D.C. potpourri

D.C. Potpourri

By Stan Mackiewicz

May-June 1998

Last month, we forecasted that FAA Suspected Unapproved Parts Chief Ken Reilly would be leaving his post in June. It seems that forecasting the weather is easier than figuring out what will happen at the FAA no matter how close you are to the action. Ken now says he plans to stay around for another year to finish a few projects.

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The Aeronautical Repair Station Association (ARSA) had their annual symposium again this year in Washington, D.C. Headed by ARSA's Executive Director Sara MacLeod, this forum covered a number of topics of interest to repair station owners, managers, and others. There were a number of good speakers, but two of note to the individual aviation maintenance technician were:

Ava Mims, chief of the Aircraft Maintenance Division (AFS 300), talked about a reorganization aimed at providing better service to the FSDOs and their customers (us). By focusing responsibility for responding to congressional inquiries into a special group, the rest of the staff will be able to finish many of the open projects that plague the division. If you have been watching, there have been a number of orders issued designed to standardize interpretation of the regulations by the field.

AFS 2 Richard (Dick) Gordon, deputy director, Flight Standards Service, was a breath of fresh air. Gordon appears to be a no-nonsense, 30-year veteran who spent most of the last years in Alaska. When queried about some airworthiness inspectors returning Major Repair and Alteration 337 field approval forms without action, he had a lot to say. First, he stated he nor anybody else wants an airworthiness inspector to sign off on an alteration or repair that is outside his or her area of competence or training. Second, he wants the airworthiness inspectors to help resolve these issues. Leaving it up to us to troll through the agency for knowledgeable resolution to a 337 is a no-no. He said it is a duty of the airworthiness inspector to assist in finding help.

He calls it a service and he expects the airworthiness inspectors to provide it. He also had some strong words to say about standardized interpretation of the rules. He wants to know when rogue or uninformed airworthiness inspectors attempt to force their will outside the regulations. Get supervisors involved early and request that FAA give opinions in writing. He promised you might not get the answer you want, but you will get an answer.

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FAR 11.25 governs petitions to the FAA. Some people have been complaining that petitions submitted in good faith are given a "We don't have time, people, or money to read (or consider) your petition, go away" letter. Amendment 1 of the constitution states, "Congress shall make no law respecting and to petition the Government for a redress of grievances." Since the constitution gives people the right to petition, what causes the FAA to think they can dodge their responsibility? Perhaps they should read FAR 11.27 (5)f Denial of Petitions.

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Out of the sunlight within the rule making process is a group wrestling with a conundrum. How do you advance safety of older aircraft while preserving the type design and without breaking the back of the general aviation modification and STC business? An International Certification Procedures Working Group proposal would have modifiers which would, for example, put 10G seats onto 4G floors to meet new Part 25 certification requirements. Compromises are in the air and details should be available soon.

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The United States Office of Personnel Management is reviewing job-grading standards for government aircraft mechanic (8852). The standard does not require that a government AMT have an A&P certificate. Some of these people work on public use aircraft that are to be operated and maintained under the requirements of Part 91. Admonitions to review this situation were not well received. Thankfully, some progressive agencies like the U.S. Border Patrol only employ certificated AMTs to work on their aircraft.