See, wasn't that easy?
Syd
On Sep 14, 2009, at 8:22 AM, Bill BIGGS wrote:
Hello Bill,
What it says on the registration certificate is not an issue. What
it says on the airworthiness certificate is. So long as the
aircraft has always been certificated as a 415C, and there are no
maintenance records to indicate that it was ever switched to a 415D,
you'll be fine. The airworthiness certificate and maintenance
records are the key.
Joe Norris
EAA Aviation Services
EAA Aviation Center, Oshkosh, WI
888-322-4636, extension 6806
[email protected]
CC: [email protected]
From: [email protected]
Date: Mon, 14 Sep 2009 06:36:33 -0500
Subject: Re: [ercoupe-tech] 415-C/D - When it is an LSA and when it
is not?
Ed, William and everyone else that's made comments on this:
Guys, you are making this waaaaaay too complicated. Just call my
friend Joe Norris at EAA. He was on the joint EAA/FAA committee
that WROTE the Light Sport rules. He can tell you EXACTLY the
answer to all this controversy.
Syd
On Sep 13, 2009, at 11:36 PM, Ed Burkhead wrote:
Well said, Bill.
Please let me adjust and amplify, riffing on your last couple of
paragraphs where you said:
>>>>>>>>>>>>>>>>>>>>>>>
That reasoning, unfortunately, validates a perception of the FAA as
mostly untrustworthy bureaucrats who prefer to rule the aviation
community by intimidation and fear rather than by way of competent
and equitable administration. It encourages intentional ambiguity in
the drafting of FAA Rules and Regulations so as to increase the
discretionary power of the agency and its individual
representatives. True or not, I find such possibilities so utterly
and intensely repulsive as to oppose such almost reflexively.
If it were up to me, I'd push for an official interpretation on FAA
letterhead from a representative of appropriate authority. I deem it
"bad for the fleet" as a whole when different FSDOs are free to
differently interpret and enforce applicable rules in their
individual feifdoms. Such violates the constitutional right of each
and every one of us to equal application of the law, and substitutes
the rule of men for the rule of the law.
<<<<<<<<<<<<<<<<<<<<<<<
My thought pattern is this:
Time in the Army gives one experience in dealing with really big
organizations. One of the things that can be learned is that it
takes a lot of organization to get it to function at all.
Next is that, even so, in any enormous organization, the
imperfections of people, words, procedures, etc., make things
sometimes just not work right.
It’s usually not malignancy (but sometimes it is). The aphorism,
“When trying to decide whether something is coming out badly due to
ill will versus incompetence, choose incompetence and you’ll almost
always be right.”
That’s not to say the FAA people are all that incompetent. But,
what they and the organization as a whole are being asked to do is
detailed, picky, layered, sometimes life-and-death critical and more.
Like the dancing bear, it’s amazing that the FAA (and the Army) does
as well as it does and can dance at all!
I don’t for a second think the FAA intentionally wrote that
regulation ambiguously. But, have you ever tried to write an
unambiguous, perfect set of rules that enforces exactly what you
want? I made a career of it for a few years as a computer
programmer. It sure ain’t that easy in a rigorous programming
language and I think it’s impossible in English.
In the good old days, the FSDO had engineering representatives who
were engineers! They could make evaluations based on aviation needs
and reality. As there aren’t enough of those engineers to go
around, we’re making do with the best the FAA can get and many (?
most?) of them do pretty well, most of the time.
I agree with you, Bill, that the dependence on local FSDO rulings is
inequitable and silly. Yet, we all worry about trying to centralize
all such decisions because it might get taken over by the
legalistic, bureaucratic jerks who are worried about career building
and have little personal involvement an love for aviation. And then
we’d get no good rulings at all.
At least the FSDO people are close to local aviation.
At the higher levels, the FAA is generally unwilling to respond to
individuals or small groups. For now, we do have people working
with the FAA on our behalf, trying to get that FAA letterhead
document which does what we’d like to see. There are people, it
seems, in Coupe-air-space and the FAA who think it may be possible
to get this done. Do not bet big amounts of money on this till
after it is written and published.
Yes, a centralized, national, official document is what we want, as
long as it says what we want and not the opposite!
I hope we’ve made it clear to owners and potential owners where the
risks are in LSA-ambiguous aircraft. I hope it’ll shake out the way
we want and we’ll all certainly do what we can to help that happen.
Ed
Ed Burkhead
http://edburkhead.com/Ercoupe/index.htm
ed -at- edbur???khead.yyy change -at- to @, remove the ??? and
change yyy to com
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