It is impossible for me to consider these "proposed" rule revisions as anything
other than the death of kit building as we know it.
Some of us rather naively hoped that the rule revisions being considered by the
FAA would address the current state of the kit building industry in a positive way.
Rather than taking this opportunity to recognize how advances in the industry
have resulted in increasingly sophisticated and unquestionably safer amateur built
aircraft, the FAA has chosen to look backward more than 20 years and resurrect
an outmoded internal directive, FAA Order 8130.2B.
Four and a half years ago I began building a Vans RV7A. I invested something
more than 2,000 hours of thinking, studying, reading, drilling, dimpling, bucking,
wiring, designing, fabricating and learning the aircraft as it slowly came together.
I purchased a firewall forward automotive conversion. At different times I enlisted
the help of various experienced kit builders and paid experts in specific specialties
(fiberglass, electronics, and painting to name a few) that I worked side by side
with to help me translate my ideas into reality.
This was a quick-build kit, perhaps the most popular currently available, and if I
read the rules correctly, I had used up almost all of the 49% non-builder
contribution by the time the sub-kits arrived. Under the new rules could I use the
help of those experts who taught me the necessary skills and helped me avoid a
myriad of pitfalls in the process of building a safe and capable machine? It does
not seem so.
It is difficult to consider any rule that will undoubtably result in a decrease in the
quality and safety of the aircraft being produced under it as being reasonable or
prudent.
Larry Simpson
This is comment on Rule
Notification of Policy Revisions, and Requests for Comments on the Percentage of Fabrication and Assembly that Must Be Completed by an Amateur Builder to Obtain an Experimental Airworthiness Certificate for an Amateur-Built Aircraft
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