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Amendment and Revision to Kit Building Rules - Where's the

 
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Deems Davis



Joined: 09 Jan 2006
Posts: 925

PostPosted: Sat Feb 23, 2008 8:06 am    Post subject: Amendment and Revision to Kit Building Rules - Where's the Reply with quote

Thanks for the insight Dave, and Thanks also for volunteering to spend
your time on this issue. I'm just another 'special interest' that
doesn't' want the abuses of a few to end up limiting or restricting the
abilities of the critical amateur mass. Having already written and sent
my letter, I'll calm back down and now wait for the NPRM and hope that
the right things happen.

Deems Davis # 406
'Its all done....Its just not put together'
http://deemsrv10.com/

Dave Saylor wrote:
Quote:


Deems,

The ARC did agree on a few things. We agreed that flagrant pro building
exists and that it should not, and we agreed on several fixes to the current
system.

Where we disagreed most significantly was in how to define the major
portion. No one thought we should count hours or dollars. No one wanted a
rivet (epoxy/thread/grain) count. I believe the rule was poorly written and
has somehow managed to serve us anyway. A lot of credit for the success of
the current situation is, I believe, that initially there was not any real
financial incentive to pro building. Back in the day you could buy a nice
plane for less effort than you or a pro could build one. When that equation
started to change, pro building became worthwhile and there wasn't anyone
enforcing the fact that it was not within the rules. It was a cottage
industry.

Now that there is real money involved (several hundred million dollars by my
accounting--very little mine >Sad), you are correct in that the parties at
the table mainly had their interests in mind. Everyone wants it to work for
himself after it all shakes out. You are also correct in that the committee
was pretty well balanced in terms of personalities so that no one party
emerged as the leader for the rest of us to rally around. I don't think
that was intentional when the committee members were selected. I think the
FAA wanted a broad and representative sample of the industry and that's what
they got. Earl Lawrence from EAA was helpful and did stand up for its
membership and the industry as well as he could, especially considering that
a workable definition of "major portion" is such a slippery critter.

I think there is an elegant solution that has not yet surfaced. I hope that
with more input from more people it will show itself. I don't really think
that amateur building is in much danger. Violaters will probaly not be
tolerated much longer, but those who've gotten away with it so far, I think,
are pretty safe. FAA lawyers made it pretty clear that pursuing what's
already happened under current conditions would be difficult to impossible.

Write those letters!

Thanks for listening,

Dave Saylor
AirCrafters LLC
140 Aviation Way
Watsonville, CA
831-722-9141
831-750-0284 CL
www.AirCraftersLLC.com




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