By Stan Mackiewicz
Put April 20 to 22, 1999 on your calendar now for a trip to Phoenix, AZ for the Aviation Services and Suppliers SuperShow (AS3), the combined trade shows of PAMA and NATA. PAMA Ô99 Technician Symposium, held during AS3, will offer an attendee the ability to accumulate up to 13 hours of training, available from over 100 technical and professional development sessions. A new feature at the Chili Cook-off is a dunk tank. Some key FAA personnel have volunteered to let attendees take a shot, all in the name of the scholarship fund. One person suggested calling it "Dunk-a-Fed."
On January 8, 1999, the gong sounded, closing industry comments for the Notice for Proposed Rulemaking (NPRM) for the certification of aviation maintenance technicians. Summarized, extended, funny, detailed, well thought out, informed, and uninformed comments were submitted in earnest from virtually every segment of the aviation maintenance industry. Individual mechanics working on general aviation aircraft on their own or in an FBO or repair station, submitted comments. So did corporate, air carrier, ag operators, and space shuttle A&Ps, so did some of the larger Part 145 repair stations and Part 147 schools. Many FAA employees submitted comments as well. Almost 1,100 comments were received including thoughtful reviews by most of the associations, including PAMA.
Now the FAA must read, catalog, and analyze each and every one.
This will be a time-consuming process accomplished by FAA people and consultants. The specifics of this review will not be generally available to the public unless or until rulemaking is done.
The FAA has several options. After this review, the FAA can make changes and issue a rule without soliciting or considering further public comment. With the number of comments and changes proposed this is the least likely option.
The FAA can issue a supplemental Notice of Proposed Rulemaking to address specific issues, then issue a rule with short notice.
Or, the FAA can go back to ground zero and start the process all over again. Of the available options, this is the most likely.
The original rule change premise was attacked by many organizations that submitted comments. They charged that the basis for the rule had changed, and therefore the results were no longer valid. Most of these comments revolved around the supposed high technology in the "Transport" world, which is not common fare in most general aviation business aircraft. It's the old rule, "if the facts change, the result must change or be modified."
Most respondents saw problems with the implementation of the two-tiered architecture. They did not like the record keeping the rule would require, the currency or the reliance on the certification base of the aircraft. It comes down to fixing and keeping the two-tiered license or abandoning it altogether. It will take a lot of courage for the FAA to say they were wrong and scrap this part of the proposed rule. Many of the industry participants in this rulemaking (ARAC) have already admitted they were wrong in their comments to the NPRM.
Another significant area of comment revolved around the requirement for recurrent training. Although the NPRM specified no amount of required training, some respondents felt the need to develop and maintain a skilled work force was an unwarranted expense. This is not a view shared by PAMA.
There were many calls for a name change to Aircraft Maintenance Engineer.
The bottom line is that there will be no significant change to the way we are certified for the foreseeable future.
ALERTS AC 43-16A
By now most people know that without notice, the FAA cancelled the printing and distribution of the hard copy of the Alerts Bulletin. If you are one of the 29,000 subscribers or one of the many thousands of aviation mechanics, pilots, students, instructors, engineers, or owners who read Alerts, you may want to know why.
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