Industry Responses and Requests
By Stan Mackiewicz
Responding to a petition by PAMA, the FAA has agreed to extend the closing date for comments from November 6, 1998 to January 8, 1999, on the proposed rule for certification of mechanics. PAMA's petition cited the complexity of the rule, trade publication dates, and difficulty the public had in ordering a copy of the rule as reasons for the extension. All aviation maintenance technicians are urged to read the Notice of Proposed Rule Making and comment. The final rule will impact you (the A&P) for the next 30 years on how you approve work, your training, and your certification.
Two-tiered license hit
The Part 66 NPRM proposal to develop a two-tiered license is being hit by PAMA members and non-members alike. Our mail is running four to one against the transport category rating. Those commenting are saying the proposed new rule does nothing for safety and permits new graduates to approve for return to service Part 25 and Part 29 aircraft, while more experienced mechanics go through requalification training or six months experience. Corporate and regional airline mechanics with mixed fleets will be required to keep detailed records to assure compliance with the rules. Even mechanics from the airlines are hitting the rule as punishing general aviation. Some comments received:
• Why are CAR 3, 4a and 4b aircraft excluded? Are they not transport category aircraft? This rule won't work.
• I am an A&P working for a Part 135 operator. The name should be changed to AME (Aircraft Maintenance Engineer), so that the United States is on par with the rest of the world.
• I want to thank you for this attempt to drag the certification and titling of today's aircraft mechanic out of the age of the Wright brothers.
• Appendix A, ((e), (2)). Acquiring transport category aircraft, materials, and equipment is going to be very expensive. My school is only at 1/4 of capacity now. I can't afford this rule and may have to close my doors.
• I think Sec 66.105 is a bad idea. It will contribute to the problem of attracting qualified mechanics into the airline maintenance area. It also turns general aviation mechanics into a "lower class" mechanic.
• I fully agree with Mr. Dick Wussler's comments in the September 1998 issue of Aircraft Maintenance Technology magazine.
• Why is recency of experience in 66.111(a) needed when repair stations and airlines approve for return to service aircraft, not the AMT?
FAA appoints McSweeny to top regulation and certification post Jane Garvey, FAA Administrator, has appointed a veteran FAA certification engineer to the post of Associate Administrator for Regulation and Certification. Tom McSweeney's biographical material makes no mention of maintenance in his background nor does he have an A&P certificate. While McSweeney may be a good selection for the top regulation job, Garvey's executive row continues to lack solid maintenance experience that we feel is a prerequisite for making safety decisions involving maintenance.
Fred Workley, familiar to most readers of AMT magazine, is in the running for the head of AFS 1, Flight Standards Service. Although not a FAA insider, Workley would be a capable and informed addition to that staff. It is time for the FAA to reach out to industry and select a certified maintenance professional for the post of top aviation maintenance advisor.
What does Y2K and the shortage of AMT's have in common?
Answer: Both could cause a loud crashing sound early in the 21st century. Failures of the industry and leadership within the FAA have caused a situation where aircraft may sit on the ground, or (perish the thought), fly unsafely because of the lack of qualified and experienced maintenance professionals.
The aviation maintenance industry is now beginning to respond having finally recognized the problem, but money and support are lacking from the FAA. If the maintenance industry could have a fraction of the budget money spent on correcting the date problems in computers, the industry could assure a positive flow of quality candidates into the schools to become aviation maintenance professionals.
PAMA Calls for Papers
PAMA is issuing a call for papers for PAMA 99 Technical Symposium and Trade Show scheduled for April 20-22, 1999, in Phoenix, AZ next year. This is the associations' first call. A blue ribbon peer panel has been assembled to review papers on topics affecting the individual aviation maintenance professional, and have chosen the theme phrase of "Professionals in Every Sense of the Word." Selected papers will be presented at the Symposium. The panel is made up of industry, education, manufacturing, media, and technical aviation maintenance professionals. Writer's guidelines are as follows:
• Obtain a Call for Papers form from the Professional Aviation Maintenance Association (PAMA) by calling (202) 216-9220, or write to its offices at 636 Eye St., NW, Suite 300, Washington, DC 20001
• Paper must be submitted to PAMA by February 1, 1999
• Papers will be selected on the basis of appropriateness and originality
• Selected authors will be notified by March 2, 1999. There will also be a press release
Some of the topics sought include:
• Federal government - are they really here to help?
• Parts acquisition
• Cost of doing business
• Safety - lessons learned
• Paperless maintenance programs
• New technology
King Kong meets David
Two Aviation Rulemaking Advisory Committees (ARAC) have been wrestling with the issue of Major/Minor repairs and alterations. The Major/Minor and Part 43 Working Groups are coming together after years of working on different aspects of the issue. The joint meeting of the committees, one dominated by air carrier and FAA certification engineers, and the other made up of general aviation associations and proponents, will meet to attempt to resolve the issues. Last year, a meeting was held in Washington with top FAA officials who gave the green light to the ARAC to solve the problem.
Proposals include changing the FAR Part 1 definition and adding a new appendix to Part 43 containing a list of items that better define when a repair is major.
How should Thanksgiving be spent?
Answer: Reading and responding to the NPRM for Part 66. As of the end of September, less than 100 comments have been received by the FAA Office of Chief Counsel, Rules Docket. They are happy, they think the industry agrees with the proposed rule as written. Do you?