Burl Rogers

Notice of this NPRM was given me at 10:30AM, Friday, Sept. 30, 2011 by a fellow manufacturer. I also discovered that the ACO in Anchorage was directed NOT to tell anyone of this notice. I'm guessing that was because the comments and feedback might be more than those involved in this yet another FAA layer of time consuming, expensive to implement, small business killer. The "Safety Index" point system is designed to address the needs of large aircraft manufacturers and completely ignores the requisites of smaller manufacturers and businesses and puts them at a complete disadvantage to vie for the services required for their projects. In short, I ask that more time be allowed to comment on this before closure of the comment period. The tactics used in this situation are underhanded and deceitful with the full intent to deprive small business and equal time use of FAA resources. I would seriously challenge anyone on the committee or board that was involved with dreaming up this "SOP" to go out into the private sector for just one year and try and get a project completed following all the rules that have to be complied with IN ADDITION to this fiasco. I guarantee you it will not happen. I am a one-man show; I do it all by myself. I do not have an engineering staff; I have to use DERs (when I can find one) and handle all the rest myself from concept, design, manufacture, production and sale to my customer. I started 29 yrs ago with $2,000.00 to where I am today; a TC, TSO, & PMA holder with over 20 STCs, 30+ PMAs. And each year the quagmire of FAA rules, regulations, POLICIES, etc. just keeps getting deeper. What is God's Name are you Thinking? You are no longer a help but a hindrance.