October 1, 2002
David E. Cann
Manager - Aircraft Maintenance Division
Federal Aviation Administration
800 Independence Ave S.W.
Washington DC 20591
RE: Federal Aviation Administration (FAA) Flight Standards Handbook Bulletin for Airworthiness (HBAW) 02-03
Dear Mr. Cann:
The Aircraft Owners and Pilots Association (AOPA), representing the interests of over 380,000 pilots and aircraft owners, has reviewed HBAW 02-03 and the referenced revision to FAA Order 8300.10 Volume 2 Chapter 1 - Perform Field Approvals of Major Repairs and Major Alterations. We offer the following comments:
Decline in Field Approval Service
Approximately 75% of all aircraft owners are members of AOPA. Over the past several years, many of those members have reported a steady decline of a willingness on the part of many FAA Aviation Safety Inspectors (ASIs) to perform field approvals each year. The reasons given by the various ASIs and Flight Standards District Offices (FSDOs) for their unwillingness to provide this very necessary and valuable service were varied. This situation has forced many of our members to "shop" around the country for those dwindling number of ASIs and FSDOs willing to do a Field Approval, thus needlessly increasing the cost of approval.
It was apparent to AOPA that the previous version of this FAA Order had become ineffective and didn't have the necessary support within FAA management. AOPA shared its concern with FAA that Field Approvals were becoming more difficult to obtain and asked the FAA to provide improved service in that area. In response to our request, the FAA Field Approval Process Improvement Team (FAPIT) began work on this issue. In July 2001, AOPA met with FAA officials to share its concern that the overall Field Approval process was still in desperate need of improvement and offered to assist FAPIT. The first positive outcome of this is the FAA's issuance of HBAW 02-03.
AOPA's Opinion on the Revised FAA Order
AOPA supports revisions to FAA Order 8300.1 Vol 2 Ch 1. It provides clearer instructions on what can or can't be done under the Field Approval process. AOPA is pleased that the revised order also includes clarified instructions as to the FSDO's and ASI's duties and responsibilities on how to help the applicant obtain a Field Approval. These two revisions alone should contribute to an overall improvement of the Field Approval process.
However, as with any order or policy, this revised FAA Order will not have the intended desired effect of improving the Field Approval process if it isn't supported by the FAA management and staff. AOPA hopes that the FAA will train and encourage its Regional Office and FSDO management and staff to support the spirit of the revised order to improve the Field Approval process.
AOPA appreciates the opportunity to comment on this revised Order and we hope that the FAA continues to find ways to improve its Field Approval process and service.
Sincerely,
Lance Nuckolls
Director - Air Traffic, Regulatory and Certification Policy
Government and Technical Affairs Division
Attachment: AOPA Statement to FAA - FAA Field Approval Process Improvement