Delegating Responsibility to the Private Sector

I am an aerospace engineer with a company�specializing in aircraft structural modification and repair operating in Canada. I find your magazine very informative, an excellent source of information to keep up with what is happening in the aviation maintenance world.

I found your editorial note in the June 2005 edition to be interesting; however I cannot agree that your approach would solve the problem that you are referring to. In the maintenance world, as I am sure that you are aware, the job of the mechanic is to ensure conformance to the aircraft type design. In the event of a type design change, it is the responsibility of the agency that issues the approval to ensure compliance. This means engineering substantiation of each relevant regulation or standard that the modification impacts. Such meticulous attention to detail is why aircraft are safe. It is also where the work is and why the wait times can be so great when a company applies directly to the FAA (or Transport Canada) for a modification approval. With regards to the FARs, they only set a minimum acceptable standard. An alternate standard such as those offered by the ASTM International would only do the same.

In my opinion, the answer to the problem that you refer to is not a new system but increased delegation to the private sector.

When a company approaches the regulating agency (the FAA or Transport Canada) for an approval of a modification, it is the taxpayer that is paying�for it. Operators that are looking for quick approvals should be approaching private engineering companies (or individuals) that can provide that service. Yes,�that does mean that operators should pay for this service. It should be the FAA's role to monitor the companies offering these services.

It is much the same as how an AMO is delegated to perform maintenance on a given type or types of aircraft. Would you take your aircraft to the FAA for repair?

John Tremblay
Toronto, Canada

The Best Way to Promote Change: Get Involved

I agree with your suggestion on how to fix the broken wheel (FAA). In Australia I am an industry member of the working group developing our version of Light Sport Aircraft. We had input thru the Civil Aviation Safety Authority (CASA) into the ASTM LSA standards. We provided safety reasons to increase the LSA Stall Speed to 45 knots.

As you may be aware, we have had CASA regulations for over 10 years allowing our ultralights to operate at 544 kilograms with a stall speed of 45 knots in the landing configuration.

I also represent the aviation industry on the rewriting of CASA's safety regulations, a task that has been ongoing for more than 10 years.

John Washbrooke, CEO
FloJon Consulting
Yass, NSW
Australia

Congress, Are You Listening?

Excellent editorial in the July issue of Aviation Maintenance, Mr. Thurber. You did an excellent job of explaining the economic benefits-to the whole economy of the U.S.-of our country's vibrant aviation environment.

I hope you'll circulate your essay to congressional leaders and the White House.

Mike Truffer
AeroGraphics
DeLand, Florida