Well we finished another year and are starting to take on a brand new one. 2003 was a year of slow but steady progress for the aviation industry. Some of the bright spots were that the large air carriers started to shake off the effects of 9-11 and many commercial flights are flying full once again. Another positive was that corporate jets were coming off the assembly line at record numbers. However, GA levels of flight instruction, rentals, and maintenance performed at FBO's were still below 9-11 levels. But the bean counters noted some slight improvement in the GA marketplace in the second half of the year as the economy started to gain strength.
On the down side, we lost two regional air carrier aircraft, both Raytheon 1900s with fatalities. Preliminary NTSB reports attributed the cause of the accidents to maintenance errors; specifically, mechanics not following the guidance in the maintenance manual, but taking short cuts. It appears that we have not yet learned our lessons from the DC-10 crash in Chicago on May 25, 1979, or the Boeing 727-297 becoming a convertible near Maui on April 28, 1988, or the MD-88 stabilizer jackscrew failure on Jan. 31,
2000. When the final NTSB reports come out on these Raytheon 1900 fatal accidents and probable cause is formally established, I expect the FAA will be tasked with making some changes either to Part 121/135 rules or to existing policy regarding air carrier maintenance. What changes will be made I am not sure of, but I am sure changes will be made.
Recognizing mechanics and repairmen
Despite the good and the bad that happened in 2003, we did have a chance to celebrate and recognize mechanics and repairmen for their achievements. During the 2003 calendar year, FAA's FSDOs nationwide proudly presented 87 mechanics the Charles Taylor Master Mechanic award and issued more than 24,000 Aviation Maintenance Technician Awards representing more than
300,000 hours of maintenance training.
Part 145 and other policy changes
Last year the FAA was busy with new rulemaking and policy changes. So much so, that the new Part 145 effective date was postponed twice, once in April at the FAA's request and more recently in October by the industry's request. The new effective date of the rule is Jan. 31, 2004. This is also the date when the Part 145 manual and quality control system is due at the local FSDO and, no, I do not expect any more postponements of the effective date.
Please keep in mind that the "new" Part 145 is not quite finished; the FAA still has to address the changes on the rating classifications and the policy dealing with the training program that is due in April 2005. So look for a Notice of Proposed Rulemaking in the Federal Register on Part 145 in either late fall of 2004 or early 2005. It is vital that all repair stations participate in this future rulemaking process. During the last Part 145 NPRM process, less than 10 percent of the repair stations commented on the proposed rule. This is one area where we all must do better.
For mechanics who work on the popular L-39, Albatross, a Czech built military jet trainer, the FAA has published a recommended inspection program for
this aircraft in the form of AC 43-209. The inspection program includes inspecting Hot Seats, as well as establishing recommended overhaul and replacement times for engines and components. There are more than 230 of these aircraft registered in the United States with approximately 140 of them now flying under a special airworthiness certificate, Experimental, Exhibition. This AC was created in response to L-39 owner's complaints about the lack of FAA standardizing the inspection program for this make and model aircraft nationwide. You can pull up the AC by punching in www.airweb.faa.gov. Check the left hand column of the webpage and click on Regulation and Guidance Library. That is where all the ACs are kept.
Light sport aircraft and field approval
During my travels I have had many questions from mechanics on the status of the Light Sport Aircraft rule. This rule deals with certification, maintenance, and pilot requirements to fly aircraft that were once identified by the industry as "fat ultralights." The proposed final rule was signed out of the FAA by the Administrator in late July and then sent to the Office of the Secretary of Transportation (OST) for review. As of the date this article was written, the proposed rule is still over in OST. Once OST signs the coordination grid on the proposed rule and the FAA satisfies any concerns or comments that OST has, the next hoop the rule has to pass through is another review at the Office of Management
and Budget. Then it is back to the FAA where additional changes, if any, are made, an effective date is established, then the Administrator signs it. Once signed, it becomes a final rule and is published in the Federal Register.
I personally have no idea on when the rule will be ready for final signature. However, once the final rule has been approved, I will write an article on the maintenance requirements of these U.S. registered light-sport aircraft.
On May 21, 2003, seven months after the FAA made the first substantive revision to field approval policy in 20 years, the FAA issued a second revision. This latest revision is Change 16 to Volume 2, Chapter 1 of FAA Order 8300.10, Airworthiness Inspectors Handbook. You can get a copy of the order and revisions by visiting http://www2.faa.gov/avr/afs/faa/8300/.
For the most part, field approval policy has remained 90 percent the way it was. However there were three major changes to field approvals policy. First, the elimination of the field approval that allowed multiple field approvals to like make and model aircraft that were performed by the original modifier. Second change was the addition of a decision flow chart (appendix 1-2) for the field approval process that is applicable both to industry
and FAA inspectors to improve standardization. Third change was the incorporation of a 12-page job aid for major alterations which details whether or not the major alteration you are proposing should be an STC, or needs FAA engineering approval, or it may be eligible for a field approval from the local inspector.
FAA's request for a waiver from the FCC to include the term "maintenance" in the radio call sign when mechanics are taxiing or towing an aircraft at an ATC controlled airport was granted. So now if you want the guys in the tower to talk a little slower to you when you are moving an aircraft to or from the gate, call up ATC ground control and use the word "maintenance." For example, "Denver ground control, this is Sky-Bus Boeing 767, "maintenance," 623 Sierra Tango at gate 47, taxi to Sky-Bus's hangar." I figure it will take another year before we and ATC all get used to it.
What about the future?
So much for the past. We can learn from it, improve upon it, but we can't change it. Now, what about the future? The rest of the FAA notwithstanding, I intend to put in the Federal Register a request for comments before February 2004, dealing with proposed changes to AC 43.13-2A, Acceptable Methods, Techniques, and Practices, Aircraft Alterations.
The AC on alterations was last revised in 1977, so I would like to make this revision a good one. I plan to revise the AC in two phases and it will take three years to complete. The first phase revision will change the document's text so it matches today's current AC format so it can be easier to revise in the future. We will also make corrections and include a small amount of revisions. The second phase revision will be published 18 months after the first revision and if approved by the FAA legal department, would be a major change on how we will do business.
The second phase would create policy in which the AC would contain data on alterations such as installation and removal of avionic equipment, instruments, fuel tanks, aircraft strobes/lights, and tundra tires to noncomplex, nonpressurized aircraft. The data in the AC could be approved by the IA or repair station if the alteration data is "appropriate,"
"applicable to the alteration being made," and "not contrary to the manufacturer's recommendations."
This new policy would be identical to the current policy in AC 43.13-1B Acceptable Methods, Techniques, and Practices, Aircraft Repairs. The signature page in the current 1-B allows IA/repair stations to "approve" acceptable repair data found in the AC. This self-inflicted major repair data approval policy has worked very well for the last 15 years. So I have precedent, and lawyers like precedent. So I have a chance of making this change if we gather enough public comments to support it.
The goal of the new proposed policy would be to reduce the need for field approvals for simple, noncomplex alterations. This in turn would reduce the workload on the FSDO inspectors, and the paperwork requirement and waiting time for the IA or repair station. If FAA legal agrees, we are talking about eliminating thousands of hours of extra work for both the FAA and the industry without impacting safety.
The downside of this proposed policy change is the IA and/or the repair station alone holds the wet paper bag of responsibility in this decision-making process. Under the current policy for field approval for a major alteration, the FAA inspector becomes the IA's or repair station's partner when he
signs block 3 of the form 337. Under the new proposed policy the mechanic or repair station must be sure the decision to use the data in the AC was the correct one, because if the major alteration installation turns ugly, the FAA inspector who was once your partner would now be your judge.
Send comments
But this is just my idea on how to improve the system of checks and balances that we all work under. If you would like to comment early on this proposed change of doing business, instead of waiting for the Federal Register notice, e-mail me at william.o'[email protected] or fax me at (202) 267-5115 or send a letter addressed to my attention at:
FAA Headquarters
AFS-305, 800 Independence Ave, S.W.
Washington, DC 20591
Along with your comments on this proposed AC, I would like to create a cadre of industry and FAA subject matter experts in such areas as avionics, fuel systems, landing gear, engine mods, instrumentation, ELT, installation of lights and strobes, etc. This cadre of subject matter experts' main job is to ensure that the information in the AC remains technically accurate, current, and complete. Their second job is to prevent me from writing policy in the AC that does not pass the common sense test.
If you have some information you want to share in these areas or just have time to review the contents of the proposed AC and make corrections or additions, please let me know, I would appreciate your help.
Thanks.
