EAA Government Advocacy
EAA continues to work hard on these issues and others of importance to EAA members and other aviators. There is strength in numbers, not only in EAA member participation but also in joining with other aviation groups and important allies such as the general aviation caucuses in the House and Senate.
- Defending the Future of Homebuilts: More Regulation Does Not Mean More Safety
- EAA Joins Fight Against New Mexico Seaplane Ban
- Repair Station Proposal Could Be Costly
- The Final Word: sUAS Regulations On the Horizon
There's one goal everyone agrees on: Continuing to improve and enhance safety in all of aviation, including amateur-built aircraft, is a top priority. Without improving safety, all the rest of our flying rights and privileges in homebuilts and other aircraft are open to further scrutiny and regulation.
Since the National Transportation Safety Board released its study and 16 recommendations for improving amateur-built safety on May 22, EAA has been reviewing and analyzing those recommendations and what they could mean to individuals who want to build and fly aircraft. EAA officials have talked with the volunteer members of our Homebuilt Aircraft Council as well as to those in the industry, the flying community, and government about the possible ramifications of those NTSB recommendations.
If we do not improve ground and flight safety or create cultural, technical, and educational opportunities to do so, it could bring more regulation. That would hamper those who want to become part of the homebuilt community and hurt all of us in the long run. EAA has always maintained education is more effective than regulation to raise the safety bar. That's why we're working with the FAA General Aviation Joint Steering Committee, type clubs, kit manufacturers, and others to develop and improve safety programs. EAA also formally commented to the FAA in October on where we agree and disagree with the NTSB.
EAA agrees with some of the 16 NTSB recommendations, including:
- Encouraging additional flight training prior to conducting flight tests or transitioning into a new amateur-built aircraft.
- Partnering with the FAA to create a current listing of individuals who make their amateur-built aircraft available for flight training.
- Identifying when a second pilot may be allowed on a test flight as a safety observer.
- Building a coalition of kit manufacturers, type clubs, and others to build "best practices" guidance for those who fly homebuilt aircraft.
There are other recommendations where EAA disagrees, because it would create cost, paperwork, and/or technical requirements that would keep people away from building and flying aircraft. Those where we disagree and have made recommendations to accomplish the goals in a different manner include:
- Mandated functional test of aircraft fuel systems.
- Required FAA approval of initial and completed flight-test programs.
- Compulsory use of electronic data recording during test flights.
- The requirement that an aircraft owner must create an aircraft flight manual before moving into Phase 2 operations.
EAA's Technical Counselor and Flight Advisor programs are essential building blocks to improve safety. We'll be refining and improving those programs so they are even more effective for those who use them.
What can you do? Think safety and act safely at all times by doing such things as:
- Always seek transition training before test flying or flying any unfamiliar aircraft.
- Stay proficient as a pilot while building an aircraft.
- Don't be a test pilot unless you're qualified and current in that make and model of aircraft.
Finally, be a high safety standard for others at your airport. EAA will do its part to protect the future of amateur-built aircraft, but all involved must also play a role in continually improving safety. Our actions now will determine our freedoms in the future.
Earlier this autumn, the state of New Mexico slipped a line item into a proposed revision of its Administrative Code that stated simply and definitively, "The taxiing, landing or takeoff of seaplanes or floatplanes is prohibited in the state parks system." New Mexico is not a land of many lakes, but those that are accessible to seaplane operations fall under the jurisdiction of the state park system. Thus, this regulation has the very real potential to close seaplanes to the entire state.
Upon learning of the proposal, the aviation community sprang into action. EAA joined AOPA, the Seaplane Pilots Association, and many others in submitting written testimony to the New Mexico State Parks Division opposing the measure. EAA members also responded enthusiastically to requests by the Advocacy and Safety team to submit their own comments.
New Mexico holds considerable importance in the seaplane community as a vital link in the only year-round cross-country route for aircraft on non-amphibious floats. Aircraft using the Mississippi River System to make such a trip must make at least one fuel stop in the state. The ban also makes no exception for firefighting amphibious aircraft, posing a dangerous and completely avoidable risk to New Mexico residents and their property.
In its letter, EAA addressed the state's concern that seaplanes are a potential threat to public safety and can transport invasive species. The comments point out that seaplane pilots are highly trained aviators who have an exceptional record of safely sharing the water with boaters. In addition, owners of seaplanes have as much interest in protecting the water as any other user, and organizations such as the Seaplane Pilots Association have developed effective ways to mitigate the spread of invasive species by airplane.
EAA is confident that the aviation community can and will work with the state of New Mexico to address any concerns it may have without such a draconian and unprecedented regulation as banishing an entire group of aviators from the state.
The FAA has published proposed regulations that dramatically alter the rules governing more than 4,000 repair stations of all kinds, including those that serve general aviation. The proposals are believed to have a significant economic and administrative impact on these repair stations, most of which are very small businesses, and have particular impact on the instrument and avionics segment of the industry.
EAA is very concerned that the direct and indirect costs of complying with the proposed rules will drive many small repair stations out of business, further constraining an already depressed general aviation service industry that is the backbone of sport and recreational aviation maintenance. We filed comments by the November 19 deadline.
The Final Word - Sean Elliott, EAA Vice President of Advocacy and Safety
sUAS Regulations On the Horizon
sUAS STANDS for Small Unmanned Aircraft System. UAS is the current term for what we have called UAV or unmanned aerial vehicle, or even more commonly a drone. The unmanned aircraft business hates the word drone, but it is the term commonly used by the public and general news media.
These small aircraft are built in a huge range of types including rotary-wing and fixed-wing aircraft. Use for these UASs range from aerial photography for realtors, for example, to surveillance by law enforcement, to news media looking for traffic bottlenecks to report. It is an industry that is growing big and growing fast!
The FAA has recognized the following three facts: 1: The national airspace system is ever increasing in congestion and complexity. 2: There is a proliferation of sUASs being rapidly developed for commercial and public use. 3: Advancements in technology/performance of unmanned aircraft of all types is necessitating the need for new regulation.
The process for integrating UASs into the airspace system began when the FAA established an aviation rulemaking committee (ARC) in 2008. A recommendation from the ARC was submitted to the FAA in March of 2009, and the agency has been developing an NPRM (new set of proposed rules) since that time.
The proposed NPRM has the potential to have a far reaching impact on many types of recreational aviation. It appears that part of the scope of this new set of regulations might even include model aircraft. That's right, RC, control line, and even free-flight models that many of us enjoy right along with full-size aviation in our life might now be subject to new FAA regulations.
EAA is also watchful for how these new regulations will impact our airspace system. Obviously, until the NPRM is published, we don't know for sure what the actual ramifications will be. However, it is important for you to have awareness of the pending proposal and be ready to react should it include troubling elements.
EAA has been working with the Academy of Model Aeronautics (AMA) as the lead organization on the issue. AMA is a 147,000 member strong association with nearly 2,000 AMA chartered clubs across the country! It has done a fantastic job of advocating on behalf of its membership with both the agency and members of Congress.
EAA will continue to work in collaboration with the AMA once the NPRM is published. The publishing date of the NPRM has been pushed back several times, and we are currently anticipating a date of release early in 2013. Our goal will be to fully understand and react to the potential downsides of the proposed regulations in a coordinated fashion. The EAA and AMA have many parallels amongst our respective memberships, and supporting each other's communities will benefit all of us. After all, grassroots aviation has no limitations when it comes to the scale of the airplane!
EAA's Government Relations department works to preserve the freedom of flight and reduce the regulatory barriers affecting affordability and access to EAA members’ participation in aviation. Protecting the freedom to fly is the foundation on which all of the organization’s advocacy initiatives are built. EAA fights to preserve this freedom by providing clear solutions and practical alternatives backed by hard work and dedication. EAA’s history of success is a testament to that philosophy.