3. Part 65. This is the rule that sets the certification standards for mechanics and repairmen. These standards are more than 50 years old and need to be revised. For example, an additional 300 hours of electrical/avionics training must be included in the certification requirements for Airframe and Power Plant (A&P) mechanics ratings to ensure that the new mechanic has the background to learn and maintain the new “all electric” aircraft such as the Boeing 777, 787, and the Airbus series of computer-driven aircraft. This would be the first step in creating the training requirements for an Avionics rating.
Along those same lines A&P mechanics should be given a means of progressing further in their profession. I recommend that you consider a new FAA rating for mechanics called the FAA Maintenance Engineering Rating. I see this rating as a mechanic’s interface between the hangar floor and management and/or engineering in large air carriers or repair stations. This rating will build on the existing A&P rating by allowing the applicant to take additional FAA accepted maintenance-related courses at an FAA approved college or university. Once the mechanic completes the approved course, the FAA will issue the rating without further showing. This rating would be the maintenance equivalent of an Air Transport Pilot (ATP) rating.
4. Inspection Authorization (IA): This authorization is issued to A&P mechanics to sign off annual inspections, major repairs, major alterations, and to conduct progressive inspections. To renew one’s IA you must perform at least four annuals or sign off eight, FAA Form 337, major repairs or alterations or one progressive inspection. I recommend that IAs should be given credit for renewal of their IA, if they returned to service under their A&P, after completing one large corporative, turbine-powered aircraft inspection covered under section 91.409. I would also recommend that you allow an IA to sign off repairs identified on the FAA Form 8130-3 Airworthiness release tag.
5. Improving communications: First, please do away with plain language question and answer policy that created rules as found in Part 11, Part 39, and other documents. No other Civil Air Authority writes rules this way. It has done little to improve the image of the FAA’s ability to communicate with the people it serves because reading those plain language rules raises more questions than providing answers.
6. Open door policy: My next request is to open your FSDO once more to the public. Since 911 the FSDO doors are locked, walk-ins are discouraged, and appointments with inspectors are required. I know you have Homeland Security rules to follow and you have employees to protect but this is an industry that still requires a lot of face time. I’m sure there is a sensible way of addressing security as well as providing service to the aviation community. At least have a question and answer forum at each FSDO web site along with a list of employee telephone numbers to contact.
7. Ombudsman office. The term ombudsman is of Swedish origin which means arbiter. The purpose of the ombudsman is to hear cases or complaints against the government. That individual also has the authority to override all previous governmental decisions. The European Union has had one in place since April 2003.
I would like to propose that you consider establishing two FAA Ombudsman offices. One office will strictly deal with external industry issues or complaints, the second will deal only with internal employee issues. Each office will report directly to you and would have its own budget and staff. Each office will serve as the final review of complaints from citizens or from your employees as applicable. The Ombudsman office will only enter a dispute after all other methods have been exhausted. It is perhaps the best way to ensure that industry and FAA employees have the benefit of a fair and im-partial review of their grievances. These offices would also reduce the impact of complaints in your policy and rulemaking offices in headquarters and in your regions.
8. AC 43.13-2B Alterations. On a personal note I would appreciate it if you would take a vested interest in why Aircraft Certification Service has seen fit to non concur with the new Advisory Circular (AC) 43.13-2B after it was signed off by Flight Standards Service, General Council, and the industry. We really need this AC. The AC will give the mechanic “approved data” for common, non-complex alterations. Like its sister AC 43.13-1B on repairs, it will reduce the FSDO field approval workload on such things as avionics installations, cargo nets, battery relocations, etc., by 20 percent, but even more importantly, it would standardize those alterations.
I just completed this year's round of IA renewal seminars.
Implications for continued airworthiness and corrosion control
It was just after lunch, on a hot July day when I found my heavy eyelids slowing closing. I was faintly aware that my forehead began its slow motion plunge towards my computer keyboard.
There are two very important pieces of paper that are issued by the United States Government that, once issued, are usually forgotten by the aviation community.