FAA 51% rules change - Important

[gyrogreg]

I'm not sure the rotorcraft community is aware that the FAA has proposed changes the Experimental Amateur Built (E-AB, 51%) criteria. The proposed changes can severely affect the advances in sport rotorcraft safety and technology that have been made in recent years:

The Docket number is FAA-2008-0823-0001. The change is to REQUIRE that at least 20% of the FABRICATION be accomplished by the builder. This presents difficulties for other aircraft types, such as the "glass" airplanes from Europe. The EAA had argued against these changes, for some of the same reasons I outline below, but the FAA has moved on with these proposed changes anyway!!!!

The docket is currently open for comments - but only until the end of September!! I believe we urgently need the Experimental Rotorcraft community to respond. I believe the impact on experimental rotorcraft has even more severe consequences than a lot of what the EAA is arguing for airplanes is.

The main issue is that it is very difficult to find at least 20% of the FABRICATION of an experimental rotorcraft KIT that the factories are willing to allow the builder to fabricate. (The rule also proposes that at least 20% of the ASSEMBLY be accomplished by the builder. For the kits I've considered with the proposed 51% checklist, the ASSEMBLY is not a problem - easily more than 51% of the ASSEMBLY is done by the builder. But, the story is much different for rotorcraft kits on the FABRICATION percent by builder!)

Rotorcraft, gyros and helos, have very few components that do not require precision, skilled and reliably fabricated parts. (Traditional airplanes have wings and empennage, etc. that can more easily and safely be fabricated by builders. Even some of the new high-tech composite airplanes do not lend themselves very well to even 20% builder fabrication!)

Many of the available gyroplane and helicopter kits were designed to be fully-built in a factory with skilled and precise fabrication to make the assembly cost effective and safe. That means that components are engineered for precision fit with careful control of weight and strength, etc. For these aircraft producers, especially from foreign factories where KITS are not required, probably including Magni, Xenon, ELA and MT03, it would probably not be practical to "down-design" kit components that would allow for less precise and possibly less reliable components to be fabricated by a builder – just to satisfy this 20% fabrication requirement in the U.S. The U.S. is the only country whose rules REQUIRE that sport rotorcraft be built under these rules - cannot be purchased fully-built! I'm not even sure that some American kit gyros, such as Air Command and Sport Copter could qualify for the 20% fabrication! If this rule goes through, it may set back the sport rotorcraft industry and safety in America more than a decade! The FAA Rotorcraft Directorate on the other hand (that doesn’t talk to the other hand) has commented that they are encouraged by the developments they are seeing in sport gyroplanes – the SH, Magni, Xenon, etc. These recognized advances would be stopped dead if these important kits were no longer available in the U.S., at least not in their mature and safely fabricated form!

To make matters worse, the FAA does not consider this change to be a RULES change - it was purposefully not published on the normal REGULATIONS.gov comment website. It is even difficult to find documents that detail what the FAA is proposing. Attached here are four pages of the new proposed 51% checklist. Also attached on the second post is the summary of the FAA proposal – not easily available otherwise! I consider must be reviewed to even realize the impacts of the proposed change - not available easily on the web or anywhere else!!!!

The following posts are comments that I have made to the FAA. Until I brought the REGULATIONS.gov comment website to the attention of FAA coordinator Miguel Vasconcelelos, he was not even aware that the proposec changes were even posted on regulations.gov!! Comments MUST be emailed to [email protected]

If you agree with my concerns about the impact on availablility and safety, I hope you will compile your own comment and send it to the FAA ([email protected])

[I apologize for the resolution of the attachments - it is difficult to convert the FAA doc to a size that can be attached to the forum.]

- Greg Gremminger

 

[gyrogreg]

Comment 1

Comment 1

FAA-2008-0823-0005 Greg William Gremminger 08/26/2008:

Comment:
I have not been able to find the proposed changes documents. I have a copy of Fig 9-3, apparently the proposed new checklist.

The checklist instructions say all 187 tasks should be counted. But, many of the tasks do not apply to Rotorcraft and other non-airplane aircraft. It appears that tasks cannot be considered NA. Can "NA" be applied to tasks that do not apply - 0therwise there is no way to get to 51%. The instructions need to at lest clarify this.

On each Tasks category, there is one line for "Additional Items". Could additional tasks be added - for non-airplanes? How would we add more than one "Additional Task". Would we have to add enough tasks to equal 187 total?

There really does seem to be poor consideration in the development of these tasks. Seems to be developed or applied to airplanesonly (previous checklists at least included some Rotorcraft Tasks). And then, it appears that there is overly detailed breakdown of some airplane parts - such as every internal and external component of wings and stabilizers, etc. Some construction does not have all these parts - such as fiberglass or molded control surfaces, stabilizers, etc.

Including so many "fabricate" tasks, in my opinion could encourage unsafe practices. Many of these "fabricate" tasks would much more safely be done by skilled factory workers using proper tools, molds, processes, QA equipment and processes, etc.

The "Education" part of the E-AB definition should be education on things that improve safety without compromising safety - knowledge for good decision making, inspections, maintenance, operation, etc. Such minute detailed breakdown to internal wing and tail surfaces is little value to education for safer pilots. The real education items that are valuable for safety include assembly of parts, adjustments and rigging, controls assembly and adjustments, engine installation (controls, cooling fuel, lubrication, etc.), instrument panel assembly, wiring, checkouts, Phase I testing, etc. Focus on so many minor "fabrication" tasks does not add to safety education and could result in unsafe aircraft.

The Regulations.gov website is difficult for me to use - could never find the actual proposed changes, links take you in circles or return "invalid host" error messages. If this is a common difficulty, those problems need to be changed and the comment period extended. The site made me almost quit trying - over several hours of trying to find the changes to comment on!! I finally decided to comment on the checklist someone sent out!

 

[gyrogreg]

Comment 2

Comment 2

FAA-2008-0823-0008.1 Greg William Gremminger 09/02/2008 :

Comment:
Point 1 – 20% fabrication:
I feel a requirement for any builder fabrication will severely disadvantage American builders and producers. Many aircraft producers around the world are applying evolving fabrication technologies that are furthering aviation safety, performance, and reliability. Such technologies, such as composite construction, welding and materials require skilled workers, special controlled processes, tooling, and even testing to assure proper and safe application of these involved technologies. This proposal to require even a minimum
fabrication percentage seems to be an effort to salvage an outdated 20 year old rule. The original 1987 14CFR 21.19(g) does say “fabrication AND assembly”. But, that did not anticipate such advances in materials and processes that are growing beyond safe amateur fabrication and application. Rather than try to salvage an outdated rule for outdated reasons, this proposal should update part 21.19(g) criteria to substitute fabrication tasks with tasks that focus on educational values that do not limit American aviation to 1987 technologies. The future is bright for applying even more advanced materials, components and fabrication technologies to aviation; and the homebuilder and providers are often at the forefront of such advances. The U.S. should be at the forefront of these advances, rather than sticking with a “fabrication” paradigm that unnecessarily limits American advances. The rule should be adjusted so as not to discourage the application of such technologies in the U.S while the world moves on to more advanced technologies. A requirement for “fabrication” of any components can limit future innovation and advances in America.

Many new technology aircraft, welded airframes, composite wings, tails and control surfaces, are incorporated into fully-factory built aircraft in countries other than the USA. Those fully-built producers optimize fabrication to exacting standards for productivity, cost, weight and performance while enhancing structural reliability and safety. To provide that same aircraft in a kit form that requires even 20% of the components to be “fabricated” by an amateur often would require complete re-design. In many cases, the extra costs and re-design, and to provide a safe and reliable builder fabrication level prevents those safer and more efficient designs to be imported into the U.S. In other cases, liability concerns with inferior amateur fabrication might discourage marketing such a kit in the U.S. It is likely that such re-design to accommodate outdated Experimental rules would raise the cost of such kits beyond even the available factory built costs – the traditionally lower cost for a kit is a major incentive for builders to purchase a kit, and such kits have been a significant portion of the American aviation community.

Even if a re-design for kit distribution is not required, the amateur fabrication of critical components such as internal wing or airframe parts adds unnecessary risk when that fabrication is not to the standard required for the design structural integrity – such as mis-drilled, oversized or elongated holes as stressor points, improperly cured resins, etc. With today’s emphasis on efficiency and safety, focus on “fabrication” adds unnecessary safety risk to an E-AB kit version of a production aircraft. With the advent of SLSA in the U.S.
and the fully-built market in Europe and elsewhere in the world, even domestic producers would likely be discouraged from E-AB kits – a major component of the sport aviation market due to a historically less cost. Re-design of a proven fully-built aircraft to a kit form with any required fabrication would likely raise the cost of that kit substantially – since the U.S. is the only place in the world where that version would be marketed.

In this world of higher volume producible aircraft employing sophisticated high tech materials and fabrication processes, E-AB kits should eliminate the builder fabrication requirement and focus more on assembly and checkout. I suggest that the intent of Part 21.19(g) for educational purposes should be a focus on the education that is important to safety. Fabrication skills becoming more and more sophisticated but are a less and less important element of pilot knowledge and safe decision making – unless that pilot has safety or reliability concerns about their own fabrication of internal critical components. Pilots should not need to have doubts because they made that part and can’t be sure they did as good a job as the factory does. Real education toward improved safety IS gained
in the assembly of critical components and systems in the aircraft. Assembly and alignment and tuning are much more important in the education for safer aviation knowledge and decision making. Engine installations, fuel, lubrication, electrical and control installations and alignments provide knowledge that applies directly to safety of operation and maintenance. Instrumentation and wiring and connections of such are valuable safety educational tasks. Checkout and flight adjustments and evaluations are all much more critical activities than fabrication of parts that risk safety if not accomplished to the standards more reliably achieved in a factory by skilled workers with proper tools and processes and experienced inspectors!

The proposed EA-B “Fabrication and Assembly Checklist” (attached) lists many internal structural fabrication tasks that are often not even included on many aircraft types or in certain fabrication technologies – such as one-piece welded airframes and molded flying surfaces and components. I suggest substituting more safety education related tasks such as engine checkout, instrument panel and engine wiring, plumbing, controls, etc.

Point 2: Overly focused on AIRPLANES:
The fabrication requirement and the proposed new checklist with the many fabrication tasks are obviously focused on traditional airplane construction – to the neglect of other aircraft categories. Other aircraft types, such as rotorcraft and Weight Shift are at a noticeable disadvantage with the proposed “fabrication” requirement. These aircraft have very few components where, for safety and reliability reasons, amateurs should not be the fabricators. Rotorcraft do not have wings. Powered Parachutes and Trikes do not have
traditional wings, or wings that should be fabricated by an amateur. One-piece metal or composite frames and structures are reliable and efficient and repeatable for production efficiencies. Professional Tig or Mig welding is becoming more common for airframes. Exotic composite materials are in growing use in airframes. None of these skill and process involved fabrications should be left to inexperienced amateurs, especially without the proper tools and processes. Even some of the newer all-glass aircraft might have difficulty safely meeting a 20% builder fabrication number.

Rotorcraft, Helicopters and Gyroplanes, would especially have difficulties with any builder fabrication requirements. Very few components, including the airframes, can risk failure because the requisite quality of fabrication might be missing. More and more application of carbon fiber and other composite materials for reliability, weight, performance, durability and fatigue life are being employed. Critical components such as rotors, propellers, engines and rotor drive train components are also not be required for builder fabrication. That does not leave much, if anything for the builder to fabricate! But, builder ASSEMBLY is a much more valuable safety educational experience than
attempted fabrication of components – including airframes and stabilizer surfaces that are at a minimum, weight critical. For gyroplanes, the advent of more use of light composite stabilizer surfaces has advanced safety considerably – such as in newer models from Europe. Especially since even SLSA (or ELSA) versions of rotorcraft are not allowed, E-AB kits of these models are the only option. However, it is difficult to achieve even a 10% builder fabrication goal for kit rotorcraft – and even that may compromise safety.

I suggest the fabrication requirement for rotorcraft, PPC, Weight Shift and fiberglass construction airplanes be eliminated. Other educationally important assembly and checkout tasks should replace the builder fabrication requirements.
Additionally the proposed EA-B checklist (attached)should be adjusted to identify and accommodate tasks that are applicable to aircraft other than traditional AIRPLANE construction.

- Thanks, Greg Gremminger
Attachment: 51% checklist - new

 

[gyrogreg]

Comment 3

Comment 3

FAA-2008-0823-0007 Greg William Gremminger 09/02/2008:

Comment:
This was my second attempt to find a way for commenters to actually review the details of this proposal. I have not been able to find any such details from this site comment site - commenters need the details in order to formulate comments!

I did receive three documents from an email request to Mr. Miguel Vasconcelos ([email protected]). I suggest that until better sources are available otherwise, commenters should email to Mr. Vasconcelos to request detail documents - more details.

The three documents that Mr. Vasconcelos sent me did not include the new proposed" Fig 9-3 Amateur-Built Fabrication and Assembly Checklist". This was missing in the documents Mr. Vasconcelos sent to me!! - Marked in Appendix 8 as "Insert Checklist when Finalized"!!!! I did get a copy of this checklist from other sources. I suggest this checklist is very revealing and should be part of the review by commenters.

This unavailability of review documents is a poor way to request comments. I suggest these documents should be clearly available on this docket, and that a full 90 day comment period should be started AFTER those documents are readily available. This is a very important and onerous proposed change. This needs good review and comments from users. I agree with a previous commenter that this appears to be a way to squeeze some onerous rules through the community - that is not the way we expect our government to do business.

I hope many others will take the time to prepare well thought out comments also. At this time, the deadline appears to be Sept 30 - not the 90 day comment period that should be applied to such a widely impacting rule change. My first opinion is that this rule change may set back aviation and Experimental aviation far behind what is going on in the rest of the world.

- Greg Gremminger

 

[chuter]

Greg,

Thanks for once again keeping on top of this stuff.

With only a quick look-through I didn't find a definition of "fabricate".

Is cutting an aluminum keel piece to length and drilling holes in it "fabrication"?:noidea:

 

[Resasi]

Greg the US gyro movement should be grateful that you are watching out for this, and will hopefully support you in your attempts to minimize the adverse effects of the proposed legislation.

 

[Mike Schallmann]

I know this will probably ruffle a few feathers --but so be it. I for one am FOR this --these are experimental aircraft !! Jeez we only have to fabricate 20 % of the aircraft--and ultimately assemble 51% of the aircraft. What is so unrealistic about that! What it means is that if you want to fly under the EAB rules you will have to get off your duff and actually FABRICATE (ie BUILD) an aircraft---

 

[RotorTom]

I know this will probably ruffle a few feathers --but so be it. I for one am FOR this --these are experimental aircraft !! Jeez we only have to fabricate 20 % of the aircraft--and ultimately assemble 51% of the aircraft. What is so unrealistic about that! What it means is that if you want to fly under the EAB rules you will have to get off your duff and actually FABRICATE (ie BUILD) an aircraft---

I do not agree. If the real goal of the FAA is to enhance safety, then professionally built parts, components and even entire aircraft do not present a danger. But SAFETY is NOT the reason for this regulation.

The real purpose of the 51% rule is to keep people from "short-cutting" the certification process. They do not want to relax standards to a point where people will start building and selling planes as "experiential" rather than going through certification.

Here is my problem with that thinking: Why shouldn't anyone be able to build an aircraft and sell it? So long as that aircraft is safe and sound and has been inspected!

If safety is our goal, then let's change the paradigm completely. Instead of calling it "Experimental", why not call it "Non-Certified".

Simply make it mandatory that "Non-Certified" aircraft must be built using certain standards and they must be periodically inspected while being built.

Wouldn't it be better to have a DAR inspect the aircraft while it is being built? And sign off each stage before construction can continue? Then anyone can buy an aircraft in any stage of construction and know where they stand. It would not matter who started it, who took it over in the middle and who finished it.

Right now, the system sucks and the new rules won't make it any better. Right now, a DAR doesn't even look at the plane until it is done. There is not a DAR alive who can truly certify an aircraft is airworthy without knowing what is on the "inside" -- especially with composite construction.

Most people answer a few questions and show a few photos and the DAR assumes they built it. Why not take all the guess work out of it.

Don't PRETEND the owner is building everything. Simply admit that some people like building things. And they may get help. Hold them to a standard, inspect them regularly and let them have at it!

"NON-CERTIFIED" IS THE WAY TO GO.

 

[Heron]

Please someone tell me what is better: a part fabricated by an amateur in its backyard or the same part made in a specialized shop?
Most experimentals are put together with parts over the counter and made to order or customized.
In the assembly line of a factory, the workers are trained to do the best job. Why not replicate that in home built?
Heron

 

[gyrogreg]

With only a quick look-through I didn't find a definition of "fabricate". Is cutting an aluminum keel piece to length and drilling holes in it "fabrication"?

In the proposed Draft Advisory Circular, AC 20-27G, the FAA defines Fabrication:
Note: The FAA defines fabrication “to construct a structure or component from raw stock or materials.” This excludes rebuilding or restoring activities. Go to Draft AC 20-27G

Take a look at the "tasks" in the proposed checklist. The allotment of credit for a task is different than the previous checklists. On previous checklists, there was a simple check box for either builder or manufacturer - it was 100% or nothing. Then, you simply counted up the check marks in each column to come to at least 51% of the check marks for the builder. Even the FAA inspector (the one that approved the 51% kit for the Magni M16 and M14) found justification to credit 100% of "fabricate" items to the builder - even if the builder only drilled out pilot holes in the welded steel airframe! So, even with the old checklist and the FAA's 51% approved letter, it was doubtful than many kits actually had 20% fabrication done by the builder.

The new proposed checklist is different - you can allot a percentage of each task to each of the columns. You may be able to convince your DAR that drilling out some pilot holes counts for some % for some items, but the FAA definition of "fabricate" in the AC could be interpreted that drilling pilot holes does not count at all!. So, the definition of "fabricate" and the percentage alloted may be in the eyes of the DAR. I would make the claim that any material or component cutting, drilling, painting, filing, etc. might apply some part of that fabrication to the builder. But, for instance, in the fabrication of a precision TIG welded part or airframe, would drilling out some pilot holes be accepted as 20% of the fabrication? Considering the critical part of fabricating that part is the quality of the welds, the precision of the material and jigs, and the precision of the holes - that's hard to claim to be ony a small bit of the fabrication - but it is probably seen by the engineer as critical to be done right!

Note, it is not such a simple matter for a factory, that fabricates components to productively "bolt together", to drill "pilot holes" instead of the normal precision hole. Even pilot holes require tool changes and add to cost over just drilling the designed hole for factory assembly! For higher production aircraft, components are likely to be out-sourced with specifications to assure fit on the factory assembly line. Just changing the specs for a kit component that does not have the same finish work adds to teh cost and discourages Engineers from risking such down-engineering.

Take, for instance a composite flight surface - rudder, tail parts, enclosures. Most quality composite parts are done with a surface gel coat and requires very little work to fill and paint - and most people hire a professional painter to get a good job anyway. And, how much of the fabrication credit would a DAR be willing to give the builder in light of the skilled work and special tooling and materials that goes into laying up a strong weight critical part. Technology is moving to lighter and stronger materials such a Kevlar and Carbon Fiber - what aircraft Engineer wants to count on the builder doing this right - or TIG welding right. And, what safety or educational value is there in filling and sanding and painting parts, or drilling out pilot holes! Providers of kits that travel from overseas would prefer to protect their steel parts from corrosion by applying paint, or at least primer.

I'd say that cutting a tail boom from raw tube stock and drilling holes could be counted as 100% fabrication. But, not all kits allow this - mainly because the Engineers and factories might want to be sure it is done right - without score marks on the inside of tubes, without stresser points, without oblonged holes to fit, etc. Then some aircraft, to improve performance, weight and durability are designing structural members in 4130 or Stainless steel - where quality of weld joints are critical. Some are using composite materials for landing gear, etc. The day is not far off when we will likely see carbon fiber airframes - technology advances, but the FAA is stuck in a 1987 amateur "fabrication" concept! How many aircraft producers would want to risk uncontrolled fabrication flaws to sell KITs in the U.S.? Do you think a producer who has designed for safety would want to allow an amateur to build a fuel tank?

Do keep in mind that the FAA does not include engines, rotorheads, instruments, propellers, rotors, gearboxes, wheels, brakes, etc. in the count of what the builder must build OR fabricate. On any gyro or helicopter (or PPC or Trike), what is left? - airframe, tails and rudder and a few miscellaneous items such as lights and instrument panel.

My point is, do we want to eliminate advanced sport aircraft designs in the U.S., where they are proliferating in non-KIT countries? Do we want to risk inferior structural integrity or reliability and increased costs to meet an arbitrary "fabrication" requirement? Is fabrication of components as valuable to the safety "education" and recreation purpose as assembly of controls, instrumentation, engine installations, etc.? I think this can discourage U.S. technology advancements in use of materials and processes that have already advanced the gyro world - look at the ELA and MT03 that have applied Stainless steel to their airframes and cut the weight significantly! Or the Xenon that is displacing a standard air"frame" with cutting edge composite technology.

It seems to me that the focus of this rule change is the traditional construction of AIRPLANES. Look at the checklist - there are a lot of tasks assembly of wings, etc. - traditional wings! For rotorcraft, where very few of the components can afford to be less than professional quality, it is much more difficult to find components that can safely and practially be fabricated by the builder. But a large percentage of a rotorcraft construction can be attributed to "ASSEMBLY" of those parts. In some of the check sheets I've attempted to fill out for aircraft I've built ranging from ultralight FW to several gyroplane "kits", it is not hard to achieve over 51% of tasks for the builder - mostly "ASSEMBLY" tasks. But, it is rare that I can find or justify listing even a few % of the tasks in the "FABRICATE" column - especially for gyros and helicopters. Try it yourself to see how it works out for your favorite kit rotorcraft.

- Greg

 

[gyrogreg]

I for one am FOR this --these are experimental aircraft !! Jeez we only have to fabricate 20 % of the aircraft--and ultimately assemble 51% of the aircraft. What is so unrealistic about that! What it means is that if you want to fly under the EAB rules you will have to get off your duff and actually FABRICATE (ie BUILD) an aircraft---

Hi Mike. Thank you for your input. This "policy" change will likely not affect the "scratch" gyro builder. And we do certainly want to encourage such experimenting. But, not everyone is a scratch builder or has confidence in their own abilities or have the equipment or tools to do fabrication, much less design. I don't think we want to limit our sport to just a few "scratch" builders. And, any standard proven design with professionally engineered and proven reliability and strength, will likely not be improved in safety and reliability if the builder does some of the more critical fabrication themselves. And what aircraft producer or engineer is going to readily say - OK you can fabricate these critical parts?

But, all opinions are welcome and I do think you should send your thoughts to the FAA. But, before you do, please do me a favor and fill out the tasks checklist for your favorite gyro. I'm sure you could meet 20% fabrication for a plans built Bensen - maybe, considering the parts you will probably purchase ready made anyway! But, also try it for your favorite kit gyro - say SH or RAF or Air Command too. Let us know, in each case, where you were able to find 20% of the fabrication for the builder.

My look at this suggests that 20% FABRICATION" is a killer for the kit rotorcraft market and technology. My recommendation to the FAA is to eliminate the 20% fabrication requirement, but stick with the overall 51% construction. I would like to see some credit also to the tuning and adjustments of flight controls and systems - real safety educational value - not just fabrication and assembly!

Thanks, Greg

 

[Mike Schallmann]

Xenon Tom --- the three letters EAB define it all EXPERIMENTAL AMATEUR BUILT -I dont see the word PROFESSIONAL anywhere in that. I really pretty much like it the way it is and the way it was originally intended.

The problem is that it has gotten a lot out of hand in the last ten years or so--I realize that the world changes and that new technologies alter the way products are made--but that in no way should affect the rule of EAB--wanna use these new technologies in an aircraft --well petition the FAAfor a NEW catagory --its a relatively painless process - it should only take about 10-15 years or so ---

You are slightly biased in your opinion as you are Promoting a commercially built gyro --why not press the Xenon company to type certify the gyro so they wouldnt have to try and slip in the back door with their products-- Im not against type certified gyros or even comercially built gyros --but they dont need to be in the EAB catagory!!

EAB was implemented for the person who wanted to get his hands dirty and actually build an aircraft. He could design it or buy plans and build it -- the entrepreneurs came along and designed kits that met the letter if not the intent of the rule--this worked
OK for quite a while -- but it got out of hand and now the FAA is reining it in --as it should--some technologies are not adaptable for the majority of the AMATEUR builders--but there are a great many AMATEURS that are capable of learning these technologies and use them in their quest for an AFFORDABLE aircraft--

BTW --I have actually FABRICATED and built two FW Aircraft and three gyros, including the making of redrives and rotorheads --I admit I havent built a set of blades --yet ! But if it becomes a requirement I will ! This in my opinion is what EAB is ALL about--want something different --read para #2 above--

 

[RotorTom]

No one is denying the way it WAS and IS. But times change. If you want to built it 100% yippie for you. If someone can get professional help -- big deal! The MOST IMPORTANT THING IS THE INSPECTION PROCESS.

No one is going to "slip through the back door" as you put it. Single built, individually inspected aircraft can never compete with certification -- and they shouldn't! That is NOT what I am advocating.

As an aside ... I do not know what you mean when you say I am hawking the Xenon?

I run a website for owners. I am not selling them, nor am I selling mine. I am not hawking anything!

 

[gyromike]

And, any standard proven design with professionally engineered and proven reliability and strength, will likely not be improved in safety and reliability if the builder does some of the more critical fabrication themselves. And what aircraft producer or engineer is going to readily say - OK you can fabricate these critical parts?

Actually, didn't Burt Rutan do exactly this when he started selling plans for aircraft built with moldless composite construction?
I have a set of Long -EZ plans and Burts moldless composite construction handbook. This was cutting edge back then, yet thousands of aircraft were built with this technology before kit makers jumped in. People are still doing it 'old school'.

The whole purpose of EAB was for education and recreation.

Learn the skills.
Build the parts.
Fly the plane.

 

[scottessex]

Looks like the FAA is here to help.......

I understand the nature of the rule, but the reason the builder assist and quick build kits exist is that most people do not have 10 years to build an aircraft.

But again why are LSA aircraft allowed, and no LSA rotorcraft?

the FAA needs to be specific in the rotor craft catagory.

 

[Russ Hobbs]

Greg, I personally want to thank you for calling attention to these changes, I am building a Dominator and it will have modifications to both the air frame and the engine. Could I build this thing from scratch with my abilities, nope. But with a little help along the way and a well designed machine to start with, I can hopefully realize my dream to fly. Make it any more difficult and I wouldn't have even considered building my own an option. Building is half the fun to some, and an obstacle to others who's real passion is to fly the darn thing.

 

[scott heger]

Mike S, most of us , including me,don't have the skills, tools or brains to fabricate 20 % of a gyro. Your gyro gets broken ,you make new. Most of us are fine with ordering parts to fix items. Look at the flight line at a gyro gathering, and I would guess you are going to be the one a just a couple that would qualify as a 20 %fabricator. You mentioned that a SportCopter would probably not qualify, I agree. The only part of the machine I fabricated was the wiring and making of the instrument panel. I don't do rotors, motors, switches, radios etc powder coated aluminum tubes, etc. I still consider "my" gyro as my creation. Letting the FAA fatten up the rulebook with new regulations will further destroy homebuilt aviation. Great inequalities are going to occur if this rule changes. You will get guys that get a pass from local inspectors, and others that will be put through hell. It just encourages more cheating of the system, not less.

I like the rule just the way it is. I built my gyro, and the only thing Sportcopter assembled was the rotorhead. I was never questioned beyond filling out a declaration that I built 51% or more. No pictures, no logs , nothing. Same for my repairmen's license,maybe I just look honest. I guess some builders get questioned a lot about what they built, but I am hardly putting together a glass cockpit jet aircraft, and telling the FAA I did it all in my garage. I understand the FAA's concern as kits can be a million dollars or more in some cases. I still think the factories should be allowed to fabricate all essential parts with known quality materials that may not be available to the average amateur builder. If a simple SportCopter type gyro won't pass muster, not much else flying would either, and certainly no EAB helicopter.I don't think many people are interested in flying a individual's 20 % fabricated helicopter, as a current helicopter owner, I certainly would not. Way too much to go wrong. Rotorway and Safari might as well shut their doors if this rule becomes law.

Scott Heger,Laguna Niguel,Ca N86SH

 

[gyrogreg]

Send your comments to the FAA

Send your comments to the FAA

Keep the conversations going. This is a good way to formulate your opinions. I hope you will send your comments and suggestions to the FAA. - Greg

 

[Mike Schallmann]

Im sorry that the kit manufacturers are going to have such a tough time in dealing with these changes -or should I say being required to comply with the intent of the regs. But lets face it we only have to fabricate 20% that LEAVES 80% that can be professionally fabricated, and if we assemble the professionally fabricated parts with our own fabricated parts we will meet the letter and intent of the rules.

As to my favorite gyro --well I like the SH and I think that 20% of it could be fabricated by the builder --but it would do away with the easy/quick build parts. Quality control would have to be maintained by the builder -but this is not insurmountable. BTW my favorite gyro has yet to be built -the design is still floating around in my head---Scott I dont think I mentioned any specific gyro -other than the Xenon--( a nice gyro -BTW )Tom --I m editing my previous post from "hawking " to "promoting" Also Scott dont sell yourself short YOU do have the skills and ability to scratch build a gyro --you may not have the tools -but they can be bought --what you dont have is the TIME --

The average homebuilder is quite capable of fabricating 20% of the parts in a gyro --this IS a time consuming process and has a pretty steep learning curve --but that is what this is all about. You dont get instant gratification if you are a homebuilder --you get a hell of a lot more --a sense of accomplishment

 

[Resasi]

Mike although I sincerely wish I was over with my son getting more time doing our home build project together, which is pretty much a scratch build. I do know that he is loving the process and will no doubt get the pride of accomplishment, mine will have to come if I can fly it.

There are certainly good points to be made for home building. However there are those who would prefer to leave the quality control to the factory and assemble rather than fabricate from scratch, as admirable and rewarding as that might be. Either through not having the time, inclination, or the skills. Especially for the more complex Gyros that are out there like the Xenon and Magni.