I think someone's April fools day joke slipped out early...
BeechboyA36......where did you see this, exactly?
I think someone's April fools day joke slipped out early...
BeechboyA36......where did you see this, exactly?
I have seen it too Marty.. can;t say where for various reasons, but I can assure you it is 100 percent serious. One of those things though, if people want something like this - then they need to voice their opinion loudly.
But I have to ask too - Beechboy, where exactly did you get this?
Some really asinine thinking in that document. Especially considering the FAA came unglued when Canadian O-M aircraft, which have more restrictive rules than proposed, tried to fly in the US. I really can't believe someone would let this drivel out to the public. It looks like it was written by someone who couldn't be bothered to build, but just wanted to mod his Cessna and have even less restrictions. Instead of a well thought out plan with sound reasoning, it reads like a bunch of rednecks who want to hot rod their planes and pull the wool over the public's eyes.
One nugget of stupidity:
"Owners can “opt out” of Airworthiness Directives at their discretion."
One can argue all day about whether a switch from Napa is better than a 80 year old used replacement, but to let someone "opt out" of say, a critical wing attachment AD is ludicrous. This site is a prime example of people that would spend a few grand on an auto pilot, but use the cheapest fuel line money can buy to save a few pennies. Do we really need some cheap owners flying clapped out, fatigued Tomahawks with no AD's done over our houses because they think it's their god given right?
Which is followed by:
The name “non-commercial” was chosen deliberately to accomplish several goals
1. It does not carry the same connotation or public stigma as “Experimental” – the general public does not have
the same fear of ‘non- commercial” aircraft flying over their neighborhoods as they do experimental aircraft.
2. It would make it far more difficult for municipalities to ban Experimental AB aircraft – with this change of designation they would have to ban all Non Commercial aircraft. This would be considerable harder if not impossible because the new name does not invoke the same level of public reaction.
3. This same concept carries over to Non-Commercial (TC) aircraft – there is very little public fear to leverage to require unwarranted operational restrictions.
It SHOULD carry the same or worse stigma as Experimental. When you allow someone to fly an aircraft with a known safety issue that warranted an AD, you are saying that the defect wasn't serious in the first place, or that you condone unsafe aircraft flying over neighborhoods. If the public can get riled up over lead in avgas, they can get riled up over unsafe aircraft flying overhead. Using the Non-Commercial moniker unfairly stigmatizes private owners that want no part of that category. If a municipality wanted to ban experimentals due to safety, with the new category wording they would just ban ALL small planes.
This proposal needs to die. Quickly.
Well, if it's a proposal to the ARC, has it been proposed yet? It is going to be proposed on April 1? The Part 23 ARC will be reviewing part 23 and supposed to make recommendations by Feb. of 2013. Have they discussed/debated the proposal yet? Does it fit in with the commitee's direction? Okay, say it makes it to the NPRM stage. The FAA will have to open a comment period. I'll certainly be sure to comment in support of such rule changes but it needs major, major clean up work. I think it's a long, very long shot in the dark.
Last edited by martymayes; 03-25-2012 at 07:43 PM.
IMHO changing the aircraft's airworthiness certificate to a "PRIMARY " aircraft would suit the purpose better. Trained pilot/owners could then return their aircraft to service with out supervision.
READ CFR 21.24 // and change this para to read a sensible number
(1) The aircraft—
(i) Is unpowered; is an airplane powered by a single, naturally aspirated engine with a 61-knot or less Vsostall speed as defined in §23.49; or is a rotorcraft with a 6-pound per square foot main rotor disc loading limitation, under sea level standard day conditions;
Last edited by Tom Downey; 03-25-2012 at 08:27 PM.
There is a guy in Fort Worth who has an STC for C-150/2 aircraft changing them to primary category aircraft. I seem to recall he was intending to seek primary category STCs for a number of aircraft but the project apparently stalled during the base to final turn.
Sorry in advance for such a long post...
I have often thought that it would be nice if there was a way to convert older aircraft to an experimental category (or at least to an experimental category with more freedom than research, exhibition, or racing). I think this is a good way to get the discussion going, but I think there are some major flaws in this proposal.
1. I don't think that "non-commercial" is the right term, and the FAA and aircraft manufacturer's lawyers aren't going to allow it for liability reasons. Experimental is the right word, but we need to keep on supporting the EAA and their local chapters as they continue to help the public understand that it isn't a bad word.
2. If you stick with the current proposal, I think that all AD's are going to have to be complied with. Not mitigating the risk is just idiotic. I do think that there is going to be a point where it is going to be difficult to determine which AD's need to be applied to a highly modified aircraft.
3. I don't think you are going to have a path back to a standard category aircraft under this proposal. The reason that research planes have that ability is because the item/change that has made the aircraft non-compliant is specifically recorded by a certified mechanic and they are supposed to be actively trying to get the aircraft back into a certified status. Without any training (and personal risk of losing license/livelihood/etc), there is no way that a pilot/owner is going to make sure that all maintenance/mods are recorded. And, there is no IA in their right mind that would sign off that they have checked an aircraft and determined that every single component of an aircraft has been returned to a certified status on a plane that has had free-reign for any amount of time.
4. You're going to have to get aircraft manufacturer's to buy into this somehow. If their name is going to still be on the aircraft, they are going to have to battle the widow in court. My guess is that at minimum you are going to have to completely obliterate their name from the aircraft (again, making it hard to ever return to standard category).
5. Then you'll have the FAA hot button issue of counterfeit parts. If you open up a market for a whole bunch of people who want to build faux-Cessna parts for these new experimentals, how will it be controlled so that they don't "accidently" get marked with the original part number and get sold as the real-deal? Or, if the plane is disassembled in the future, how will someone know that the "Piper wing" that is for sale was internally modified one time with a non-certified part, and is structurally not safe for use on a damaged Cherokee. There may be some risk of this currently, but the 51% rule mitigates some of that risk.
6. In addition, there may be some unforeseen backlash to all of this, as we've had a rare gem in the aviation world that companies like Cessna have still produced parts for 60+ year old aircraft. Who is to say that they don't use this to force all aircraft over 10 years old to go to the experimental class to avoid liability? That would make flight training and new aircraft ownership even harder to obtain for a low cost.
7. Don't expect a lot of A&P's to come running to get your business. There is limited risk in signing off an aircraft that has the records to indicate that it has been kept in accordance with the manufacturer's specifications. At least with Ex-AB, someone's name is listed as a manufacturer.
I think you really have two options to get close to what you want:
A. If you want the owner-maintenance portion; Propose a new experimental category that allows less than 51% amateur building. You'd have to obliterate all original manufacturer's markings, and then apply for a new registration under the new Experimental - Amateur Assembled (or whatever) category. (Big hurdles and impacts to consider with this one, not to mention it still doesn't provide an answer to some of the issues listed above).
B. If you just want to be able to upgrade items without STC's and testing; Alter the proposal to eliminate the owner maintenance portion and open up the Experimental - Research & Development category for people who aren't actively trying to return the aircraft to a completely certified state. You'd simply allow the certified mechanic to maintain a list of non-TSO/certified parts that are currently installed in the plane within the log-books. And, like present day, you may find a mechanic that knows/trusts you, and would allow you to perform some of the work yourself.