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Home Built 51% Rule Under the Gun



 
 
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  #1  
Old September 16th 06, 10:44 PM posted to rec.aviation.homebuilt
Kyle Boatright
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Posts: 578
Default Home Built 51% Rule Under the Gun


"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


  #2  
Old September 18th 06, 02:41 AM posted to rec.aviation.homebuilt
Roger (K8RI)
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Posts: 727
Default Home Built 51% Rule Under the Gun

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
  #3  
Old September 18th 06, 03:34 AM posted to rec.aviation.homebuilt
Jim Carriere
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Posts: 57
Default Home Built 51% Rule Under the Gun

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.
  #4  
Old September 19th 06, 06:06 PM posted to rec.aviation.homebuilt
Bob Kuykendall
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Posts: 1,345
Default Home Built 51% Rule Under the Gun

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.

  #5  
Old September 21st 06, 06:02 PM posted to rec.aviation.homebuilt
Bret Ludwig
external usenet poster
 
Posts: 138
Default Home Built 51% Rule Under the Gun


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....

  #6  
Old September 21st 06, 08:09 PM posted to rec.aviation.homebuilt
Ernest Christley
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Posts: 199
Default Home Built 51% Rule Under the Gun

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.
  #7  
Old September 22nd 06, 02:39 AM posted to rec.aviation.homebuilt
Roger (K8RI)
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Posts: 727
Default Home Built 51% Rule Under the Gun

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
  #8  
Old September 22nd 06, 10:18 PM posted to rec.aviation.homebuilt
Bret Ludwig
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Posts: 138
Default Home Built 51% Rule Under the Gun


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.

  #9  
Old September 23rd 06, 07:28 AM posted to rec.aviation.homebuilt
Roger (K8RI)
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Posts: 727
Default Home Built 51% Rule Under the Gun

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
  #10  
Old September 22nd 06, 10:20 PM posted to rec.aviation.homebuilt
Bret Ludwig
external usenet poster
 
Posts: 138
Default Home Built 51% Rule Under the Gun


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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