From: "Marvin Kaye" <marv@lancaironline.net>
Subject: Re: [LML] Re: FAA trying to stop us my .02
To: lml
Date: Mon, 19 Sep 2005 23:41:15 -0400
Message-ID: <web-727385@logan.com>
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Posted for "John W. Cox" <johnwcox@pacificnw.com>:

  Hey Bryan, I have the utmost respect for your post and your gorgeous
  aircraft, N132BB.  However, with 23 years as a DPE, a 141 Training
  School Operator, now doing maintenance with one of the nation's top Part
  121 regional carriers, I take a separate view from my narrow
  perspective.
  
  The FSDOs drag 135 operators over broken glass to get operating
  approvals.  They harass the operation with periodic and ineffectual
  inspections.  The personnel who work 121 do have a different task load
  than 91 - on that we agree.  Many of my past friends could see the light
  and made the career change.
  
  The FSDOs and MIDOs have not been allowing Factory Assist to just get
  around any rule. They have been comfortable with the way the rule was
  written before the market moved the bar up several rungs in quality, in
  safety and in complexity. A prudent builder can drive a Freightliner
  through the hole which everyone has known was there.  VanGrunsven has
  done quite well with a range of simple products that do not hold a
  candle to the skill sets of almost any Lancair builders. Yet both sets
  go home with the Repairman Cert after the dust settles. If Carl built a
  non approved kit and Rick did not obtain the coveted Letter of
  Authorization before marketing it... then my heart is truly heavy for
  both of them.  I agree this is an important issue needing clear, fair
  and swift resolution.
  
  I think value to current and future builders might be received if we
  focused our political clout on how a new and modified rule should be
  shaped and then push for its adoption.  I hate to just wait for the feds
  to drop the other shoe.  And yet I must trust Rick's judgment with the
  assistance level he is says he is receiving from EAA.  I value the
  education received and the increased quality obtained by specific
  professional assistance through the build process. I do not condone
  handing the process away and letting the federal resentment to where the
  industry now stands, alter this opportunity.  I strongly support the
  continuation of Factory Assistance by any manufacturer.  I also would
  lobby loudly on the value of retention in being able to build the whole
  damn thing away from their facility as well.  I do not share with Dick
  VanGrunsven, the attitude that building a plane at an airport is wrong
  or that the education received is more valued if building it in an auto
  garage - next to your kitchen and bedroom.
  
  I intend to become a Kit Build DAR, I intend to offer professional
  assistance and I now must patiently wait in the wings for this saga to
  unfold.  I just don't know what that privilege will look like when it
  finally comes.  I think the Kit Factory parts manufacturers should come
  together with the DARs, along with FAA MIDO leadership, in authorizing a
  Kit Build IA designation for the more complex finished products.  Then
  just let builders get back to acquiring the satisfaction and education.
  
  I am just squatting on the proverbial high roof, waiting for the hot
  water of scrutiny to recede and for the federal relief team from
  MMAC/OKC to leave town (on this issue). Then let's help builders get
  back to building great products.  I see no problem in periodic builder
  inspections and holding professional builders to a higher inspection
  requirement than kit purchasers.  It is the rare builder who chooses not
  to spend the extra hard earned bucks for assistance but rather climbs
  the mountain solo that now needs protection from the downside fed slide.
  Documentation and Inspection Authorization performed on workmanship by
  professional builders should be a "No Brainer".  The weak link is in the
  certification of the finished kit where we now should shine the light of
  each of your experiences.  A simple Orals and Practicals session the
  Repairman applicant would shed light on the education process and then
  this all would be moot.  Wouldn't it?
  
  My prayers are with both Carl and Rick.
  
  John - KUAO