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September 4, 2008 - "Having expressed
concerns about compliance with amateur aircraft-building
requirements for more than two years, the FAA has proposed a new
policy that would overcomplicate participation in amateur aircraft
building without solving the fundamental compliance concerns."
This conclusion of an EAA analysis document
underscores the EAA community's call to action:
Tell
the FAA to enforce the existing amateur-built aircraft rules and
to abandon its proposal that would impose new and complicated
requirements for documenting and reporting an amateur aircraft
builder's work.
"If adopted, the FAA's proposal would have a
dampening effect on participation in amateur-building activities.
That, in turn, would adversely affect kit manufacturers and
suppliers of engines, parts, equipment, and accessories. A
considerable segment of general aviation could experience a
downturn," said Earl Lawrence, EAA vice president of industry and
regulatory affairs.
Lawrence urges EAA members to voice their concerns
to the FAA. Accordingly,
EAA
is providing guidance for members who'd like to write-in before
the Sept. 30 comment-period expiration. A more
in-depth
analysis of the FAA's proposals and EAA's responses is also
available.
The FAA's statements of concern have focused on
some commercial practices related to kit design and commercial
builder assistance that leave too few construction tasks to the
amateur builder. A cornerstone of the FAA's proposed remedy would
entail requiring amateur builders to ensure, and prove, that they
performed at least 20 percent of the total construction tasks doing
"fabrication" work, at least another 20 percent of total
construction tasks doing "assembly" work, and at least another 11
percent of total construction tasks doing any combination of these
kinds of work, adding up to a minimum 51 percent of total
construction performed by the amateur builder.
"This would greatly complicate an amateur builder's
compliance with the regulation, which simply states that the amateur
or group of amateurs must perform a majority of the total tasks
involved in constructing the aircraft," Lawrence said. "This
proposed change would place a significant burden on our members who
are building aircraft within the letter and spirit of the
regulations while doing little to address the limited cases of
excessive commercial assistance," he said.
Lawrence served as co-chair of an FAA-chartered
aviation rulemaking committee (ARC) that studied amateur-building
issues and rendered recommendations from August 2005 through
November 2006. Today the FAA announced plans to reassemble the ARC
beginning in October to provide additional input.
"Our involvement on the committee, combined with
comments from our members, might help to steer the outcome in a
better direction," Lawrence said. "We're counting on our members -
and anyone who cares about the future of general aviation, for that
matter - to raise a voice of concern," he added.
Tell the FAA to enforce the existing amateur-built aircraft
rules and to abandon its proposal that would impose new and
complicated requirements for documenting and reporting an amateur
aircraft builder's work. |
