# 10/23 Raptor Video

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#### BillyJ

##### New Member
Was worth a read to help me remember back to where this all started for Peter, Re: Raptor Kit Aircraft

#### Vigilant1

##### Well-Known Member
As with "build for hire" E-AB aircraft, I'd like to see there either be consequences for ignoring the rules, OR a rule change to indicate that the FAA really doesn't give a crap what we do... One or the other...
Amen. Rules that exist but are not enforced are worse than no rules at all. They make folks who play by the rules into chumps. And, they encourage capriciousness on the part of regulators ("piss us off and we've got rules and penalties to make you hurt").
Let us know what the boundaries are, and concentrate enforcement on those fewer, important, boundaries.

#### BoKu

##### Pundit
HBA Supporter
...it's clear that the DAR's verbal indication to Peter is nonsense...
Just curious, is there a realistic probability that the DAR issued revised OLs along the lines of what you'd see for EAB? Is that even possible?

#### WINGITIS

##### Well-Known Member
I've expounded on your comment, and yes - it's clear that the DAR's verbal indication to Peter is nonsense. The OL's will win, no matter what he claims the DAR said or didn't say.

That said, it's also clear that the FAA cares almost not one whit about anything like this unless or until an accident occurs. If Peter has insurance on the plane, it will not be in force, and the FAA would violate him and probably make him take some remedial training. But 99.9% sure this is one of those situations that reinforces stupid decision making since no consequences occur almost any time someone ignores the rules.

I gave him two suggestions on how to do the rest of his flight to ID legally. I don't expect that he'll pay any attention, for the reasons stated above.

And all this pisses me off no end, as I've spent umpteen hours writing Program Letters and creating test areas for the three planes that the company I'm working with (Merlin Labs - recently came out of stealth) is flying in the E-R&D and Optionally Piloted E-R&D categories. We've done everything right, per the book. As with "build for hire" E-AB aircraft, I'd like to see there either be consequences for ignoring the rules, OR a rule change to indicate that the FAA really doesn't give a crap what we do... One or the other...
Merlin Labs, New Zealand offshoot, got 3 Million NZ Dollars from the New Zealand Government a year ago to do autonomous flights between three centers in New Zealand. Supposedly a shovel ready project(Ready to go)

Interesting stuff for sure, I would say certification for testing that here will be just as stringent as in the USA.

K

A couple of the fleet in NZ

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#### BBerson

##### Light Plane Philosopher
HBA Supporter
An EAA Ultralight Council member (will not be named) told the audience at a forum that FAA will not enforce all of FAR 103. They only enforce single seat and 5 gallons fuel, he said.
I don't like this regulation ambiguity because it inhibits legitimate commerce.

Regarding Raptor, 8130.2j seems to have some leeway on the DAR oversight and changes after compliance with 91.319b which only requires "controllable throughout maneuvers to be executed". Full stalls are not normal for canard, I was told, so opinion may vary on that and other things for research aircraft.

(from 8130.2J)
{d. Duration of Assignment to the Flight Test Area.

(1) Duration. Except for amateur-built aircraft and experimental light-sport aircraft (ELSA), there are no specific flight time requirements or guidelines for operation within an assigned flight test area. Judge each case based on the type, complexity, and condition of the aircraft and the complexity of the test. For example, flight testing in conjunction with a minor STC alteration may require only one hour in an assigned flight test area while the initial operation of a prototype jet aircraft or a former-military aircraft may require much more time. In some cases, it may be appropriate to specify the duration as completion of the flight test program, not a fixed flight time.

(2) Finding Compliance. You may amend the operating limitations to permit flight outside of the assigned flight test area after the applicant shows and you find compliance
with § 91.319(b). Your finding may be based on a statement by the pilot in the aircraft maintenance records that the aircraft is controllable throughout its normal range of speeds and throughout all of the maneuvers to be executed and has no hazardous operating characteristics or design features. You may also witness flights or inspect the aircraft if deemed necessary. You may also find compliance based on the FAA-approved procedures of a PC holder or modifier as discussed in paragraph 4-94-9 of this order. Note that an application is required to amend the airworthiness certificate/operating limitations.

e. Phased Operating Limitations. Phased operating limitations are allowed for exhibition, air racing, operating amateur-built aircraft, or operating light-sport aircraft under § 21.191.

(1) Phase I means the initial flight testing period for a newly assembled aircraft, not a newly manufactured or newly built aircraft. Newly manufactured or newly built aircraft must complete initial flight testing comparable to experimental amateur-built aircraft.

(2) Phase II means a period in which an aircraft has completed phase I testing and has not been altered from the tested configuration or flown outside the flight tested envelope.

f. Operating Outside Flight Test Areas. After complying with § 91.319(b), aircraft may be operated outside of an assigned flight test area. Except as provided for in paragraphs 4-9 and D-3 of appendix D to this order, operation of the aircraft outside an assigned flight test area will require issuance of an amended experimental airworthiness certificate with amended operating limitations. }

#### BoKu

##### Pundit
HBA Supporter
...And now it looks like the comments from Marc Z and I on that latest video have been nuked. It could be I'm not looking right, but I tried two different accounts and a private window, and none of them show our comments. Of course, it's his prerogative, but it could be we touched a bit of a nerve.

Maybe I'll keep an eye on FlightAware to see what his next move is.

#### Marc Zeitlin

##### Exalted Grand Poobah
Just curious, is there a realistic probability that the DAR issued revised OLs along the lines of what you'd see for EAB? Is that even possible?
Per Order 8130.2J as quoted by @BBerson in reply 3184, yes - it's possible that the DAR can issue revised OL's, and if they've done so after March (when I got the ones issued in August, 2020), then he could theoretically be legal. But in his response to me in the YT comments section, he clearly stated that he was operating more than 50 miles from Valdosta based on a verbal from the DAR who indicated that all he needed to do was to make a logbook entry after a 40 hour period. None of which is listed in his OL's as being the process to use, as shown in @BBerson's quote from 8130.2J.

Peter needs to not only make a logbook entry entry showing compliance with 91.319(b) (which, of course would be nonsense if he did so, but there's no way for the DAR to know that unless he reviewed all the youtube "testing" videos and knew what he was looking at) but then get amended OL's via an application. Peter did not indicate that he had amended OL's or had applied for them - only that he made a logbook entry. Necessary, but not sufficient.

First time DAR's paid no attention to Order 8130? Hardly - I've had a DAR issue completely nonsensical OL's for an R&D test program, and because I didn't want the FAA to be able to come back and bite us, I indicated what needed to be done to make them compliant with 8130 and useful for the test program so that the FSDO wouldn't have a cow.

Also, I'll thank @BBerson for pointing out that section of 8130, with which I was not familiar. It does give Peter another avenue for being legal, which would be to get amended OL's while staying in R&D, rather than switching to Exhibition, Marketing, or just getting a ferry permit. Good to know.

#### Paul Saccani

##### Member
I've expounded on your comment, and yes - it's clear that the DAR's verbal indication to Peter is nonsense. The OL's will win, no matter what he claims the DAR said or didn't say.

That said, it's also clear that the FAA cares almost not one whit about anything like this unless or until an accident occurs. If Peter has insurance on the plane, it will not be in force, and the FAA would violate him and probably make him take some remedial training. But 99.9% sure this is one of those situations that reinforces stupid decision making since no consequences occur almost any time someone ignores the rules.

I gave him two suggestions on how to do the rest of his flight to ID legally. I don't expect that he'll pay any attention, for the reasons stated above.

And all this pisses me off no end, as I've spent umpteen hours writing Program Letters and creating test areas for the three planes that the company I'm working with (Merlin Labs - recently came out of stealth) is flying in the E-R&D and Optionally Piloted E-R&D categories. We've done everything right, per the book. As with "build for hire" E-AB aircraft, I'd like to see there either be consequences for ignoring the rules, OR a rule change to indicate that the FAA really doesn't give a crap what we do... One or the other...
Yeah. You're doing the right thing, expending a lot of effort to do it, and when the incompetents/scofflaws auger in, who is that then has to cope with increased regulatory oversight - the people, like you, who were never a part of the problem - meanwhile, the incompetents/scofflaws carry on as before. It can be damned unjust to follow the regulations, when so many of those regulations exist precisely because of the conduct of those who aren't going to follow them anyway!

May I ask, within the US FAR, do you guys have something along the line of the Australian special airworthiness category for "Private Operations of Prototype Aircraft", which may be obtained after operating under an R&D SAC for one year? This removes OL for geographical limits, parachute wearing and locking of external stores when parked and most restrictions on who may be carried, but adds a limit of 6 occupants maximum.

#### cheapracer

##### Well-Known Member
Log Member
Interesting twist that they want to give the deposits back.
Simple business tactic. I proposed a long time back in this thread that he needed to do it because it unlocks the fixed price he originally, and somewhat stupidly set.

#### lelievre12

##### Well-Known Member
HBA Supporter
If it's true that all the monies will be returned and contracts nullified, I see that as a way to not have to deliver at the discounted prices for some investors or having to sell kits at the $130K price for the rest of deposit holders. That could save millions if the project ever delivers actual kits down the road. Sorry if that is a dark view. I just don't see any company getting involved in this project financially to "show the world" as PM set out to do originally while losing money at it. Business doesn't work like that and the talk of "open source" and offering components at cost originally were wishful thinking. Here in Silicon Valley there has been sustained and heavy investment in autonomous electric and hybrid powered personal aircraft tech of all sorts. I have personally seen folks like Catto Prop using most of their manpower making custom props for these projects. Or Viking selling some engines to folks making hybrid BLDC generators. My guess is that the value of Raptor would be in its sexy, spacious and futuristic airframe. That could be used as a platform for some of this work. I have no idea what tech we are talking about, however for investors, having a sexy futuristic aircraft in which your secret tech is mounted, is way better than showing the same tech in a repurposed old C337. Better in that you can attract VC money etc. Having lived here I can confirm that 'sexy' and 'futuristic' are going to attract investors as much/more than 'practical' and 'well engineered'. As you alluded, many investors are not that tech minded and go from their 'intuition' rather than know-how. Having been a tech CEO myself, I know that the cost of designing and building a futuristic looking airframe from scratch would far exceed the$\$ probably offered to PM inhale his project. So from where I sit, buying out Raptor and putting it on the front page of my "whatsit tech' slide deck pitching my B Round makes lots of sense to me.

Perhaps we're not going to see 3.0TDI canards sold to mums and dads, but we may see Raptoresque looking air taxis some day.

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#### Vigilant1

##### Well-Known Member
Here in Silicon Valley there has been sustained and heavy investment in autonomous electric and hybrid powered personal aircraft tech of all sorts. I have personally seen folks like Catto Prop using most of their manpower making custom props for these projects. Or Viking selling some engines to folks making hybrid BLDC generators.

My guess is that the value of Raptor would be its sexy and futuristic airframe that could be used as a platform for some of this work.
Wow. Replacing the Raptor's IC engine with an IC engine, generator, batteries, electric motors, etc to create a "hybrid' won't do much to solve the prototype's existing weight problem.
It will have to be autonomous, it won't have enough remaining useful load to carry a pilot.
But, you are probably right: bought to be a prop. IMO, technically competent investors probably won't be attracted by the decision.

#### Hot Wings

##### Grumpy Cynic
HBA Supporter
Log Member
But, you are probably right: bought to be a prop.
I seem to remember he was converting his CAD from SW to some other format for the future developers to use?
If the new investors are looking for just the "shape" his software has some value as well.

#### ToddK

##### Well-Known Member
HBA Supporter
Merlin Labs, New Zealand offshoot, got 3 Million NZ Dollars from the New Zealand Government a year ago to do autonomous flights between three centers in New Zealand. Supposedly a shovel ready project(Ready to go)

Interesting stuff for sure, I would say certification for testing that here will be just as stringent as in the USA.

K

A couple of the fleet in NZ
Anyone foolish enough to trust their lives and property to autonomous aircraft with no human pilot deserves whatever tragic fate befalls them. The same goes for the investors who dump money into this nonsense.

#### 231TC

##### Well-Known Member
Anyone foolish enough to trust their lives and property to autonomous aircraft with no human pilot deserves whatever tragic fate befalls them. The same goes for the investors who dump money into this nonsense.
Pilot error causes a whole lot of fatal crashes and we haven't stopped trusting human pilots with our lives. Autonomous aircraft will certainly kill some people. My bet is it will be fewer than human pilots do. But I'll still take the risk of flying myself simply because it's fun.

#### WINGITIS

##### Well-Known Member
Anyone foolish enough to trust their lives and property to autonomous aircraft with no human pilot deserves whatever tragic fate befalls them. The same goes for the investors who dump money into this nonsense.
It certainly raises issues such as "MID AIR COLLISIONS" with other aircraft that do not have onboard radar/lidar.

BUT in New Zealand now we have a "RISK AVERSE" leadership coven who want control of everything and to suppress anything that is a freedom based activity if it has ANY RISK AT ALL.

So New Zealand I believe has signed up to the "automated digital skyways" initiatives which are also rushing forwards in many juristictions around the world...mostly to cater for electric taxis.

So automation of air vehicles may just happen anyway, as it appears it could for road transport vehicles in the future. Hence tech companies rush in to take the funding available from whichever source.

The Raptor diesel idea would be gone anyway because the leadership here is progressively banning fossil fuel use as a future option anyway!

Many of these automated technology initiatives do not pan out and could be easily seen in advance as NON STARTERS, others will be successful, it is always hard(for some) to see which is which....

It was a great publicity stunt, but did not continue.

#### BJC

##### Well-Known Member
HBA Supporter
Pilot error causes a whole lot of fatal crashes and we haven't stopped trusting human pilots with our lives.
There have been some recent crashed that have been attributed to software problems. I would trust a USA-trained pilot over any software development team.
But I'll still take the risk of flying myself simply because it's fun.
Yup, that is what we do.

BJC

#### PPLOnly

##### Well-Known Member
There have been some recent crashed that have been attributed to software problems. I would trust a USA-trained pilot over any software development team.
Yup, that is what we do.

BJC
Look at the safety record of modern aircraft, the incredible drop in major accidents over the last few decades is directly related to automation. Any airliners is full of software and computers, your blanket statement is ridiculous.

#### John Halpenny

##### Member
Look at the safety record of modern aircraft, the incredible drop in major accidents over the last few decades is directly related to automation. Any airliners is full of software and computers, your blanket statement is ridiculous.
Is automation better than the best pilot, at the top of his form? Possibly not. Is it better than one of the slower pilots, after a bad day? Very definitely yes.

John

#### mcrae0104

##### Well-Known Member
HBA Supporter
Log Member
Look at the safety record of modern aircraft, the incredible drop in major accidents over the last few decades is directly related to automation. Any airliners is full of software and computers, your blanket statement is ridiculous.
No blanket statement was made (e.g., "All recent crashes can be attributed to software problems") so that argument falls flat right there.

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#### Topaz

##### Super Moderator
Staff member
Log Member
Look at the safety record of modern aircraft, the incredible drop in major accidents over the last few decades is directly related to automation. Any airliners is full of software and computers, your blanket statement is ridiculous.
Gently, please. We can disagree without being antagonistic.

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