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FAA/DERs

 
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PostPosted: Sat Nov 03, 2012 8:59 pm    Post subject: FAA/DERs Reply with quote

Where do I vent?

I've been very patient with the FAA on minor change paperwork. No responses in 5 months.

I've been very patient with the DER on 2 PMAs and an STC. No response in 4 months.

I just about have the PMA for the instrument panel overlays. Would you believe I need to do a stress analysis on the overlay because it's attached to the instrument panel? I have to show that the aluminum is as good as the plastic. The PSCP (the package I send in to approval) is on its 5th revision. For a simple flat piece of decorative aluminum, I need to spend $5,000+ to get approval to make it for a certified airplane.

Gary
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PostPosted: Sun Nov 04, 2012 3:25 am    Post subject: FAA/DERs Reply with quote

And people wonder why so few people fly anymore. It seems many of the faa processes are so archaic or il conceived that the system no longer works. I don't believe that the original intent of the rules was to prevent any changes to a certified bird, but that is what has happened by the design of the system that we must work with. There is a strangle hold on innovation and progress. Aviation is almost frozen in time and the light at the end of the tunnel is fading. Simple changes or even more major changes should not take so much time and expense as is currently required. One should not have to reinvent the wheel for every change. Why not allow a certified category for those who wish to continue to conform to the type cert., and a hybrid experimental for those who wish to deviate from the stock configuration. I'm not suggesting that no testing be done, but rather that if one can reasonably prove the change works then it would be allowed as is done in the homebuilt category. Also one standard applied equally throughout the system would be nice as well. Enough with things being interpreted one way here and another at each of the various offices. For non commercial opps the system is unrealistic. I'm glad that there are at least a few folks left who have the patience to keep trying to make progress. Thanks for your efforts.

Gary L Vogt <teamgrumman(at)yahoo.com> wrote:

Quote:


Where do I vent?

I've been very patient with the FAA on minor change paperwork. No responses in 5 months.

I've been very patient with the DER on 2 PMAs and an STC. No response in 4 months.

I just about have the PMA for the instrument panel overlays. Would you believe I need to do a stress analysis on the overlay because it's attached to the instrument panel? I have to show that the aluminum is as good as the plastic. The PSCP (the package I send in to approval) is on its 5th revision. For a simple flat piece of decorative aluminum, I need to spend $5,000+ to get approval to make it for a certified airplane.

Gary
Sent from my iPad




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deej(at)deej.net
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PostPosted: Sun Nov 04, 2012 12:33 pm    Post subject: FAA/DERs Reply with quote

On 11/4/2012 12:59 AM, Gary L Vogt wrote:
Quote:
For a simple flat piece of decorative aluminum, I need to spend $5,000+ to get approval to make it for a certified airplane.


Which is exactly why the experimental market has seen a significant
increase in the past few years...

-Dj

--
Dj Merrill - N1JOV
Sportsman 2+2 Builder #7118 N421DJ - http://deej.net/sportsman/
Glastar Flyer N866RH - http://deej.net/glastar/


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PostPosted: Sun Nov 04, 2012 1:25 pm    Post subject: FAA/DERs Reply with quote

Buddy,
I understand the 'cover-your-ass' theory. Except, none of the FAA employees can be sued. No one involved in the overlay PMA process thinks they need a stress analysis . . . expect for the structures people at the ACO.
Gary
From: Buddy Cox <buddycox(at)gmail.com>
To: teamgrumman-list(at)matronics.com
Sent: Sunday, November 4, 2012 12:28 PM
Subject: Re: FAA/DERs


Put yourself in the shoes of an FAA employee. The most important thing to him is keeping his job. His mission is to make aviation safer.  His priority it to approve changes that make flying safer. If you have a fix that will solve a problem causing accidents, it will go to the top of his priority list for approval. Changes of a cosmetic nature are way down the list. Every time he signs his name to a change, his job is on the line; it is just safer for him not to approve any changes unless it is one that if not approved can be shown to have caused and accident. He is a little safer if the person that is requesting the change has a reputation of making safe, long lasting fixes versus changes that require SB's or AD's.
A tip I was given many years ago for getting government people to do something: Think of the government employee as a trained, dancing elephant. The elephant does not like to dance and much prefers eating to dancing. To get him to dance, you have to prick his feet with something sharp enough to be painful. Translation: call, write, visit, become a total pain in the ass until you get what you want.
Buddy Cox
On Sun, Nov 4, 2012 at 5:24 AM, Kevin <aa5_driver(at)yahoo.com (aa5_driver(at)yahoo.com)> wrote:
Quote:
--> TeamGrumman-List message posted by: Kevin <aa5_driver(at)yahoo.com (aa5_driver(at)yahoo.com)>

And people wonder why so few people fly anymore. It seems many of the faa processes are so archaic or il conceived that the system no longer works. I don't believe that the original intent of the rules was to prevent any changes to a certified bird, but that is what has happened by the design of the system that we must work with.  There is a strangle hold on innovation and progress. Aviation is almost frozen in time and the light at the end of the tunnel is fading.  Simple changes or even more major changes should not take so much time and expense as is currently required. One should not have to reinvent the wheel for every change. Why not allow a certified category for those who wish to continue to conform to the type cert., and a hybrid experimental for those who wish to deviate from the stock configuration. I'm not suggesting that no testing be done, but rather that if one can reasonably prove the change works then it would be allowed as is done in the homebuilt cat!
 egory. Also one standard applied equally throughout the system would be nice as well. Enough with things being interpreted one way here and another at each of the various offices. For non commercial opps the system is unrealistic. I'm glad that there are at least a few folks left who have the patience to keep trying to make progress. Thanks for your efforts.

Gary L Vogt <teamgrumman(at)yahoo.com (teamgrumman(at)yahoo.com)> wrote:

>--> TeamGrumman-List message posted by: Gary L Vogt <teamgrumman(at)yahoo.com (teamgrumman(at)yahoo.com)>
>
>Where do I vent?
>
>I've been very patient with the FAA on minor change paperwork. No responses in 5 months.
>
>I've been very patient with the DER on 2 PMAs and an STC. No response in 4 months.
>
>I just about have the PMA for the instrument panel overlays. Would you believe I need to do a stress analysis on the overlay because it's attached to the instrument panel? I have to show that the aluminum is as good as the plastic. The PSCP (the package I send in to approval) is on its 5th revision. For a simple flat piece of decorative aluminum, I need to spend $5,000+ to get approval to make it for a certified airplane.
>
>Gary
>Sent from my iPad
>
>
>
>


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le, List Admin.
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PostPosted: Sun Nov 04, 2012 1:25 pm    Post subject: FAA/DERs Reply with quote

Things such as those you speak of are just another example of our out of control government not serving the people. It is really unacceptable and we should not stand for this behavior.

We as a group need to be more vocal in our rejection of bad behavior and service from our government. Don't forget to vote for those who will represent us and vote out those who do not.

Buddy Cox <buddycox(at)gmail.com> wrote:

[quote]Put yourself in the shoes of an FAA employee.  The most important thing to him is keeping his job.  His mission is to make aviation safer.  His priority it to approve changes that make flying safer.  If you have a fix that will solve a problem causing accidents, it will go to the top of his priority list for approval.  Changes of a cosmetic nature are way down the list.  Every time he signs his name to a change, his job is on the line; it is just safer for him not to approve any changes unless it is one that if not approved can be shown to have caused and accident.  He is a little safer if the person that is requesting the change has a reputation of making safe, long lasting fixes versus changes that require SB's or AD's.

A tip I was given many years ago for getting government people to do something:  Think of the government employee as a trained, dancing elephant.  The elephant does not like to dance and much prefers eating to dancing.  To get him to dance, you have to prick his feet with something sharp enough to be painful.  Translation: call, write, visit, become a total pain in the ass until you get what you want.

Buddy Cox

On Sun, Nov 4, 2012 at 5:24 AM, Kevin <aa5_driver(at)yahoo.com> wrote:



And people wonder why so few people fly anymore.  It seems many of the faa processes are so archaic or il conceived that the system no longer works.  I don't believe that the original intent of the rules was to prevent any changes to a certified bird, but that is what has happened by the design of the system that we must work with.  There is a strangle hold on innovation and progress.  Aviation is almost frozen in time and the light at the end of the tunnel is fading.  Simple changes or even more major changes should not take so much time and expense as is currently required.  One should not have to reinvent the wheel for every change.  Why not allow a certified category for those who wish to continue to conform to the type cert., and a hybrid experimental for those who wish to deviate from the stock configuration.  I'm not suggesting that no testing be done, but rather that if one can reasonably prove the change works then it would be allowed as is done in the homebuilt cat!
 egory.  Also one standard applied equally throughout the system would be nice as well.  Enough with things being interpreted one way here and another at each of the various offices.  For non commercial opps the system is unrealistic.  I'm glad that there are at least a few folks left who have the patience to keep trying to make progress.  Thanks for your efforts.

Gary L Vogt <teamgrumman(at)yahoo.com> wrote:

>
>
>Where do I vent?
>
>I've been very patient with the FAA on minor change paperwork. No responses in 5 months.
>
>I've been very patient with the DER on 2 PMAs and an STC. No response in 4 months.
>
>I just about have the PMA for the instrument panel overlays. Would you believe I need to do a stress analysis on the overlay because it's attached to the instrument panel?  I have to show that the aluminum is as good as the plastic. The PSCP (the package I send in to approval) is on its 5th revision. For a simple flat piece of decorative aluminum, I need to spend $5,000+ to get approval to make it for a certified airplane.
>
>Gary
>Sent from my iPad
>
>
>
>


===========
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ooks.com" target="_blank">www.buildersbooks.com
et="_blank">www.homebuilthelp.com
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le, List Admin.
===========
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===========
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===========




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PostPosted: Sun Nov 04, 2012 2:01 pm    Post subject: FAA/DERs Reply with quote

The tip I was referring to came from the wing commander during commander's call.  The wing king stands in front of the crew dogs and answers questions and complaints.  His response was in response to a complaint about not being able to get a new pair of boots from supply.  "I put in a request form 4 months ago and have not gotten any boots yet."  This is just the way government works.  There is no profit motive like there would be if the person was given cash and allowed to buy their won boots.  Milton Friedman, in his book Free To Choose, said their are 4 kinds of spending:
Type 1: Spending YOUR money on yourself-- always the most careful kind of spending
Type 2: Spending YOUR money on someone else -- like a gift, still careful but less so
Type 3:  Spending SOME ONE ELSE's money on yourself-  like an expense account where you demand for 1st class everything
Type 4: Spending SOME ONE ELSE's money on someone else-- government spending always the most wasteful spending.
A government employee will spend $600 on a hammer because it satisfies the specifics of the purchase request.  Buying a cheaper, similar hammer will get them fired where choosing the cheaper on for themselves has no consequences.
 
This is true no matter who is in charge of the government,  There is a pawn shop in my home town HONEST CHARLIE'S.  His sign says "We buy junk; Sell only highest quality merchandise."  Maybe I am a skeptic because I have never bought anything from Honest Charlie.  Political promises are like the promises you make to the wife when you want to buy an airplane.  We will fly to see your Mom all the time and save all kinds of money by not having to stay in hotels.  Once you get the plane, the weather is always too bad en route to Mom's so you just fly to your alumni football games. 
 
If you want the government certification, you have to play by their rules.  Go experiential and loose the government certification; you have a choice.  It is getting to be a closer call.  I prefer the certification.
Buddy Cox
On Sun, Nov 4, 2012 at 3:25 PM, Kevin <aa5_driver(at)yahoo.com (aa5_driver(at)yahoo.com)> wrote:
[quote] Things such as those you speak of are just another example of our out of control government not serving the people. It is really unacceptable and we should not stand for this behavior.

We as a group need to be more vocal in our rejection of bad behavior and service from our government. Don't forget to vote for those who will represent us and vote out those who do not.

Buddy Cox <buddycox(at)gmail.com (buddycox(at)gmail.com)> wrote:

Put yourself in the shoes of an FAA employee.  The most important thing to him is keeping his job.  His mission is to make aviation safer.  His priority it to approve changes that make flying safer.  If you have a fix that will solve a problem causing accidents, it will go to the top of his priority list for approval.  Changes of a cosmetic nature are way down the list.  Every time he signs his name to a change, his job is on the line; it is just safer for him not to approve any changes unless it is one that if not approved can be shown to have caused and accident.  He is a little safer if the person that is requesting the change has a reputation of making safe, long lasting fixes versus changes that require SB's or AD's.
A tip I was given many years ago for getting government people to do something:  Think of the government employee as a trained, dancing elephant.  The elephant does not like to dance and much prefers eating to dancing.  To get him to dance, you have to prick his feet with something sharp enough to be painful.  Translation: call, write, visit, become a total pain in the ass until you get what you want.
Buddy Cox

On Sun, Nov 4, 2012 at 5:24 AM, Kevin <aa5_driver(at)yahoo.com (aa5_driver(at)yahoo.com)> wrote:

Quote:
--> TeamGrumman-List message posted by: Kevin <aa5_driver(at)yahoo.com (aa5_driver(at)yahoo.com)>

And people wonder why so few people fly anymore.  It seems many of the faa processes are so archaic or il conceived that the system no longer works.  I don't believe that the original intent of the rules was to prevent any changes to a certified bird, but that is what has happened by the design of the system that we must work with.  There is a strangle hold on innovation and progress.  Aviation is almost frozen in time and the light at the end of the tunnel is fading.  Simple changes or even more major changes should not take so much time and expense as is currently required.  One should not have to reinvent the wheel for every change.  Why not allow a certified category for those who wish to continue to conform to the type cert., and a hybrid experimental for those who wish to deviate from the stock configuration.  I'm not suggesting that no testing be done, but rather that if one can reasonably prove the change works then it would be allowed as is done in the homebuilt cat!
 egory.  Also one standard applied equally throughout the system would be nice as well.  Enough with things being interpreted one way here and another at each of the various offices.  For non commercial opps the system is unrealistic.  I'm glad that there are at least a few folks left who have the patience to keep trying to make progress.  Thanks for your efforts.

Gary L Vogt <teamgrumman(at)yahoo.com (teamgrumman(at)yahoo.com)> wrote:

>--> TeamGrumman-List message posted by: Gary L Vogt <teamgrumman(at)yahoo.com (teamgrumman(at)yahoo.com)>
>
>Where do I vent?
>
>I've been very patient with the FAA on minor change paperwork. No responses in 5 months.
>
>I've been very patient with the DER on 2 PMAs and an STC. No response in 4 months.
>
>I just about have the PMA for the instrument panel overlays. Would you believe I need to do a stress analysis on the overlay because it's attached to the instrument panel?  I have to show that the aluminum is as good as the plastic. The PSCP (the package I send in to approval) is on its 5th revision. For a simple flat piece of decorative aluminum, I need to spend $5,000+ to get approval to make it for a certified airplane.
>
>Gary
>Sent from my iPad
>
>
>
>



===========
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ooks.com" target="_blank">www.buildersbooks.com
et="_blank">www.homebuilthelp.com
="_blank">http://www.matronics.com/contribution
le, List Admin.
===========
List" target="_blank">http://www.matronics.com/Navigator?TeamGrumman-List
===========
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===========





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BARRY CHECK 6



Joined: 15 Mar 2011
Posts: 738

PostPosted: Thu Nov 08, 2012 6:04 am    Post subject: FAA/DERs Reply with quote

Gary:
What can I say, you just don't talk FAA.
Your lips are not big enough and you don't bend over far enough.
Barry

On Sun, Nov 4, 2012 at 12:59 AM, Gary L Vogt <teamgrumman(at)yahoo.com (teamgrumman(at)yahoo.com)> wrote:
[quote]--> TeamGrumman-List message posted by: Gary L Vogt <teamgrumman(at)yahoo.com (teamgrumman(at)yahoo.com)>

Where do I vent?

I've been very patient with the FAA on minor change paperwork. No responses in 5 months.

I've been very patient with the DER on 2 PMAs and an STC. No response in 4 months.

I just about have the PMA for the instrument panel overlays. Would you believe I need to do a stress analysis on the overlay because it's attached to the instrument panel?  I have to show that the aluminum is as good as the plastic. The PSCP (the package I send in to approval) is on its 5th revision. For a simple flat piece of decorative aluminum, I need to spend $5,000+ to get approval to make it for a certified airplane.

Gary
Sent from my iPad[b]


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