LSA Weight to be 3600 Pounds soon !!!

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BBerson

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'm no attorney, but I understand that 2700 lbs is the limit for an aircraft built from a kit, and, although the Raptor will ultimately be built from a kit, the prototype, for all intents and purposes, was not. Which would explain why he hasn't been busted by your friendly FDSO rep.
Raptor kit has nothing to do with 21.24 (issuance of a type certificate)
 

Dana

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Is there a summary somewhere for people who don't want to sit through a video?
 

cblink.007

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Raptor kit has nothing to do with 21.24 (issuance of a type certificate)
If you can explain for my understanding/clarification/education, I would be most appreciative, because 21.191, 21.193 & 21.195 pointed at 21.24...with respect to kits. So, am I correct that, in the context that I think you and I are agreeing on, that "one-offs", ie R&D and prototype aircraft, are not bound by the weight and or seat restriction?

Just wanting to make sure I understand all this correctly...
 
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cblink.007

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1st I've heard about a 2700 lb limit on kit planes. Where'd you see that? The Murphy Super Rebel/Moose has a 3500 lb gross, IIRC.
Same for me...but read regulations last night. I am inclined to think this 2700 (as well as the 4 seat limit) is for LSA aircraft only, and not E-AB, kit or otherwise, to include one-offs, prototypes, R&D birds, etc, but I am not 100% sure that I am understanding it correctly. It would be awesome if a member here who understands these particular regulations can explain...because I want to understand it more clearly!!
 

BBerson

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If you can explain for my understanding/clarification/education, I would be most appreciative, because 21.191, 21.193 & 21.195 pointed at 21.24...with respect to kits. So, am I correct that, in the context that I think you and I are agreeing on, that "one-offs", ie R&D and prototype aircraft, are not bound by the weight and or seat restriction?

Just wanting to make sure I understand all this correctly...
21.24 is strictly Primary category. Your misunderstanding is that Raptor is not applying for a Primary category type certificate. Nor does the 2700 pounds limitation apply to any other category.
I think a Primary type certificate holder does have the option to offer a 99% complete kit. That kit criteria only applies to Primary category under 21.191 (h). The builder can apply for an "operating Primary kit-built" experimental certificate. (not the same as 21.191(g) for EA-B)
 
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gtae07

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No, the reference in 21.191(h) to 21.24(a)(1) is for aircraft certified (i.e. with a type certificate) in the Primary category, assembled from a kit produced by the holder of a Production Certificate for that kit, but not assembled under the supervision and QC of that PC holder (there was also an option to assemble the kit under that supervision and get a standard airworthiness certificate instead of experimental, if I’m reading it right). I can’t think of any E-AB aircraft that are derived from/copies of an aircraft certified in the Primary category. Therefore, this has no application whatsoever to E-AB or LSA.

Reading through AC 21-37 and Order 8130.2, it looks like this was an early prototype form of a blend of S-LSA and the proposed PNC rules from several years ago. It probably went nowhere because the “simplified” certification process probably wasn’t any less onerous—the vast majority of Part 23 still had to be met (it just seems like it was less duplication of testing/documentation?), you still needed a production certificate, and there was no real maintenance benefit because you were still under the yoke of rigid configuration control and even after training, owners could only do a few additional maintenance tasks. So, just like with single-seat S-LSA and low-performance S-LSAs, the manufacturers overwhelmingly decided that since full standard-category Part 23 certification was just a little bit more money but opened up a lot more potential for sales, nobody bothered with it.

If MOSAIC lives up to all our hopes and dreams and the PNC proposal gets implemented, then maybe Primary category will go somewhere. But I think it’s just basically become obsolete, between LSA and increasing E-AB popularity.
 

cblink.007

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No, the reference in 21.191(h) to 21.24(a)(1) is for aircraft certified (i.e. with a type certificate) in the Primary category, assembled from a kit produced by the holder of a Production Certificate for that kit, but not assembled under the supervision and QC of that PC holder (there was also an option to assemble the kit under that supervision and get a standard airworthiness certificate instead of experimental, if I’m reading it right). I can’t think of any E-AB aircraft that are derived from/copies of an aircraft certified in the Primary category. Therefore, this has no application whatsoever to E-AB or LSA.

Reading through AC 21-37 and Order 8130.2, it looks like this was an early prototype form of a blend of S-LSA and the proposed PNC rules from several years ago. It probably went nowhere because the “simplified” certification process probably wasn’t any less onerous—the vast majority of Part 23 still had to be met (it just seems like it was less duplication of testing/documentation?), you still needed a production certificate, and there was no real maintenance benefit because you were still under the yoke of rigid configuration control and even after training, owners could only do a few additional maintenance tasks. So, just like with single-seat S-LSA and low-performance S-LSAs, the manufacturers overwhelmingly decided that since full standard-category Part 23 certification was just a little bit more money but opened up a lot more potential for sales, nobody bothered with it.

If MOSAIC lives up to all our hopes and dreams and the PNC proposal gets implemented, then maybe Primary category will go somewhere. But I think it’s just basically become obsolete, between LSA and increasing E-AB popularity.
Thanks gents. Makes logical sense!
 

cblink.007

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21.24 is strictly Primary category. Your misunderstanding is that Raptor is not applying for a Primary category type certificate. Nor does the 2700 pounds limitation apply to any other category.
I think a Primary type certificate holder does have the option to offer a 99% complete kit. That kit criteria only applies to Primary category under 21.191 (h). The builder can apply for an "operating Primary kit-built" experimental certificate. (not the same as 21.191(g) for EA-B)
Makes perfect sense, thank you! Leads to the question of how some of these '2 weeks to taxi' programs satisfy the "major portion" of the fabrication on the part of the owner-builder. Are the manufacturers people merely 'directing' the entire build, with the builder following their lead, and you simply declare it on the FAA 8130-12? One of my closest friends is a SJA attorney, and even he asks me how a company like Lancair threads the loophole on this! I reply by telling him that I am just a humbled aero engineer, not a lawyer; therefore it follows the rules!
 
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rv7charlie

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Having done all the 'construction' on an RV7 (minus the forward top skin), I can tell you that I probably have 10 'units' of puzzling out the plans, searching for parts on the parts list, then searching for them on the shelf, setting up wing jigs, etc etc, for every 'unit' of actual 'fabrication and assembly'. And that's for one of the better-done kits.

I use 'unit' instead of 'hour' because time is not a factor, in the eyes of the FAA. The FAA speaks of 'fabrication and assembly' *tasks*; puzzling, parts hunting, figuring out, etc are not 'tasks' in the actual fabrication and assembly of a homebuilt. You're either making a part, or assembling the part to other parts.

If someone who had all the jigs & tools ready, in a perfectly laid-out workspace, was looking over my shoulder, telling me exactly how to perform each task in the most efficient manner, handing me exactly the right tool at exactly the right time, checking off the items in the assembly manual, etc, they wouldn't be participating in any of the 'fabrication and assembly', but they would have saved me *years*.

The above is nothing like the hired gun build shops where the owner has only proverbial P 51 time (if you're too young, google it in relation to 'logbook').

My *opinion*, is that for all the abuse the FAA takes, they have realized that the more fabrication/assembly done in a 'professional' (in the sense of 'high quality') manner, the safer the resulting plane is likely to be. The result of this over the years is that they've adjusted their attitude when *interpreting* their own 51% rule. Ex: At one time, the RV6 quickbuild kit came to the builder, one rib shy of a full set. To meet the fabrication section of the rule, the builder had to make one rib. That's no longer the case with later kits. There's still some fabrication of brackets & such, but the QB kit is now primarily assembly, with the vast majority of that already done at the factory. Riveting a couple of skins satisfies the riveting 'task'. You don't have to do *all* the riveting to satisfy that 'task'; you just have to rivet. Make sense?

There's at least one company that's been approved by FAA to approach it from the other direction. When you participate in their build assist program, you come to the factory, you fabricate the parts by loading materials into the fab machines, pushing the 'start' buttons, etc, then go home while they assemble the pieces.

Result, in either case, is much more likely to be a safe a/c, which meets one of the FAA's prime directives. The arbitrary '51' number in the 51% rule has always been a political artificial construct to let us build while satisfying certain lobbying money, and avoiding conflict with existing design/production FARs; the FAA just works with it while 'interpreting' it.

Charlie
 

Hot Wings

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Is there a summary somewhere for people who don't want to sit through a video?
I understand the not wanting to use the time - Webinars being the most inefficient method of communication invented by man.
It could have all been said in 25ish minutes but it is worth watching with liberal use of the click forward method.....IMHO
 

TFF

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I’m wondering what the thought process is on the FAAs side? Sounds like a be careful for what you ask for regulation.

Schweizer I-26 kit gliders received certified airworthiness certificates in the day, just like the factory ones. You might have put it together but you needed an A&P to maintain it. With the FAA there is always a feedback loop. They tend to make rules worse not better. It also tends to be exclusionary, we give you this if you give up that. The hope is to get you away from the “that” thing, like controlled airspace or altitude or type of airplane.
 

gtae07

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Having done all the 'construction' on an RV7 (minus the forward top skin), I can tell you that I probably have 10 'units' of puzzling out the plans, searching for parts on the parts list, then searching for them on the shelf, setting up wing jigs, etc etc, for every 'unit' of actual 'fabrication and assembly'. And that's for one of the better-done kits.
Yep. Looking for the tool I just set down, looking for parts, going to get parts, staring at things thinking “how exactly do I want to do this?”, online research... lots of ”non-productive time” spent. And that’s not even counting the cleanup and setup, and the mental-reboot cycle that happens each time I go back out to the shop. You can get a whole lot done in a couple weeks of long uninterrupted build sessions.

My *opinion*, is that for all the abuse the FAA takes, they have realized that the more fabrication/assembly done in a 'professional' (in the sense of 'high quality') manner, the safer the resulting plane is likely to be. The result of this over the years is that they've adjusted their attitude when *interpreting* their own 51% rule...

Result, in either case, is much more likely to be a safe a/c, which meets one of the FAA's prime directives. The arbitrary '51' number in the 51% rule has always been a political artificial construct to let us build while satisfying certain lobbying money, and avoiding conflict with existing design/production FARs; the FAA just works with it while 'interpreting' it.
Full agreement here. As an aircraft systems engineer by profession I gripe a bit about the rule being so heavily tilted to structure, but this is pretty much exactly what the FAA is thinking.

I’m wondering what the thought process is on the FAAs side? Sounds like a be careful for what you ask for regulation.
I think the thought process is that the FAA only has limited resources (time, money, manpower) and would rather spend them focusing on commercial aircraft, especially in the wake of the MAX debacle. The E-AB and LSA communities have done a good job showing the FAA that we can still be relatively safe even without all the rules, so the FAA is willing to relax the rules some—with the unspoken message being “don’t **** this up, or else”. By deregulating a category of aircraft larger than current LSAs but still well within the “personal light aircraft” category, they free up those resources and reduce their liability exposure. We get more new airplanes and some relaxation of some rules. I reserve final judgment until the Final Rule is issued, but this looks like a win to me.
 

PagoBay

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“Your faithful, apolitical, bureaucrats are working hard on doing what is best for you. We will finish when we are finished.”
BJC
Not quite. As Dan says, the finish deadline was imposed by Congress. Otherwise, God only knows when this would get a conclusion.

Also:
Dan mentions at the end and only ever so briefly about a change in professional build support. I have emailed for more information.
 

gtae07

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Is there a summary somewhere for people who don't want to sit through a video?
 
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