Bret Ludwig wrote:

IMO the regulation needs to say that the amateur builder needs to
accomplish 51% of the total build hours and do a representative example
of each of the tasks required to go from raw material to airplane.

First, define 'raw material'. Do I have to head out to the north-west
to hunt down a spruce tree or two, and then do a little mining to get
some iron ore? Will the neighbors in Jacksonville, Fl object to the
aluminum smelter in the backyard?

Second, build time will mean nothing in this context. If I stare at an
aluminum wing rib for 3 hours with a beer in each had trying to figure
out which way is up, how many build hours have I invested? Who's
counting, and do we really want another list of rules to specify
"certifiable build time"?

He
may work "under the supervision of" an A&P or other professional but he
has to do it with his own physical involvement. An amateur builder
being someone who does not work as an aircraft mechanic or production
worker.

So aircraft mechanics and production workers will no longer be allowed
to build their own aircraft? That's an awfully severe restriction on
the liberties of these people.

They should be allowed to build an Experimental Amateur Built
for their own use but serious restrictions on how many they build, how
much they must fly it and how long they have to keep it should be
enacted to stop the hired guns cold. And the Builder Centers should be
very limited in how much of the work can be done there.


What if the project is never completed by the person who starts it?
What if the starter dies, loses his medical or just finds that he hates
sheet metal/epoxy/sawdust/MEK/etc? What if I get cancer from the MEK
and need to sell the airplane to pay the doctor? Why are builder
centers bad? Is it safer to bend a rib on the centers jig in 2 minutes
or to cobble together my own jig in several days that takes an hour to
bend one...only to throw the jig away and have all the other builder's
duplicating the same inefficiency?

Type Certification is either good or it is bad. If it is good, and I
think it is, what we are seeing in experimental amateur built aviation
is largely a dodge around type certification.

Type Certification is bad because it was implemented with no more
foresight that what you have shown. Laws have to exist in the real
world just like the airplanes we build. The idea that a mechanical
system can be completely specified and then have holy water sprinkled on
it and declared safe from a bevy of bureaucrats is fundamentally flawed.
Washington will never do it, because it entails voluntarily
relinquishing power (bureaucrats don't do that), but the FAA and FDA
both need to back the hell up, assume the role of an advisory
organization, and quit trying to act as if they can guarantee 100%
safety through their "certification". They don't and never will know
everything any more than I will.

The law should be that an airplane be allowed to post a placard that
says, "This aircraft complies with FAA standards for safety." or some
such wordy mumbo-jumbo that the bureaucrats choose, IF and ONLY IF the
producer of the aircraft chooses to pursue the compliance. Everyone else
must carry a placard stating that the airplane does not comply with the
regulations. Does not vs may not, because not choosing to pursue the
compliance will in itself be a non-compliance. People who buy
airplanes, in conjunction with their insurance companies, can decide for
themselves if they give a flip about FAR compliance. Airplanes would
have to be insured in order to work for hire, just like the rest of the
transportation industry. The insurance company will take care of
verifying for hire aircraft safety, just like they do in the rest of the
transportation industry.

Same with the FDA. I should be allowed to hand money to any quack I
choose to pull a splinter, but you can bet your bottom I'll be searching
for a real reliable certification before someone comes at me with a
knife. Difference is, I get to choose. Problem is, people don't want
choice. They want to be coddled, so this foolishness will continue.