Thomas Turnbull

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. Five years ago I began building a Vans RV7A. I have invested something more than 2,200 hours of thinking, studying, reading, drilling, dimpling, bucking, wiring, designing, fabricating and learning the aircraft as it slowly came together. I purchased a lycoming clone and MT prop. At different times I enlisted the help of various experienced kit builders and 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 fuselage and slow build wings, perhaps the most popular currently available, and if I read the rules correctly, I have 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. I understand there are builders assistance operations who have go beyond the intent of the 51% rule. However, this proposed change is a step towards the dark ages in comparison to the small number of commercially produced homebuilt aircraft.