Awash with negative comments regarding its proposed air carrier contract maintenance requirements rules, the U.S. Federal Aviation Administration has extended the original February 11 comment period to March 13. The proposed rule would change the maintenance regulations for domestic, flag and supplemental operations, and commuter and on-demand operations for aircraft type certified with 10 or more passenger seats (excluding any pilot seat).
The National Air Transportation Association (NATA) questions the logic of including Part 135 operators in a process that requires development of policies, procedures, methods and instructions for performing contract maintenance and cites several issues it considers inappropriate. One of the major issues cited by NATA relates to a requirement for the operator to have an approved list of maintenance providers.
“While it was the FAA Modernization Act of 2012 that sparked this NPRM, the FAA has gone beyond the scope of what the statute requires,” NATA wrote in its comments to the FAA. “Section 319 of the act requires the FAA to issue regulations for Part 121 operators. There is no mandate to require similar regulations for Part 135 operators, nor is there a requirement in the act for the proposed list of maintenance providers. NATA is concerned that the NPRM does not adequately justify the inclusion of Part 135 ten-or-more-seat operators in this rulemaking. NATA believes that the FAA must consider the unique aspects of Part 135 air carrier operations or limit a final rule on this matter to Part 121 air carriers as required by the act.”
NATA points out that while airlines fly specific routes and secure maintenance providers throughout their route structure, Part 135 operators don’t have that luxury. “By their nature, Part 135 companies operate on an ad-hoc basis to locations that are unpredictable and often change. … [They] fly to thousands of airports worldwide and it is not atypical for a flight to [fly to] a destination at which the carrier has not previously operated. Part 135 operator compliance with this proposal is not an impossible task with regard to scheduled maintenance that is typically conducted at pre-determined times and locations. However, the need for unplanned maintenance can and does frequently occur.”