Rick,

 

I totally agree with you.  If the 8000-38 is the way you determine major portion, than the DAR should use the form.  Or the FAA should change the rules for everybody. If I had to certify my ES, I'd be in big trouble if it's based on time spent!  But even the proposed rule change doesn't make any substantial changes to 8000-38.

 

But if they change the rules Epic won't be the only company with problems.  If you went by hours, every Lancair would fail to pass the test.  Every Glasair, Glastar, Vans Quickbuild, and about 20 others would be in deep trouble.  Major companies have been built by the use of 8000-38, Epic included.

 

Mike