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Date: Sat, 17 Sep 2005 11:52:37 -0400
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From: Rick Schrameck <rickschrameck@cox.net>
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Subject: Re: [LML] Re: FAA trying to stop us.
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Bryan,

I have spent a lot of time on this and I have to say that some of your 
beliefs are not correct.  The regs say major portion of the aircraft  
That does not mean that you can buy a firewall forward, have someone 
make and install the avionics or install the engine.  I was of the same 
belief as you until last week.  No where does it state that it is really 
the airframe, lift surfaces,control surfaces, etc.  I was told by the 
Regional head of the Seattle MIDO that 51% major portion means the 
complete aircraft.  You do not have to build the engine, prop, 
instruments or PFD's but you must be involved in the installation of all 
of them to meet the 51% rule.

Please all of you take a close look at the new regs.  The government 
does not do anything without a reason.  The FAA told the EAA yesterday 
that no changes are going to happen today, that does not mean they will 
not change with the new order.  If this is the case what are the new 
regs for?  They say clarification that they have been working on for 
years.  The order does not change the regulations only how they can deal 
with them.  The new regs do not effect the already evaluated kits but 
allows them to deny your certificate if you use commercial help.  If the 
builder is not present when the FAA guy demands entrance into the build 
shop you are in big trouble.  The FAA can not do that under the existing 
order without special permission from the top or he has to give his 
bosses justification for demanding entry into the facility.  I think 
this is a BIG deal.  With the new regs they have much more freedom to 
deny quick build, factory builder shops and commercial assistance.  Read 
the part that says if an FAA inspector comes to a builder assist shop 
and is not let in he can turn down your certificate.  It is not a change 
in the regs but a major position that the FAA can take when it decides 
to go unannounced into Lancair and the many build shops in Bend and 
Redmond and for that matter anywhere in the country.

The EAA is saying that there are no changes that affect the builder.  I 
believe the new 8130-2 order gives the inspectors dramatic powers to 
deny you your certificate if you use any help past a "fast build kit"

If any of you have access to a friendly lawyer, not one that owns a kit 
company, have them read the new proposed order highlights that Carl has 
given you.  I believe the lawyer will tell you that the FAA has given 
themselves more power than the old order did.

Rick


Legacy 123
and Epic 001


Marvin Kaye wrote:

> Posted for "Bryan J. Burr" <bjburr@mwheli.com>:
>
>  I believe another important point to mention is that there are some
>  items that are done during the build process that don't even get
>  considered in the 51%-49% rule.  These items can be done by paid
>  professionals.  IE. Firewall forward, engine build, engine installation,
>  propeller installation, panel build, panel installation, interior,
>  paint, etc.  The rule really applies to the airframe, lift surfaces,
>  control surfaces, etc.
>  
>  Bryan
>  N132BB
>  
>
> -- 
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>