'Commercial Builder's Assistance' Under Review

[Don Parsons]

This will be worth keeping up with...

http://www.aero-news.net/index.cfm?ContentBlockID=84d3185a-26d1-4173-a6cf-180d8fae7cbb

DP

PS: If the above URL does not work for you, I have set up the following
shorter URL as a backup.

http://tinyurl.com/n3k78

[Bret Ludwig]

Don Parsons wrote:
> This will be worth keeping up with...
>
> http://www.aero-news.net/index.cfm?ContentBlockID=84d3185a-26d1-4173-a6cf-180d8fae7cbb
> 'Commercial Builder's Assistance' Under Review

Mon, 07 Aug '06
FAA Charters Panel To Discuss Changes To 14 CFR 21.191
News and Analysis by ANN Correspondent Mark Sletten

The FAA has decided to review the requirements of 14 CFR 21.191, the
rules regarding amateur-built aircraft. According to FAA Order
1110.143, dated 07/26/2006, current guidance on the subject of amateur
built aircraft has not kept pace with technology or the market. The
order directs the formation of a committee to assess the current rules
and, if necessary, recommend new ones.

You may remember last year's dustup between Aircraft Investor Resources
(AIR) and the FAA when their first Epic LT customer was initially
denied an experimental Airworthiness Certificate. The Epic LT is a
complex, 6-pax, turbine-powered aircraft built of composite materials.

After requiring both AIR and their customer to provide additional
documentation regarding the build process, the FAA did begrudgingly
grant a certificate, but one has to wonder if that experience started
the slow wheels of bureaucracy turning toward a recent look at the
industry, at large...

The meat of 1110.143 charters the yet-to-be established committee to
define commercial assistance within the strictures of the traditional
51% rule. Additionally, the committee will "identify and define the
regulatory, directive, and policy changes needed for the FAA: to
perform oversight of builder or commercial assistance; to convey to
applicants their responsibilities when using builder or commercial
assistance; and to convey to the providers of builder or commercial
assistance their responsibilities to the applicant and the FAA."

The FAA will select the committee membership from "industry
associations and/or organizations" with AIR-200, FAA manufacturing and
engineering field representatives, AFS-800, AFS-300, EAA, and Kit
Manufacturers specifically mentioned. As for public participation:
Unless you are a committee member you must get permission to attend any
meeting. Public comments to the committee must go through a committee
member.

Why all the fuss? Frankly, some of today's kit aircraft are capable of
remarkable performance, which can be had at a fraction of the cost for
a comparable certified aircraft.

A fully-loaded Columbia 400SLX is slightly less than $600,000. A
Lancair ES-P fast-build kit (an outwardly similar airframe to the
certified Columbia) is $112,500; throw in another $200,000 for an
engine and avionics, thousands of hours of sweat equity, and you can
have Columbia performance for slightly more than half-price (not
counting your labor) - pretty appealing for someone willing to work for
it.

In the pre-Rutan era -- when the current rules were established --
carbon-fiber and glass-foam-glass construction techniques allowing
complex, aerodynamic shapes (and those oh so sexy curves) were
impossible. Mix modern construction with a turbine engine and one can
bake up a fire-breathing, pressurized, 400 knot dragon that can easily
carry 6 or more people -- at least that's the fantasy for some
builders!

The reality is only the most knowledgeable and experienced of home
builders possesses the requisite skills to complete this fantasy
project. Realizing this -- and that many builders are frustrated with
the length of the build process -- some kit manufacturers and
commercial enterprises have obligingly offered "builder's assistance."

The strategy is that with assistance fantasies can be fulfilled; you'll
get your kit completed in less time and always have an expert at hand
to help when necessary.

All of this "helpfulness" begs the question: Can one complete a project
of this scope without assistance? That, apparently, is what the Feds
want to know.

While no specific accusations have been made, the fear seems to be that
some "wanna-be" airplane manufacturer might try to "game the system."
Specifically, a manufacturer without the means (or desire) to go
through the aircraft certification process might circumvent it by
marketing and selling an aircraft as a "kit" of such complexity that
you must build it at the factory.

Obviously, this would not be in the best interest of public safety, and
would unfairly disadvantage legitimate aircraft manufacturers that
follow the rules -- not to mention jeopardizing a long-standing rule
that allows one the freedom to build one's own aircraft.

[Bret Ludwig]

Bret Ludwig wrote:
> Don Parsons wrote:
> > This will be worth keeping up with...
> >
> > http://www.aero-news.net/index.cfm?ContentBlockID=84d3185a-26d1-4173-a6cf-180d8fae7cbb
> > 'Commercial Builder's Assistance' Under Review


Hallelujah!!!! Help is on the way!!!


A homebuilt should be just that-something built from a set of plans in
a residence or garage by an individual on a not for profit, personal
recreational and educational basis. A kit of materials with limited
preforming is OK, provided the kit is optional and does not impede the
necessity of the builder mastering all needed skills to build the
airplane.

Get rid of the quick build programs, get rid of the hired guns and get
rid of the de facto factory built aircraft using Experimental Amateur
Built as a dodge around type certification.

Yes!!!