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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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