Hi Guys,
Get your comments in on the 51% rule by Sept 30.
Here is my 2 cents.
Hello Miguel,
I am a member of EAA. I completed a Lancair 360 in 1992 and have enjoyed over 2200
hours flying it over this great country of ours. I am an EAA technical counselor
and have inspected many projects in various stages of construction and have yet
to run into anybody trying to violate the spirit of the rules.
Imposing more rules on the vast majority of builders to
catch a few bad apples makes no more sense than lowering the speed limit from 75
to 45 in response
to a few extreme speeders. The rules for homebuilders are OK as is.
An amateur builder with no skills or experience can buy an
RV7 kit, build it in his back yard, and then sell it to you.
Dick VanGrunsven can buy a kit from his company, build it in
his spare time, and then sell it to you.
If Dick sets up a factory to assemble RV’s to his impeccable
standards he cannot sell them, without going through a horribly expensive
certification process. Does this make sense?
There are several hundred million cars in America.
Each car has two spindles smaller than your thumb holding the front wheels on.
If a spindle snaps off your car or that of an oncoming car, it could veer
across the centerline killing you in a heartbeat. Not one of these spindle
designs has been certified by government engineers. There is no paper trail
certifying the materials and process used to manufacture these parts.
Would our quality of life be better if Ford and Chevy were
building certified models of the cars they built in the 50’s, at $200,000 a
copy?
Imagine a world in which the only way to obtain a high
performance car was to build your own in the garage, would that make sense?
Would they be safer than a Corvette or Mazda Miata?
Decades of overregulation have stifled the natural evolution
of general aviation technology that would have occurred in an environment of
unfettered competition. We have become comfortable with this condition and we
strive to jump through the shrinking hoops of government regulation without
getting stuck.
But there is a huge group of people who want a modern high
performance plane and are willing to accept the potential risk of the
experimental category, but lack the skill, desire or time to build their own. A
tiny subset of this group is willing to violate the homebuilding rules to meet
their needs.
The FAA should focus its effort on creating a new class of
experimental aircraft that satisfies this market.
Kit manufacturers should be able to sell kits built to any
level of completion including 100%, flight tested. The planes would require
annual condition inspections by certified mechanics, and buyers would be
required to sign a statement that they understand that the design has not been
through the traditional certification process and that it is not approved for
commercial use. They would contain the usual passenger warnings found in all
experimental aircraft. People like Van would be free to push the technology as
hard as possible while providing aircraft as safe as or more safe than true
amateur built experimentals.
The cash flow from this large new stream of customers can
finance the research and development of light aircraft technology, accelerating
the evolution process.
Homebuilt light aircraft performance has already far
surpassed the traditional offerings. My Lancair has made several nonstop
flights from Denver to Lakeland
and one nonstop return flight at over 200mph while burning only 6 gph. No
certified aircraft comes close to this performance.
Safety follows performance. If the FAA allows factory
produced experimentals, they will evolve to become safer than traditional
certified planes. Imagine lightweight two, four and six passenger planes with active
control systems and artificial intelligence. They will be built with a survival
instinct that makes them very difficult to stall, spin, overstress, fly into
thunderstorms, ice or fly into the ground.
Some aircraft are equipped with parachutes and they have
saved many lives. But there are cases where the pilot pulled the chute
unnecessarily, or failed to pull it when needed. With artificial intelligence
the unemotional computer will deploy the chute at the optimum time.
People who actually build more than 50% of their airplane
should continue to get a repairman certificate.
Now fast forward 15 years. The chairman of the senate
transportation committee calls his local FBO and says, “I need to charter a fast
plane to make a fundraiser 500 miles
away.” “Come on out senator, we have a plane ready to go.” The pilot walks the
senator out past a sleek, compact, Lancair jet, to a clapped out Baron. “Why
aren’t we taking that jet” the senator asks. The pilot responds “Well senator,
that jet is twice as fast as this Baron, much more reliable, more comfortable,
safer, quieter, easier to maintain, easier to fly, better instrumented and
burns less fuel, but it’s not certified, and we are not allowed to use non
certified aircraft for business.” That’s when things will really change.
As each non-certified aircraft design accumulates a track
record that demonstrates safety equal or better than certified counterparts
they will be made eligible for commercial use. The percentage of experimental
aircraft in commercial service will expand in an orderly fashion and the pace
of technological evolution will accelerate.
Some will say that flying is more dangerous than driving,
therefore certification is required. Competition, informed customers and the
threat of legal action will curtail the bad actors and produce the near optimum
risk benefit ratio. Buyers will still have the option to purchase a traditionally
certificated aircraft, manufacturers will have the option to offer new products
as certified or experimental. Let the customer decide which is best.
With these changes flying your own plane will become safer
than driving. This rule change is needed to comply with the FAA’s mandate to
protect and enhance public safety.
Regards,
Bill Hannahan
e-mail: miguel.vasconcelos@faa.gov
U.S.
Mail:
Miguel L Vasconcelos
Production and Airworthiness Division
AIR-200, Room 815
800 Independence Ave., SW
Washington, DC 20591
Fax: 202-267-8850
EAA asks that you also send your comments to govt@eaa.org.
To learn more about the 51 percent rule, the FAA’s proposed new
policy, and EAA’s analysis of the proposal, or to submit a comment on the FAA
proposal, visit www.EAA.org/govt/.
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