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FAA Proposed Rule Changes

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jhs_61(at)yahoo.com
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Posted: Sun Sep 14, 2008 1:51 pm Post subject: FAA Proposed Rule Changes

Just my thoughts, hope it helps others who might be in the process of writing.    

    

   

4002 Oakridge Drive  

Crestwood, KY  40014  

September 14, 2008  

   

   

   

Miguel L. Vasconcelos  

Production and Airworthiness Division  

AIR-200, Room 815  

800 Independence   Ave., SW  

Washington,  D.C. 20591  

   

Reference: Proposed Policy changes regarding Certification of Amateur Built Aircraft.  

   

Dear Mr. Vasconcelos;   

   

I am a recreational aviation pilot who has built a Van’s Aircraft RV-10 metal airplane, which was an educational experience for my whole family.  Building this aircraft took 13 months and 9 days with the help of my wife and teenage daughters building with me full time.  It was certificated in 2006 and we have flown it together all over the U.S.  I will be purchasing another kit and building an airplane in the near future and am very concerned about the changes to the future 51% construction rules.    

   

I do not see a need to change the rules as they stand.  This proposal is the typical response that takes place when a small percentage of individuals blatantly disregard the rules.  Those types of individuals will always exist and the new rules will not prohibit their disregard.  In any society, there will always be those who cross the line and the new rules will not be an exception.  Those individuals who tempt fate will ultimately sponsor new and more stringent rules.  The result of which, typifies treatment of the symptom and not the disease.  Enforcement is the real solution, as without it, those who suffer are the ones adhering to the rules.    

   

My primary concern is that the complexities of this new policy will place significant new burdens on amateur aircraft builders and make them reluctant to participate in a market that has become an industry phenomenon.  Those of us who have followed the regulations as they stand today are concerned that the daunting task of producing an airworthy craft will become secondary to a bureaucratic nightmare.  This would not be in the best interest of the overall experimental market.   

   

In my lifetime, I have never witnessed a government agency’s intervention actually promote the advancement of the free enterprise system.  In fact, there is a basic premise that I have observed in terms of absolutes and that is; regulation is not the friend of free enterprise.  Has the FAA considered the negative economic impact that these regulations could induce?  It wouldn’t be the first time that regulation killed or crippled an entire industry.  It should be self evident that the overregulated commercial side of this industry has experienced this crippling effect.  This is the primary reason the experimental market has had so much success.  I fear that your proposed rule changes could have a far reaching and devastating effect on this market segment, i.e. the vendors, suppliers, and their employees and families.  Please give this point of view the consideration it deserves and don’t fix it if it’s not broken.  The rules worked well when the industry was in its infancy, they should work just as well now that it has matured.    

   

You will no doubt receive hundreds if not thousands of letters voicing concerns about this issue.  Many will attempt to espouse the virtues of their changes to your proposed rules as they have already conceded that these changes are coming whether we speak out or not.  I am of the belief that you are of an open mind, otherwise you would not have solicited our input.    

   

I sincerely appreciate the opportunity to submit my comments on this proposed policy change.  

   

Very Truly Yours,   

   

   

   

   

Jack H Sparling, Jr.  

   

       [quote][b]

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n395v

Joined: 10 Jan 2006
Posts: 450

Posted: Mon Sep 15, 2008 4:46 am Post subject: Re: FAA Proposed Rule Changes

Well put Jack.



do not archive

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