The absurdity of the new “Amateur-Built Assembly Checklist” is frightening.
The official check list numbers 187 items. In actuality, there are additional
unnumbered rows labeled “Additional items” for each of the 6 sub sections, so you
can fill in 193 rows on the official form. It is not a stretch to assume that you could
list each of the additional items separately, resulting in a lot more than 187 items
in your final list. Yet, the directions in Note 2 instruct you to “divide by 187”. Does
this mean you can list additional items but they don’t count? If you list 207 items
will the FAA allow you to divide by that number? That would be at least
superficially logical, but who knows?
Each item carries the same weight. So if you “Fabricate Seat Brackets and
Fittings” (item 182) you get exactly the same amount of credit as if you “Fabricate
Electrical Wiring, Controls and Switches” (item 186). Well, I did both of those
things. Item 182 took part of one day while Item 186 took the better part of a year.
And the FAA considers these of equal weight and significance? Oh yeah, I had
some professional help on item 186, so I only get partial credit.
“Fabricate Engine Propeller” (Item 169) counts the same as “Assemble Propeller
to Engine” (Item 171)? I assembled the propeller to my engine. It took 6 bolts and
10 minutes. Fabricating a propeller? I couldn’t in a million years, but even an
experienced amateur with access to a machine shop is going to spend several
days to weeks at that process. But the FAA says they count the same.
There are four columns on the check list, including one for “commercial
assistance”. There is no column for "Other assistance". So if I work side by side
with a professional that I am paying, I get only partial credit. If I work side by side
with my buddy or my brother and don’t pay him but maybe I owe him a favor, I
guess I get full credit? The message here seems to be it is OK to barter with and
get help from other amateurs who may not have a clue what they are doing (they
don’t count), but God forbid you should pay a professional to teach you proper
technique and help you do the job right.
Where is the common sense?
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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