Kayberg(at)aol.com
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 Posted: Sat Mar 01, 2008 6:54 am Post subject: 51 % rule |
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Just a couple wry comments about the 51% kit approval.
Of course it doesn't apply to Tailwinds NOW, but in the interest of education, I want to point out my take on it.
First, it just makes paperwork easier for the DAR or Feds. Means a couple less pages to submit.
Second, it does tell the builder that he is buying a kit that has a locked in production run. Any changes to the kits require inspections and approval.
Third, the Feds do no engineering on the kits, they just check to be sure the 1) the work to complete the kit meet the criteria as interpreted 2) there is a parts list 3) there is a fixed location for the owner 4) at least one has been built from the kit and they want to see a kit ready to ship.
Fourth, the determination is made mostly based on airframe assembly, not engine, instruments or painting. Those dont count toward 51%. However, you only need to do one small part of the construction of the component to qualify. For example, if you receive a flap that must have a hole drilled, a jig made to drill the hole, and the fitting of an end rib, that component is considered to be fully built by you. ANY effort to complete some part of the component counts. I am not trying to detail this point exactly, so others may feel the need to correct me on this, but my larger point is that currently the application of this rule is subjective, not reflective of how kits are currently being built and not particularly restrictive.
Fifth, there can be a real advantage to a 51% kit if critical components are done well by the "factory". By using jigs; rigging and key components can be precisely done. High skill, high tech requirements like welding or state-of-the art composite work can be nearly flawless. However the rule doesn't adequately address critical structural components now.
Again none of this applies to Tailwinds or Buttercups. But if mostly welded fuselages, jigged struts and wing attaches were available, fittings and control surfaces were available yet met the 51% requirements; it is fun to think of the number of additional builders that might come along.
I am glad some revision is in the works. I just hope it doesn't get crazy.
Doug Koenigsberg
Delicious ideas to please the pickiest eaters. Watch the video on AOL Living.
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