Home Built 51% Rule Under the Gun

On 21 Sep 2006 10:02:35 -0700, "Bret Ludwig"
wrote:


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

And how are you going to determine total build hours? For that
specific example, or for that particular make and model? Make and
model wise the hours vary more than 2:1 from one plane to another.
Some people put more hours into the paint job than some of us will put
into the whole airplane including paint.

I think the current FAA task list works well. You can get any one be
they pro, AI or the guy down the street to help you on the
"representative sample". You could hire the rest done but it's a
relatively small number that could afford to do so and fewer still
that avail them selves of the service. The factory build centers keep
the new owner involved. They really cut down on the hours required by
working with the builder by using factory jigs and fixtures and
showing them the fastest and easiest way to do things. OTOH the
plane rolls out the door in the 90% done, 90% to go state.

of each of the tasks required to go from raw material to airplane. He

You really only need to do one from raw material to finished state.
You have learned how it's done and that is supposed to be the goal.
The original G-III (which is one of the most labor intensive kits on
the market) really puts you through the mill on this one. For the
control surface ribs there are only these statements. Locate the rib
here, use 1/4" or maybe 1/2" foam of a given weight, seal the sides
with a thin microsphere mix, lay-up two layers of BID on each side
over lapping onto the control surface and shear web by about one inch
(after bonding said sealed foam in place.). There is nothing telling
you what dimensions, or how to get the proper shape.

I'd dearly love to have one of those "jump start kits" and for the
proper price I'd get one it took me nearly 1000 hours of work just to
get as far as I would have been taking the jump start kit out of the
crate.

When it comes to the wing the main wing spar is already bonded in
place For the rear spar they tell you to cut the following pieces of
1/2" foam and give the dimensions. You are expected to figure how to
fit them together, then fit, sand,seal, and build up the sides with
BID. The spar caps are already molded into the wing surface.
They give some round about ways of building the wing fixture. I took
some short cuts that made sense and then called the factory to verify
it was OK. The comment was, "that's the way we do it here".


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

I
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

This would be a bit too restrictive as far as I'm concerned. I know of
several builders who discovered once the plane was finished they did
not like the characteristics. Sure they flew representative models
before starting, but after years of building it's easy to find your
results a too fast, too slow, too big, too small, wouldn't do
aerobatics, not enough range, time they finished the hot rod they no
longer had the ability to fly something that hot... The list could go
on and on

very limited in how much of the work can be done there.

The goal for the builder is clearly stated. They have to do so many
specific representative tasks. They either do them and the plane
meets the amateur build category, or they don't and it doesn't.

All of the required elements to meet the intent of the so called 51%
rule are already in place. The only thing not in place is some form
of policing of the policy.


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

People build because they like to build and/or they build because they
can not get what they want in a certified plane. I fall into the and
category as I like to build things and I could not come any where near
the performance in a certificated aircraft. Even were one available I
couldn't afford it. To me every home build is an end run around
certification, but that may be due to the way I view the definition.

If I build because I like to build and I can not build a certificated
(the word is not certified) airplane then that is an end run. If I
build to save money as I can build far cheaper than purchasing (IF I
only count my time at about 25 cents per hour)

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.

There is no need to change anything as the rules are already quite
clear. They only need to put a checks and balance system in place to
make sure all adhere to it. Under the 51% rule, but builders centers
can offer a real service to those who can afford it without
circumventing either the intent or letter of the rule and to me that
is a good thing even if I can't afford it.


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

There is nothing wrong with that if the engine is truely certified. IE
they can produce all the records to show it was properly maintained
AND it has a data plate. Isn't the data plate supposed to be removed
from a non certified engine?

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

Technically if the engine records are there and the engine still has
the data plate there should be no problem and no reason not to move
the engine to a certificated aircraft that takes that particular make
and model engine..
I purchased a run out K1A5 IO-540 and plan to have it rebuilt by a
custom shop which will leave it certified.

purpose of course is to drive up costs of certified engines on used
homebuilts....

Why? I think they are a good thing and it saves me hours in the
required fly-off time. Besides, that is the engine my G-III was
designed around.

The point is that every thing required is already in the rules.
Nothing there needs to be changed. They only need to keep the
builders centers honest and even then there only a few are problems.

Roger Halstead (K8RI & ARRL life member)
(N833R, S# CD-2 Worlds oldest Debonair)
www.rogerhalstead.com