For your information EAA is working on making this bill of sale issue easier
on manufacturers & builders both.
Bob Jacobsen
N165BB
June 2, 2004 - EAA's recently submitted a request to change a Federal
Aviation Regulation (FAR) that would ease administrative burdens on for
homebuilders when they register their kit-built aircraft. FAR 47.33
currently requires the owner of an aircraft built from a kit to submit a
bill of sale with the application. The problem is most manufacturers do not
provide a bill of sale with the delivery of a kit. However, they do provide
an invoice.
EAA's recommends adding the words "or invoice" to FAR 47.33(c) as follows:
"If he built the aircraft from a kit, the applicant must also submit a bill
of sale or invoice from the manufacturer of the kit."
In February this year, FAA requested public comments for amending, removing
and simplifying any FAR. EAA's Aviation Services department routinely helps
EAA members sort out problems encountered while registering their aircraft.
the lack of a bill of sale is by far the biggest cause for delays in the
process.
"The requirement of a bill of sale causes a disproportionate number of
rejected registration applications that results in an administrative burden
on both the FAA and the aircraft builder," said Aviation Services Director
Charlie Becker. "Nothing is more frustrating to a builder than having the
paperwork process unnecessarily delay the first flight of the aircraft that
they worked so hard to complete."
The FAA's goal in requiring this documentation is to establish that a
particular kit was the starting point in the construction of the aircraft
regardless of the make or model listed by the amateur builder.
"This can be accomplished with an invoice," Becker said.
EAA members should note that it could take the FAA up to one year to
implement the requested change. EAA will continue to monitor the progress of
this change request as it works its way through the FAA/DOT rulemaking
system.
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