rgf(at)dcn.davis.ca.us
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 Posted: Sun Sep 14, 2008 3:57 pm Post subject: RV-List: FAA Proposed Rule Changes |
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From VAF.
I read the postings by Van and the EAA about the NPRM. Vans shows why he's the man and most of us just gawkers:
"As always, name-calling and vague gripes serve no purpose other than to help convince the FAA that we are a bunch of idiots."
- The proposed rule has nothing to do with accommodating pro-built planes, even though some of us, maybe including me, think that should be allowed. Probably the FAA would need a directive from Congress to address that. So no point in mentioning such potential accommodation in a response.
- Van again: "Unless the FAA sees a serious safety reason, they will not re-evaluate existing kits that have previously been found to meet the major portion rule." So most of us are good now. Of course we can still comment for the sake of future kit designs, but I see no problem for future builders of today's kits.
- Aside from some relatively minor changes for clarity, the only change I'd like to see is a further definition of "fabrication" and percentage: by time? by task? Unlike the EAA and others, I think the further refinement of what constitutes an amateur built aircraft is welcome, or at the very least, simply not a big deal. I find it very unlikely that a legitimate amateur builder now will not be legit with these new rules. It might be a little more onerous documenting one's work, but I think better logging of work is to the good.
- My guess is that in addition to wanting to halt the blatant pro-building, the FAA wants to head off a potential future problem: well-meaning amateur builders getting more and more pre-fabbed parts until only assembly, not fabrication, is done. I think such concern is fair and even forward-thinking, contrary to some stereotyped responses here.
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