November 25, 2002
James J. Ballough Director, Flight Standards Service Federal Aviation Administration 800 Independence Ave., SW Washington, DC 20591
RE: Revised FAA Flight Standards Airworthiness Inspectors Handbook 8300.10 Vol.2 Chapter 1 - "Field Approvals"
Dear Mr. Ballough:
The Aircraft Owners and Pilots Association (AOPA), representing the interests of over 388,000 general aviation pilots and aircraft owners, is very concerned about problems with the new revision (Change 15) to the Federal Aviation Administration (FAA) field approval policy. These problems are hindering FAA approval of routine alterations and repairs to general aviation aircraft nationwide and alterations that would have been routine field approvals under the previous guidance are now being denied. For this reason, AOPA requests that the FAA immediately rescind Change 15 in all regions and issue guidance that pre-Change 15 interpretations remain in effect.
In addition to the problems FAA has identified in Alaska, AOPA has received complaints from regions all across the country indicating that the problems are systemic and not confined to just the Alaskan region. Operators indicate that FSDOs in the "lower 48" are refusing field approvals for things like wingtip strobes, conversions to alternators from generators, and conversion of drum to disc brakes already covered by an STC. AOPA has even experienced the problem firsthand with an aircraft we are restoring. AOPA's maintenance shop was denied a field approval to install improved brakes on our 1939 Waco sweepstakes aircraft. The bottom line is that it is increasingly more difficult, if not impossible, to get field approvals since Change 15 to the FAA Order 8300.10 addressing field approvals was issued.
General aviation operators nationwide rely on field approvals to safely enhance their operations and safely maintain their aging aircraft. Though the FAA has publicly stated that Change 15 was intended to improve field approval service across the United States, it obviously has had quite the opposite effect and has served to hinder it.
AOPA understands that from the joint FAA/Industry meetings it attended in Alaska last week, the FAA has elected to suspend Change 15 and is permitting prior change interpretations in Alaska. We also understand that this suspension action in Alaska will stay in effect until such time as the FAA has issued another change to its field approval policy.
The problems of Change 15 are affecting field approvals across all regions and not just in Alaska. Therefore, AOPA requests that the FAA immediately rescind Change 15 in all regions and issue a statement that pre-Change 15 interpretations remain in effect. AOPA hopes that this action will serve to bring field approval service across the country back to at least where it was prior to Change 15.
Thank you for your time and consideration regarding this matter.
Melissa K. Bailey Vice President Air Traffic, Regulatory and Certification Policy
AOPA thanks our members for their continued support in protecting the freedom to fly.