While the FAA did rescind Notice N8000.336 regarding addition of airplanes to Part 135 certificates, late last year it reissued the policy in a new notice, with only one change. Like N8000.336, Notice N8000.343 requires FAA principal inspectors to obtain concurrence from FAA headquarters before allowing an operator to add a new turbine-powered airplane to its OpSpecs.
The change in N8000.343 is an exemption for “newly manufactured airplanes delivered directly to the certificate holder.” Nevertheless, the procedure could slow the addition of airplanes to OpSpecs, according to National Air Transportation Association (NATA) manager of regulatory affairs Lindsey McFarren.
“Previously, aircraft additions [to a Part 135 certificate] were approved at the FSDO level or referred to the regional level if circumstances warranted,” she explained. On the other hand, in regions where inspectors are reluctant to add new airplanes, the N8000.343 procedures “might speed the process,” she added, although NATA is disappointed “that the FAA did not accept our recommendations, including a ‘grandfather’ clause for aircraft already in the conformity/approval process.”
NBAA, too, is not satisfied with the revised document. “Already, we have heard from frustrated operators about the long delays caused by this notice,” the association wrote the agency in a January 10 letter. “It is clear that the two-day turnaround is not working. The association believes a more practical solution would require the FAA inspector to submit a report to agency headquarters listing all aircraft that have been added to an air carrier’s operations specification.
“This revised process would achieve the FAA’s goals of notification of new aircraft on charter certificates while allowing headquarters staff to review the submitted reports,” NBAA said. “The FAA would then need to notify [only] the air carrier of any aircraft [about] which the FAA has concerns.”
Additionally, NBAA believes that any response to the air carrier must include “a detail of the concerns, allowing the operator an opportunity to correct the problems.”