% of fabrication
% of fabrication
I don't know if this answers some questions about what constitutes fabrication? But, the new AC and the new checklist divides each task into 0 % increments of that task to determine what percent of each of the tasks you actually do. So, drilling holes in a cheek plate might account for partial fabrication of a cheek plate - perhaps even 50% - if someone else cuts or stamps out the plate. It appears you can divide these in 10% increments - to manufacturer, to commercial service, and to builder.
I'm sure we could argue we don't have to mine and smelt and extrude our own tubing. But, the definition in the proposed AC says basically to make a finished part from raw stock materials. If a tube is already cut and bent to shape, then drilling out pilot holes and painting it might account for 20% of the task to make that finished tube. (And providing pilot holes to help assure accuracy is an extra step and expense the manufacturers don't need to take in a precision jig, CNC machine or on the factory assembly floor!)
The checklist also does not break down as detailed as "cheekplate". For airplane wings and flying surfaces, it does break down to some internal detail - for 1987 tech airplane construction. But, for gyroplanes, after you exclude the parts the FAA does not expect you to build - rotors, rotor heads, wheels, motor, gearboxes, prop, brakes, seat tanks, instruments - since they don't have wings, ailerons, elevators, etc., most gyros are left with just a few areas you might be able to "fabricate". For instance a bolt together aluminum tube frame might come under "Fuselage" or "Empennage". Look over the proposed checklist to see what tasks might apply for a gyro frame - but for a "plans built" gyro I'd say a large % would be builder fab. But, for the "kit" gyroplanes, the manufacturer might not so readily risk faulty amateur welding, composite layup, tube bending or even drilling holes. The kit manufacturer probably has precision jigs or contracted CNC fabrication, or expensive autoclaves - they do this for producability, for stength, weight and performance. With so much of these high tech aircraft going to the fully-built market outside of the U.S., the U.S will just be SHT (Sucking Hind ----) to the rest of the world! Already European aircraft manufacturers are re-thinking whether it's worth it to try to provide kits just for the U.S. - Xenon, Magni, ELA, MT03 - just to mention the gyro world!
"Intent": Do we really know what the "intent" of the 1987 "Education and Recreation" rule really is or was? When they say "education", shouldn't the "intent" be for safety? I suggest there is high (safety) "educational" value in installing an engine, flight controls, fuel systems and instrumentation - "Assembly". And, there is high "educational" value in tuning, calibrating and flight testing - but the builder doesn't get credit for these highly educational areas! These critical areas might not have much "fabrication" - and is cutting, filing, drilling, sanding and painting any real value to safety! I doubt the intent was just to make people pay their dues with dirty hands that had no safety value. Does the FAA really want each builder to get an education in Tig welding or composite lay-up - especially if that "fabrication" done by a one-time amateur instead of a skilled craftsman or precision tool, might actually compromise safety? The intent of the original rule, IMHO, was not, or should not have been to "fabricate" just for the purpose of getting your hands dirty. The "education" part should have had, and should have the intent of education in knowledge elements that actually improve aviation safety (preflights, maintenance, inspections, repairs, problem recognition and resolution, decision making, etc.) Not to mention an actually safer aircraft when built from quality parts to the engineering standard intended for those parts.
- Thanks, Greg