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piperrocks2013
10-12-2017, 07:44 PM
And two others that I know of.

There are a few differences between what I'm doing and Eddie's wing. First is the spar splices, aileron and flap spar splices, trailing edge splices. Single flap hinge per flap. Wing tip.... which I'm a bit concerned about... I feel the need for the wing tips with the fence...a squared off wing tip will reduce the effectiveness of the outboard end of the aileron. If the wing tip can't be installed.... will need to get some engineering help with spar reinforcement.

Nothing in my wing build is spliced together, the leading edge and false spar metals are .020" not the original .016" The additional flap hinge per flap is an insurance policy. I have on occasion pulled the first notch of flap above the white arc on the airspeed indicator.

I think the only other modifications that are non standard is the seat belt retractor mounts, belly pan at the tail, additional structure at the tail, the entry steps I added to the landing gear duplicating the re-fueling step, USB power supply for the Stratus 2 and iPad, fly pad mount, dual impulse couplers, starter solenoid, key/start switch, and a switch operated master solenoid. It's still a Pacer.

I will be moving the access to the aileron turn buckles/flap mechanism. Instead of round or rectangular covers on the bottom side of the wing I'll modify the tank bay false spar to gain access through it with flush covers. And where ever I can...install counter sunk nut plates and flush rivets.

The stall fence mount structure will differ from what Charlie Center supplied with the leading edge cuff kit...and I haven't decided if I'll install Charlie's gap seals... if I do they'll need drain holes... can imagine a rain shower...then freezing temperatures... not good.

One big reason I'll not take the experimental route is insurance... can't insure any experimental aircraft in Alaska....if is moving.



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did not know that about Insurance. In Canada OM category aircraft don't even change rates.

Gilbert Pierce
10-12-2017, 08:10 PM
Certified parts in any form don't count toward rhe 51% rule foe amateur built. The best he could get would be Experimenral Exihibition.

wyandot jim
10-12-2017, 09:30 PM
Certified parts in any form don't count toward rhe 51% rule foe amateur built. The best he could get would be Experimenral Exihibition.

Gilbert,
I don't believe that anybody on this Forum understands what the 51% rule really is.
I know I don't, but what I do know is that you do not have to build 51% of the airplane. You can satisfy the rule by WORKING on 51% of the parts. Cub Crafters has pretty much defined this with their builder assist program.
For instance my Grandson went to Cub Crafters last July to build a FX Cub for a dealer friend of ours because he didn't have the time to do so. Grandson was there for 5 days and his name will be on the data plate as the builder after he goes back when the plane is completed. There are a lot of factory parts that count now days.

FWIW I don't understand how you can't get insurance on an EAB in Alaska with all of them that have to be there.

A newly announced Carbon Cub FX (http://www.cubcrafters.com/carboncubfx) builder's assistance program bonds builders to the intricacies of their aircraft because factory specialists walk them through each part of the Experimental amateur-built (E-AB) manufacturing process during a five-day construction session at CubCrafters’ Yakima, Washington, headquarters.
https://aopa-d.openx.net/w/1.0/ri?ts=1fHBpZD01MzcwNjYzMjF8cmlkPTYzOTA2MTVkLTkzYmQ tNGZlZi1iMWEyLWFjMzMxYzk3NGMzNnxydD0xNTA3ODYwNzk5f GF1aWQ9NTM4MzAzOTE3fGF1bT1ETUlELldFQnxhdXBmPWRpc3B sYXl8c3NpZD01MzcwNjY1Mjh8c2lkPTEwODl8cHViPTIwOTR8c GM9VVNEfHJhaWQ9MTk0MDFiNDYtYjhjYy00MmM3LWEwNGItN2U zMGEwYWNhOGI3fHJzPTF8YWlkPTUzODUxODcyOHx0PTF8YXM9M zAweDI1MHxsaWQ9NTM3ODI1MjI3fG9pZD01MzczNTQ2MzJ8cD0 zMDAwMHxwcj0zMDAwMHxhdGI9MzAwMDB8YWR2PTY0NzQ5fGFjP VVTRHxwbT1QUklDSU5HLkNQTXxibT1CVVlJTkcuR1VBUkFOVEV FRFZPTFVNRUdPQUx8bGl0PVZ8dXI9dFVLUXEwMUxRag

Jim Richmond, CubCrafters founder and CEO, explained in a press release that builders of the $219,900 Carbon Cub FX (http://www.cubcrafters.com/carboncubfx/index) begin with five eight-hour days on the factory floor working hand-in-hand with technicians to construct their Cub using steel, aluminum, and composite aircraft components. Then, CubCrafters assembles these customer-built components for a nearly complete Carbon Cub FX.
About 50 days later, builders return to put the finishing touches on their aircraft. They’ll spend one day completing final assembly and preparing for airworthiness inspection; another day is reserved for the airworthiness inspection, certification, and at least two test flights by CubCrafters test pilots.

Steve Pierce
10-13-2017, 05:39 AM
Cub Crafters has FAA approval for their builder assist as do other manufacturers. Is your grandson listed as the builder of that FX on the owner's paperwork? Nothing similar to 51% rule. For homebuilders their is a 51% worksheet and it specifically calls out not taking a certified airplane and making it an experimental with some mods. This was the cause of a huge split in the EAA very early on. "This Is EAA" by Duane Cole is a good read and covers the rif.

Gilbert Pierce
10-13-2017, 10:01 AM
Jim
In my opinion CubCrafters has been working FAA loop holes for years. You and I could never get by with the stuff they do.
An LSA CUB with a 180hp + engine and a placard that limits full throttle to x number minutes to satisfy the speed limit requirements. Really!

wyandot jim
10-13-2017, 11:31 AM
"Is your grandson listed as the builder of that FX on the owner's paperwork?"


Yes he is as far as I know. He is listed as an employee of the company.
No matter how you look at it, the FX is E-AB category same as my Starduster TOO. The BUILDING of 51% of that plane does not apply.
I assume that you can still build a Breezy which uses Cub wings, and tail surfaces. So all you build is a uncovered fuselage. Not much of the 51% pertains to it. And the list goes on and on.

I'm with you Gilbert. Same as some of the two place LSAs that you can't put two people and gas in. :-)

Rick-CAS
10-13-2017, 02:13 PM
FAR 21.191 Expermental Certificates:
g) Operating amateur-built aircraft. Operating an aircraft the major portion of which has been fabricated and assembled by persons who undertook the construction project solely for their own education or recreation.

From AC 20-27G:

Note: The major portion of the aircraft is defined as more than
50 percent of the fabrication and assembly tasks, commonly referred to as the “51-percent rule.” For example, an amateur-built kit found on the FAA List of Amateur-Built Aircraft Kits has 40 percent of the fabrication/assembly completed by the kit manufacturer. In order to be eligible for an experimental amateur-built airworthiness certificate and per the major portion rule, the fabrication and assembly tasks that may be contracted out (for hire) to another individual (or builder/commercial assistance center) needs to be less than 10 percent.

Converting a Type-Certificated Aircraft to an Amateur-Built Aircraft. The practice of performing alterations, repairs, and rebuilding of previously type-certificated aircraft for the purpose of obtaining an experimental amateur-built airworthiness certificate is not authorized under § 21.191(g). Such maintenance actions properly fall under 14 CFR part 43, Maintenance, Preventive Maintenance, Rebuilding, and Alteration. You will not receive credit for these actions toward fabrication or assembly. We will not accept applications for airworthiness inspections on such aircraft.
(1) This policy has been in effect since 1952 under section 1.74-3 of the
Civil Aeronautical Manual 1 (CAM 1), which specifically states that “structural components of other aircraft may be used [for amateur-built aircraft]; however, it is not intended that this provision be used to avoid obtaining approval of major alterations to aircraft previously certificated in another category....”
(2) You should use the normal supplemental type certificate process for modifications to these aircraft and they should be kept under their existing maintenance programs to ensure continued airworthiness

AC 20-27G is a pretty good read to explain the FAA's stand on this. Then you get to play with your local FSDO on their own interpretation of the rules.

wyandot jim
10-13-2017, 02:29 PM
I'm well aware of what is supposed to take place. Remember I'm the Guy that built a plane from a set of plans.

FAR 21.191 Expermental Certificates:
g) Operating amateur-built aircraft. Operating an aircraft the major portion of which has been fabricated and assembled by persons who undertook the construction project solely for their own education or recreation.

Seems like a WHOLE lot of folks are getting around this requirement. I know of three on our airfield. Two RVs and one Glass Star.

So tell me how you can BUY a complete airframe like a Smith Super Cub and call it E-AB.
Read the rules to me again :-)

We won't even talk about the Mono Cub ( you can probably find it on the internet) that won Silver and beat me out at Oshkosh. Yea mostly Cub Parts.

Found it for you. Now tell me again how you can't make a Certificated into an E-AB

http://www.airport-data.com/aircraft/N37PD.html

http://www.airport-data.com/images/aircraft/small/000/793/793151.jpg (http://www.airport-data.com/aircraft/photo/000793151L.html)

Rick-CAS
10-13-2017, 08:03 PM
Read my last sentence in my post above. Even if you follow the rules to the tee you still have to get the local office to play along the same page. My friends cliped wing Luscombe is a perfect example. He ran what he wanted to do by the FSDO office before he started just to make sure it was doable. They said that he had more than qualified to go E-AB at that time. Three years later when it was done they changed their tune. The tail is all new made from scratch only Luscombe parts are the hinges. The fuselage has four skins that are Univair replacement skins that are hydroformed the rest he made. Wings were cut down spars, hat sections, and cut down struts. All was documented as per the regs. The best he could do was put it in experimental exhibition. The amount of work done fabricating parts and assembling was far more than the RV-8 quickbuild that was being built at the same time. If he wanted to call it something other than a Luscombe it might have been a muddy path to an E-AB certificate. It all boils down to what the local interpretation of the law is.

Gilbert Pierce
10-13-2017, 09:16 PM
The mono cub above has a symmetrical wing airfoil. Not Piper. Elevator has a trim tab and no jack screw. Cowl and struts are different.

rsrguy3
10-13-2017, 11:34 PM
Sooo... Is it that the are the feds caving to CC because they are basically building a copy of a certified A/C in factory conditions? Or is it simply a case of corruption the likes of which ruined the medical reforms initial driver license intent... (I personally believe companies with LSA's to market helped to kill it). I seriously think the regs need to change. The original educational intent idea behind the eaa is a bit of a stretch today.... back then sure with all the certified a/c in production it made sense, that was a logical argument. Not so much today, with Vans, wag, heintz, stoddard.... etc. I mean HTG! What's the difference between a pile of CC parts, a pile of Stoddard parts, a pile of Dicks parts, or Bill, or Walter or Clydes? ... Nothing, all are proven designs, and the guys building them didn't fab hardly anything. Here's the difference, it wasn't an airplane before someone assembled it. I just think these rules are archaic and really do not serve the same purpose they did when Steve W. was doing what the rules actually were meant to support. Maybe instead we should ad a different classification for proven designs both certed and eab (like rv's etc) and just have some sort of set construction standard that can easily be inspected and approved. Oops, I just realized something.... that would increase the workload on our previous over worked beurocrats.... never going to happen.

rsrguy3
10-14-2017, 08:49 AM
This feels like an out of thread experience. ...lol

Rick-CAS
10-14-2017, 08:54 AM
I agree with you!

dgapilot
10-14-2017, 09:28 AM
FAA has a checklist for E-AB to determine "major portion". They also have a group of inspectors that will evaluate a kit to see if it meets the "major portion" requirement. They only evaluate if the kit manufacturer requests it. While everyone has complained for years about FAA standardization, there are variations and the checklists are supposed to help with standardization.

The checklist is TASK oriented, not hours oriented, so for example, building one rib satisfies the requirement to build ribs, all the rest could be completed as part of the kit.

Any components that were previously installed on a certified aircraft cannot count towards tasks for the major portion as work on them is considered maintenance under Part 43.

As a DAR, when I do an E-AB certification, I have to complete the checklist, and that checklist gets filed with the FAA as part of the certification paperwork.

Keep in mind that a builder has to submit an 8130-12, and making fraudulent statements on this form carry fines and prison terms under Title 18. So all those alleged homebuilts where somebody paid someone else to build it could be looking at a $10000 fine and 5 years prison time.

Now, for the Carbon Cub, is it an E-AB, or an E-LSA, rules are very different and no 51% requirement for the E-LSA. I know lots of Carbon Cubs are S-LSA when factory built, so I would think the kits are E-LSA.


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rsrguy3
10-14-2017, 09:57 AM
Dg, we've all heard it before, we've all read the regulations and what they say, but it's all legal speak, none of it is serving GA in a productive way, companies like cubcrafters are getting around the intent. What I'm asking here is can we discuss what a revamp of the rules would look like. This is supposed to be a land of liberty were supposed to be able to do pretty much what we want, and we've been over regulated to death. Building an airplane from what was a pile of certified parts at home should just be considered amateur built ( there is no difference between that and what cubcrafters does at all except if you build an airplane at home from a pile of vintage certified parts you actually put more work and time into the air frame) especially if the design is already been proven. This is just an example of how much Common Sense leaves society when lawyers and bureaucrats and big business run the show.

dgapilot
10-14-2017, 10:34 AM
Dg, we've all heard it before, we've all read the regulations and what they say, but it's all legal speak, none of it is serving GA in a productive way, companies like cubcrafters are getting around the intent. What I'm asking here is can we discuss what a revamp of the rules would look like. This is supposed to be a land of liberty were supposed to be able to do pretty much what we want, and we've been over regulated to death. Building an airplane from what was a pile of certified parts at home should just be considered amateur built ( there is no difference between that and what cubcrafters does at all except if you build an airplane at home from a pile of vintage certified parts you actually put more work and time into the air frame) especially if the design is already been proven. This is just an example of how much Common Sense leaves society when lawyers and bureaucrats and big business run the show.

Unfortunately, FAA decided years ago that the work performed on previously certified parts doesn't count towards the major portion. Now, that is Policy, not regulatory. That came out of the 2006 & 2008 ARC meetings between FAA and Industry and EAA was a party to those meetings. The Checklist Briefing Guide https://www.faa.gov/aircraft/gen_av/ultralights/amateur_built/kits/media/am_blt_chklist_job_aid.pdf gives a pretty good review of what is expected and how to fill out the checklist. The actual checklist for fixed wing is here https://www.faa.gov/aircraft/gen_av/ultralights/amateur_built/kits/nket_list/media/FixWingSling4.pdf

Now, I agree that companies like CubCrafters are exploiting the checklist to the greatest extent possible. I haven't seen a checklist that was done on a CarbonCub FX, so I don't know what exactly they are doing. The FX is not on the List of kits reviewed, so the FAA team hasn't made a determination. The DAR that certifies each one has to make that determination. I'm working with the guys that are putting the Clipwing Monocoupe kit together and their method for complying with the Major Portion. Their concept is similar to CubCrafters, but the buyer will be more involved and the current plan shows that the buyer meets about 63% even with most of the work being completed at the factory.

As for using previously certified parts, I have to agree with FAA policy. I've seen "homebuilts" that were certified back in the 60s-80s that were nothing more than an assembly of previously certified parts. I remember when Bud Dake put his 110 Special together the first time, using a 90A fuselage and wing and tail fabricated from scratch he got an E-AB certificate. A year or so later, after an Ercoupe took out the wing, FAA made him surrender the E-AB certificate and go E-Exhibition with the original 90A data plate and serial number, even though two wings were built from scratch along with the complete tail assembly and engine installation.

Keep in mind that as individual users you have the right to petition FAA to change the regulations, and using the Directive Feedback form in the back of each Order request changes to Policy. Order 8130.2J is the current Policy for certification of all aircraft, so that would be the order you would be requesting a change to. If you get enough people to request a change, it will happen. I've gotten Orders changed, and I've made input to most major regulatory NPRMs over the years. Discussing it here doesn't get change, writing feedback and making comments to NPRMs along with writing Petitions For Rule Changes are what gets things changed in DC. I'll also admit that I've been pushing for changes to the policy on Data Plates for years (write a new directive feedback for each revision to 8130.2) and still can't get any traction.

rsrguy3
10-14-2017, 10:57 AM
I disagree with using old airworthy certed parts. It's irrelevant what the faa did in the past for the questions I've posed. My question is no different than the other threads that ask "what would make for the ultimate bush pacer?" Or "what would your dream panel include". A guy or gal that builds a Cessna 180 wing from old airworthy ribs and new sheet is still getting a higher level knowledge and skill then cubcrafters builder. I'm just trying to ask the right questions, that is all. This is no different than a dream plane. What would a rule change petition look like. Mark, Dg, Steve, all of you, if you could snap your fingers and change the regs what would it look like. GA is dying a slow death and I hate that, let me take a stab at the first fairy tale rule change.

G.A.R #1
Any proven aircraft design constructed by a non certified mechanic in a non production environment inspected and found to be in compliance with the Uniform Aircraft Construction Code (UACC) shall be awarded with an airworthiness certificate for the remainder of that aircraft's serviceable lifespan. An A/C constructed or rebuilt under this category shall henceforth be denoted as amateur built experimental, or amateur reconstructed ex-certified-experimental.

How about it? Give it a go!

dgapilot
10-14-2017, 11:27 AM
Rsrguy, Truth be told, the limitations for Experimental Exhibition aren't much different than E-AB. You can use all the certified parts you want for an Exhibition aircraft. The main differences are you can't get a repairmans certificate, and you have to submit a program letter each year. Other than that you are good to go, oh yeah, one more thing, if it still retains the identity of the original aircraft then Part 43 still applies regarding maintenance. So that said, you can take a TriPacer, extend the fuselage, extend the wings, do whatever you want, call it an "Rsrguys skywopper" and apply for an Experimental Exhibition certificate, no need to meet 51%. That gives you what you want. The DAR will review what you have, and make a determination of "Safe for Flight" which means that it is safe enough that you won't kill people on the ground, but no guarantee that you won't kill yourself, and issue a certificate with Op Limits that aren't much different from E-AB. The two primary differences will be the need for an A&P for the condition inspection, and the previously mentioned program letter. So the existing regulations and policy already give you what you are asking for.

rsrguy3
10-14-2017, 11:56 AM
And there's the rub.... anyone that does that much work should get the repairman certificate. Not to mention the whole idea of opps limits. In case you or anyone reading this hasn't grasped it, I'm not keen on control especially when it doesn't make sense. The certified issue is bogus as well, more unnecessary control. If I buy a pile of parts I should be able to assemble them and as long as they pass inspection there shouldn't be any restrictions private or commercial. We're over regulated to death. Cessna, Beech and all the others would prefer if all the vintage stuff would just vanish. The level of control borders on insanity. It would be exactly the same thing as Ford telling you that after over 80 years you couldn't build a high boy Roadster from your 32 Coupe, and then threaten you that if you did, you can only drive it in parades.

dgapilot
10-14-2017, 02:11 PM
And there's the rub.... anyone that does that much work should get the repairman certificate. Not to mention the whole idea of opps limits. In case you or anyone reading this hasn't grasped it, I'm not keen on control especially when it doesn't make sense. The certified issue is bogus as well, more unnecessary control. If I buy a pile of parts I should be able to assemble them and as long as they pass inspection there shouldn't be any restrictions private or commercial. We're over regulated to death. Cessna, Beech and all the others would prefer if all the vintage stuff would just vanish. The level of control borders on insanity. It would be exactly the same thing as Ford telling you that after over 80 years you couldn't build a high boy Roadster from your 32 Coupe, and then threaten you that if you did, you can only drive it in parades.

You have to remember, Congress gave control of the sky to the FAA for the safety of the general public. While you may not do stupid things, consider some of the stuff I've seen in my day to day job as a System Safety Engineer. We have contractors that tried to pull the wool over ours and the FAAs eyes by trying to change the maintenance program on prior military jets to eliminate life limited components. Play games with fatigue issues and a whole lot of other things. I've seen workmanship so bad that I wouldn't issue a certificate for a homebuilt. I've seen workmanship so bad from A&Ps and IAs that the airplane ended up as scrap (One was a PA-12). Not everyone has the ability to construct an airplane that will be safe, so there needs to be some control. Granted there are things that don't make much sense, but the saying goes that all those regulations have been written in blood.

rsrguy3
10-14-2017, 02:51 PM
It's not likely anybody that's a thinking individual would disagree with you in terms of the idiots that are out there and the stupid things that they do. I'm not calling for the wild west here. I just think we should standardized safety inspections, if the airplane doesn't pass it it doesn't fly. I believe if we have less restrictions with competent individuals like you doing the inspecting we can can have a safer more diverse Fleet and a thriving GA industry. There will always be incompetent stupid people out there that try and cheat the system. Aviation is the exception, its one of the safest mechanized Industries out there and I have to believe its because of the prevailing level of operator competence not over regulation. Sounds to me like you're a practical guy, I wish we had more like you at FISDO's and in government. Zero fatalities isn't a realistic goal, we can police ourselves provided we have a logical common sense framework that isn't corrupted by outside special interest. Cost here is the main factor the regs have pushed prices into the stratosphere 250+ K? For a super cub that's leaps and bounds better than it was when it was certified and built in Lockhaven? Don't you think it's gone just a lot to far?

dgapilot
10-14-2017, 06:53 PM
Thanks for the compliments! Yes, I try to be practical and have tried to help guys out of a hole more than once. The FAA inspectors know and see very little anymore, they are saddled with filling in boxes on their computer screens. Truth be told, regulation doesn't really add that much to producing an already proven design. The labor to build an aircraft is the biggest issue along with product liability. Low volume production is expensive. Consider just recovering a Cub or Pacer. In today's world, a shop would have to charge over 30k just to break even. The last shop I ran, about 15 years ago, my product liability insurance premium was over 75k. You have to sell a lot of labor to cover that. Now, for all the A&P, IA, DAR, and DER work I do, I'm hanging out for liability otherwise I would have to charge 3 to 5 times what I do just to cover liability insurance. The only thing I can say is I try and do the best I can so it would be unlikely to get tied up in litigation. Hope I never have to face that!


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dgapilot
10-15-2017, 09:23 AM
Mark,
You have done enough changes/mods/work that you might want to put it in Experimental Amateur Homebuilt.

I don't think it would qualify. Work done on certified parts don't count towards the 51%. He could go Experimental Exhibition though. Since it was "previously certified" part 43 would still apply so he would still need 8110-3 engineering approvals.


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CamTom12
10-15-2017, 09:38 AM
Dga, here's a question I have:

Previously certified parts mean parts that have flown on a certified aircraft, correct?

If you just were to buy new cub ribs and spars (from Dakota or somewhere) and build your own wings, would that assembly count towards the fabrication/assembly box checks?

andya
10-15-2017, 10:13 AM
Is Experimental Exhibition require a letter every year as to where you plan to operate the aircraft. My friend had a British Bulldog and I thought he had to
file that letter every year and get approval. I was guessing his was Experimental Exhibition.

Rick-CAS
10-15-2017, 12:07 PM
You are required to file a Program Letter with the local FSDO each year for flights outside the operating area listed in the operating limitations. Most were around 100 miles from the home airport. The FAA did not need to approve them just be notified. The current limitations today seem to be very liberal in distance from the home airport. I know two aircraft with 500 mile limitations. They can go just about anywhere they want with out needing to file a program letter since it's in the operating area. If they decide to go farther than the 500 mile limit they email a notice of the destination and dates they are going to and from.

dgapilot
10-15-2017, 12:35 PM
Dga, here's a question I have:

Previously certified parts mean parts that have flown on a certified aircraft, correct?

If you just were to buy new cub ribs and spars (from Dakota or somewhere) and build your own wings, would that assembly count towards the fabrication/assembly box checks?

That would be correct, major assemblies that were installed on certified aircraft don't count. If you take piece parts, you can't take credit for fabricating them, but you can take assembly credit for adding them to your assembly. The guidance is silent on the use of PMA parts, so I would evaluate them the same. Remember, it is task based, so if you build one rib and use PMA ribs for all the rest, you pretty much get credit for "building ribs".


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dgapilot
10-15-2017, 12:44 PM
Is Experimental Exhibition require a letter every year as to where you plan to operate the aircraft. My friend had a British Bulldog and I thought he had to
file that letter every year and get approval. I was guessing his was Experimental Exhibition.

It depends on when the op limits were issued. FAA has changed the requirement over the years. For about the last 10 years Exhibition op limits have had the requirement to submit a program letter each year. That said, there is no "requirement" for FAA to approve said program letter. In fact there is no guidance for what an inspector does with the program letter!

Just keep in mind that the regulations say Experimental aircraft can't be used for purposes other than what they were certificates for. In the case of Exhibition, that is proficiency flights and exhibiting them. Your program letter should state that the aircraft will be exhibited at some place during the year. Doesn't matter where, could be an Airshows or a pancake breakfast. Just because you put it on the program letter doesn't mean you have to go. Just make sure you meet the purpose requirement.


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dgapilot
10-15-2017, 12:45 PM
You are required to file a Program Letter with the local FSDO each year for flights outside the operating area listed in the operating limitations. Most were around 100 miles from the home airport. The FAA did not need to approve them just be notified. The current limitations today seem to be very liberal in distance from the home airport. I know two aircraft with 500 mile limitations. They can go just about anywhere they want with out needing to file a program letter since it's in the operating area. If they decide to go farther than the 500 mile limit they email a notice of the destination and dates they are going to and from.

Again, this is a holdover from old guidance. Op limits issued today have no geographic boundaries other than a phase 1 test area.


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andya
10-15-2017, 12:52 PM
Seems like the FAA person he worked with wanted specific locations he might visit. He got tired of the hassle and sold the airplane

chrismax
08-06-2019, 01:01 AM
Under the 51% rule you get absolutely no credit for a salvaged parts like fuse, legs , engine mount , wings
even though they can be modified even greatly, you get no credit under the rules


kitsets are different because you get the % points for building up assembling the fuse, legs , wings etc.

The rules are quite clear under FAA AC20-27G
What I have done is purchased some homebuilt Falconar wings and tail with virtually the same specs as the pacer.
That makes my project about 60%, well over the 51% rule.

My Experimental will still look like a Pacer except for the tail.

Bob H
10-02-2020, 09:27 AM
This thread looks pretty dead but ill ask anyway.
Suppose I had a 1950 PA20. Could I buy some 4130 cr. Tube and start rebuilding. Starting with extending landing gear. And continue until I meet the 51% rule. And about where would that be. Could I just mock the entire frame. And move all the components to the new frame?

chrismax
10-02-2020, 04:23 PM
This thread looks pretty dead but ill ask anyway.
Suppose I had a 1950 PA20. Could I buy some 4130 cr. Tube and start rebuilding. Starting with extending landing gear. And continue until I meet the 51% rule. And about where would that be. Could I just mock the entire frame. And move all the components to the new frame?

If you or some other homebuilder builds the wings and tail 100% you will achieve the 51% FAA rule easily, but work changing or modifying an existing fuse including putting new gear on though allowable cannot be added in to the equation at all - the FAA rules and Calculation Form are in AC No 20-27G , it is also internationally acceptable

I am currently fitting some Falconar Wings another homebuilder made onto a Tripacer I have modified with PA20 legs , and I will build my own tail empenage close to a PA20 design which is easy , I have done all the math on the form - which the authorities here or anywhere cannot refuse

I recommend starting with the form first, the hard facts, and see what you can achieve - all the best!

Steve Pierce
10-03-2020, 08:09 AM
To legally take a certified airplane to experimental it would have to be in the exhibition category not ameteur built.

Steve Pierce
10-03-2020, 08:13 AM
Rick points out the regulations on this in post 7 of this thread.

flyincajun
01-08-2021, 12:13 PM
Actually, just parts by themselves are not considered an aircraft by the FAA, as noted in the legal interpretation of Krause :https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2018/Krause%20-%20(2018)%20Legal%20Interpretation.pdf

So a fuselage without any markings is simply an assembly of tubing material. You get no credit for the fabrication of it, but you could get credit for fabricating any additions/extensions and assembly of attachments.
I have seen a couple projects take this route with success. Just make sure you use the checklist (even present it ahead of time to your FSDO guy).

dgapilot
01-10-2021, 03:35 PM
Actually, just parts by themselves are not considered an aircraft by the FAA, as noted in the legal interpretation of Krause :https://www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations/Data/interps/2018/Krause%20-%20(2018)%20Legal%20Interpretation.pdf

So a fuselage without any markings is simply an assembly of tubing material. You get no credit for the fabrication of it, but you could get credit for fabricating any additions/extensions and assembly of attachments.
I have seen a couple projects take this route with success. Just make sure you use the checklist (even present it ahead of time to your FSDO guy).

In DAR school they tell us if it was installed on a certified airplane, you can’t get credit for anything done to it, work on those parts would be maintenance under Part 43. I agree with you, best to get the checklist

https://www.faa.gov/aircraft/gen_av/ultralights/amateur_built/kits/media/AmBuiltFabAssyCklistFW.pdf

And fill it out, then talk it over with your DAR, FSDO or MIDO to make sure everyone is on the same page if it gets close to that 51%.

The Krause letter was only dealing with the definition of an aircraft as it relates to registration, and isn’t applicable when talking about parts salvaged from a certified aircraft for use in an Experimental Amateur Built aircraft. If you can’t meet the 51%, then you would be looking at Experimental Exhibition. I had one client that we had to go that route with.


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andya
01-10-2021, 04:11 PM
Experimental Exhibition? is that a program where you have get a letter from the FAA which allows you to fly only to special places or locations. ?

flyincajun
01-10-2021, 04:41 PM
Experimental Exhibition? is that a program where you have get a letter from the FAA which allows you to fly only to special places or locations. ?

You don't get the letter from the FAA, you write the letter and send it to them.

flyincajun
01-10-2021, 04:51 PM
The Krause letter was only dealing with the definition of an aircraft as it relates to registration, and isn’t applicable when talking about parts salvaged from a certified aircraft for use in an Experimental Amateur Built aircraft.

But it also set the precedence that the individual parts were no longer considered an aircraft by definition. A couple of people have used that to convince certain FAA personnel that they were using a part that was equivalent of a part that would come in a kit. Plus it was modified in the process.The remaining pieces were enough to clear the 51% hurdle.
They did submit a sample checklist during the pre-build meeting and everyone was on-board.

dgapilot
01-10-2021, 06:35 PM
Experimental Exhibition? is that a program where you have get a letter from the FAA which allows you to fly only to special places or locations. ?

21.197 lists 9 different “purposes” for Experimental certificates. Amateur Built and Exhibition are only two of those purposes. There is Research and Development, Crew Training, Air Racing, Show Compliance, Market Survey, Primary kit built, and LSA.

Keep in mind that 91.319 says you can only operate an Experimental aircraft for the Purpose for which it was Certificate.


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