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FAA Issued Letter On The 51% Rule

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jkreidler

Joined: 13 Feb 2008
Posts: 151
Location: Sheboygan Falls WI

Posted: Thu Jul 17, 2008 3:53 am Post subject: FAA Issued Letter On The 51% Rule

Found this on AVweb, looks like the FAA has issued something on the 51% rule.  Not sure how to interpret it, just FYI.... 

 

http://edocket.access.gpo.gov/2008/E8-16093.htm 



 Thanks, Jason Kreidler 

4-Partner Build (Jason Kreidler, Tony Kolar, Kyle Hokel, Wayne Elsner) 

Sheboygan Falls, WI 

#40617 Finishing 

Do Not Archive [quote][b]

_________________
Jason Kreidler
4 Partner Build - Sheboygan Falls, WI
Tony Kolar, Kyle Hokel, Wayne Elser, Jason Kreidler
N44YH - Flying - #40617

bbreckenridge(at)gmail.co
Guest

Posted: Thu Jul 17, 2008 4:50 am Post subject: FAA Issued Letter On The 51% Rule

Well, I sure hope that mating, drilling, reaming, deburring, scuffing, smoothing, dimpling, priming, cursing & crying are all part of the fabrication process.



Bruce

 40018 Wings

On Thu, Jul 17, 2008 at 4:48 AM,  <jason.kreidler(at)regalbeloit.com (jason.kreidler(at)regalbeloit.com)> wrote:

 	  Quote: 	
		    

Found this on AVweb, looks like the FAA has issued something on the 51% rule.  Not sure how to interpret it, just FYI.... 

 

http://edocket.access.gpo.gov/2008/E8-16093.htm 



 Thanks, Jason Kreidler 

4-Partner Build (Jason Kreidler, Tony Kolar, Kyle Hokel, Wayne Elsner) 

Sheboygan Falls, WI 

#40617 Finishing 

Do Not Archive  [/b] 	
[b]

AirMike

Joined: 27 Feb 2007
Posts: 514
Location: Nevada

Posted: Thu Jul 17, 2008 7:00 am Post subject: FAA Issued Letter On The 51% Rule

If I interpret it correctly, it looks like the FAA is proposing to go to a 20% rule - where the manufacturer and assembly shop do 80% and the builder does a minimum of 20%. The intent seems to be that the builder is then minimally capable of doing maintenance with their repairman certificate.

_________________
See you OSH '18
Q/B - sold.

Dave(at)AirCraftersLLC.co
Guest

Posted: Thu Jul 17, 2008 7:06 am Post subject: FAA Issued Letter On The 51% Rule

Cursing and crying are  the "recreation" part.  Bleeding is generally considered  "education".

  

 do not  archive



   From: owner-rv10-list-server(at)matronics.com  [mailto:owner-rv10-list-server(at)matronics.com] On Behalf Of bruce  breckenridge

Sent: Thursday, July 17, 2008 5:44 AM

To:  rv10-list(at)matronics.com

Subject: Re: FAA Issued Letter On  The 51% Rule

 

 Well, I sure hope that mating, drilling, reaming, deburring,  scuffing, smoothing, dimpling, priming, cursing & crying are all part of the  fabrication process. 



 Bruce

 



 40018 Wings

 



 On Thu, Jul 17, 2008 at 4:48 AM, <jason.kreidler(at)regalbeloit.com (jason.kreidler(at)regalbeloit.com)>  wrote:

 [quote]

Found this on AVweb, looks like the FAA has issued    something on the 51% rule.  Not sure how to interpret it, just    FYI.... 



http://edocket.access.gpo.gov/2008/E8-16093.htm    



Thanks, Jason Kreidler 

4-Partner Build (Jason Kreidler, Tony Kolar, Kyle    Hokel, Wayne Elsner) 

Sheboygan Falls,    WI 

#40617 Finishing 

Do Not Archive [/b] 	  Quote: 	
		  	




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[b]

flysrv10(at)gmail.com
Guest

Posted: Thu Jul 17, 2008 7:19 am Post subject: FAA Issued Letter On The 51% Rule

This is funny!  Keep going guys.



Rob.



On Jul 17, 2008, at 11:00 AM, Dave Saylor wrote:

 	  Quote: 	
		    Cursing and crying are the "recreation" part.  Bleeding is generally considered "education".

  

 do not archive



   From: owner-rv10-list-server(at)matronics.com [mailto:owner-rv10-list-server(at)matronics.com (owner-rv10-list-server(at)matronics.com)] On Behalf Of bruce breckenridge

Sent: Thursday, July 17, 2008 5:44 AM

To: rv10-list(at)matronics.com (rv10-list(at)matronics.com)

Subject: Re: FAA Issued Letter On The 51% Rule

 

 Well, I sure hope that mating, drilling, reaming, deburring, scuffing, smoothing, dimpling, priming, cursing & crying are all part of the fabrication process. 



 Bruce

 



 40018 Wings

 



 On Thu, Jul 17, 2008 at 4:48 AM, <jason.kreidler(at)regalbeloit.com (jason.kreidler(at)regalbeloit.com)> wrote:

  	  Quote: 	
		  

Found this on AVweb, looks like the FAA has issued   something on the 51% rule.  Not sure how to interpret it, just   FYI.... 



http://edocket.access.gpo.gov/2008/E8-16093.htm   



Thanks, Jason Kreidler 

4-Partner Build (Jason Kreidler, Tony Kolar, Kyle   Hokel, Wayne Elsner) 

Sheboygan Falls,   WI 

#40617 Finishing 

Do Not Archive  	  Quote: 	
		  	


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 [quote][b]

Lenny Iszak

Joined: 23 Mar 2008
Posts: 270

Posted: Thu Jul 17, 2008 7:25 am Post subject: Re: FAA Issued Letter On The 51% Rule

What is pinching your fingers with the pneumatic squeezer considered? How about two at the same time? 



Lenny,

#40803 baggage area

Tim Olson

Joined: 25 Jan 2007
Posts: 2872

Posted: Thu Jul 17, 2008 7:53 am Post subject: FAA Issued Letter On The 51% Rule

I'm thinking it's a bit different.  I'm thinking that whereas

so many of our parts are currently prefabricated with the kit,

that they will want to see more actual part fabrication on

behalf of the builders.  There really aren't that many of

the standard critical parts that we ourselves fabricated,

so what I think it is, is that the 51% rule still applies,

but they'll want increased documentation, and will want to

require that the builder actually fabricate or have a hand

in fabricating 20% of the parts, and do 20% of the assembly

of the kit too.



It does seem that this would be a big positive IMHO.  Personally

I think that an experimental models safety record probably has

something to do with how much the builder actually participates

in the build...as they know the plane better, and care more for

their blood, sweat, and tears...all of which I know I shed on

my kit. 



Tim Olson - RV-10 N104CD - Flying

do not archive

AirMike wrote:

 	  Quote: 	
		   

 

 If I interpret it correctly, it looks like the FAA is proposing to go

 to a 20% rule - where the manufacturer and assembly shop do 80% and

 the builder does a minimum of 20%. The intent seems to be that the

 builder is then minimally capable of doing maintenance with their

 repairman certificate.

 

 -------- OSH '08 or Bust (busted) be there in &quot;09 Q/B Kit -

 exited cabin top/door purgatory

 

 

 

 

 Read this topic online here:

 

 http://forums.matronics.com/viewtopic.php?p=193366#193366

Matt Dralle
Site Admin

Joined: 08 Nov 2005
Posts: 25858
Location: Livermore CA USA

Posted: Thu Jul 17, 2008 7:55 am Post subject: FAA Issued Letter On The 51% Rule

At first, it sounds like they want to reduce the amount of prefab and assembly currently occurring in the homebuilt industry.  But, then in the third-to-last paragraph it sounds like a significant reduction, e.g. 20% fabrication minimum, 20% construction minimum.



Imagine what Van's could do with a 20/20 ruling!  Wow.



Matt



At 05:44 AM 7/17/2008  Thursday, you wrote:

 	  Quote: 	
		  Well, I sure hope that mating, drilling, reaming, deburring, scuffing, smoothing, dimpling, priming, cursing & crying are all part of the fabrication process.



Bruce



40018 Wings

On Thu, Jul 17, 2008 at 4:48 AM, <<mailto:jason.kreidler(at)regalbeloit.com>jason.kreidler(at)regalbeloit.com> wrote:



Found this on AVweb, looks like the FAA has issued something on the 51% rule.  Not sure how to interpret it, just FYI.... 



<http://edocket.access.gpo.gov/2008/E8-16093.htm>http://edocket.access.gpo.gov/2008/E8-16093.htm 



Thanks, Jason Kreidler 

4-Partner Build (Jason Kreidler, Tony Kolar, Kyle Hokel, Wayne Elsner) 

Sheboygan Falls, WI 

#40617 Finishing 

Do Not Archive 


	


Matt G Dralle | Matronics | PO Box 347 | Livermore | CA | 94551

925-606-1001 V | 925-606-6281 F | dralle(at)matronics.com Email

http://www.matronics.com/ WWW | Featuring Products For Aircraft

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Matronics Email List Administrator

msausen

Joined: 25 Oct 2007
Posts: 559
Location: Appleton, WI USA

Posted: Thu Jul 17, 2008 8:18 am Post subject: FAA Issued Letter On The 51% Rule

It seems to me that they are moving from a list of tasks to actual percentage of work to determine 51% in addition to the 20/20 part.



Michael



--

scottmschmidt(at)yahoo.co
Guest

Posted: Thu Jul 17, 2008 8:31 am Post subject: FAA Issued Letter On The 51% Rule

I agree with that assessment Tim. 

Didn't the FAA already come out and say that Van's kits are basically one of the standards the new rules will be written too? 

And if that is the case, I don't feel like I made 20% of the parts in the kit even though it was a slow-build.  

That sounds like another rule that will be left to interpretation.  Does fabricate mean to bend your own ribs or just deburr them.  Or do you have to mine the raw material, purchase a plasma furnace and extrude your own angle (J/K).  

I'm sure there will be alot of information at Oshkosh on this.  



I'm most excited to see this new jet pack they are going to debut on Tuesday at 9:00am.  Anybody have some insider info on this? 

Let's face it, we all need a jet pack.  I  can see it now, people texting while flying their jet pack.  

Scott Schmidtscottmschmidt(at)yahoo.com



---

rene(at)felker.com
Guest

Posted: Thu Jul 17, 2008 8:45 am Post subject: FAA Issued Letter On The 51% Rule

It depends on what they call fabrication.....are pre-punched holes

"fabrication".  Is cutting the sheet metal to size "fabrication"?  The devil

is in the detail.  My guess is that is exactly what they are doing and that

is why it is only 20%.......But that is just my opinion........



Rene' Felker

RV-10 N423CF Flying

801-721-6080

--

pascal(at)rv10builder.net
Guest

Posted: Thu Jul 17, 2008 9:00 am Post subject: FAA Issued Letter On The 51% Rule

When I saw the 20% manufacturer piece I thought the  same way Scott, but I do think cutting angle and shaping it for the fuselage and  the bending of the skins and the fiberglass work!!, I pretty much grabbed the  piece I was sent and "built" it to fit the aircraft as the way it was sent would  never work for me. There is also the piece of those extras we customize for our  planes, the air vents, access panels, in some cases Panels, like Fred Williams,  etc.. when added all up I think the raw parts are "fabricated" to work and I  don’t see that fitting in the "assembly" component, so if not assembly than by  default it must be "fabricated". 

 That is my interpretation, but I agree when it  comes to getting a Airworthiness and repairman's cert the FAA FSDO may see it a  different way in their interpretation and in the end that is really the  issue.

 Pascal

  

  



  From: Scott Schmidt (scottmschmidt(at)yahoo.com) 

 Sent: Thursday, July 17, 2008 9:26 AM

 To: rv10-list(at)matronics.com (rv10-list(at)matronics.com) 

 Subject: Re: Re: FAA Issued Letter On The 51%  Rule

 



 I  agree with that assessment Tim. 

Didn't the FAA already come out and say that  Van's kits are basically one of the standards the new rules will be written too?  

And if that is the case, I don't feel like I made 20% of the parts in the  kit even though it was a slow-build.  

That sounds like another rule  that will be left to interpretation.  Does fabricate mean to bend your own  ribs or just deburr them.  Or do you have to mine the raw material,  purchase a plasma furnace and extrude your own angle (J/K).  

 I'm sure there will be alot of information at Oshkosh on this.   



I'm most excited to see this new jet pack they are going to debut on  Tuesday at 9:00am.  Anybody have some insider info on this? 

Let's face  it, we all need a jet pack.  I can see it now, people texting while flying  their jet pack.  

Scott  Schmidtscottmschmidt(at)yahoo.com

 



 

 -----  Original Message ----

From: Tim Olson <Tim(at)myrv10.com>

To:  rv10-list(at)matronics.com

Sent: Thursday, July 17, 2008 9:49:09 AM

Subject:  Re: Re: FAA Issued Letter On The 51% Rule



--> RV10-List  message posted by: Tim Olson <Tim(at)myrv10.com (Tim(at)myrv10.com)>



I'm thinking it's  a bit different.  I'm thinking that whereas

so many of our parts are  currently prefabricated with the kit,

that they will want to see more actual  part fabrication on

behalf of the builders.  There really aren't that  many of

the standard critical parts that we ourselves fabricated,

so what  I think it is, is that the 51% rule still applies,

but they'll want increased  documentation, and will want to

require that the builder actually fabricate  or have a hand

in fabricating 20% of the parts, and do 20% of the  assembly

of the kit too.



It does seem that this would be a big  positive IMHO.  Personally

I think that an experimental models safety  record probably has

something to do with how much the builder actually  participates

in the build...as they know the plane better, and care more  for

their blood, sweat, and tears...all of which I know I shed on

my kit.  



Tim Olson - RV-10 N104CD - Flying

do not archive

AirMike  wrote:

 	  Quote: 	
		   --> RV10-List message posted by: "AirMike" <Mikeabel(at)Pacbell.net (Mikeabel(at)Pacbell.net)>

  

 If I interpret it correctly, it looks like the FAA is proposing to  go

 to a 20% rule - where the manufacturer and assembly shop do 80%  and

 the builder does a minimum of 20%. The intent seems to be that  the

 builder is then minimally capable of doing maintenance with  their

 repairman certificate.

 

 -------- OSH '08 or Bust  (busted) be there in &quot;09 Q/B Kit -

 exited cabin top/door  purgatory

 

 

 

 

 Read this topic online  here:

 

 http://www.matronics.com/Navigator?RV10-List 

--> http://forums.matronics.com 
	


-Matt 

href="http://www.matronics.com/contribution">http://www.matronics.com/contribution 

=========== [/b][quote][b]

Tim Olson

Joined: 25 Jan 2007
Posts: 2872

Posted: Thu Jul 17, 2008 9:47 am Post subject: FAA Issued Letter On The 51% Rule

That's what I thought too...that perhaps the kits would be

sent with a few more uncompleted parts or something to qualify

them under new rules.  Although the old kits would be grandfathered

from what we've heard before.  So maybe we have to do a few

more ribs, or cut more brackets...or heck, even do some welding

or something?  Not sure, but my guess is that a full QB kit

would NOT qualify anymore if it weren't grandfathered.



Now, what you and I can do, Scott, is fabricate our own

Jet packs.....if we fabricate it ourselves, shouldn't

we still be eligible for slapping an N-number on it under

the experimental amateur built rules? 

Tim Olson - RV-10 N104CD - Flying

do not archive

Scott Schmidt wrote:

 	  Quote: 	
		   I agree with that assessment Tim.

 Didn't the FAA already come out and say that Van's kits are basically 

 one of the standards the new rules will be written too?

 And if that is the case, I don't feel like I made 20% of the parts in 

 the kit even though it was a slow-build. 

 That sounds like another rule that will be left to interpretation.  Does 

 fabricate mean to bend your own ribs or just deburr them.  Or do you 

 have to mine the raw material, purchase a plasma furnace and extrude 

 your own angle (J/K). 

 I'm sure there will be alot of information at Oshkosh on this. 

 

 I'm most excited to see this new jet pack they are going to debut on 

 Tuesday at 9:00am.  Anybody have some insider info on this?

 Let's face it, we all need a jet pack.  I can see it now, people texting 

 while flying their jet pack. 

 

 Scott Schmidt

 scottmschmidt(at)yahoo.com

Dave(at)AirCraftersLLC.co
Guest

Posted: Thu Jul 17, 2008 10:38 am Post subject: FAA Issued Letter On The 51% Rule

>>There is also the piece of those extras  we customize for our planes, the air vents, access panels ...<< 

  

 All those  extras count!  There are lots of extra spaces in each section of the tally  sheet.  If your work isn't on the list, you can add it and take  credit.

  

  Dave Saylor

 AirCrafters LLC

 140 Aviation Way

 Watsonville, CA 

 831-722-9141

 831-750-0284 CL

 www.AirCraftersLLC.com

pitts_pilot(at)bellsouth.
Guest

Posted: Thu Jul 17, 2008 11:43 am Post subject: FAA Issued Letter On The 51% Rule

I think Pascal has hit the nail square ...... Y'all are trying to apply logic and common sense to a document created by the FAA, who purposely write their rules/regs vague enough so that they can apply THEIR interpretation as needed for the situation at hand.  They've already said they don't have a problem with Van's kits.  What they do have a problem with is little factories churning out planes to order.  Those surely don't fit the image of owner-builder for educational purposes.

 My 2 pennies

 Linn

 do not archive

 pascal wrote: [quote]            When I saw the 20% manufacturer piece I thought the same way Scott, but I do think cutting angle and shaping it for the fuselage and the bending of the skins and the fiberglass work!!, I pretty much grabbed the piece I was sent and "built" it to fit the aircraft as the way it was sent would never work for me. There is also the piece of those extras we customize for our planes, the air vents, access panels, in some cases Panels, like Fred Williams, etc.. when added all up I think the raw parts are "fabricated" to work and I don’t see that fitting in the "assembly" component, so if not assembly than by default it must be "fabricated". 

   That is my interpretation, but I agree when it comes to getting a Airworthiness and repairman's cert the FAA FSDO may see it a different way in their interpretation and in the end that is really the issue.

   Pascal

      From: Scott Schmidt (scottmschmidt(at)yahoo.com) 

   Sent: Thursday, July 17, 2008 9:26 AM

   To: rv10-list(at)matronics.com (rv10-list(at)matronics.com)   

   Subject: Re: Re: FAA Issued Letter On The 51% Rule

   I agree with that assessment Tim. 

 Didn't the FAA already come out and say that Van's kits are basically one of the standards the new rules will be written too? 

 And if that is the case, I don't feel like I made 20% of the parts in the kit even though it was a slow-build.  

 That sounds like another rule that will be left to interpretation.  Does fabricate mean to bend your own ribs or just deburr them.  Or do you have to mine the raw material, purchase a plasma furnace and extrude your own angle (J/K).  

   I'm sure there will be alot of information at Oshkosh on this.  

 I'm most excited to see this new jet pack they are going to debut on Tuesday at 9:00am.  Anybody have some insider info on this? 

 Let's face it, we all need a jet pack.  I can see it now, people texting while flying their jet pack.  

   Scott Schmidt   scottmschmidt(at)yahoo.com (scottmschmidt(at)yahoo.com)

   ----- Original Message ----

 From: Tim Olson <Tim(at)myrv10.com> (Tim(at)myrv10.com)

 To: rv10-list(at)matronics.com (rv10-list(at)matronics.com)

 Sent: Thursday, July 17, 2008 9:49:09 AM

 Subject: Re: Re: FAA Issued Letter On The 51% Rule

 --> RV10-List message posted by: Tim Olson <Tim(at)myrv10.com (Tim(at)myrv10.com)>

 I'm thinking it's a bit different.  I'm thinking that whereas

 so many of our parts are currently prefabricated with the kit,

 that they will want to see more actual part fabrication on

 behalf of the builders.  There really aren't that many of

 the standard critical parts that we ourselves fabricated,

 so what I think it is, is that the 51% rule still applies,

 but they'll want increased documentation, and will want to

 require that the builder actually fabricate or have a hand

 in fabricating 20% of the parts, and do 20% of the assembly

 of the kit too.

 It does seem that this would be a big positive IMHO.  Personally

 I think that an experimental models safety record probably has

 something to do with how much the builder actually participates

 in the build...as they know the plane better, and care more for

 their blood, sweat, and tears...all of which I know I shed on

 my kit. 

 Tim Olson - RV-10 N104CD - Flying

 do not archive

 AirMike wrote:

 > --> RV10-List message posted by: "AirMike" <Mikeabel(at)Pacbell.net (Mikeabel(at)Pacbell.net)>

 > 

 > If I interpret it correctly, it looks like the FAA is proposing to go

 > to a 20% rule - where the manufacturer and assembly shop do 80% and

 > the builder does a minimum of 20%. The intent seems to be that the

 > builder is then minimally capable of doing maintenance with their

 > repairman certificate.

 > 

 > -------- OSH '08 or Bust (busted) be there in &quot;09 Q/B Kit -

 > exited cabin top/door purgatory

 > 

 > 

 > 

 > 

 > Read this topic online here:

 > 

 >    	  Quote: 	
		  http://www.matronics.com/Navigator?RV10-List 

--> http://forums.matronics.com 

-Matt 

href="http://www.matronics.com/contribution">http://www.matronics.com/contribution 

=========== 

 href="http://www.matronics.com/Navigator?RV10-List">http://www.matronics.com/Navigator?RV10-List

 href="http://forums.matronics.com">http://forums.matronics.com

 href="http://www.matronics.com/contribution">http://www.matronics.com/contribution

 [b]

seipel(at)seznam.cz
Guest

Posted: Thu Jul 17, 2008 12:36 pm Post subject: FAA Issued Letter On The 51% Rule

Not sure if this has been posted, but here's the link to the actual 

draft documents and it tells you who to send comments to if you have 

recommendations/corrections/comments.  If you look at the checklist, I'm 

not sure how you get 187 points when some of the things like "wing 

struts" don't apply.



PJ Seipel

RV-10 #40032



http://www.faa.gov/aircraft/draft_docs/display_docs/index.cfm?Doc_Type=Pubs



Dave Saylor wrote:

 	  Quote: 	
		   >>There is also the piece of those extras we customize for our planes, 

 the air vents, access panels ...<< 

  

 All those extras count!  There are lots of extra spaces in each 

 section of the tally sheet.  If your work isn't on the list, you can 

 add it and take credit.

  

 Dave Saylor

 AirCrafters LLC

 140 Aviation Way

 Watsonville, CA

 831-722-9141

 831-750-0284 CL

 www.AirCraftersLLC.com

 *

 *

taildragon(at)msn.com
Guest

Posted: Thu Jul 17, 2008 3:23 pm Post subject: FAA Issued Letter On The 51% Rule

<?xml:namespace prefix="v" /><?xml:namespace prefix="o" /><![endif]-->  And let us not forget that all the fiberglass parts are all bolt-on  perfect.

 [quote]   ---

ricksked(at)embarqmail.co
Guest

Posted: Thu Jul 17, 2008 4:36 pm Post subject: FAA Issued Letter On The 51% Rule

Com'on Linn!!...Day frum duh Guvment!!! Day here ta hepp ya!! 

Rick...no last name 

40185 

do not archive

---

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