X-Virus-Scanned: clean according to Sophos on Logan.com Return-Path: Sender: To: lml@lancaironline.net Date: Fri, 16 Sep 2005 21:52:00 -0400 Message-ID: X-Original-Return-Path: Received: from imo-m16.mx.aol.com ([64.12.138.206] verified) by logan.com (CommuniGate Pro SMTP 5.0c2) with ESMTP id 724689 for lml@lancaironline.net; Fri, 16 Sep 2005 21:19:04 -0400 Received-SPF: pass receiver=logan.com; client-ip=64.12.138.206; envelope-from=Sky2high@aol.com Received: from Sky2high@aol.com by imo-m16.mx.aol.com (mail_out_v38_r5.5.) id q.126.657f2b94 (48576) for ; Fri, 16 Sep 2005 21:18:17 -0400 (EDT) From: Sky2high@aol.com X-Original-Message-ID: <126.657f2b94.305cc8d9@aol.com> X-Original-Date: Fri, 16 Sep 2005 21:18:17 EDT Subject: Kit Aircraft, EABAs and the FAA - X-Original-To: lml@lancaironline.net MIME-Version: 1.0 Content-Type: multipart/alternative; boundary="-----------------------------1126919897" X-Mailer: 9.0 Security Edition for Windows sub 5009 X-Spam-Flag: NO -------------------------------1126919897 Content-Type: text/plain; charset="US-ASCII" Content-Transfer-Encoding: 7bit OK, the Sky is not falling for most. Before the real nut of the issue, first consider some milestones (mill stones?). 1. Early Experimental Amateur Built Aircraft (EABA) were mainly either one off original designs or plans built with a parts list. These sometimes required sophisticated tools and craftsmanship. They took a long time to build and the cost was spread over years. Generally they were simple and flew slowly in the daytime. The FAA was capable of inspecting these aircraft during building stages. There was no internet. Now using Lancair as an example. 2. Early kit airplanes were supplied with all the airframe molded elements and parts so no scrounging had to be done. Interior, paint, instruments and firewall forward were left to the imagination of the builder. The builder had to assemble major components such as the main spar, wing ribs, etc. There was a great deal of variance in the quality of resulting aircraft and different craftsmanship was required. Tools were simple. The FAA clarified that major work must be done by the builder and established a list of kit planes that qualified. Building was quicker and the cost was spread over fewer years though still affordable by many. FAA ability to ascertain the airworthiness of such planes was being pushed. 3. The "fast build" kit was promulgated and such kits were re-qualified by the FAA as far less than 49% built by the supplier. The FAA was happier because things like the main spar was installed on jigs by the factory which made major structural components assembled more consistently (and safely). Tools still remained relatively simple. Time and costs were more compressed. Builders were able to focus on other, more sophisticated elements, engines, instruments, and mission. No longer the Sunday afternoon flivver, these were serious airplanes capable of long cross country trips in less than perfect weather. Still, the builder became educated and the use was most often for pleasure. If certain EAA guidelines were followed, insurance was available right from the first flight. 4. The next period was the super fast build and highly complex kit aircraft. IV, IV-P, IVPT, Legacy etc. Taking the Legacy (I had kit # 2), the kit came with hardware installed, flaps and ailerons built, fuel sealer in the wing tanks, etc. All one had to do to the FAA requirements to build the wing was bond on the top skin. I pestered Lancair for over 9 months to get the letter from the FAA that this kit qualified under the 51% rule. If I remember correctly, Lancair claimed that the FAA considered the factory built part to be under 40%. The factory assist program was born and as long as the owner/builder showed up and worked on his plane, the assistance was no problem to the FAA. As a matter of fact, it could be seen as a benefit since now these aircraft are actually comparable to each other - same flight characteristics and quality. Other Lancair kits were far more complex - take Harry League's IV-PT. Harry has sent interested parties his photo log of each days work - about 3-4 months of work after 4 weeks in the builder assist (I think it was that long) and if I was a FAA inspector, he would easily qualify as doing more than 50% of the work. Fast build panels, interiors, painting and firewall forward kits came along and still the planes met the 51% rule since the builder and hired elfs were wiring the plane, hanging the engine, doing a little sanding, etc. Hmmmm, I believe that one can purchase an airframe wiring harness for the Legacy. Now, build time is even shorter and the builder may have to come up with quite a wad of cash in one year. The FAA is completely incapable of performing the final inspection of these sophisticated, complex and even high altitude airplanes. The mission is getting bent - less education in the building crafts, more expensive tooling required, and one does not take a turbo prop for a Sunday afternoon pleasure scurry over the countryside of the now $200 hamburger (ballistic arcs notwithstanding). However, if one does his paperwork, logs, photos and communicates with the FAA before committing FAR sins, a DAR would not have a problem certifying the aircraft. By paperwork, I include making sure the kit is on the FAA approved list. Insurance is for later. 5. Now, a new kit comes along that goes further than any other and is so complex than the factory requires it be almost completely built at their assist center. Before buying into such a kit, one should check that the FAA has approved such a scheme (part of the paperwork). OK, that's it for the FAA control over the equipment and the builder so far. Or, maybe not. Thus the memo that seems to be troublesome. Maybe it would be easier for the FAA to add just a single additional limitation to the Experimental Amateur Built Aircraft (EABA) airworthiness certificate - No flight of this aircraft is authorized above FL250. Period. Of course, a new category of non-STC'd aircraft could be constructed by the FAA. Just don't expect my support and neither should the EAA support such a thing since it is so far away from their mission and the FAA's definition of education and pleasure - million dollar airplanes aren't just built, they are bought. Now, on to the more controlling topic, INSURANCE. As we have moved from item 1 to 5, note that the FAA controls the equipment build/flight rules and the insurance companies gain more and more control of the pilot requirements. Does an instrument rating, recurrency training, many hours of experience, type rating, and high altitude training ring a bell? Did you check that you can actually insure the thing you are building (buying) or afford the insurance (more paperwork)? If its turns out to be your personal JET, maybe you can hire a Jet ATP/CFII to fly you places while giving you instruction. Have you considered how you can get rated in the aircraft you are building? Who is going to fly off the time? At what cost? Who would go with you? Count me out of further discussion of this topic, I am still experimenting, learning and enjoying at least 80% of my flights (some are for serious purposes - like going to a cross country race). If I should build another EABA, I am not worried about the FAA rules changing since the mission I would have for such a plane is experimental in nature and, save cranial failure, I would learn something too. Scott Krueger AKA Grayhawk Lancair N92EX IO320 SB 89/96 Aurora, IL (KARR) PS I would build it myself or it wouldn't be worth it. -------------------------------1126919897 Content-Type: text/html; charset="US-ASCII" Content-Transfer-Encoding: quoted-printable
OK, the Sky is not falling for most.
 
Before the real nut of the issue, first consider some milestones (mill=20 stones?).
 
1. Early Experimental Amateur Built Aircraft (EABA) were mainly ei= ther=20 one off original designs or plans built with a parts list.  These somet= imes=20 required sophisticated tools and craftsmanship.  They took a long time=20= to=20 build and the cost was spread over years.  Generally they were simple a= nd=20 flew slowly in the daytime.  The FAA was capable of inspecting these=20 aircraft during building stages. There was no internet.
 
Now using Lancair as an example.
 
2.  Early kit airplanes were supplied with all the airframe molded= =20 elements and parts so no scrounging had to be done.  Interior, paint,=20 instruments and firewall forward were left to the imagination of the=20 builder.  The builder had to assemble major components such as the main= =20 spar, wing ribs, etc.  There was a great deal of variance in the qualit= y of=20 resulting aircraft and different craftsmanship was required.  Tool= s=20 were simple.  The FAA clarified that major work must be done by the bui= lder=20 and established a list of kit planes that qualified.  Building was quic= ker=20 and the cost was spread over fewer years though still affordable by many.&nb= sp;=20 FAA ability to ascertain the airworthiness of such planes was being=20 pushed. 
 
3. The "fast build" kit was promulgated and such kits were re-qualified= by=20 the FAA as far less than 49% built by the supplier.  The FAA was happie= r=20 because things like the main spar was installed on jigs by the factory=20 which made major structural components assembled more consistently (and=20 safely). Tools still remained relatively simple.  Time and costs w= ere=20 more compressed.  Builders were able to focus on other, more sophistica= ted=20 elements, engines, instruments, and mission.  No longer the Sunday=20 afternoon flivver, these were serious airplanes capable of long cross countr= y=20 trips in less than perfect weather.  Still, the builder became educated= and=20 the use was most often for pleasure.  If certain EAA guidelines were=20 followed, insurance was available right from the first flight.
 
4. The next period was the super fast build and highly complex kit=20 aircraft.  IV, IV-P, IVPT, Legacy etc.  Taking the Legacy (I = had=20 kit # 2), the kit came with hardware installed, flaps and ailerons built, fu= el=20 sealer in the wing tanks, etc.  All one had to do to the FAA=20 requirements to build the wing was bond on the top skin.  I pestered=20 Lancair for over 9 months to get the letter from the FAA that this kit quali= fied=20 under the 51% rule.  If I remember correctly, Lancair claimed that the=20= FAA=20 considered the factory built part to be under 40%.  The factory assist=20 program was born and as long as the owner/builder showed up and worked on hi= s=20 plane, the assistance was no problem to the FAA.  As a matter of fact,=20= it=20 could be seen as a benefit since now these aircraft are actually comparable=20= to=20 each other - same flight characteristics and quality. 
 
Other Lancair kits were far more complex - take Harry League's IV-PT.&n= bsp;=20 Harry has sent interested parties his photo log of each days work - about 3-= 4=20 months of work after 4 weeks in the builder assist (I think it was that long= )=20 and if I was a FAA inspector, he would easily qualify as doing more than 50%= of=20 the work.  Fast build panels, interiors, painting and firewal= l=20 forward kits came along and still the planes met the 51% rule since the buil= der=20 and hired elfs were wiring the plane, hanging the engine, doing a little=20 sanding, etc.  Hmmmm, I believe that one can purchase an airframe=20 wiring harness for the Legacy.  Now, build time is even shorter and the= =20 builder may have to come up with quite a wad of cash in one year.  The=20= FAA=20 is completely incapable of performing the final inspection of these=20 sophisticated, complex and even high altitude airplanes. 
 
The mission is getting bent - less education in the building crafts, mo= re=20 expensive tooling required, and one does not take a turbo prop for a Sunday=20 afternoon pleasure scurry over the countryside of the now $200 hamburger=20 (ballistic arcs notwithstanding).  However, if one does his paperwork,=20 logs, photos and communicates with the FAA before committing FAR sins, a DAR= =20 would not have a problem certifying the aircraft.  By paperwork, I incl= ude=20 making sure the kit is on the FAA approved list.  Insurance is for= =20 later.
 
5.  Now, a new kit comes along that goes further than any other an= d is=20 so complex than the factory requires it be almost completely built at their=20 assist center.  Before buying into such a kit, one should check that th= e=20 FAA has approved such a scheme (part of the paperwork).
 
OK, that's it for the FAA control over the equipment and the builder so= =20 far.  Or, maybe not.  Thus the memo that seems to be=20 troublesome.  Maybe it would be easier for the FAA to add just a=20 single additional limitation to the Experimental Amateur Built=20 Aircraft (EABA) airworthiness certificate - No flight of this=20 aircraft is authorized above FL250. Period.  Of course,=20= a=20 new category of non-STC'd aircraft could be constructed by the FAA.  Ju= st=20 don't expect my support and neither should the EAA support such a thing= =20 since it is so far away from their mission and the FAA's definition=20 of education and pleasure - million dollar airplanes aren't just=20 built, they are bought. 
 
Now, on to the more controlling topic, INSURANCE.  As we have move= d=20 from item 1 to 5, note that the FAA controls the equipment=20 build/flight rules and the insurance companies gain more and more contr= ol=20 of the pilot requirements.  Does an instrument rating, recurrency=20 training, many hours of experience, type rating, and high altitude training=20= ring=20 a bell?  Did you check that you can actually insure the thing you=20= are=20 building (buying) or afford the insurance (more paperwork)?  If=20 its turns out to be your personal JET, maybe you can hire a Jet ATP/CFI= I to=20 fly you places while giving you instruction.  Have you considered how y= ou=20 can get rated in the aircraft you are building?  Who is going to fly of= f=20 the time?  At what cost?  Who would go with you?
 
Count me out of further discussion of this topic, I am still experiment= ing,=20 learning and enjoying at least 80% of my flights (some are for serious purpo= ses=20 - like going to a cross country race).  If I should build another EABA,= I=20 am not worried about the FAA rules changing since the mission I wo= uld=20 have for such a plane is experimental in nature and, save cranial failure, I= =20 would learn something too. =20
 
Scott Krueger=20 AKA Grayhawk
Lancair N92EX IO320 SB 89/96
Aurora, IL=20 (KARR)
 
PS I would=20 build it myself or it wouldn't be worth it.




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