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Thread: Experimental?

  1. #11
    rsrguy3's Avatar
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    Default Re: Platinum Pacer Wings

    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.
    Last edited by rsrguy3; 10-13-2017 at 11:38 PM.

  2. #12
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    Default Re: Experimental?

    This feels like an out of thread experience. ...lol

  3. #13
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    Default Re: Experimental?

    I agree with you!

  4. #14

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    Default Re: Experimental?

    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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  5. #15
    rsrguy3's Avatar
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    Default Re: Experimental?

    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.
    Last edited by rsrguy3; 10-14-2017 at 10:00 AM.

  6. #16

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    Default Re: Experimental?

    Quote Originally Posted by rsrguy3 View Post
    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/...st_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/...WingSling4.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.

  7. #17
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    Default Re: Experimental?

    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!
    Last edited by rsrguy3; 10-14-2017 at 11:02 AM.

  8. #18

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    Default Re: Experimental?

    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.

  9. #19
    rsrguy3's Avatar
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    Default Re: Experimental?

    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.

  10. #20

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    Default Re: Experimental?

    Quote Originally Posted by rsrguy3 View Post
    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.

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