AC-90-APP Additional Pilot Program for Phase I Flight Test Draft

[Ylinen]

Todd,
Thanks so much for pointing me to that. After listening to the video, I am even more in opposition. Charpentier has done what EAA and AOPA are good at which is join the FAA in their goals rather than ours. They spent so much time defining what a QP is, they lost sight of the goal which was to get the builder help with a person more experienced than them. I have two simple questions for the EAA. How many members in EAA would qualify to be a QP in the 10 most common kit built planes? And how much will those QPs charge to perform that service?

I am convinced this will be worse than the LODA solution. The FAA answered the NTSB findings and recommendation and EAA request to provide relief from the regulations to allow for transition training in non-owned aircraft. The result is less than 100 LODAs US wide. Great program.

[WLIU]

I will offer the observation that the formulation of the requirements is pretty reasonable for our friends at FAA. They have to justify why having a second pilot increases safety vs a single pilot. After all, the builder does not have to make the first flight. A more current and qualified pilot can make the first flights while the builder observes from the ground. Safety is not about ego and what we want to do. Its about what will get the airplane off the ground and back, demonstrating that the build has been successful, without damage.

So I have to say that once you get past the current popularity at the agency of expressing everything in a spreadsheet, a lot of the numbers look pretty reasonable. A pilot who has more total hours and more recent hours in the same model aircraft is going to add more value than a pilot who only flew 10 hours in the last year and none in the type aircraft being tested.

I think that it is unreasonable to expect that FAA is going to endorse putting two low time pilots in an airplane for the first few flights.

The bounding of the policy to well known types of homebuilts also makes sense from a policy change point of view. Once the program is proven successful, we can lobby that it be expanded. It appears to me that the "sweet spot" of the policy change is clearly the RV community. Those folks have a mature track record of successful first flights and follow on fleet safety. They have a great support system in the community and the factory. Aiming the new policy at those folks helps make sure that the new policy is a success.

If you want a big change from a federal agency, you will almost always be disappointed. The current draft is the first step, but does not have to be the last. It opens the door. That is a big deal for policy from a federal agency. After all, today you must fly solo. Tomorrow you can find a qualified individual and have help. I applaud EAA for working with FAA on this.

Best of luck,

Wes
N78PS

[Tom Charpentier]

"How many members in EAA would qualify to be a QP in the 10 most common kit built planes? And how much will those QPs charge to perform that service?"

Thanks for sitting through the webinar. With regards to how many people at your average airport would be eligible, as I said in the presentation you should take a look at the matrices and run a few scenarios. Yes, the matrix does seem overly complicated but it was the best way we found to make sure the program is as flexible as possible to allow as many as possible to participate. For example, I can run myself through it for an RV-6A:

Recency of experience:

-I have more than 10 landings in the past 90 days, so I get 10 points
-I have time in the model family, so I get 15 points
-I have 42 hours in the past 12 calendar months, so I get 10 points
-I have about 210 total hours, so I fail to qualify for total time (which is fine, I agree I'm a low-time pilot)
-It's a tri-gear plane, so I get 10 points without needing tailwheel landings (although I have enough)

The minimum is 60, so to pass this matrix, I would need 500+ hours totals (10 points) and 70+ hours in the past year (15 points) or 1000+ hours total and 40-69 hours in the past year. Neither is particularly unreasonable to expect from an experienced, active GA pilot.

Let's go on to the second matrix and assume I have 500 hours total:

-I would have 500 hours category and class for 20 points
-I have about 78 hours in the RV family so I get 15 points
-I have time in the exact model (RV-6A) so I get 10 points
-I DON'T have any phase I time so I get -75 points
-I don't have more than 20 models flown as PIC so I don't get points for that
-Non-complex/canard/HP/pressurized aircraft, so no deductions for that
-I don't have CRM training, so no points for that
-I'm a private pilot, so I get 5 points.

OK, so I'm sitting on -25 points, which is probably good because without any Phase I time I'm not really cut out to advise a builder on his/her first few flights from the cockpit. BUT, if I made a first flight previously (even in this aircraft if the owner let me) now I'm up to 70 points and I need 90. So if I had that and 20 makes/models in my logbook, OR more than 100 hours in the model family (I'm only 22 hours away as a fairly new RV pilot), I pass.

So to answer your first question, just about any homebuilder who has made a first flight or at least has Phase I experience, has at least 500 hours logged total, and has put a little time on their airplane can pass as a QP in the model family. You don't need to be a professional test pilot. For common types such RVs, Zeniths, Sonexes, Kitfoxes, etc, etc... most homebuilders of the type who are finished and flying should qualify. For more uncommon types, any commercial pilot or CFI with at least 1000 hours category/class, a variety of models flown, and phase I experience will pass. Breadth of experience will substitute for time in type. Notice that at no point did I mention the credit for test pilot school graduates. It's designed to give those people proper credit but is NOT necessary.

How much will QPs charge? It's up to them but you can use current homebuilt test pilots as a model - anywhere from pro-bono to whatever the market will pay.

With regards to sport pilots qualifying as OPs, see Paragraph 12(a) on Page 15:

[Observer pilot must] Have at least a private pilot certificate with the appropriate category and class ratings for the test aircraft, and have received all necessary endorsements, as required per § 61.31, appropriate to the test aircraft. For light-sport aircraft, have at least a Sport Pilot Certificate and the appropriate logbook endorsements for the category and class of the aircraft to be flown, as required by § 61.317.

By the way, the last draft of the AC is temporarily off the FAA's site, so I'm posting it here if anyone wishes to review it further.

Best,

Tom