X-Virus-Scanned: clean according to Sophos on Logan.com Return-Path: Sender: To: lml@lancaironline.net Date: Fri, 16 Sep 2005 21:52:00 -0400 Message-ID: X-Original-Return-Path: Received: from imo-m24.mx.aol.com ([64.12.137.5] verified) by logan.com (CommuniGate Pro SMTP 5.0c2) with ESMTP id 724687 for lml@lancaironline.net; Fri, 16 Sep 2005 21:15:15 -0400 Received-SPF: pass receiver=logan.com; client-ip=64.12.137.5; envelope-from=MikeEasley@aol.com Received: from MikeEasley@aol.com by imo-m24.mx.aol.com (mail_out_v38_r5.5.) id q.8.704f40e0 (16781) for ; Fri, 16 Sep 2005 21:14:25 -0400 (EDT) From: MikeEasley@aol.com X-Original-Message-ID: <8.704f40e0.305cc7f0@aol.com> X-Original-Date: Fri, 16 Sep 2005 21:14:24 EDT Subject: Re: [LML] Re: FAA trying to stop us. X-Original-To: lml@lancaironline.net MIME-Version: 1.0 Content-Type: multipart/alternative; boundary="-----------------------------1126919664" X-Mailer: 9.0 Security Edition for Windows sub 5200 X-Spam-Flag: NO -------------------------------1126919664 Content-Type: text/plain; charset="US-ASCII" Content-Transfer-Encoding: 7bit Carl, 146.4c, at least the way I interpret it, says that kits that are all completed parts aren't eligible. Lancairs and RVs wouldn't fit that description. These kits have already passed the FAA test, and it doesn't look like the test is changing in this document. 147a (3) spells out what I said in an earlier post. If you are there, you can say you did the work. If you do little bits and pieces, leave for a couple weeks, and let the hired help do the rest, you will drop below the 51% and lose your amateur built status. The description of doing one rib and someone else doing the rest applies to what happens after you receive your 51% approved kit. If the kit is approved with all the ribs in, and you only glue on the bottom wing skin (like my ES kit), you are fine because the FAA has already determined that the builder still has 51% to do. But don't leave the facility when any work is being done on your plane, or you are at risk of dropping below the magic 51% line. I think Lancair can avoid the potential disqualification in 148a, where a kit is too complex to be built by an amateur in their own shop, because some IVPs, even IVPTs have been built by individuals. That paragraph looks like it is aimed directly at Epic. Virtually every change in the wording points to the DAR needing to make a determination, and every one of the planes that has some amount of builder assist must be evaluated on an individual basis. The real core of the changes center around the difference between "building" and "assisting". I'm not sure how the professional builder "assist" guys handle it now, but I'm sure they walk a fine line. Mike -------------------------------1126919664 Content-Type: text/html; charset="US-ASCII" Content-Transfer-Encoding: quoted-printable
Carl,
 
146.4c, at least the way I interpret it, says that kits that are all=20 completed parts aren't eligible.  Lancairs and RVs wouldn't fit that=20 description. These kits have already passed the FAA test, and it doesn't loo= k=20 like the test is changing in this document.
 
147a (3) spells out what I said in an earlier post.  If you are th= ere,=20 you can say you did the work.  If you do little bits and pieces, leave=20= for=20 a couple weeks, and let the hired help do the rest, you will drop below the=20= 51%=20 and lose your amateur built status.
 
The description of doing one rib and someone else doing the rest applie= s to=20 what happens after you receive your 51% approved kit. If the kit is approved= =20 with all the ribs in, and you only glue on the bottom wing skin (like my ES=20 kit), you are fine because the FAA has already determined that the builder s= till=20 has 51% to do.
 
But don't leave the facility when any work is being done on your plane,= or=20 you are at risk of dropping below the magic 51% line.
 
I think Lancair can avoid the potential disqualification in 148a, where= a=20 kit is too complex to be built by an amateur in their own shop, because some= =20 IVPs, even IVPTs have been built by individuals. That paragraph looks like i= t is=20 aimed directly at Epic.
 
Virtually every change in the wording points to the DAR needing to make= a=20 determination, and every one of the planes that has some amount of builder=20 assist must be evaluated on an individual basis.  The real core of the=20 changes center around the difference between "building" and "assisting".
 
I'm not sure how the professional builder "assist" guys handle it now,=20= but=20 I'm sure they walk a fine line.
 
Mike
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