January 15, 1999
Mrs. Ava Mims, Manager Aircraft Continuous Airworthiness Division, AFS-300 Federal Aviation Administration 800 Independence Ave., SW Washington, DC 20591
Dear Mrs. Mims:
The Aircraft Owners and Pilots Association (AOPA), representing the aviation interests of more than 340,000 pilots and aircraft owners, is deeply concerned with the stated intent of the Federal Aviation Administration (FAA) to discontinue publication of Advisory Circular (AC) 43-16A, Aviation Maintenance Alerts. In the December 1998 edition of AC 43-16A, the FAA indicated that a combination of the “new technological age” and “government downsizing and shrinking budgets” were responsible for the need to restrict dissemination of aviation service experience solely to the Internet. AOPA agrees that the Internet can play a significant role in the dissemination of data to the aviation community, particularly library or archive type information. However, we do not believe that safety-related information such as AC 43-16A should be relegated solely to the Internet since many people who benefit from this information do not have Internet access or capability.
Today, the aviation maintenance alerts are one of the only non-regulatory mechanisms the FAA has in place for sharing airworthiness issues or concerns. As such, they are widely read by both the aviation maintenance community and the owners and pilots of affected aircraft. The general aviation community benefits greatly from the aviation maintenance alerts because they provide a necessary exchange of potentially safety-critical information based upon the service experience of other similar or identical equipment. By widely distributing this information, the FAA is genuinely promoting an improvement in aircraft reliability and safety. Any restriction in the distribution of this information can only have a negative effect on overall safety.
The Malfunction and Defect (M&D) Reporting System is often criticized by both the FAA and industry for its incomplete nature and the infrequency with which maintenance personnel or aircraft operators report abnormal airworthiness conditions. One of the leading faults of the M&D system that is identified over and over again is that submitters of airworthiness information do not feel that their information is ever acted upon or distributed to other potentially affected parties. Many maintenance personnel do not bother submitting M&D reports because they feel that the information goes into a black hole in Oklahoma City and rarely receive any feedback. Perhaps the only feedback mechanism for M&D reports the FAA has used over the years is AC 43-16A, Aviation Maintenance Alerts. Removing the printed distribution of this valuable feedback mechanism for airworthiness concerns will reduce the input to the M&D reporting system even further and ultimately could lead to a reduction in aviation safety levels.
For a number of years now, AOPA has been engaged in a long-term effort to change the way the FAA Aircraft Certification Service approaches airworthiness concerns. In the past, when the FAA was confronted with an airworthiness concern, there was but one choice: either issue an airworthiness directive (AD) or do nothing. More often than not, doing nothing was not an option, so an airworthiness directive was invariably the resulting outcome for any airworthiness concern, regardless of magnitude or severity. This has led to a situation where the importance of the AD has been greatly diminished in the eyes of the aviation community because it is no longer preserved for the truly safety-critical information. As a result, the credibility of the AD process has suffered, and this is beginning to show up in compliance rates.
To address this potential problem, AOPA has been encouraging the development of a formal process for prioritizing the severity or potential impact of airworthiness concerns that are brought to the attention of the Aircraft Certification Service. By engaging in this prioritization process, a determination can be made by the FAA as to what level of communication and compliance is required to achieve the desired awareness or level of safety. As the FAA and AOPA have applied this approach to various airworthiness issues, it has become evident that the “one size fits all” communications approach to addressing airworthiness concerns (the AD process) does not work well. In light of this, the importance of non-regulatory communications vehicles as a means of distributing safety-related information, such as the special airworthiness information bulletins (SAIBs) and AC 43-16A, Aviation Maintenance Alerts, is increasing rapidly. As this FAA/industry safety partnership continues to expand, the reduced distribution of AC 43-16A will become a significant obstacle to the successful dissemination of airworthiness-related information to the maintenance and aircraft owner communities.
AOPA urges the FAA Flight Standards Service to continue the printed publication and distribution of AC 43-16A, Aviation Maintenance Alerts, to pilots, aircraft owners, and maintenance professionals who do not have, or wish to use, access to the Internet for locating safety-critical airworthiness information. AOPA stands ready to assist the FAA in achieving this goal, and if there is a need for additional information, please feel free to contact me at 301/695-2207, Monday through Friday, and I will endeavor to provide any assistance possible.
Douglas C. Macnair Director Regulatory and Certification Policy
January 12, 1999
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