

    • The amateur-built regulations as they stand right now are sufficient to stop excessive commercial assistance and "pro building". FAA should enforce the current regulation rather than implementing new policies that would have a negative impact on the entire homebuilder community.

    • The regulations found in 21.191(g) only require the builder to fabricate and assemble the major portion of the amateur-built aircraft. No specific percentage of fabrication or assembly is specified. To require a specific percentage (e.g., at least 20% fabrication and 20% assembly) imposes a burden on the homebuilder community that is beyond the scope of the regulation, and is in fact regulation by policy.

    EAA has prepared detailed comments and a sample letter that may help you formulate your letter to the FAA. For more info, see the following web page:

    http://www.eaa.org/news/2008/2008-09-04_proposal.asp

    Your comments may be submitted via email: miguel.vasconcelos@faa.gov

    Please email a copy of your submission to govt@eaa.org.

    Or you can mail your comments to the following address:

    Miguel L. Vasconcelos
    Production and Airworthiness Division
    AIR-200, Room 815
    800 Independence Ave., SW
    Washington, D.C. 20591

    If you submit via US Mail, please send a copy to me at:

    Joe Norris
    EAA Aviation Center
    P.O. Box 3086
    Oshkosh, WI 54903-3086

    Remember, your comments must be sent to the FAA by September 30th, so please take time right now to provide your input on this important issue.
    Joe


  2. #2
    behindpropellers's Avatar
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    Joe-

    Would you mind highlighting the proposed changes that will affect us?

    Thanks

    Tim

  3. #3

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    I'll do it.

    But I got to wonder who is driving this, part of me wants to say its the Certified aircraft companies.

  4. #4
    Marty57's Avatar
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    I think the 51% rule works just fine. The problem arises from a currently unrestricted category of aircraft; that being the "Owner Assembled / Factory Produced" aircraft. No, it doesn't exist BUT the FAA has in effect gone around it's own certification standards and let this one exist off the books. This is the "Two Week to Taxi" program. I would be in favor of leaving the "Amateur Built" category alone and creating (like the LSA) a new category that fills this obvious market need; someone who wants the experience of building his own aircraft but doesn't have the time (or desire) to fabricate parts him or her self. Maybe one of the restrictions could be not issuing a repair certificate to the "assembler" but requiring the annual be done by an A&P or IA. The "assembler" could maybe be allowed to do more maintenance than on a certified AC but less than on an "Amateur Built" AC. LSA aircraft and pilots with only a Sport Pilot ticket are restricted from owner maintenance afforded a pilot with a PPL as an example. Looks like the FAA is trying to create a problem to cover up it's own mistakes. Just my opinion here, maybe this is what we need to communicate to the FAA (without the self created problem part )

    Marty57 (happily scratch building because I like to build and still have that choice)

  5. #5
    AntiCub's Avatar
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    While I'm not certain what impact the proposed change is going to have, I certainly agree with the FAA's intent here. The amateur built, 51% rule clearly states it's for "Education and Recreation". I've always understood this to mean you're building a plane because you want to learn how to build a plane, and/or enjoy building planes. Not because you want to get a plane cheaper than buying a factory new plane. And I think some of the factory assist and quickbuild kits out there are clearly flying in the face of that intent.

    When the 51% rule was originally written there was no such thing as a kit plane. At best you might be able to buy a materials kit. I'm not saying this is a superior method. In fact today's kit built planes are probably a lot better quality than many of the old plans built ones. But I think the FAA is correct that it's time to re-examine the rule.

    And I definitely agree with Marty57, that if you built a plane in 2 weeks with a factory rep holding your hand each step of the way, you probably don't deserve the Repairmans Certificate. Face it, would you want someone who just went though a 2 week crash-course to be in charge inspecting and maintaining your plane? Or one you were riding in? That sort of spits in the face of all good A&P's and AI's.

    Compare that to the old time plans builders who welded every joint themselves, fabricated every fuel and brake line, cut, fitted and jigged every fitting and bracket, installed every control cable etc. That guy/gal really knows that plane intimately. To put them in the same category as the "2 weeks to taxi" guy is down right insulting.

    OK, I'll get off my soapbox now.

    Phil

  6. #6

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    Joe,
    I have sent a response to the FAA on the information I can find on the EAA and FAA web sites. I have not been able to find a revised "Checklist", referred to as the "Amatuer-Built Fabrication and Assembly Checklist, Appendix 8, of Draft AC20-47G. In the latest version of the draft (as of last weekend) on the FAA site, this checklist is labeled as "Insert Checklist When Finished". I have heard of threads on the internet referring to a revised checklist that would have scary results as far as fabrication is concerned. Do you have access to this FAA proposed checklist?

    I agree that the 51% rule is fine as it stands, but I suspect the FAA will not rest until they change something. I think the 20% fabrication requirement could work depending on how they define fabrication and if it includes credit for partial fabrication, say fabrication of the skin on the wing of a Super Cub from "raw" fabric, glue and coating. There are many partial fabrication tasks on the experimental kits that I am familiar with. Another factor is how percentage of fabrication or assembly is defined. Is it by labor hours, cost, weight, number of parts in assembly, etc. This whole thing could get complicated real fast!

  7. #7
    Marty57's Avatar
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    Phil,
    I want to say thanks for your statement;

    "Compare that to the old time plans builders who welded every joint themselves, fabricated every fuel and brake line, cut, fitted and jigged every fitting and bracket, installed every control cable etc. That guy/gal really knows that plane intimately. To put them in the same category as the "2 weeks to taxi" guy is down right insulting."

    I guess I am the guy above you are talking about (except for the Old fart or was it part ). There are lots of guys like me who look at the two week thing as a bit of a slap in the face. I thought I saw the last of the yellow "Cliff Notes" when I was "studying" for finials in college. They never worked for me. I had to read the entire book to make sense out of it ! Some guys could just read the yellow thing the night before and get the same credit. I hope my doctor didn't study that way. Come to think about it, next time he is poking where the sun don't shine I'll have to ask ......... maybe not.

    Marty57

  8. #8
    AntiCub's Avatar
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    I guess I am the guy above you are talking about (except for the Old fart or was it part ).
    Marty57
    Guess I should have said "Traditional" instead of old time. Especially since I'm planning to add myself to that category. Though I did cheat a little and order preformed ribs, but it is an incomplete set, so I still get to bang out a few myself.

    bsantana
    I'm guessing if you used the blanket method that would count as fabrication. Pre-sewn envelopes might be questionable though.

    Phil

  9. #9

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    new EAA rules

    I admire and envy the guys that can truly build an airplane. I looked at Charlie Aileron's Crimson Cub with awe. I could never do what he does. If I tried to, I would be afraid to fly in the finished product. The "two weeks to taxi" program appeals to guys like me. I would learn something about how the airplane is built, and get a much safer airplane than if I tried to do it on my own. It is not the same as the true homebuilder, but it is not wrong, or immoral or anything else.

    I would agree with the statement that two weeks in a factory would not qualify me to inspect and maintain an aircraft (or to call myself a builder).

    I just wanted to post the klutz point of view. Not all people that love aviation are mechanically inclined.

  10. #10
    Randy's Avatar
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    51% rule

    bump...time is running out....
    comment period ends Sept 30

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