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![]() "Stache" wrote in message ups.com... Committee To Review 51% Rule Government, Industry Partnership To Review Amateur-Builder Statutes The FAA is concerned that some builders-for-hire and commercial "builder's assistance" providers are doing more that the FARs permit when it comes to amateur-built aircraft. snip The Committee will meet next in November in Washington, D.C. I'd say the 51% rule is in no danger. People who set up professional build shops, and their customers are the ones who will suffer. Rightly so, IMO. KB |
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On Sat, 16 Sep 2006 17:44:15 -0400, "Kyle Boatright"
wrote: "Stache" wrote in message oups.com... Committee To Review 51% Rule Government, Industry Partnership To Review Amateur-Builder Statutes The FAA is concerned that some builders-for-hire and commercial "builder's assistance" providers are doing more that the FARs permit when it comes to amateur-built aircraft. According to the FAA they can do a lot. So those abusing the system are apparently constructing major portions of the project without the builder being involved. snip The Committee will meet next in November in Washington, D.C. I'd say the 51% rule is in no danger. People who set up professional build shops, and their customers are the ones who will suffer. Rightly so, IMO. The FAA clarified the rule earlier this year by saying: When they say 51% they do not mean the builder actually does 51% of the labor, but (and they clarified that by saying. If the builder does one aileron then they know how to do an aileron and some one else may build the other.) The basic tenant was the builder learn and do the building requirements. OTOH it's difficult to build half a stabilizer on many planes like the G-III where the horizontal stab is one piece when finished. OTOH in the jump start kit the ribs are already bonded to the top shell (bottom as jigged) and the stab is about ready to close. For the first time builder of that plane it saves a lot of hours. Even the builder's centers can legally do well more than half the physical labor IF the purchaser does over half the items. I'm trying to find a better way to phrase that, but it gets back to multiples of the same item. If the builder does one of ten identical items they said that met the learning intent. IE you don't learn much more by building 10 of something than you do building one. Most of the learning comes with the first. I'm trying to remember but I believe they also said it's OK to use the existing/factory fixtures in which to construct the parts. I've probably spend at least as much time building fixtures and I have on the airplane. At any rate the problem comes from those centers that go ahead and put the structural members together without the actual builder/owner being involved. Such as that aileron. The center can have an employee work with the builder showing him/her how to do the work and the builder does that one aileron. The center can then go ahead and to the other one. It gets sticky when we start talking control surfaces instead of ailerons, flaps, elevator, and rudder if they have different processes in building them. If I build one aileron and the builder's center constructed the other I'd probably end up with an asymmetrical set of ailerons that would require some strange rigging to get it to fly straight. :-)) OTOH I may end up with that situation with me constructing both. Most of the quick build kits sort of follow this route, but supposedly with a margin for the builder, built in and most of the jump start, or fast build kits have been checked out and OK 'd by the FAA. I could legally hire some one to put my G-III together working in my shop and doing it under my direct supervision (IF I could afford it, which I can't so we don't need to go there) When it comes to closing things like the horizontal stab, elevators, and wing, I will have, and have had at least two others helping. By the time one person finished putting in all the resin/mill fiber mix so they could close, the first part would have already set up. It has to get really cold in there to have much more than 20 minutes to gel time. If it's near 70 F I only have about 15 minutes. Knock five minutes of each for available working time. More than once I've gone to add a bit of resin to a spot only to find a big gob of snot hanging on the brush. Twice I've come up with the mixing pot firmly attached to the brush. So when my helpers arrive we go through the steps of what has to be done and how to do each step. Then we go to the resin mixing. I determine how much each person will mix and usually measure out the resin and catalyst. I show them the mixing procedure, I have the necessary mill fiber for each in a cup, the Cabosil in another plastic cup, and the last thing before starting is to fill three syringes to the proper level with catalyst.Then we work in unison. Add the catalyst, stir 30 seconds following my procedure, add a measured amount of mill fiber, stir in, add some Cabosil, stir in, add more mill fiber to the proper consistency and stir. If need be we add more cabosil, but each batch gets the same amount of everything. We also work from the same can of resin and the same bottle of catalyst. I have good quality masks with activated charcoal filters for each helper as the fumes from catalyzed Vinyl Ester Resin are not at all good for you even if they do smell good. OTOH if the day is right with the temperature about 65 to 68 with a light to medium breeze I'll open the big doors and we may work without the masks If need be I do a small sacrificial batch before we start so any one who has not worked with the stuff knows what to expect. Even then I try to build something out of that sacrificial batch and work until it starts to gel. The builders center can do the same thing, but they can show the builder the best method for mixing as well as the best mix and procedure. What took me many hours to develop they can impart to the builder in a few minutes. They and the builder may then work together constructing that part. This approach saves many hours. They also know many short cuts to save time that the builder might stumble on if they were lucky. That and they can work FAST! Doing this can leave a fine line between what can and can not be done, but "I think" the shops giving problems are going far beyond the line leaving little doubt. KB Roger Halstead (K8RI & ARRL life member) (N833R, S# CD-2 Worlds oldest Debonair) www.rogerhalstead.com |
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Roger (K8RI) wrote:
The FAA clarified the rule earlier this year by saying: When they say 51% they do not mean the builder actually does 51% of the labor, but (and they clarified that by saying. If the builder does one aileron then they know how to do an aileron and some one else may build the Unless it's changed (nice disclaimer, right?), there is a list of tasks, FAA Form 8000-38. In the case of ailerons, there are actually 12 tasks. About half of those are fabricate various components. The other half are install or assemble those components. Of course, as you describe, a builder gets full credit for performing each task just once. The list is 154 tasks long (I counted). Several of the tasks described probably don't apply to most aircraft (things like canards and rotor systems jump off the page as obvious examples), so I guess the builder is left with fewer than 154 tasks, and has to have completed 51% of those. There tasks also vary widely in difficulty. "Install seats" is equal credit to "fabricate propeller." By the way, nice and realistic description of construction. |
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Earlier, Jim Carriere wrote:
...there is a list of tasks, FAA Form 8000-38. In the case of ailerons, there are actually 12 tasks. About half of those are fabricate various components. The other half are install or assemble those components... I've seen copies of a couple of 8000-38s. There are extra spaces on the form where you can add tasks to the lists. And, I've seen where builders have struck out a few of the listed tasks and written in "N/A" for "Not Applicable." Judicious application of these two practices (and reasonable justification for them), combined with careful naming of the kit parts by the manufacturer, can be used to demonstrate "51%" compliance on the 8000-38. Bob K. |
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![]() Roger (K8RI) wrote: On Sat, 16 Sep 2006 17:44:15 -0400, "Kyle Boatright" wrote: "Stache" wrote in message oups.com... Committee To Review 51% Rule Government, Industry Partnership To Review Amateur-Builder Statutes The FAA is concerned that some builders-for-hire and commercial "builder's assistance" providers are doing more that the FARs permit when it comes to amateur-built aircraft. According to the FAA they can do a lot. So those abusing the system are apparently constructing major portions of the project without the builder being involved. snip The Committee will meet next in November in Washington, D.C. I'd say the 51% rule is in no danger. People who set up professional build shops, and their customers are the ones who will suffer. Rightly so, IMO. The FAA clarified the rule earlier this year by saying: When they say 51% they do not mean the builder actually does 51% of the labor, but (and they clarified that by saying. If the builder does one aileron then they know how to do an aileron and some one else may build the other.) The basic tenant was the builder learn and do the building requirements. OTOH it's difficult to build half a stabilizer on many planes like the G-III where the horizontal stab is one piece when finished. OTOH in the jump start kit the ribs are already bonded to the top shell (bottom as jigged) and the stab is about ready to close. For the first time builder of that plane it saves a lot of hours. IMO the regulation needs to say that the amateur builder needs to accomplish 51% of the total build hours and do a representative example of each of the tasks required to go from raw material to airplane. He may work "under the supervision of" an A&P or other professional but he has to do it with his own physical involvement. An amateur builder being someone who does not work as an aircraft mechanic or production worker. They should be allowed to build an Experimental Amateur Built for their own use but serious restrictions on how many they build, how much they must fly it and how long they have to keep it should be enacted to stop the hired guns cold. And the Builder Centers should be very limited in how much of the work can be done there. Type Certification is either good or it is bad. If it is good, and I think it is, what we are seeing in experimental amateur built aviation is largely a dodge around type certification. If it is bad, the EAA and AOPA should at least have the balls to say that is their belief, either on functional or libertarian grounds. I say we put the kibosh on this subversion of rules that are for the benefit of everyone. Two more things, since you love my opinions so much, one, time spent homebuilding needs to be explicitly allowed to be applied to A&P certification if it is done "under the supervision of", and two, the certified engine provisions wiith regard to shorter test times need to apply strictly to powerplants operated and maintained as certificated engines, with the same recordkeeping and signoff requirements as those in type certificated aircraft. That way a certified aircraft owner can buy a homebuilt and if it is a certified engine pull its engine off and put it on his certified aircraft. This is now "sometimes" possible "depending on" how the locals interpret things, meaning aircraft dealers won't look at an engine that has been on a homebuilt. My purpose of course is to drive up costs of certified engines on used homebuilts.... |
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Bret Ludwig wrote:
IMO the regulation needs to say that the amateur builder needs to accomplish 51% of the total build hours and do a representative example of each of the tasks required to go from raw material to airplane. First, define 'raw material'. Do I have to head out to the north-west to hunt down a spruce tree or two, and then do a little mining to get some iron ore? Will the neighbors in Jacksonville, Fl object to the aluminum smelter in the backyard? Second, build time will mean nothing in this context. If I stare at an aluminum wing rib for 3 hours with a beer in each had trying to figure out which way is up, how many build hours have I invested? Who's counting, and do we really want another list of rules to specify "certifiable build time"? He may work "under the supervision of" an A&P or other professional but he has to do it with his own physical involvement. An amateur builder being someone who does not work as an aircraft mechanic or production worker. So aircraft mechanics and production workers will no longer be allowed to build their own aircraft? That's an awfully severe restriction on the liberties of these people. They should be allowed to build an Experimental Amateur Built for their own use but serious restrictions on how many they build, how much they must fly it and how long they have to keep it should be enacted to stop the hired guns cold. And the Builder Centers should be very limited in how much of the work can be done there. What if the project is never completed by the person who starts it? What if the starter dies, loses his medical or just finds that he hates sheet metal/epoxy/sawdust/MEK/etc? What if I get cancer from the MEK and need to sell the airplane to pay the doctor? Why are builder centers bad? Is it safer to bend a rib on the centers jig in 2 minutes or to cobble together my own jig in several days that takes an hour to bend one...only to throw the jig away and have all the other builder's duplicating the same inefficiency? Type Certification is either good or it is bad. If it is good, and I think it is, what we are seeing in experimental amateur built aviation is largely a dodge around type certification. Type Certification is bad because it was implemented with no more foresight that what you have shown. Laws have to exist in the real world just like the airplanes we build. The idea that a mechanical system can be completely specified and then have holy water sprinkled on it and declared safe from a bevy of bureaucrats is fundamentally flawed. Washington will never do it, because it entails voluntarily relinquishing power (bureaucrats don't do that), but the FAA and FDA both need to back the hell up, assume the role of an advisory organization, and quit trying to act as if they can guarantee 100% safety through their "certification". They don't and never will know everything any more than I will. The law should be that an airplane be allowed to post a placard that says, "This aircraft complies with FAA standards for safety." or some such wordy mumbo-jumbo that the bureaucrats choose, IF and ONLY IF the producer of the aircraft chooses to pursue the compliance. Everyone else must carry a placard stating that the airplane does not comply with the regulations. Does not vs may not, because not choosing to pursue the compliance will in itself be a non-compliance. People who buy airplanes, in conjunction with their insurance companies, can decide for themselves if they give a flip about FAR compliance. Airplanes would have to be insured in order to work for hire, just like the rest of the transportation industry. The insurance company will take care of verifying for hire aircraft safety, just like they do in the rest of the transportation industry. Same with the FDA. I should be allowed to hand money to any quack I choose to pull a splinter, but you can bet your bottom I'll be searching for a real reliable certification before someone comes at me with a knife. Difference is, I get to choose. Problem is, people don't want choice. They want to be coddled, so this foolishness will continue. |
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There is some logic missing from this 51% argument.
Aircraft in the Amateur built category have a number of limitations. As they are not certified they can only be used for personal use and except for a few are not worth as much monetarily as the equivalent certificated aircraft (if there is one) Even if a person had a builders center build the entire thing, it still would have to operate under the same rules. Amateur built. Any one of us can purchase a used G-III, or Vans RV. The only thing is we do not qualify for the repairman's certificate. How does that differ from having a builders center do all the work? Agreed having the builders center do all of the work would not satisfy the educational aspect of the current rules, but neither does purchasing a used one. Me? I'd be afraid of a used G-III I could afford. BTW building fixtures was mentioned. I'd guess I have close to as much time in building good fixtures as I do in the actual building process and with the price of steel those fixtures are getting expensive. When I'm done they most likely will get pitched into the scrap pile. That is a lot of 1" square tubing that varies from 12 Ga to 1/4" wall. I'd guess I have a good $500 into the wing fixture alone, probably more. That sucker is big! It has to be as the wing is one piece tip to tip. The top is made of true 2 X 6 milled lumber laminated with 3/4" birch plywood and bolted to a steel tube frame top that is welded to a heavy bottom steel frame with 10 casters and 10 3/4" leveling bolts. The contoured portion to fit the wing is 3/4" birch plywood while the trailing edge clamps are a good 40 feet of milled 1 X 2s. If I need to move the wing, I loosen the locking nuts and give each leveling bolt one turn "up", kick the caster locks and roll the whole works out. When finished with what caused the need for that area, I roll the fixture back in so the leveling bolts line up with the proper marks on the floor, give then one turn CW and tighten the locking nuts. Speaking of clamps I have almost a dozen of the squeeze clamps (sorta like a ratchet) that will open to about 18" and another dozen of the spring clamps that look sorta like a giant clothes pin except they'll pinch a whole lot harder. Again more money for things the builders center would have. Again this is where the builders center would excel. They have the fixtures and clamps that can be reused so the wing can be closed and installed on the airplane in a small fraction of the time I can do it and they still meet both the letter and intent of the 51% rule. The same is true of the horizontal stab and elevators. They know just how thick that stab should be when the shear web is bonded in. This will save many hours of fitting the elevators to the stab and you can be sure the left and right sides will match. As far as I can see a *good* builders center operating with in the letter and intent of the 51% rule could teach me more in one week than I can learn on my own stumbling around for a year or two. I'd learn more and get things done faster. Unfortunately as I have said before, being retired and on a budget that is not an option. Roger Halstead (K8RI & ARRL life member) (N833R, S# CD-2 Worlds oldest Debonair) www.rogerhalstead.com |
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![]() Roger (K8RI) wrote: There is some logic missing from this 51% argument. snip As far as I can see a *good* builders center operating with in the letter and intent of the 51% rule could teach me more in one week than I can learn on my own stumbling around for a year or two. I'd learn more and get things done faster. Unfortunately as I have said before, being retired and on a budget that is not an option. Why not enroll in A&P school? If there's a community college around it should not be too expensive and a Pell grant will probably pay half for free anyway. |
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On 22 Sep 2006 14:18:40 -0700, "Bret Ludwig"
wrote: Roger (K8RI) wrote: There is some logic missing from this 51% argument. snip As far as I can see a *good* builders center operating with in the letter and intent of the 51% rule could teach me more in one week than I can learn on my own stumbling around for a year or two. I'd learn more and get things done faster. Unfortunately as I have said before, being retired and on a budget that is not an option. Why not enroll in A&P school? If there's a community college around it should not be too expensive and a Pell grant will probably pay half for free anyway. At my age? I'm already retired and have been for 10 years. I'd be too old to use it by the time I finished the apprentice part and the nearest school is about 100 miles at the same airport where I took the PTS for my instrument rating. Roger Halstead (K8RI & ARRL life member) (N833R, S# CD-2 Worlds oldest Debonair) www.rogerhalstead.com |
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![]() Ernest Christley wrote: Bret Ludwig wrote: snip Same with the FDA. I should be allowed to hand money to any quack I choose to pull a splinter, but you can bet your bottom I'll be searching for a real reliable certification before someone comes at me with a knife. Difference is, I get to choose. Problem is, people don't want choice. They want to be coddled, so this foolishness will continue. What, are we libertarians? We are not libertarians yet, and you may tell that to your followers! (Arthur Miller, The Crucible) |
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