This is from another group, makes sense to me:
This is the comment I submitted:
-Dana
A computer lets you make more mistakes faster than any invention in
human history... with the possible exception of handguns and tequila.
----- Original Message -----
From: turner402001
To: Sent: Friday, March 05, 2010 8:23 PM
Subject: Exemption to FAR 65.107
Hello Group. I used to own a CGS Hawk Single Seat Classic. Please read the folowing letter that I sent to my local EAA club.
Hello. I own an Experimental plane, a Zodiac 601 HDS, that I did not build, so I am not allowed to do the annual condition inspection. It is difficult to find A+Ps who will do the annual condition inspection on Experimental planes, so I have requested an exemption from the FAA to FAR 65.107 to allow me, as the owner of an Experimental Amateur-built aircraft, to attend a light-sport aircraft repairman inspection rating training course, and upon sucessful completion of that course be allowed to apply and receive a LSA Repairman Inspection Rating Certificate for the purpose of conducting annual condition inspoections on my Zodiac 601 HDS.
A while back there was a glitch that allowed Experimental Planes to be registered as ELSA, which then allowed the owners, even if they did not build the planes, to take a course which would allow them to do the annual condition inspection. My request to the FAA would allow present owners who did not build their planes to get the same benefit.
I do not think that changing this regulation would offend AP/IAs because they do not want to work on Experimental planes anyway. It might increase their business because if the owner could sign off his own condition inspection then I suspect that AP/IAs would not mind helping with the annual inspections.
Also, I suspect that allowing owners who did not build their planes to sign off the annual inspections would increase the value of Experimental planes.
There is a chance that this Exemption could be obtained. By submitting a petition it will show the FAA that there is public demand for changing the regulations.
My petition for exemption has been assigned a DOT docket number of FAA-2010-0165- 0001. Anybody can make a comment to this by going to the docket web site: Regulations.gov - typing those numbers in the "Enter Keyword of ID search block. Then on the right side of your docket will be a "submit comment" icon - by clicking on that anyone can request to be added to my petition or can make general comments about the petition.
Regards,
Damien
This is the comment I submitted:
This petition is in the public interest and should be approved, for the general case and not just for this individual.
During the so called "fat ultralight" transition period, owners had the choice of whether to convert their aircraft to an Experimental Light Sport Aircraft (ELSA) or, if it met the guidelines, to an Experimental-Amateur Built (E-AB). In many cases, identical aircraft were granted different certifications due to the whim of the builder. Many chose the E-AB route to avoid having to take the 16 hour class. If an E-AB aircraft fits within the guidelines of ELSA, it should be allowed to be maintained and inspected as ELSA, just as a Sport Pilot can fly an aircraft with stand certification provided it meets the LSA limits.
-Dana
A computer lets you make more mistakes faster than any invention in
human history... with the possible exception of handguns and tequila.
