Stephen G. Powell

As a pilot, but not an aircraft builder, I would like to offer my observations. The new proposed regulations are counterproductive in advancing the cause of safety in aviation and innovation in construction techniques of experimental aircraft. The safest planes would result from the use of time tested materials and components, even if they were manufactured by a kit builder or adapted from other certified or non-certified aircraft. Making a "fabricated" category for the requirements separate from the overal assembly requirement makes planes less safe and for no reason. Does the FAA really want a builder doing critical tasks at the limit of his/her ability just to justify the requirements for fabrication time? Would it really be a good thing to risk having faulty welds in an exhaust manifold or weak areas in a propellor just so the builder can say he/she put in the time to make them? As a matter of fact, the preferable goal may be for a builder to assemble a very safe aircraft from whatever resources he/she can mobilize, forgetting a "percentage" rule, and call it experimental but certify its safety via FAA inspectors/designees. Then the market would determine whether the airplane competes with certified aircraft or not. This would allow builders and manufacturers the greatest leeway in advancing innovative and efficient aircraft design.