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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
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