Regulatory Brief -- FAA issues change to field approval policy

Regulatory Brief

FAA issues change to field approval policy

The issue:

On May 21, 2003, the Federal Aviation Administration (FAA) published Change 16 to its Flight Standards Service Airworthiness Inspector's Handbook Order 8300.10. Change 16 is in response to AOPA's continued request that the FAA improve field approval service nationwide, and to correct problems with field approvals that arose after the FAA issued Change 15 in September 2002.

The importance to our members:

FAA inspectors issue field approvals for a major aircraft alteration that does not require detailed engineering analysis. The field approval process is a vital part of the life-blood of the general aviation fleet. General aviation operators nationwide rely on field approvals to safely enhance their operations and safely maintain their aging aircraft. Examples of major alterations include but are not limited to: major aircraft restorations, certain avionic installations, wingtip strobes, generator-to-alternator conversions, drum-to-disc brake conversions, landing gear alterations, engine and propeller alterations, and instrument panel alterations.

AOPA pressure helps change field approval process

Significant provisions:

Change 16 to FAA Flight Standards Service Airworthiness Inspector's Handbook Order 8300.10 includes the following significant changes over Change 15:

Order 8300.10 Volume 2 Chapter 1 - Perform Field Approvals Of Major Repairs And Major Alterations -

Instructs an FAA Aviation Safety Inspector (ASI) to deny a request for field approval if the alteration or repair is determined not to be a "major" repair (i.e. "minor"), or deny a request for field approval for an alteration or repair that already has adequate supporting approved data. In either case, the ASI is required to explain the reason for denial and, if requested, provide that explanation in writing to the applicant/operator.
A listing ("job aid") of alterations that may require engineering evaluation, FAA Aircraft Certification Office assistance, or a Supplemental Type Certificate. There is a separate listing for general aviation airplanes, rotorcraft, transport category airplanes, and engines/propellers/APUs.
Includes additional references to:
- FAA Order 8110.45 - Use of Data Approved By Designated Engineering Representatives To Support Major Alterations.
- FAA Advisory Circular AC 23-17 - Systems And Equipment Guide For Certification Of Part 23 Airplanes.
Removes the statement that 14 CFR Section 21.95 authorizes the field approval process
Removes the statement that the FAA's Changed Product Rule (CPR) does not apply to field approvals. (For information regarding CPR, see AOPA's issue brief.

The changes to 8300.10 Vol 2 Ch 1 - Field Approvals will not immediately apply to Alaskan operators. Per an agreement with the Alaskan general aviation industry, this change will be effective after two years in order to put in place the necessary infrastructure and resources.

Change 16 also includes other revisions to FAA Order 8300.10 -

Changes Vol 2 Ch 2 - Issue SFAR 36 (SFAR 36 permits Part 121 and 145 operators to develop their own techincal data for the approval of major repairs when "approved" data doesn't exist)
Adds Vol 2 Ch 5 - Evaluate Operator's Application To Conduct Flight In Airspace Where RVSM Minimums Are Applied
Changes Vol 2 Ch 91 - Evaluate Pt 135 (9 or less pax seats) Operator/ Applicant's Inspection And Maintenance Requirements
Adds Vol 3 Ch 9 - Conduct Ramp Inspections On Cargo Loading (Part 121/135)
Changes Vol 3 Ch 125 - Monitoring Pt 121 Operators Before, During, And After Labor Dispute, Strike or Bankruptcy

AOPA position:

General aviation operators nationwide rely on field approvals to safely enhance their operations and safely maintain their aging aircraft. With its recent policy change, the FAA is attempting to improve and standardize field approval service nationwide, which did not happen when it issued Change 15, most notably in Alaska. AOPA hopes that the implementation of Change 16 will restore nationwide FAA field approval service back to where it was prior to the recent policy change and improve from there. AOPA's goal is to make sure that the FAA's field approval policy is "user friendly" and robust. AOPA will continue to work with the FAA to ensure that aircraft operators have access to this important process.