Excellent idea.
Ed can you call? Hartmut CC: [email protected] From: [email protected] Date: Mon, 14 Sep 2009 09:03:56 -0500 Subject: Re: [ercoupe-tech] 415-C/D - When it is an LSA and when it is not? Hartmut and all, EAA's phone number is 920-426-5912. Ask for Joe Norris. I suggest that Ed Burkhead should call Joe and then report back to the group, rather than 50 or 60 of us asking the same question and irritating him. Syd On Sep 14, 2009, at 8:13 AM, Hartmut Beil wrote: Syd, you need to add the phone number of your friend. Else we can't call. Hartmut 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 With Windows Live, you can organize, edit, and share your photos. _________________________________________________________________ Show them the way! Add maps and directions to your party invites. http://www.microsoft.com/windows/windowslive/products/events.aspx
