terpster...
Concur with your assessment...
The FAA has gone down the path of facilitating self certification..
In reality...the regulators are 'validating' the validity of the submission to them..
It is NOT the mission of any regulatory agency to approve, therefore assume liability for the aircraft....
It is only the regulators duty to approve what was submitted to meet the minimum requirements, and it is NOT the regulators scope to design by regulations, how the system meets the criteria...
A significant disconnect in my view..