When FAA says minimum 20% fab and minimum 20% assembly, they aren't talking
about a 40% rule.

In the proposal, the phrase "the amateur builder only fabricates 10 to 20
percent of an aircraft, and assembles 80 to 90 percent" does not refer to
the entire aircraft, only the builder's portion.

What they mean is that of the 51% you have to build, they want 20% to be
either fab or assembly.  And not 20% of 51%;  if 20% is fabrication, 31% has
to be assembly or visa versa.  The assignment of 20% vs. 7% or 25.5% or
whatever was arbitrary and was one of the things FAA did after the ARC had
finished its work.  We discussed a minimum amount of fabrication but never
got anywhere with it.

During the ARC discussions we came up against a wall at almost every meeting
trying to define 51%.  The industry generally agreed that it should be 51%
of the tasks required.  FAA would like to see an approximately equal mix of
fabrication tasks and assembly tasks, but EAA and the rest of the industry
believe that the line is too blurred in many cases to really try to define
which is which.  For example, when you bond RV-10 door skins together, are
you fabricating or assembling?  For all-composite planes it gets even
trickier.

We think it should be left as "tasks".  Do a task, get a point.

The FAR says "fabricated and assembled", and does not specify a ratio.  So I
would think that ANY amount of fabrication would be sufficient.

EAA is essentially proposing to leave the rule as is but tighten up the
documentation and give DARs a standard set of criteria.  That should help.
But trying to parse how much assembly and how much fabrication will lead to
more confusion and more loopholes.  It would be helpful if we speak to the
FAA as a common voice.  EAA should be giving some guidance to its members
soon about how to reply to the proposal.  If we follow EAA's advice we'll
have the most impact.

Dave Saylor
AirCrafters LLC
140 Aviation Way
Watsonville, CA
831-722-9141
831-750-0284 CL
www.AirCraftersLLC.com