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notsew_evets(at)frontiern
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 Posted: Sat Feb 16, 2008 7:58 am Post subject: FAA Kits |
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I m not an expert these days but I have built three other AB Experimental aircraft...
If I recall correctly the rule says that the aircraft must be built (51%) by an amature. It doesnt say by who or how many.
High school class project are sometimes built by a class of young kids, each making a "part". Then at the end of the school year the "teacher" get the credit from the FAA and is listed as the builder...
If Zenith QBK is in trouble, then watch out Lancair, Glassair.
Wag Aero Cubby, well the list will be a whopper.....
I will understand the new rule if a commercial airpland factory builds your aircraft... I have a QBK and absolutely guarantee that I ve done more than 51%. They say there is 90% of the work in the last 10% of construction. If your not at the point of instrument panel, engine installation then you might not get the picture....
Again, the FAA loves to screw with the public. They might give us a bad time in the future.
Steve Weston
almost, almost almost DONE !
[quote][b]
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john.marzulli(at)gmail.co
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| Posted: Sat Feb 16, 2008 10:44 am Post subject: FAA Kits |
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The important thing to remember is that this is in response to kits that are way more prefabricated than anything Zenith makes.
There are two main problems that the FAA is trying to deal with:
- Kits that come highly pre-assembled that meet the letter, but not the spirit of the current interpretation of the 51% rule.
- Builder assistance programs that also undermine the 51% rule.
The current trend has been towards aircraft kits that are almost turn key, but still technically fulfill the FAA-8000-38 checklist in the builder's favor.
I doubt that this will have any negative outcomes for Zenith Builders, except for those who may started, but not completed a CH-701 "Quick-Start" kit provided by QSP or Flightcrafters before the E-LSA deadline, and even then those builders may be OK.
DO NOT ARCHIVE
On Feb 16, 2008 7:54 AM, steve <notsew_evets(at)frontiernet.net (notsew_evets(at)frontiernet.net)> wrote:
| Quote: | I m not an expert these days but I have built three other AB Experimental aircraft...
If I recall correctly the rule says that the aircraft must be built (51%) by an amature. It doesnt say by who or how many.
High school class project are sometimes built by a class of young kids, each making a "part". Then at the end of the school year the "teacher" get the credit from the FAA and is listed as the builder...
If Zenith QBK is in trouble, then watch out Lancair, Glassair.
Wag Aero Cubby, well the list will be a whopper.....
I will understand the new rule if a commercial airpland factory builds your aircraft... I have a QBK and absolutely guarantee that I ve done more than 51%. They say there is 90% of the work in the last 10% of construction. If your not at the point of instrument panel, engine installation then you might not get the picture....
Again, the FAA loves to screw with the public. They might give us a bad time in the future.
Steve Weston
almost, almost almost DONE !
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--
John Marzulli
http://701Builder.blogspot.com/
"Flying a plane is no different than riding a bicycle... it's just a lot harder to put baseball cards in the spokes.
-Airplane The Movie [quote][b]
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psm(at)att.net
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| Posted: Sat Feb 16, 2008 4:27 pm Post subject: FAA Kits |
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I have been following this "Thread" from the FAA and EAA for a while now. I don't think quick build kits are the target of this action. It is professional builders "Helping" the amateurs that are being targeted.
As I see it, the moratorium just means builders of non-approved kits must be prepared to prove they did over half of the operations to build their airplane to the DAR or FAA inspector. This is done with logs and pictures which we all seem to be accumulating. Also, if the first inspector doesn't think you did 51%, then perhaps the second or third one will.
I don't know the exact targets of this whole regulatory movement, but I think it has to do with very high performance "Kit Planes" that are a long way from Zenith designs. They probably have turbine engines, pressurized cabins, and galleys and toilets (or some similar arrangement). The FAA is seriously concerned that these planes are created to avoid part 23 certification rather than the education and recreation of their builders.
Anyone who is really worried about getting their 601 airworthiness certificate should write an email to the EAA and ask for clarification of this whole mess.
Paul
XL fuselage
do not archive
At 07:54 AM 2/16/2008, you wrote:
[quote]I will understand the new rule if a commercial airpland factory builds your aircraft... I have a QBK and absolutely guarantee that I ve done more than 51%. They say there is 90% of the work in the last 10% of construction. If your not at the point of instrument panel, engine installation then you might not get the picture....[b]
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steveadams
Joined: 10 Jan 2006
Posts: 191
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| Posted: Mon Feb 18, 2008 5:01 am Post subject: Re: FAA Kits |
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While the target is clearly "hired gun" builders and complex aircraft requiring a lot of factory assistance, there could be much wider impact. While industry reps and EAA are against it, the FAA wants to get rid of "shared credit" when determining who built the majority of the aircraft. Without this shared credit, The CH640 QB kit I built would not give me enough credit to have built 51% of the aircraft using the current checklist. I don't know for sure about other kits but I doubt most QB kits would be safe under the proposal. In essence this would change the current standard that basically says if you do one task, say fabricate a rib, you get full credit for that task; to one where if the factory does a portion of a task, say fabricate one rib, they get full credit for the task and the builder gets 0 even if they fabricated every other rib. I would be cautious about thinking the proposed changes won't effect us.
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klr12(at)psu.edu
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| Posted: Mon Feb 18, 2008 5:48 am Post subject: FAA Kits |
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February 17, 2008 New Guidance For Kitbuilt Aircraft On The Way [img]cid:part1.08070509.08020706(at)psu.edu[/img]Email this article |[img]cid:part2.03070208.00090503(at)psu.edu[/img]Print this article
By [url=http://www.avweb.com/cgi-bin/udt/im.author.contact.view?client_id=avflash&story_id=197174&title=New%20Guidance%20For%20Kitbuilt%20Aircraft%20On%20The%20Way&author=Marc%20Cook&address=http%3A//www.avweb.com/avwebflash/news/NewGuidanceForKitbuiltAircraftOnTheWay%5F197174%2D1.html&summary=On%20Friday%2C%20the%20FAA%20published%20the%20final%20report%20%28%3Ca%20href%3D%22http%3A//www.faa.gov/aircraft/gen%5Fav/ultralights/amateur%5Fbuilt/media/ARC%5FFINAL%5Freport.pdf%22%20target%3D%22%5Fblank%22%3EPDF%3C/a%3E%29%20from%20the%20Amateur%2DBuilt%20Aircraft%20Aviation%20Rulemaking%20Committee%20that%20outlines%20plans%20to%20keep%20the%20%22home%22%20in%20homebuilt.%20There%20will%20be%20a%20public%20comment%20period%2C%20which%20EAA%20predicts%20will%20be%20announced%20in%20April%20or%20May%2C%20and%20the%20FAA%20intends%20to%20have%20a%20final%20rule%20by%20October.%20The%20report%20follows%20months%20of%20work%20by%20the%20FAA%20and%20industry%20repres entatives%20in%20an%20attempt%20to%20curb%20flagrant%20violations%20of%20the%20experimental/amateur%2Dbuilt%20rules%2C%20which%20state%20that%20individuals%20must%20%20complete%20a%20%26%23147%3Bmajor%20portion%26%23148%3B%20of%20the%20aircraft%20to%20be%20eligible%20for%20registration%20in%20that%20category.%20The%20report%20acknowledges%20that%20some%20companies%20provide%20de%20facto%20manufacturing%20facilities%20for%20kitbuilt%20%20aircraft%20in%20which%20the%20builder%20does%20little%20actual%20work.%20%26%23147%3BIn%20the%20most%20extreme%20cases%2C%20other%20persons%20fabricate%20and%20assemble%20the%20major%20portion%20%20of%20an%20amateur%2Dbuilt%20aircraft%20for%20the%20applicant%2C%26%23148%3B%20according%20to%20the%20report.]Marc Cook[/url], Editor, Kitplanes Magazine
[img]cid:part3.06020908.05080004(at)psu.edu[/img]
[img]cid:part4.05060907.02060807(at)psu.edu[/img] On Friday, the FAA published the final report (PDF) from the Amateur-Built Aircraft Aviation Rulemaking Committee that outlines plans to keep the "home" in homebuilt. There will be a public comment period, which EAA predicts will be announced in April or May, and the FAA intends to have a final rule by October. The report follows months of work by the FAA and industry representatives in an attempt to curb flagrant violations of the experimental/amateur-built rules, which state that individuals must complete a “major portion” of the aircraft to be eligible for registration in that category. The report acknowledges that some companies provide de facto manufacturing facilities for kitbuilt aircraft in which the builder does little actual work. “In the most extreme cases, other persons fabricate and assemble the major portion of an amateur-built aircraft for the applicant,” according to the report.
To curb these abuses, the FAA has proposed changes to the guiding documents rather than a rewrite of the FARs that govern the category. Specifically, changes are expected to Advisory Circulars 20-27 and 20-139 that more accurately tally and identify outside commercial assistance on the forms used by the builder and the final inspector of the aircraft. The intention is, according to Earl Lawrence, vice president of industry and government affairs at the EAA, to clarify which parts of the airplane are completed by the builder, what is done by the factory as part of the original kit, and what has been done by commercial assistance. Now, for example, a kit manufacturer can construct all but one wing rib while the builder “fabricates” the remaining rib, and both entities get credit for all the work. There is also no requirement to state which parts of the aircraft have been fabricated or assembled by third-party commercial assistance. The revised ACs are expected to address these issues with specific guidance.
“The vast majority [of the report] is what we expected. We still don’t know what the FAA intends,” said Michael Via, of Glasair Aircraft. “We’re waiting to see what the policies and orders state. Nothing here affects our existing customers.” Jeremy Monnett, of Sonex Aircraft, said his company has always taken the 51 percent rule to heart and enforcement is the key to ensuring all kit manufacturers and builders adhere to the rules. “The resources required to carry out this enforcement have not been made available by the FAA over the last few years,” Monnett said in a news release. “Without these resources, enforcement loosens and the rules are pushed beyond their spirit and intent, compromising the rules' continued existence.” The FAA has proposed forming a group of Aviation Safety Inspectors to validate a manufacturer’s claims that its kit allows the builder to complete the “major portion” of the aircraft. In addition to publishing the report, the FAA announced Friday that it was temporarily suspending inspection of aircraft kits for inclusion on the “51% list.” This does not impact local inspections of completed airplanes. The move halts inspection of designs at the manufacturer level until the final rulemaking is published. |
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ashontz
Joined: 27 Dec 2006
Posts: 723
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| Posted: Tue Feb 19, 2008 4:51 am Post subject: Re: FAA Kits |
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Once upon a time I fixed up an old corroding 18' aluminum boat my Dad wasn't using anymore, rebuilt the engine, installed the engine, ran some instrumentation wiring and battery wiring, installed new carpeting and seats and a new fuel tank, fixed the trailer and rewired, installed a new winch, and registered both the boat and trailer with the DMV and got insurance. I would never claim to have built the boat. LOL
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