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New FAA Policy on Amateur Building Released

Just out of curiosity I ran through the checklist for my plane (CH640), delivered as a quickbuild kit, and noticed a few problems. First of all, the checklist says you must have a total of 187 points, however my plane has no wing struts or braces, nor does it have an elevator or rudder. So how do I assign points for stuff nobody did? Anyway, I just went through giving points for things I have, and figured the percentages from there. I just made the 51% with a total 51.7% completed by the builder, however, I could only get enough credit for 16.8% fabrication. I had 1.9% commercial assistance for engine assembly, propellor fabrication, and spinner fabrication. The 640 QB kit comes with a completed stabilator, but I built my stabilator from a standard kit, which accounted for about 15% of my 51% credit. So the standard QB kit would in no way qualify under the new standards, either for 51% total or 20% fabrication. So yes, it's not the end of the world, but it will have a significant effect on those building not already approved kits, and any future kits developed by Vans or anyone else.
 
Why not?

What is wrong with a factory built experimental that must be used with all the same restrictions as an experimental you bought from joe blow who built it in his garage? What is wrong with a kit that only leaves an assembly process to the builder but must be used with all the restrictions of an experimental?

Nothing! On average, it may be safer than those built by the 51% rule.

I guess we're all supposed to be sorry for for collectively "poking the bear", and glad that the FAA didn't pull the plug entirely. I'm not!

I don't think I have read of any evidence that pro built airplanes are any more dangerous than those built in a garage. Same with super quick build kits. If they are not more dangerous, why is this a problem? We're not talking about modifying one of the 10 commandments here. Its just a government reg made before it was realized that certified GA aircraft would be virtually legislated out of existence.

A better conclusion would have been to modify the rules to explicitly allow pro building of experimental and kits that require only assembly. Those who build their own (51% rule) never have to pay a mechanic for anything (except pitot-static) as long as they own the plane. There is logic to that. They have earned the right to be considered experts in working on the airplane they built.

The rest of us fly what someone else has built and need to see a mechanic once a year.

As others have pointed out, this is typical government strangle hold. The FAA has regulated GA to the point that an airplane which is fundamentally simpler than a $20,000 car costs more than the average home in the USA. Its not just economy of scale, because the certification hurdles drive up costs, which in turn drive down volumes.

I'll reluctantly acknowledge that the FAA should have an interest in public safety. These rules, however, don't seem designed to improve safety, only to ensure FAA job security and possibly to benefit the interests of certified manufacturers who have been regulated to within an inch of their lives, and in some cases beyond.

On that subject: If I could afford to buy and maintain a Mooney Acclaim or a Columbia 400, I'd have one. Keeping me out of the air by making it hard to own a high performance airplane is not going to help Cessna, Mooney, Piper, or any certified manufacturer. In fact, it will take me out of GA, ensuring that I'll likely never buy one of their airplanes.

The whole system is broke and the way to fix it is too reduce the rules, not make more. I'm not going to thank "Big Brother" for only strangling me part way to death.
 
From the FAA document: "The major portion of a kit should be composed of raw stock, such as lengths of wood, tubing, extrusions, etc., which may have been cut to an approximate length."

So if I use leather seats, is raw stock the cow, the hide, the tanned and finished leather, or what? If I buy already-finished seats, how much does it count against the majority part that I build?

Or, if I use an EFIS or auto-pilot, what portion of the software I am required to write myself? If so, should I write it raw machine code (no assembler or compiler allowed), so that I'm using the "raw stock" level of the computer in the EFIS? If I just use the software supplied by Dynon or TruTrak, does this count against my 51 percent?

Or, if the major portion should be "raw stock", I am required to fabricate some portion of the rivets from "raw stock"? I'm guess that way over 80% of a kit just consists of already fabricated rivets. This has me worried.

Or, to look at things differently, maybe rivets, EFIS systems, auto-pilots, and seats don't really count as part of the stuff that I'm supposed to fabricate. So what does? Is this clearly spelled out? Ribs count but rivets don't?

Please help me understand.
Perhaps others have or will chime in on this also. The interior, instruments, engine do not fall under the 51% rule. You can hire these build processes out legally. So your worries about cowhide, software development or other construction steps for these parts of the airplane can be laid to rest. They do not apply here. They will not be affected by the 20% fabrication ruling.

However, you do bring up an interesting point about rivet construction. I suppose the FAA would need to clarify that issue I suppose.
 
What is wrong with a factory built experimental that must be used with all the same restrictions as an experimental you bought from joe blow who built it in his garage? What is wrong with a kit that only leaves an assembly process to the builder but must be used with all the restrictions of an experimental?

Nothing! On average, it may be safer than those built by the 51% rule.

I guess we're all supposed to be sorry for for collectively "poking the bear", and glad that the FAA didn't pull the plug entirely. I'm not!

I don't think I have read of any evidence that pro built airplanes are any more dangerous than those built in a garage. Same with super quick build kits. If they are not more dangerous, why is this a problem? We're not talking about modifying one of the 10 commandments here. Its just a government reg made before it was realized that certified GA aircraft would be virtually legislated out of existence.

A better conclusion would have been to modify the rules to explicitly allow pro building of experimental and kits that require only assembly. Those who build their own (51% rule) never have to pay a mechanic for anything (except pitot-static) as long as they own the plane. There is logic to that. They have earned the right to be considered experts in working on the airplane they built.

The rest of us fly what someone else has built and need to see a mechanic once a year.

As others have pointed out, this is typical government strangle hold. The FAA has regulated GA to the point that an airplane which is fundamentally simpler than a $20,000 car costs more than the average home in the USA. Its not just economy of scale, because the certification hurdles drive up costs, which in turn drive down volumes.

I'll reluctantly acknowledge that the FAA should have an interest in public safety. These rules, however, don't seem designed to improve safety, only to ensure FAA job security and possibly to benefit the interests of certified manufacturers who have been regulated to within an inch of their lives, and in some cases beyond.

On that subject: If I could afford to buy and maintain a Mooney Acclaim or a Columbia 400, I'd have one. Keeping me out of the air by making it hard to own a high performance airplane is not going to help Cessna, Mooney, Piper, or any certified manufacturer. In fact, it will take me out of GA, ensuring that I'll likely never buy one of their airplanes.

The whole system is broke and the way to fix it is too reduce the rules, not make more. I'm not going to thank "Big Brother" for only strangling me part way to death.
My feelings exactly! I am not one to bow to an authority figure and say: "Thank you sir. May I have another!" while they lash me with a whip!

Yeah, that is that rebellious nature in me that drives my free will!

Live Long and Prosper!

Oh yeah, I subscribe to this motto too!

LIVE FREE OR DIE!
 
Please help me understand what the status (in plain English) is for the RV12. I built and have been flying my RV6A for nine years. The idea of a no-medical/homebuilt that's easy on gas is real attractive. I'd like to build to plans but with 6-inch wheels and drive my own round-head rivets. Would one or more of you knowledgable folks care to speculate on the legal do-ability of this plan? I want the repairman certificate. TIA Jim
 
The 7AQB FAA Checklist

may not be so bad. I just went thru the checklist for my 80% completed 7A QB. Using .5 for completing the fabrication of most all parts I handled (match drilling, fluting, edge finishing, priming, multiple trial fits, etc.), I got some reasonable numbers I think.

N457RV
Manufacturer: 69 points=37%
Commercial: 1.2 points=1.2% (Steinair radio stack wiring and panel powdercoating)
Builder Assembly: 74.4 points=39.9%
Builder Fabrication: 41.9 points=22.5%

In this analysis, I'm interpreting assembly to mean "final assembly", and fabrication to mean all part prep up to that point.

See you at KOSH
 
Please help me understand what the status (in plain English) is for the RV12. I built and have been flying my RV6A for nine years. The idea of a no-medical/homebuilt that's easy on gas is real attractive. I'd like to build to plans but with 6-inch wheels and drive my own round-head rivets. Would one or more of you knowledgable folks care to speculate on the legal do-ability of this plan? I want the repairman certificate. TIA Jim

Jim,

Sounds like you want to build an am-built RV12 which you can do but they are not 51% selected. It would be up to you to convince the FAA that you did the 51%. They are not grandfathered like the other Van's and would require that you adhere to the new guidlines everyone is discussing.

Pete
 
What's the issue?

What is wrong with a factory built experimental that must be used with all the same restrictions as an experimental you bought from joe blow who built it in his garage? What is wrong with a kit that only leaves an assembly process to the builder but must be used with all the restrictions of an experimental?

Nothing! On average, it may be safer than those built by the 51% rule.

I guess we're all supposed to be sorry for for collectively "poking the bear", and glad that the FAA didn't pull the plug entirely. I'm not!

I don't think I have read of any evidence that pro built airplanes are any more dangerous than those built in a garage. Same with super quick build kits. If they are not more dangerous, why is this a problem? We're not talking about modifying one of the 10 commandments here. Its just a government reg made before it was realized that certified GA aircraft would be virtually legislated out of existence.

A better conclusion would have been to modify the rules to explicitly allow pro building of experimental and kits that require only assembly. Those who build their own (51% rule) never have to pay a mechanic for anything (except pitot-static) as long as they own the plane. There is logic to that. They have earned the right to be considered experts in working on the airplane they built.

The rest of us fly what someone else has built and need to see a mechanic once a year.

As others have pointed out, this is typical government strangle hold. The FAA has regulated GA to the point that an airplane which is fundamentally simpler than a $20,000 car costs more than the average home in the USA. Its not just economy of scale, because the certification hurdles drive up costs, which in turn drive down volumes.

I'll reluctantly acknowledge that the FAA should have an interest in public safety. These rules, however, don't seem designed to improve safety, only to ensure FAA job security and possibly to benefit the interests of certified manufacturers who have been regulated to within an inch of their lives, and in some cases beyond.

On that subject: If I could afford to buy and maintain a Mooney Acclaim or a Columbia 400, I'd have one. Keeping me out of the air by making it hard to own a high performance airplane is not going to help Cessna, Mooney, Piper, or any certified manufacturer. In fact, it will take me out of GA, ensuring that I'll likely never buy one of their airplanes.

The whole system is broke and the way to fix it is too reduce the rules, not make more. I'm not going to thank "Big Brother" for only strangling me part way to death.

I don't believe the issue here is about safety (or about self-sustaining bureaucracy). It is about people abiding by the intent of the rules of building amatuer built aircraft. If people want to commercially build a kit airplane for sale, they need to petition the FAA to adopt rules to do that and not mess up everyone elses right to build an amateur built plane. Currently that type of building is not covered by the rules.
 
Scratch build

Did you guys see that beautiful plans built Mustang II at Sun 'n' Fun this year? It won Grand Champion plans built. You guys will have to get to work!

Kits in the future will come with a 20% pile of raw materials, and factory made forms, stamps, templates, and hammers ;)
 
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...The feds will have to enforce the rules for it to make a difference. So why don't the just enforce the current rules? That would sure be simpler than all this fuss with interpretting new rules that are suppose to accomplish the same thing as the old rules.
Sounds like we should join up with the NRA.
 
Composite kits

......
If nothing less than 20% "fabrication from raw stock or materials" is going to satisfy the FAA, future kit designs are going to be a whole new deal. It is not just a quick-build issue. I don't see 20% fabrication from raw stock in a current RV slow-build kit.

The raw stock bit may make it even harder for the composite kits.
Perhaps each builder must come to the factory to lay up his parts in the factory molds....:)
 
Heh, pity the poor wood constructionist. Do you know how long it takes to grow a tree? :p
 
Follow the rules as they are

I don't believe the issue here is about safety (or about self-sustaining bureaucracy). It is about people abiding by the intent of the rules of building amatuer built aircraft. If people want to commercially build a kit airplane for sale, they need to petition the FAA to adopt rules to do that and not mess up everyone elses right to build an amateur built plane. Currently that type of building is not covered by the rules.

I agree that failing to do so will only punish those legitimately building airplanes.

I don't have to like it though.
 
Ever hear of the Celerity?

Heh, pity the poor wood constructionist. Do you know how long it takes to grow a tree? :p
I know you said that in jest, but several years ago there was a guy who built an airplane called the "Celerity" that actually did cut down a tree and process the wood. Now that is scratch built. It did BTW meet the 51% rule!
 
Sounds like we should join up with the NRA.
The NRA assumes the right stance and is generally successful with their government advocacy. EAA is weak at best. I've had (futile) conversations with their people about their positions fighting the federal government as demonstrated by the use of their wording. The big one is their insistance of using the granddaddy capitulation word - "privilege". They will never be more than minimally successful with this weak, subservient attitude.
 
Isn't the real question how the meaning of "raw" materials is interpreted by the Feds- for example, does it include preshaping and/or bending into a rough shape, welding, adding coatings like alclad or powder coats?

Are prepunched skins, or even premade parts, like rivets, considered a raw material? How about a part like a punched rib when we still have to do most of the prep work (debur edges, straighten, pre assemble subassembly and match drill, disassemble, debur holes, dimple, prime, reassemble, rivet together, inspect and repair, remove protective skins, and later prime and paint?

Our quick build options might be in trouble.
 
RV12 kit restructure?

Amateur-built requires 20 percent of the aircraft be fabricated (from raw materials) by the builder. How much of the RV-12 kit is now fabricated by the builder? How much change would be required (on Vans part) to restructure the kit so the builder does fabricate 20 percent? Case in point...the ribs are attached to the main spar by aluminum angles that are cut and bent from flat aluminum "raw stock", and then drilled. This is now done by Vans, but it could easily be done by the builder. I only have the wing kit, and have not gotten very far with it, but I suspect that there are many other similar parts that could be fabricated easily and count towards the 20 percent rule.

Now, someone is going to say "I dont want to fabricate 20 percent of the parts...". Okay, so then Vans could have 2 kits. One for for the E-AB, and one for the E-LSA. Not much difference between the two kits except for a "handful" of parts that could be fabricated by either Vans or the builder.

I say this because I am thinking that Vans is still very early in the kit design. Fuse and tail are not yet released. Would it do any harm for them to look at what would be required to make this change, and get some feedback from us? If enough people want it, they may be responsive. They currently have quick build and slow build kits. Why not E-AB and E-LSA kits.

Just a thoght...
 
20% Rule

To this point, the 51% rule referred to the percentage of different operations
in the construction of an aircraft. The thinking would have been, 'this person
has successfully fabricated an outboard wing rib, the educational value
in doing this 27 more times is questionable'. Quick build kits in times past
were supplied without that rib for that purpose.

It will be interesting to see how the percentage is now judged. If we have
scratch-built one airworthy wing rib angle, do we need to move on to a different
fabricating op to cover our 20 percent?

Sam
Temora Australia
 
In a way, this is the fault of ALL of us. For allowing people to custom build, build to hire, or build airplanes for others; for letting this get out of hand; for tacitly accepting that "yes, it's against the rules, but it happens, we aren't our brother's keeper..."; for not taking a firmer stand before the FAA stopped in to drop the hammer - everyone that wants to build a plane in the future will have to deal with new regulations, and they will be confusing!

I, for one, believe that custom-built airplanes by boutique builders would be safer, and a great way to build up general aviation which is drowning under the high cost of regulation and certification. But unfortunately, the current regulations do not allow it. We have to live within the rules, or get the rules changed to what we want. Ignoring or going around them just makes "The Bear" mad - and we WILL be paying the price.

All my opinion,

Paul


gotta disagree with you on the "it is all our fault" part.

if i was to lay blame, it would rest at the feet of Epic.

(besides, I have barely started my plane, how could i have caused this : P
 
gotta disagree with you on the "it is all our fault" part.

if i was to lay blame, it would rest at the feet of Epic.

(besides, I have barely started my plane, how could i have caused this : P

Well, I could name a lot of actual individual commercial builders other than just Epic, but the "All our fault" is metaphorical. However, when you accept that someone is breaking the rules and dont speak out, are you responsible? That is a moral/philosophical question beyond the scope of these forums....;)

Paul
 
One question I have is how could the builder community have helped to prevent the tightening of the rules and how can this same community keep it from getting worse.

Should people who had their planes professionally built have been reported? Would that have done any good? I know that few people want to "rat" someone out to the Feds, but perhaps that sort of community self-policing could have helped. I have no idea. I do know that it was an open secret that one could hire people to build their planes for them and that some of these "builder's assist" centers were really airplane factories. Even in this early stage of my journey I had several people tell me of people/companies that would build my RV or whatever kit I decide for me and allow me to customize it. How many ads on barnstormers brag about "professionally built" ExABs?

Maybe after a few more public horror stories about some guy dropping $100k-$500k on a kit and being unable to certify it enough people would be discouraged from so brazenly flaunting the intention (and sometimes the letter) of these regulations. If people actually thought that there was a likelyhood or at least a significant possibility that they would lose their investment you would see a lot fewer takers. Sure, it would be devasting to the individual owner who spent that money, but such an even could be for the better of the homebuilt community.

I am an outsider (for now) looking in. What do you guys think?
 
If someone built a kit airplane for someone else and that someone else then registered with the FAA that they built it themselves for the purpose of getting a Repairman's Certificate, that would be the "wrong" that everyone is screaming about and that the FAA is wanting to crack down on.

However, what if that someone built the kit airplane, registered it in their name as the builder, received the Repairman Certificate and then sold the flying airplane to someone else. I cannot see where this is any different than any of the many repeat builders out there.

Where is the "wrong" in this for a build assist person? Or, a build for hire program? Why would this be a violation that would cause the wrath of THE BEAR?

Why would I or you as a fellow builder get upset with that someone? After all he is doing the same thing you or I would do if we ended up selling our flying airplane and then later on decided to build another airplane. The only difference would be in the numbers and frequency at which that someone would do this compared to how often I might do it.
 
If someone built a kit airplane for someone else and that someone else then registered with the FAA that they built it themselves for the purpose of getting a Repairman's Certificate, that would be the "wrong" that everyone is screaming about and that the FAA is wanting to crack down on.

However, what if that someone built the kit airplane, registered it in their name as the builder, received the Repairman Certificate and then sold the flying airplane to someone else. I cannot see where this is any different than any of the many repeat builders out there.

Where is the "wrong" in this for a build assist person? Or, a build for hire program? Why would this be a violation that would cause the wrath of THE BEAR?

Why would I or you as a fellow builder get upset with that someone? After all he is doing the same thing you or I would do if we ended up selling our flying airplane and then later on decided to build another airplane. The only difference would be in the numbers and frequency at which that someone would do this compared to how often I might do it.

"It depends."

To have a legitimate Ex-AB aircraft, the FARs require that the major portion of that aircraft has been fabricated and assembled by persons who undertook the construction project "solely for their own education or recreation."

So, on the one end of the scale, maybe you have builder #1 who constructs a plane solely for education/recreation and then sells it later (the bold text above). No problem.

On the other hand you have builder #2 that agrees to build an aircraft for someone else in exchange for money. Ask this question: would builder #2 do it for free? If the answer is "no", how can the transaction even meet the plain words of 21.191(g), let alone the "spirit". Builder #2 is building a plane "for someone else", regardless of the formalities.

I get the distinction you're making between your two examples, but the difference is really a matter of form, not substance. "Hey I will build you a plane for money but, wink wink, I'll build it for me and then I'll sell it to you later, OK. By the way do you want Dynon or MGL and what color should the stripes be?"

In between builders #1 and #2 you have the "repeat offenders", folks who in essence have a self-financing hobby. Maybe some of them build and sell one plane at a time. Maybe some of them advertise the plane when it's "90%" so the buyer can pick the panel and paint. In my opinion, the more you look like builder #2, the more likely the FAA will say rule has been broken.

I know that is not a satisfying answer for the technical types, but I don't think the fact that "in-between" situations exist, where it might be difficult to determine the builder's intent, gets builder #2 off the hook.
 
So, on the one end of the scale, maybe you have builder #1 who constructs a plane solely for education/recreation and then sells it later (the bold text above). No problem.

On the other hand you have builder #2 that agrees to build an aircraft for someone else in exchange for money. Ask this question: would builder #2 do it for free? If the answer is "no", how can the transaction even meet the plain words of 21.191(g), let alone the "spirit". Builder #2 is building a plane "for someone else", regardless of the formalities.

I think you summed it up perfectly there. That is exactly what I wanted to say, just couldn't find the word.

In my opinion we need to protect the builder #1, and find a way to get #2 out of business, or building under an appropriate reg, as Van's has proposed.

It's not that I don't want these builders to be able to build, and sell aircraft, but they need to do it in such a way that the rest of us can continue to enjoy our privileges.
 
"It depends."

To have a legitimate Ex-AB aircraft, the FARs require that the major portion of that aircraft has been fabricated and assembled by persons who undertook the construction project "solely for their own education or recreation."

So, on the one end of the scale, maybe you have builder #1 who constructs a plane solely for education/recreation and then sells it later (the bold text above). No problem.

On the other hand you have builder #2 that agrees to build an aircraft for someone else in exchange for money. Ask this question: would builder #2 do it for free? If the answer is "no", how can the transaction even meet the plain words of 21.191(g), let alone the "spirit". Builder #2 is building a plane "for someone else", regardless of the formalities.

I get the distinction you're making between your two examples, but the difference is really a matter of form, not substance. "Hey I will build you a plane for money but, wink wink, I'll build it for me and then I'll sell it to you later, OK. By the way do you want Dynon or MGL and what color should the stripes be?"

In between builders #1 and #2 you have the "repeat offenders", folks who in essence have a self-financing hobby. Maybe some of them build and sell one plane at a time. Maybe some of them advertise the plane when it's "90%" so the buyer can pick the panel and paint. In my opinion, the more you look like builder #2, the more likely the FAA will say rule has been broken.

I know that is not a satisfying answer for the technical types, but I don't think the fact that "in-between" situations exist, where it might be difficult to determine the builder's intent, gets builder #2 off the hook.
1st comment:
My idea of discussing the idea of a builder completing a project, flying it, registering it, obtaining the Repairman's Certificate, selling it then going through the process over and over again was not designed to imply this builder would solicit buyers who would pay him up front, supply him with money and ideas on how he/she wanted the custom built airplane constructed. I was implying that the builder would build an airplane to his own specifications, register it, obtain the Repairman's Certificate, fly it then sell it. Once done he goes about doing it again and again. This in a sense is what goes on all over the country now. It is what I foresee happening with a builder program in light of the existing FAA scrutiny. This concept is what I was posing my questions upon.

Now this is not to say I would expect someone to "make a living" doing this. Perhaps he could make enough to live on but it would not make him rich. However, contrary to ideas of the majority of people in our country who cannot think of anything but "how can I get rich doing this?", there are many people who would enjoy spending their time building airplanes then selling them to others even if it did not "make them rich". If that were not so there would not be much argument for those "Professional Builders" who are already doing that and labeled as "Repeat Offenders". So why should you, I or our government begrudge those who wish to do this?

2nd comment:
Your answer leads to the idea that the FAA must now become the THOUGHT POLICE. So it is not enough that the FAA is tasked by me, the tax payer, to over see the safety of aviation. They now are going to take it upon themselves to evaluate the motivation behind why someone builds an airplane!

I don't buy that as a legitimate argument no matter how many times someone brings it up. Why? Because this infringes upon my freedoms that, as an American, I hold as a Right that no one can deny me! I am sorry if that sounds too bold for some reading this but freedom is the foundation our country was built on. Not the concept that others must be tasked to over see my safety and that of the greater society lest I or they do some harmful thing to myself or the public. Of course I should not even be talking in terms of "Safety" in this discussion because there is no way the FAA's argument concerning this ruling can be supported based on arguments of safety.

Government, nor might I add, you nor the next guy standing next to you nor the next guy standing next to him should be able to dictate to me what I can and cannot think no matter what actions come about because of my thoughts!

If anyone wishes to accuse someone that their motivation for building was not based on education or recreation because he/she chose to build and then sell an airplane hopefully would have to prove that that person's motivation was elsewhere. If I were selected to sit on a jury to determine this person's fate I would have a hard time making it through the selection process. I would most definitely oppose any case where someone had to face such accusations!

Live Long and Prosper! And if you cannot do that Live Free or Die!
 
So why should you, I or our government begrudge those who wish to do this?
If the question is why should the government should be against this type of building (ignoring the fact that there are regulations prohibiting it) I would agree and say that the government shouldn't get involved, but that is just my opinion. If there were no rules against it, I wouldn't care if someone wants to pay another to build their plane. Other than increasing the total supply of planes on the market and possibly devaluing my plane if I chose to sell it, that act alone wouldn't have an effect on me.

However, once we acknowledge that there are regulations against it, and that the government is/will get involved, then it certainly becomes important to me that these actions stop, primarily to prevent the government from responding the way it just did, by puting greater restrictions on me because someone else violated the letter/spirit of the law.

2nd comment:
Your answer leads to the idea that the FAA must now become the THOUGHT POLICE. So it is not enough that the FAA is tasked by me, the tax payer, to over see the safety of aviation. They now are going to take it upon themselves to evaluate the motivation behind why someone builds an airplane!
The reality is that very large portions of our legal system are based on determining intent, which could be construed as being thought police. The most extreme example is that deals with murder. what a jury believes you were thinking (did you intend to do it, were you planing it in your head for a while, did you kill him because you were scared or just angry) has a HUGE impact on what you are convicted of. Even if the action is the same, if the courts determine that the intent behind the action was different, you face different penalties.

Another, more applicable scenario, has to do with an area that I, and several others on this list, are interested in, guns. I'm sure that there are people on this list who have owned/collected firearms at one point. I'm also sure that at once time or another, some of these people sold one or more of their firearms to someone. As a firearm owner, you can sell one of your weapon to another individual privately without any special dealer's license. However, if you do this repeatedly, the BATFE may consider you an unlicensed gun dealer. In this case, it is up to the government and a jury to determine if you were acting as a gun dealer as opposed to a private individual selling a few of his guns. We can debate whether the government should do this or not until we are blue in the face. However, make no mistake, the government has been able to send many people to prision by "proving" to a jury what the person was thinking at the time they commited the action in question.
 
1st comment:
My idea of discussing the idea of a builder completing a project, flying it, registering it, obtaining the Repairman's Certificate, selling it then going through the process over and over again was not designed to imply this builder would solicit buyers who would pay him up front, supply him with money and ideas on how he/she wanted the custom built airplane constructed. I was implying that the builder would build an airplane to his own specifications, register it, obtain the Repairman's Certificate, fly it then sell it. Once done he goes about doing it again and again. This in a sense is what goes on all over the country now. It is what I foresee happening with a builder program in light of the existing FAA scrutiny. This concept is what I was posing my questions upon.

OK, that person is what I understand to be a "repeat offender" as that term is used. In the situation you have described, the builder is arguably always constructing the plane solely for his recreation/education. You didn't really state the "lack of pre-order" in your post.

Now this is not to say I would expect someone to "make a living" doing this. Perhaps he could make enough to live on but it would not make him rich. However, contrary to ideas of the majority of people in our country who cannot think of anything but "how can I get rich doing this?", there are many people who would enjoy spending their time building airplanes then selling them to others even if it did not "make them rich". If that were not so there would not be much argument for those "Professional Builders" who are already doing that and labeled as "Repeat Offenders". So why should you, I or our government begrudge those who wish to do this?
This is an excellent point. In the end there is probably not a lot of practical difference in the outcome between an "honest repeat offender" and a "hired gun". Both are essentially serially manufacturing aircraft.

Are you saying hired guns should be allowed, period, or are you mad that "honest repeat offenders" might get lumped in with "evil hired guns?"

2nd comment:
Your answer leads to the idea that the FAA must now become the THOUGHT POLICE. So it is not enough that the FAA is tasked by me, the tax payer, to over see the safety of aviation. They now are going to take it upon themselves to evaluate the motivation behind why someone builds an airplane!
I see this argument made frequently. It is a little over the top. There are many areas of the law where a person's intent must be discerned. Almost always there will be some external fact or action that will show that intent. "Mr. Smith, did you or did you not ask Mr. Jones which engine, prop, instruments, and paint you should install in 'your' airplane, the one you 'happened' to sell to Mr. Jones with 40.00001 hours on the hobbs?"

I don't buy that as a legitimate argument no matter how many times someone brings it up. Why? Because this infringes upon my freedoms that, as an American, I hold as a Right that no one can deny me! I am sorry if that sounds too bold for some reading this but freedom is the foundation our country was built on. Not the concept that others must be tasked to over see my safety and that of the greater society lest I or they do some harmful thing to myself or the public. Of course I should not even be talking in terms of "Safety" in this discussion because there is no way the FAA's argument concerning this ruling can be supported based on arguments of safety.

Government, nor might I add, you nor the next guy standing next to you nor the next guy standing next to him should be able to dictate to me what I can and cannot think no matter what actions come about because of my thoughts!

If anyone wishes to accuse someone that their motivation for building was not based on education or recreation because he/she chose to build and then sell an airplane hopefully would have to prove that that person's motivation was elsewhere. If I were selected to sit on a jury to determine this person's fate I would have a hard time making it through the selection process. I would most definitely oppose any case where someone had to face such accusations!
I'm not sure what you're getting at here. I take it you are specifically addresing the case where the FAA says "OK Mr. Smith, you have built 10 planes in a row and always sold them. The limit is 9, therefore we are reading your mind and deciding that your intent was not solely recreation/education?" I agree with you such a rule would stink - but I'm pretty sure that's not what is in the proposed order.
 
I too, like the idea of building aircraft for consumers by those with experience from building multiple times.

But the bottom line is competition to certified aircraft. The certified manufacturers have to jump through many hoops, and this is, without doubt, unfair competition. I can see exactly where the FAA is coming from. It amounts to mass production, while escaping most of the regulations that certified planes must adhere too.

L.Adamson --- RV6A
 
... This is an excellent point. In the end there is probably not a lot of practical difference in the outcome between an "honest repeat offender" and a "hired gun". Both are essentially serially manufacturing aircraft...
The biggest difference I see between a repeat offender and a hired gun lies in intent for me. Both may love building and gain much education and recreation. However, for the hired gun, compensation for his time is also a factor. Even if he isn't doing this job to get rich or make a living, if this person will only build a plane that he expects to make a profit on AND intends to use that profit for something other that funding other builds (e.g. buying a house, paying his bills, etc) then that person isn't doing this solely for education and recreation. He is doing it to generate income, as well.

Let me give 3 examples:

1) builder A builds RV-4s, flies off the hours, then sells the plane for only what he had in it. In this case, he isn't making any money so his only reward is education and recreation. IMHO, this guy is an amateur and is well within the law. Even if he can crank out 4 a year, so what?

2) builder 2 builds an RV-4, sells it for a profit, and uses all of that money to fund an RV-7 build. He then sells that build for a profit, but uses all of the money to fund an RV-10. The 10 is sold for a profit, but all of the funds are used to pay for a Lancair Legacy build. The Legacy is sold for a profit, and all of those funds are used to build a Lancair IVP, and so on. In this case, even if he had the expectation beforehand to sell for a profit, any profit is used solely to further his education and recreation regarding future builds, so IMHO, he is still an Amatuer builder (although I can see how some, including the FAA, may disagree).

3) Builder 3 builds RV-4s and loves doing it. He always sells for a small profit (maybe only $5,000 or $20,000 per plane). Even though he loves building, he only builds with the expectation of making a profit after the sale. Perhaps it is the only way he can justify to the wife spending so much time building airplanes instead of getting a second job. This guy, IMHO, is a professional builder. The fact that he loves his job is irrelevent. The fact that he will only do it if he receives financial compensation for his work is relevent.
 
...
But the bottom line is competition to certified aircraft. The certified manufacturers have to jump through many hoops, and this is, without doubt, unfair competition. I can see exactly where the FAA is coming from. It amounts to mass production, while escaping most of the regulations that certified planes must adhere too.

L.Adamson --- RV6A


This is the real reason for the regs, not safety. We enjoy a lot of freedoms with homebuilts here. I believe in some countries, you can't fly homebuilts at night or IFR. The only thing we can't do with our homebuilts is use them for commercial purposes. With only this minor differentiation, homebuilts and certified GA aircraft target and share a very similar market. If the homebuilt industry starts "mass" producing (relative term here) aircraft, the certified manufacturers will make a big fuss (and with good reason). If we aren't careful, they may start lobbying the FAA to further restrict how we use our homebuilts. Personnally, I would rather see restrictions on the building side rather than on the flying side.
 
Are you saying hired guns should be allowed, period, or are you mad that "honest repeat offenders" might get lumped in with "evil hired guns?"
I am not mad at anyone really. I suppose a little irritated at government regulations and restrictions is all. Please don't get me wrong. I am not a "hired gun", I have built one kit built airplane and sold it, partly to fund the RV9A I am currently building. I am sure many would consider me a repeat builder. My comments are meant to voice my opinion on whether the FAA should be affecting change on these regulations (or even if they should have such regulations at all). Many on here have commented about the GA big guns having to meet stringent FAA requirements for their planes while E-AB builders do not. To me the idea that the "hired gun" builder will be playing unfairly if they build professionally while not having to follow the same rules as the Cessnas, Pipers and such sounds like government intervention into free trade to me. If the big name GA manufacturers are threatened that much from experimental builders then they should be able to alter their product to compete. That is the whole idea behind competition and free trade.

Of course I know as well as the next guy this is the real problem. The FAA has set the rules up so that these GA manufacturers cannot compete with the new and better designs available to experimental builders. They are stymied by these ridiculous restrictive regulations on their abilities to improve on designs and take them to market in a reasonable fashion that can be affordable to the consumer while still being profitable to them. If there is anything that makes my comments sound like there is an angry tone to them it is this that fuels my comments. These new rules and restrictions are not what the aviation industry needs. We need a lifting of the restrictions not a tightening. This goes not only for the E-AB rules on building but also on the rules that stifle all GA manufacturing. This is why I have posted my previous remarks.

I'm not sure what you're getting at here. I take it you are specifically addresing the case where the FAA says "OK Mr. Smith, you have built 10 planes in a row and always sold them. The limit is 9, therefore we are reading your mind and deciding that your intent was not solely recreation/education?" I agree with you such a rule would stink - but I'm pretty sure that's not what is in the proposed order.
I am sure it is not in the proposed order as well. However, I do think it is possible the FAA could make criminals of all of us who build an airplane and then sell it. That is where I can see some future rulings going if the FAA decides to try to crack down on some "repeat builder" or "hired gun".
 
If the big name GA manufacturers are threatened that much from experimental builders then they should be able to alter their product to compete. That is the whole idea behind competition and free trade.

That's impossible. The "big names" are subject to everything being certifcated. They are also subject to liabilites that we can't even dream of.

There is simply no comparison here. We don't spend millions to get our airframes certified, and most of us don't have millions to loose, liability wise.

L.Adamson -- RV6A (the last I intend to build)
 
My take is a little different- our society (US) has significantly digressed from one driven by freedom, independence, free spirits to one of dependence on the government.

It is difficult, if not impossible, to get into any new and innovative business without first gaining the govt's approval (permits) or overcomming the legal obstacles that smother anyone without a lot of cash behind him to grease the skids.

A great example that Ive been battling recently involves running a vehicle on natural gas, the cleanest fuel we have that is cheap and domestically available. It is impossible to install one of the myriad universal conversion kits made abroad, where nat gas is use very common and highly successful, because of the legal obstacles in place from the EPA. The EPA has passed regulations to keep inefficient foreign (exotic) gas guzzlers out of our country, and those same regs make the new technology too expensive to create the demand (source of vehicles) needed to provide the incentives to epand the cng national infrastructure further than the current situation (a bunch of spot markets that support local fleets).

The regs force every conversion kit manufacturer to certify his kit in the US for every make, engine, and year of vehicle at approx $100K each and several years delay. The US OEMs (Ford and GM) quit making cng car conversions abt 5 yrs ago- so the potentially superior industry, one that burns cheaper, domestic, and cleaner-emission fuels is dead before it can get a foothold. EPA imposed tax has in effect killed the future industry and made our air quality that much worse in their short sigtedness (and ignorance). A number of European and South American countries have significant numbers (millions) of natgas vehicles on the road- far more advanced than the US market.

Incidentally, T Boone Pickens plan to get off foreign oil dependence includes a 25% changeover to from oil to natgas in the short run, until plug in electrical vehicles, fuelled mostly by electricty generated from wind and new nuclear sources, can get to market. We also need to upgrade the electrical grid to transport the energy. IMHO, he is right on the money- I hope he is able to get the govt off of our backs and let Americian ingenuity solve this energy problem!
 
That's impossible. The "big names" are subject to everything being certifcated. They are also subject to liabilites that we can't even dream of.

There is simply no comparison here. We don't spend millions to get our airframes certified, and most of us don't have millions to loose, liability wise.

L.Adamson -- RV6A (the last I intend to build)
Yes, I know and understand that. This is my point!

Why does it cost millions for the "big names"? Liability concerns are an issue of course. However, Liability exists in every industry. Those industries are not languishing in a time warp though.

As is being discussed in a similar thread, http://www.vansairforce.com/community/showthread.php?t=32167, the issue with the millions it costs for GA manufacturers can be changed if we have a change in the way we think about doing business in the aviation industry. What is going on currently is NOT WORKING! The government regulations are killing the GA industry. The more the rules and regulations are changed or newly implemented for the purpose of RESTRICTING innovation and improvement, the less choices all of us who fly will inevitably have.

We should not only be talking about this in terms of "protecting our turf", we should also be discussing the very reasons why those GA airplanes cost millions of dollars. Cessna, Cirrus, Piper and all the other GA manufacturers are not the enemy of E-AB builders. We should all be involved in getting the bureaucratic red tapers to let go of their strangle hold on this industry.

Ironically there is a similar problem that has developed in another government agency with very similar problems arising because of it. I have been researching information on running a car on alternative fuel (i.e. LPG, CNG, electric, etc.).

The EPA has developed a strangle hold on the conversion industry for these alternative fuels just as the FAA has done with aviation. The EPA has made it virtually impossible for anyone except the big fleet companies to convert to alternative fuels because they have imposed rules dictating that only EPA certified conversion kits can be used to convert to CNG for example. And guess what! Because of the draconian requirements imposed by the EPA on these conversion certifications it becomes very expensive to certify a conversion. Now doesn't that sound awfully familiar?

These kits are costing in the neighborhood of $10K to install. There are non-certified kits selling in the $1500 range but because these are not EPA certified if you install one on your car and then get flagged at some inspection down the road the EPA will fine the car owner a hefty fine.

Now here is more irony. In my state, Oklahoma, our state government has allowed a 50% tax credit for the cost of converting or buying a new alternative fuel vehicle. The federal government also has an 80% tax credit. Well, now, that sounds pretty darn good and even though it appears these conversions are expensive perhaps the tax credits would off-set the cost enough to make it feasible. Alas, not true!

The state of Oklahoma also has a law on the books that requires any technician that works on an alternative fuel vehicle to possess an Alternative Fuel Vehicle Technician Certification. So no one can legally work on one of these vehicles without this certificate. And here is the funny (read sad :() part. There are no organizations in the state that have a certification program where these technicians can get certified.

So although the state and feds want to talk the big talk and say they are supporting alternative energy by providing tax credits, realistically, they are stymieing anyone from using them. Even though I want to convert my vehicle and could probably float the up front money it would cost for the conversion until my tax credit were to come in sometime after April 15th, there is no one in this state I can contact to do the conversion for me.

So here I sit ready and willing to contribute my part to getting off of the foreign oil train but I have no viable means to do it. The rules and regulations are preventing anyone outside the major fleet owners from seeing any benefit from any of these government incentives or to even go so far as to even try it to see if it will work.

I cannot help but notice how closely the effects of these EPA RESTRICTIONS mirror the FAA RESTRICTIONS we have to live with in the aviation world.

There is a difference however. Our federal government leaders are attempting to address the EPA strangle hold by introducing a bill that if passed will change the way the EPA will treat alternative fuel conversions for automobiles. If interested here are some links discussing the issue:

http://api.ning.com/files/gNvEyvmx6i*dCaNpLjvaawdQSj*3m9M8nK47-1BKS6vhmLctfAhsDeSonAUO5qgNmAlGQo7RLxzg-G0LnhWvu6uxBxfITNXb/TheDriveAmericaonNaturalGasActof2008.pdf

Here is the senator's website that is spearheading this bill:

http://inhofe.senate.gov/public/index.cfm?FuseAction=PressRoom.PressReleases&ContentRecord_id=32cee86f-802a-23ad-4e25-8ceb2615ebae

This issue with the EPA is very similar to what has been happening to aviation since the FAA started down this restriction policy road back in 1958!
 
like minds think alike!

Rtry9a,
We must have been thinking the same thing at the same time. Just as I posted my long winded post I see your post discussing the same thing.

If anyone is interested, check out the T. Boone Pickens Plan here:

http://www.pickensplan.com/
 
SO...

What are we going to do about it? The proposed new rules I mean. Maybe it's time to start a new thread so those that want to can continue this discussion on how big bad government is the root of all evil (I agree by the way).

What I'd like to discuss is how are we going to respond to the proposed new rule? Haven't seen much discussion of this yet, and to me, this is where we need to put our energies...

Besides building of course,
 
What are we going to do about it? The proposed new rules I mean. Maybe it's time to start a new thread so those that want to can continue this discussion on how big bad government is the root of all evil (I agree by the way).

What I'd like to discuss is how are we going to respond to the proposed new rule? Haven't seen much discussion of this yet, and to me, this is where we need to put our energies...

Besides building of course,
My thoughts on what to do start with contacting your legislature. We have to have a first name basis conversation with our elected officials to let them know the status quo is not working and needs changing. Then give them your ideas on what needs changing. They need to recognize the value of GA. More thoughts later but this is all I can type now as I have to go back to my real job.
 
The first thing I did was write to EAA and let them know I don't like the proposed new rules and why. I think EAA will be our biggest ally, but not if they don't feel some pressure from members. My guess is this will mostly blow over, but it has the potential to strangle the kit industry if everyone has to return to 1970's-style "kits".
 
Regulation Constipation

The ability of a federal agency to fabricate new law from whole cloth is limited, but their ability to clarify and refine the enforcement of existing law is granted wide deference, hence clarifications and enforcement decisions rather that entirely new law.

But did they fabricate 20% or more of that law? :D
 
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What are we going to do about it? The proposed new rules I mean. Maybe it's time to start a new thread so those that want to can continue this discussion on how big bad government is the root of all evil (I agree by the way).

What I'd like to discuss is how are we going to respond to the proposed new rule? Haven't seen much discussion of this yet, and to me, this is where we need to put our energies...

Besides building of course,

In my experience the best thing to do is to get out all our howling and teeth-gnashing and appeals to the constitution out on this forum or over several beers.

Then, every person who's affected by this should respond through the designated comment channel back to AIR-200, with a well-reasoned, calm statement.

At this point they are not going to back down on having new rules. BUT, government agencies CAN be responsive to arguments that a proposed order will be burdensome or difficult to administer, and will listen to reasonable alternatives.

For example, I would like to point out how difficult it is going to be to submit a "kit w/modifications" for approval under the 51% rule BEFORE construction, when the builder isn't even sure what the changes might be.
 
Now we're talking!

For the FAA to reasonably deal with pre-approval for modifications to a 51% approved kit, they will need to define a "threshold" below which a builder won't loose their pre-approved 51% status. Otherwise the whole process is brought to it's (our) knees. Having to submit to FAA for approval plans for a change is bad enough. Having all such plans in place BEFORE the fact is impossible in an "experimental / amateur built" model.

My proposal would be to allow without prior approval any change that does not decrease the builders fabrication or assembly contribution to the build. So far, ALL of my changes to my 7A QB kit have added a LOT of both...

As written, they are creating a certified like web of terror (OK, maybe I digress a little... ):rolleyes:.
 
Phil Gramm was right...

...you guys are the biggest bunch of whiners I've seen. Thought VAF was moderated but I've seen no moderation on this thread.

Here's some clues:
  1. The FAA is not evil incarnate
  2. Government is not invariably incompetent, nor business a model of efficiency
  3. The proposed rule change--which I guess hardly anybody has read--serves to clear up and reinforce the current Amateur building rule.

Moderate this! But at the same time, could you moderate all the tirades here? Or at least, as someone else proposed, start a new thread that will discuss the topic in a reasoned manner. For, or against, or more nuanced, but always reasonable.
 
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...you guys are the biggest bunch of whiners I've seen. Thought VAF was moderated but I've seen no moderation on this thread.

Here's some clues:
  1. The FAA is not evil incarnate
  2. Government is not invariably incompetent, nor business a model of efficiency
  3. The proposed rule change--which I guess hardly anybody has read--serves to clear up and reinforce the current Amateur building rule.

Moderate this! But at the same time, could you moderate all the tirades here? Or at least, as someone else proposed, start a new thread that will discuss the topic in a reasoned manner. For, or against, or more nuanced, but always reasonable.

I got a chuckle out of this one...
1. Do you know who Bob Hoover is?
2. Have you ever heard the name Katrina?
3. "Hi. We're from the government, and we're here to help."

On a more serious note, some discussions I've had with the EAA folks indicate they are going to push back hard on the 20% rule because the rule is completely unworkable. I suppose the EAA is whiny too then...
 
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The proposed rule change--which I guess hardly anybody has read--serves to clear up and reinforce the current Amateur building rule.

Actually I've studied the PDFs that contain the proposed changes - I downloaded them 6 days ago. I'd be interested to know if you have located answers to the following:
  • Fabrication is not clearly defined because raw material is not clearly defined. E.g. Would rivets be considered raw material or assembled items?
  • The method I should use to determine the percentage that is fabricated is not defined. E.g. Under "Fabricate wing covering or skin" - assuming that flat aluminum sheets are considered "raw" material, how would I allocate the percentage of that fabrication task to measuring and marking, to drilling, to bending, to cutting to shape, to countersinking, to de-burring, and to priming? For any given chosen metric, say hours worked, energy expended, mass of items, count of items, task count, volume of items, or length(s) of items, wouldn't I have to be informed by the kit manufacturer how many of said metric it used to perform its portion of the fabrication in order for me to provide an honest estimate of the percent that I fabricated?
  • The proposed checklist is airplane-centric; do you see any way it can provide guidance to homebuilders constructing gliders, rotorcraft, airships, or balloons, for example? What's a DAR to do?
  • Did you see in the checklist that it contains scores of tasks of completely different degrees of difficulty all of which are assigned equal weight? E.g. Assembling propeller to the engine counts the same as fabricating an engine cowling? (This can be a good thing or a bad thing, depending on why the builder is building. In some cases it is good that an assembly task weights the same as fabrication - in other cases it is grossly unfair.)
  • Did you notice that aspects that previously were never included are now counted against you if you choose to farm them out? E.g. Various control panel electrical system tasks?
  • Do you see anywhere in the checklist instructions on what I should do if some items are not applicable (e.g. The plane I am building has no composite cores in the wings(!), or no flaps, or no aileron trim, or I do not need to fabricate any tools or fixtures, or....)? Notice that "Note 1" of the checklist says the totals must add up to 187! Do you think that if anyone in the FAA had actually done a proper critical/sanity review of the checklist procedure prior to publishing it that it would have been published with such a note?

The proposed changes are not, in my humble opinion, clarifications but are rather a new set of rules. And poorly thought through - in my humble opinion of course.
 
  • Fabrication is not clearly defined because raw material is not clearly defined. E.g. Would rivets be considered raw material or assembled items?
  • The method I should use to determine the percentage that is fabricated is not defined. E.g. Under "Fabricate wing covering or skin" - assuming that flat aluminum sheets are considered "raw" material, how would I allocate the percentage of that fabrication task to measuring and marking, to drilling, to bending, to cutting to shape, to countersinking, to de-burring, and to priming? For any given chosen metric, say hours worked, energy expended, mass of items, count of items, task count, volume of items, or length(s) of items, wouldn't I have to be informed by the kit manufacturer how many of said metric it used to perform its portion of the fabrication in order for me to provide an honest estimate of the percent that I fabricated?
  • The proposed checklist is airplane-centric; do you see any way it can provide guidance to homebuilders constructing gliders, rotorcraft, airships, or balloons, for example? What's a DAR to do?
  • Did you see in the checklist that it contains scores of tasks of completely different degrees of difficulty all of which are assigned equal weight? E.g. Assembling propeller to the engine counts the same as fabricating an engine cowling? (This can be a good thing or a bad thing, depending on why the builder is building. In some cases it is good that an assembly task weights the same as fabrication - in other cases it is grossly unfair.)
  • Did you notice that aspects that previously were never included are now counted against you if you choose to farm them out? E.g. Various control panel electrical system tasks?
  • Do you see anywhere in the checklist instructions on what I should do if some items are not applicable (e.g. The plane I am building has no composite cores in the wings(!), or no flaps, or no aileron trim, or I do not need to fabricate any tools or fixtures, or....)? Notice that "Note 1" of the checklist says the totals must add up to 187! Do you think that if anyone in the FAA had actually done a proper critical/sanity review of the checklist procedure prior to publishing it that it would have been published with such a note?

If it's any help, I sent in a list of comments very similar to your list, and including a few others, after I had read all of the documents. I recommend that you and others do the same. We've only got 30 days. If we don't point out the mistakes now, we've got no right to complain about it later.

PJ Seipel
RV-10 #40032
 
What does The Man have to say?

Van's website seems quiet on this announcement. Does anyone know if the company has anything to say publicly?
 
If it's any help, I sent in a list of comments very similar to your list, and including a few others, after I had read all of the documents. I recommend that you and others do the same. We've only got 30 days. If we don't point out the mistakes now, we've got no right to complain about it later.

PJ Seipel
RV-10 #40032

I do intend to submit comments similar to what I posted - what I wrote needs to be cleaned up in several ways before I submit it to the FAA. The only thing I'd add is that one should always be diplomatic (I'd never submit a comment to the FAA telling them I thought they hadn't thought their proposal through, for example! And the "tone" I'd try to impart would be non-confrontational.)
 
Some of us don't like the whole big picture

.......
  1. The FAA is not evil incarnate.........................
We're starting from the premise that the whole system is screwed up and needs to be fixed, otherwise GA IS going to die.

As far as your #1, I got my dad a T-short that read:

FAA mission statement
"We're not happy until you're not happy"
 
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