EAA Speaks Out For Vintage, Homebuilts, LSA Communities
February 8, 2007 — Financial and unintended safety ramifications for the vintage, experimental amateur-built, and light-sport aircraft fleets were the primary focus of EAA's comments to a recent FAA notice of proposed rulemaking (NPRM) regarding aircraft parts. EAA generally credits the FAA's efforts to standardize quality systems and update the regulations to reflect today's global manufacturing and continued-airworthiness standards. However, EAA had several suggestions to protect small PMA manufacturers and individual aircraft owners.
"Increased costs imposed by the new rules could actually result in decreased safety," said H.G. Frautschy, executive director of the Vintage Aircraft Association. "The small PMA manufacturers may opt to not produce parts because of the compliance costs, resulting in a diminished supply. Similarly, aircraft owners may choose not to incorporate new and improved products and technologies in their older aircraft because of the excessive costs of getting such modifications produced."
The NPRM also does not take into account older type-certificated aircraft for which the design approval holder, type certificate holder, or production approval holder has not existed for 50 or more years.
EAA asks that preamble language regarding "Falsification of applications, reports, or records" be revised to allow "legal and correct promotion" of parts and components intended for the experimental amateur-built and light-sport aircraft markets.
EAA also sides with the Univair Aircraft Corporation in taking issue with the proposed requirement to "legibly mark each part or appliance and each component of each part or appliance." EAA feels this is an unreasonable burden, impractical or impossible in many instances, and largely would not benefit safety.