Industry Requests More Time to Comment on FAA Order 8130.21J
March 28, 2025
Update: On April 17, the FAA notified the industry signatories that it had extended the comment deadline to June 6, 2025.
On March 28, ARSA joined 11 ally trade associations in requesting the FAA provide more time to comment on Draft Order 8130.21J, “Completion of FAA Form 8130-3 under Part 21.” As announced by FAA Director of Aircraft Certification Caitlin Locke during ARSA’s Annual Conference, the draft was posted on March 19 with a 33 day comment period. The group requested an additional 60 days so it could coordinate analysis of the draft through June 23.
“Past experience with unintended consequences arising from 8130-3 guidance has shown that the industry can be dramatically affected (and consequently safety is affected) by choices in the related guidance,” the request said. “The entire industry wants to help the FAA avoid unintended consequences arising from 8130.21J.”
Locke highlighted the 18 page Draft Order during the Annual Conference as representing FAA effort to curtail expansive guidance documents: “[Order 8130.21] used to be…75 pages and now it’s 18. [The agency wants to highlight] examples of where we’re able to do that, where we’re able to meet the intent of what the guidance or the policy is for, to give the explanatory information that’s needed, but not add so much that then you need more guidance to interpret what you said because what you said before wasn’t clear, so you’re saying it again and now it’s not clear and you have six more forms and you don’t know why.”
In support of that effort and to reinforce the value of guidance as instructive but not regulatory, the aerospace community must ensure it’s provided time – as a partner to its regulator – to thoroughly review agency policy updates.
To read the Draft Order, click here.
To read the industry’s request for more time to comment, click here.
ARSA members should stay tuned from more updates (and clips) from the 2025 Annual Conference in the March edition of the hotline newsletter.
In addition to ARSA, the following trade associations supported the request:
Aircraft Owners & Pilots Association
Airlines for America
Aviation Suppliers Association
Aviation Technician Education Council
Cargo Airline Association
Commemorative Air Force
Experimental Aircraft Association
International Air Transport Association
Modification and Replacement Parts Association
National Air Carrier Association
National Air Transportation Association
National Business Aviation Association
Previous updates on recordkeeping guidance...
11/19/24 - Clarifying (by Dividing) Maintenance Recordkeeping Guidance
November 19, 2024
On Nov. 19, ARSA submitted a pair of draft advisory circulars for FAA consideration to replace its proposed update to AC 43-9, Maintenance Records.
The documents divide overlapping responsibilities previously combined into a single AC. The revision to AC 43-9 provided to the FAA now focuses exclusively on recordkeeping responsibilities of persons authorized by part 43 to perform maintenance, preventive maintenance, or alteration. The elements of compliance with record-making and keeping regulations in part 91, applicable to operators, have been placed in a proposed AC 91-417, Part 91 Maintenance and Inspection Records.
The submission follows an August request for extension to the comment period, made by ARSA and a collection of industry allies. The review and drafting period took longer than projected, but produced documents that can provide useful guidance regardless of FAA action. The association encourages its members to download each document, review, circulate among personnel, and use as internal instruction for compliance with the various requirements of parts 43 and 91 – particularly in service of customers who must comply with the rules for operators.
Draft AC 43-9D, Maintenance Records
Purpose: This AC provides certificate holders authorized to perform maintenance, preventive maintenance, and alterations under Title 14 of the Code of Regulations (14 CFR) part 43 with acceptable methods for showing compliance with the maintenance recording requirements in §§ 43.9 and 43.11.
Draft AC 91-147, Part 91 Maintenance and Inspection Records
Purpose: This AC describes methods, procedures, and practices that have been determined to be acceptable means of showing compliance with the record-making and maintenance recordkeeping requirements of Title 14 of the Code of Federal Regulations (14 CFR) part 91.
8/20/24 - Industry Gets Extra Time to Review Records AC
August 20, 2024
On Aug. 9, ARSA joined 11 other aviation trade associations requesting additional time to comment on the FAA’s Draft Advisory Circular (AC) 43-9D, “Maintenance Records.” The FAA subject matter expert in charge of the AC quickly responded with an additional 60 days – the new deadline is Oct. 18.
The draft would replace the current version of the guidance document in use since 1998. The AC provides acceptable means of showing compliance with general aviation record-making and recordkeeping requirements according to parts 43 and 91. Though not regulatory – it provides a method, not the only method for showing compliance – the industry continues to push the FAA to carefully align its guidance with the regulations.
“The document contains changes that must be reviewed carefully to ensure compliance with both parts 43 and 91, while accommodating the proper method for completing an FAA Form 8130-3,” the request said. “To use an FAA Form 8130-3 as a maintenance record, information on its completion must be reconciled with the elements required by § 43.9 and multiple bilateral agreements, maintenance implementation documents, and other advisory material.”
To read the complete request, click here.
To view the coordinated copy of the draft AC, click here.
In addition to ARSA, the following organizations supported the request*:
Aircraft Electronics Association
Aircraft Owners and Pilots Association
Airlines for America
Aviation Suppliers Association
Aviation Technician Education Council
General Aviation Manufacturers Association
Modification and Replacement Parts Association
National Air Carrier Association
National Air Transportation Association
Professional Aviation Maintenance Association
Regional Airline Association
*The Aerospace Industries Association confirmed to ARSA its own separate request in support of the group’s need for more time to comment.
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