Sonex Aircraft, LLC formally submitted its comments to the FAA today, regarding proposed policy changes to the Experimental-Amateur Building regulations which empower Sonex Aircraft and AeroConversions customers in the United States with the privilege of constructing and flying their own homebuilt aircraft. The message, sent this morning by Sonex Aircraft CEO and General Manager Jeremy Monnett to Miguel Vasconcelos of the Production and Airworthiness Division of the FAA, was clear: Enforce the regulations already in-place, and do not place an undue burden upon builders complying with the spirit and intent of the Experimental-Amateur Built aircraft regulations by creating new regulation via changes in policy. Monnett¹s comments to the FAA can be found in their entirety below.
Sonex Aircraft joined the Experimental Aircraft Association (EAA) and others in calling Sonex and AeroConversions customers to action today, with a web site posting on www.SonexAircraft.com urging individuals to submit their own comments to the FAA regarding the proposed ³51 Percent Rule² calculation and enforcement policy changes before the September 30, 2008 comment-period deadline. More information, sample letters and submission instructions can be found on EAA¹s web site at: http://www.eaa.org/news/2008/2008-09-04_proposal.asp
Sonex Aircraft has participated in an FAA-chartered aviation rulemaking committee (ARC) formed to study amateur-building issues which rendered recommendations from August 2005 through November 2006, and plans a presence at the next meeting, scheduled for October 22nd and 23rd, to discuss public comments submitted in response to the FAA¹s proposal. The ARC, consisting of representatives from government and industry, was formed in response to abuses to the spirit and intent of the Experimental-Amateur Building regulations via excessive commercial assistance and ³professional builders.² As a participant in the ARC, Sonex Aircraft CEO Jeremy Monnett has been steadfast in his recommendations to simply enforce the regulations already in-place.
Sonex Aircraft, LLC Comments to FAA: September 11, 2008
Sonex Aircraft is proud to have participated in the FAA ARC set up to explore possible solutions to address professional building in the Experimental-Amateur Built Aircraft Community. Sonex Aircraft is pleased that the FAA has shown a willingness throughout this process to not just listen to industry feedback, but to use it in addressing the real and perceived problems with the current rules.
Sonex Aircraft is concerned that the proposed changes will place significant burdens on those who are building within the letter and spirit of the regulations while doing little to address excessive commercial assistance and "pro building".
*The key to the continued success of the Exp-Amateur Built rules depends on the consistent enforcement of the rules already in place. The resources required to carry out this enforcement have not been made available by the FAA over the last few years. Without these resources, enforcement loosens and the rules are pushed beyond their spirit and intent, compromising the rules continued existence.
*The regulations found in 21.191(g) require the builder to fabricate and assemble the major portion of the amateur-built aircraft. To require a specific percentage (e.g., at least 20% fabrication and 20% assembly) imposes a burden on the homebuilder community that is beyond the scope of the regulation, and is regulation by policy. Sonex Aircraft is an example of an Aircraft Kit Company that is successfully operating (and will continue to
operate) within the spirit and intent of these rules. We believe that the rules provide for tremendous cost savings to any aviator who is willing to build and fly their own aircraft for education and recreation.
*Sonex Aircraft has focused many resources on education with our highly successful series of Builder¹s Workshops and leads the industry by providing as much detailed documentation as possible to builders. Our focus on complete documentation allows builders to rely on themselves to build their own aircraft using proven and reliable practices.
Sonex Aircraft supplies aircraft kits that maximize the value of component parts per dollar spent while requiring the builder to fabricate and construct the majority of the project in accordance with Experimental-Amateur Built aircraft rules.
Sonex Aircraft, LLC put in a formal request to have our newest kit options including the machined angle kits and assembled spars reviewed. We would like to be one of the first kits to be reviewed as soon as the Draft Publication is adopted.
The priority of Sonex Aircraft is to preserve the privileges we all enjoy as homebuilt aircraft builders for future generations of Builders and Pilots.
We feel this can be accomplished by enforcing the rules we have, not adding a whole new level of bureaucracy and complexity to these rules.
Sonex Aircraft, LLC
Source: Sonex Aircraft
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