Dear 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.

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.

In closing, I want to thank you for allowing me to voice my opinions and concerns and again I wish you success in your new position.

Bill O’Brien, A&P 1809539

Well there you have it, my letter to the new FAA Administrator. Now while my ego believes that my letter will be read and acted on immediately, my experience with the bureaucracy tells me otherwise. But if the old adage that a “new broom sweeps clean” is valid and if the new Administrator received a couple of hundred letters on the same or similar maintenance-related subjects, chances are good that each of our proposals would receive an open ear.

An even better response could be anticipated if our maintenance trade organizations would pitch in together and bring these and similar issues forward by requesting face time with the new Administrator. Hmmm, mechanics and trade organizations working together to achieve a common goal — what a concept!