November 5, 2002
U.S. Department of Transportation Docket Management System 400 7th Street, SW Room PL 401 Washington, DC 20591-0001
RE: AEA/AIA/ASA/NATA Petition Dated 21 October 2002 to Postpone Implementation of the Changes to 14 CFR Â§145
To Whom It May Concern:
The Aircraft Owners and Pilots Association (AOPA), representing the interests of its more than 387,000 members who own, operate, and maintain aircraft, supports the postponement of the planned changes to the regulations pertaining to certificated repair stations, Federal Aviation Regulation (FAR) Part 145. Postponement is needed to give the Federal Aviation Administration (FAA) time to complete and publish advisory circular guidance as well as time to train its employees. With less than six months before the implementation date, AOPA believes that the FAA will not be able publish the advisory circular guidance document and complete the required FAA employee training before that date. Therefore, AOPA requests that the FAA grant the above referenced petitioners' request for postponement of the implementation of FAR Part 145.
If the advisory circular guidance and FAA employee training is not completed before the current implementation date takes effect, AOPA feels that the associated costs to general aviation will be even higher than those costs that were formally identified by the FAA. For example, the new rule requires that certificated repair stations develop new manuals for FAA approval by the rule's implementation date. In the absence of published guidance and completed FAA employee training, these new manuals will most likely have to undergo revisions. In other words, it would be counterproductive and an inefficient use of resources to implement the rule before publishing the guidance materials and before FAA employee training is completed. It will only serve to add to the affected repair station's costs of doing business without any safety benefit. Those added costs would also be passed on to consumers, in the cost of doing business. Suitably postponing implementation will help serve to minimize the overall costs associated with the development of the required manuals.
AOPA believes that granting the petitioners' request to postpone implementation of FAR Part 145 is practical and in the public's interest. Doing so will have a positive effect on regulatory compliance, will not have a negative impact on safety, and will not impose any new burdens.
Melissa Bailey Vice President, Air Traffic, Regulatory and Certification Policy
November 5, 2002
Department of Transportation,
FAA Information and Services,
A new FAA policy on obstructive sleep apnea that addresses many of the concerns raised by AOPA is scheduled to take effect March 2.
AOPA and the National Business Aviation Association have jointly filed an amicus, or friend of the court, brief in the Ninth Circuit Court of Appeals as part of the ongoing legal battle over the future of Santa Monica Municipal Airport.
AOPA worked with the flight training industry and FAA to quickly resolve a problem that suddenly put many rating applications on hold.
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