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.
