Dear Administrator

A chance to offer a bit of advice to the new FAA Administrator

By the time you read this article, Marion Blakey’s term as the 15th FAA Administrator will have expired. All in all, I would give her high marks as a manager especially her firm stance in dealing with the ATC “can of worms” problem that was dropped on her lap by her predecessor. Because of that disaster, she spent most of her five-year term negotiating with the Air Traffic Control union and being harassed by congress over the passenger delays at the nation’s airports over the last two summers because she could not control the weather. I wish her well in her new career as a re-covering bureaucrat.

I also did my time in the big house, walking in the shadows of the great and powerful. But I always held out a little bit of envy for the private citizen who could write to their elected representatives and/or employees of the executive branch and tell them what they thought, all without the threat of instant retribution.

I can assure you that as a former government employee one would not have to worry about long-term career goals in the bureaucracy if you told the powers-that-be that their shoe laces were untied. But now, as a private citizen I finally have my chance to offer a bit of advice to the new FAA Administrator. I would like to share the draft letter to the new guy with you.

Dear FAA Administrator:

I wish to offer my congratulations on your appointment to the toughest but also the most rewarding job in aviation. I will pray that you survive the ordeal. If I might be so bold I would like to offer you some suggestions dealing with a small but important part of your overall responsibilities to ensure aviation safety. My suggestions will be limited to those issues and rules dealing with aviation maintenance and ideas for improving communication between mechanics and the FAA.

1. Part 145: I would ask you to consider revising the Part 145 repair stations rule yet once again. This time to grant some relief to smaller repair stations of 15 people or less and who are not involved in air carrier aircraft maintenance functions.

This new Part 145 “Lite” rule change would not affect the current Part 145 rules for Part 121/135 aircraft nor would it have a negative impact on safety. Its only purpose would be to streamline operations at smaller repair stations by removing excessive administrative and regulatory requirements. I recommend that you call a meeting of interested parties in Washington during the month of October to draft a white paper of the proposed changes for your review.

2. Part 43: This well-written Part with only 13 rules goes back more than 50 years and has served us well, but it needs a rewrite. The problem with Part 43 is, with the addition of Light-Sport aircraft and experimental aircraft such as ex-military jets, the rule no longer clearly addresses the mechanic duties and responsibilities for aircraft issued a Standard Airworthiness Certificate or a Special Airworthiness Certificate. If Part 43 was separated into individual Sub-Parts that addressed Standard and Special Airworthiness Certificates separately it would go a long way to reduce the confusion and subsequent never-ending legal opinions that surround the rule.

Once that change to individual Sub-Parts is done perhaps a definition of “Airworthy” for aircraft issued a Standard Airworthiness Certificate and a definition for “Condition for Safe Operation” for aircraft issued a Special Airworthiness Certificate could be inserted into the rule.
In addition, the five appendixes at the end of the Part 43 are hopelessly out of date. Industry would be better served if instructions on major repairs, major alterations, and preventive maintenance, recording of major repairs and major alterations, scope and detail of items included in 100-hour/annual inspections, and altimeter and transponder inspections were put into separate FAA Advisory Circulars (AC). AC are far easier and faster to update than to worry through the rule-making process.

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