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EAA Input on New Homebuilt Advisory Circular Helps Prevent New Regulations

Dispute Remains Over Use of Accident-per-Hours Measurement

March 31, 2011 —EAA’s input to a new FAA Advisory Circular (AC) that urges transition training for those moving to amateur-built aircraft helped address major areas to improve safety without resorting to additional burdensome regulations. That AC was released by the FAA this week and is the result of a committee co-chaired by Sean Elliott, EAA vice president of regulatory and industry affairs.

 The new AC provides information and guidance to owners and pilots of Experimental category aircraft and flight instructors who teach in them. The document complements FAA’s Amateur-Built Aircraft and Ultralight Flight Testing Handbook, which address the testing of newly built Experimental Amateur-Built aircraft.

EAA is urging members to read and implement the information in the AC to enhance safety for individual aircraft owners and pilots, as well as the amateur-built community as a whole.

“We joined forces to find a way to address the major safety issues for amateur-built aircraft—including first flights, second- and subsequent owner operations, and transition training—without creating new regulations that could hinder this growing segment of aviation,” Elliott said. “Without the input of EAA, AOPA and the Lancair Owners and Builders Organization, it was entirely possible that there would have been more regulations imposed on the amateur-built category.”

EAA continues to dispute one area presented in the AC, however. The FAA continues to use accidents per flight hours in its safety analysis and comparisons of various aircraft types, despite discussion by FAA’s own government/industry General Aviation-Joint Steering Committee that the method is flawed.

 “A flight hour is not a flight hour across the board of all aircraft,” Elliott explained. “Three hours in a corporate jet with one takeoff and landing is not the same as three hours in a GA training or recreational aircraft, where there might be numerous takeoffs, landings, and low-altitude maneuvering within that period. FAA’s continued use of that methodology presents an unrealistic picture of real-world use of various airplanes. We have asked that the FAA, through the GA-JSC, explore better ways to measure the safety record of GA aircraft.”

To ensure the recommended training outlined in the AC is readily accessible, EAA encourages owners/instructors of experimental aircraft to apply for Letters of Deviation Authority (LODA), which allow for compensated training in those aircraft. EAA also encourages FSDOs to support and grant such applications for LODAs. Only with an adequate and easily accessible network of transition training aircraft and instructors will allow the new AC to be truly effective and meet FAA’s GA safety goals.


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