fritzsch(at)eskimo.com
Guest
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 Posted: Fri Sep 26, 2008 9:10 am Post subject: 51% Rule Interpretation |
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Have you written you letter yet? Don't procrastinate any longer. Here
is my contribution for whatever it is worth.
I am very concerned that the rule interpretation proposed by the FAA
will create a bureaucratic obfuscation of the 51 percent rule to the
extent that it will discourage many potential builders and inhibit
technological developments of current and future builders. To establish
a clear delineation between fabrication and assembly is impossible. To
force such a distinction will result in builders following much more
conservative practices to insure that their aircraft will meet the 51
percent rule thus eliminating much of the dynamic development that has
been a hallmark of the experimental world. This would be a great loss
to the aviation industry.
Requiring each task in building an aircraft to be designated as either
fabrication or assembly would require extensive documentation of these
tasks creating a mountain of paperwork which at best could only be given
a cursory review by the FAA. Creative people are not known to have the
inclination or the time to spend on documentation. Thus this
interpretation would likely drive some very bright people into other
avenues of development than aviation.
If the FAA is concerned about cheating on the 51 percent rule, it should
tighten up enforcement of the existing rule. It has worked well for 55
years. If there is a problem now, update the enforcement, not the rule
that has served us well for so long.
I am an A & P who has not practiced since 1965 due to a change in my
career plans. I have recently retired and am in the process of building
an RV-10. It will be a fine airplane and I will certainly put in more
than 51 percent of the effort to make this aircraft airworthy. The
project is an excellent refresher and I am updating my knowledge of
aircraft construction and equipment; e.g. we did not use fiberglass in
the early '60s.
There were 20 RV-10s lined up at AirVenture this year. While the RV-10
is a recent, standard kit, no two of the RV-10s were the same. Each was
altered to meet the needs and dreams of the builder(s). Some
alterations were minor and some were major, but all demonstrated the
spirit of experimental in aviation.
Sincerely,
David J. Fritzsche
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David J. Fritzsche
Professor, Retired
Penn State
E-mail: fritzsch(at)eskimo.com
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--
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Dave Fritzsche
Professor, Retired
Penn State
E-mail: fritzsch(at)eskimo.com
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