New Repair Station Advisory Circular: After years of meetings and multiple drafts, the FAA has at last issued the important advisory circular "Guide for Developing and Evaluating Repair Station and Quality Control Manuals" (AC 145-9), effective on October 6 in order to coordinate with the new Part 145, which will also become effective that month. An AC is not, of course, regulatory but it does contain the procedures that local FAA inspectors will follow in evaluating repair station manuals. The 81-page AC is surprisingly well organized in comparison with the confusion of the earlier versions and it is divided into four major sections: General Information; Manual Revision and Control; Repair Station Organization Chart; and Repair Station and Quality Control Manual Elements. Nevertheless, the AC is more than 300,000 words in length and it is complex and demanding reading. And once again here is another long and detailed government document with no index at the end, which would make reference to specific items so much more easy.

In its first reaction to the issuance of the AC, the National Air Transportation Association said that its repair station members need more time to analyze and study it before they try to implement the recommendations in their operations. NATA has petitioned the FAA for a 90-day extension of the effective date, something that seems unlikely at this time. NATA also feels the new AC will cause additional difficulties for repair stations involved in contract maintenance because of the increased paperwork, staff, and expense involved.

Sarah MacLeod, executive director of the Aeronautical Repair Station Association, said that the AC for all its detail does not present "a fill-in-the-blank menu" for repair station manuals and you will still have to reference and coordinate it with the coming new Part 145. This means, of course, that the manual developed by the repair station will still have to be evaluated and approved/disapproved based on the personal judgment of the inspector at the local FAA FSDO. This continues the old, old problem in aviation of inconsistent FAA decisions across the country.

The Aircraft Electronics Association, along with ARSA, is joining in NATA’s petition for an extension of the AC’s implementation date, and thus the three major associations that represent different types of repair stations operating under Part 145 think that the FAA has moved too quickly. In the meantime, AEA is preparing a guide for its members about how to use the new AC, and this is ironic because an AC is supposed to be in itself a guide of how to use the FARs. This AC is apparently so complex that an association has to make a guide for a guide. In addition, Ric Peri, AEA’s vice president for government affairs, said the AC does not address a number of issues and questions that were raised during all those meetings over the years and therefore FAA officials tell him that this matter is still a "work-in-progress." They added that they expect to issue yet another AC in the future–AC 145-9a–to further clarify these questions about repair station manuals.

However, AC 145-9 is the document of the moment and it will soon become operative. The text notes that repair station manuals "must remain current" and the word "evaluation" in the title means that inspectors will be using the AC to judge present manuals. Therefore, it becomes required reading for Part 145 repair station managers. The full text of the AC is found many places on the Internet, and one of the easier locations to access it is on the ARSA web site at www.arsa.org.

�It is always interesting to remember when these Part 145 regulations are discussed that while there are about 4,000 repair stations that are FAA certificated under Part 145, there are estimated to be more than 5,000 other repair centers that are not federally certificated and that nevertheless operate aviation businesses successfully without the obligations of Part 145. �

Blakey’s Incredible Statement: FAA administrator Marion Blakey has responded to the DOT Inspector General’s report about repair stations that was quite critical of FAA’s oversight of certificated stations. (See AM, August 2003, page 13.) In a news conference, she said that the agency agrees with the major findings in the report and is committed to stepping up surveillance of repair stations. Then she added this amazing statement: "You will not find in the report any data or indication that there is anything unsafe." She made this statement about the year-long DOT onsite audit of repair stations, which found many discrepancies in training, equipment, parts, and record-keeping–all of which are violations of the FARs. Are these not safety issues? Is not the purpose of the regulations safety and not mere red tape? Her remark flies in the face of all the federal government has been saying about safety regulations for the past 80 years. One of the delinquent items cited in the DOT report was the incorrect calibration of tools. Does not Blakey feel that an incorrectly calibrated tool is a safety concern? Does she know what calibration is? Marion Blakey, who took office as FAA administrator one year ago, is a political appointee who does not hold a professional aviation certificate of any kind and who for most of the 1990s ran her own public relations firm in Washington. She has four more years to go in office.

Najeeb Halaby: The aviation community is mourning the recent death of Najeeb Halaby, former FAA administrator and an aviation figure who went from test pilot to chairman of Pan Am. Born in Texas, he learned to fly before joining the Navy in World War II where he became a flight instructor and a test pilot for the first U.S. jet, the Bell P-59. He also made the first continuous transcontinental jet flight. Back in civilian life, President Eisenhower appointed Halaby co-chair of the commission that shaped the new Federal Aviation Agency in 1958 (it became "Administration" in 1967 when it was placed under the DOT.) President Kennedy named him FAA administrator in 1961, and during his four-year term with the young agency he insisted that people in FAA headquarters who are involved in regulatory matters should have first-hand aviation experience. In a famous episode, he rejected proposed material about skydiving when he found out the employee who wrote it had never done any skydiving himself. Halaby established this tradition of professionalism at headquarters, and it lasted almost three decades so that anyone regulating aircraft activities had to have an aviation certificate, either pilot or mechanic or ATC. Alas, this total aviation professionalism on all levels at FAA headquarters has disappeared during the last decade–as the previous story illustrates

The FAA’s Writing Style: The writing style used by the FAA–whether it is in regulations from Washington D.C. or correspondence from local inspectors–has long been a problem for the aviation industry. Simply stated, FAA material is difficult to read because it is wordy and obscure and full of legal jargon. It is not unusual to have to read an official letter a number of times to get its meaning, and even then one cannot be sure. This is true not only of FAA writing but to a large extent also materials produced by the federal government. A major attempt to correct this problem was made five years ago by a much-publicized presidential order on "Plain Language," which launched a government-wide effort to produce clearer writing in the government and instructed each agency to develop such a program. Accordingly, the FAA has had its own "Plain Language Initiative" (see the web site at www.faa.gov/language), which has resulted in a number of further memos, meetings, and classes. Unfortunately, there has been no significant change in the FAA’s writing style. But now the agency has issued a new order titled "FAA Writing Standards"(1000 36), and it is remarkably well done.

The new order is a helpful and concise seven-page document that offers practical advice about how to write easily-understandable English. It presents a series of clear language-writing principles, such as: use short sentences; use active voice; use pronouns to clarify; and use bold or italics for emphasis. Practical examples are offered. There is also a list of bureaucratic words to avoid. Instead of using "in the event that," write simply "if." Rather than "at the present time," write "now." And instead of "commence," write "begin." And above all, the order suggests, avoid those terrible run-on sentences that sometimes continue for 50 or 60 words. The order is posted on the FAA’s Plain Talk Initiative web site, and now it remains to be seen if the people of FAA will learn from it. Those of us who spend much time having to read the writings of FAA can only hope...

Certificated Flight Attendants? Be-cause pilots and mechanics are certificated by the FAA, why should not flight attendants also be certificated?� Now the issue is alive, attached to the FAA Reauthorization bill. The Association of Flight Attendants is pushing for the bill, saying that it would not only ensure and standardize adequate aviation training, but the certificate would also be portable, allowing the attendants to change jobs without having to undergo another training program. (This matter of portability was written for repairmen in the proposal for the revision of Part 65, which would allow repairmen to carry their certificates from repair station to repair station, but the proposed new Part 66 was withdrawn.) The FAA has adopted a diplomatic position by saying that it will do whatever Congress finally says.