ARSA Comments on Proposed Change to Standard Airworthiness Regulation
April 18, 2005
In a Notice of Proposed Rulemaking issued on February 15, 2005, the FAA proposed a change to 14 CFR section 21.183 that would limit the issuance of standard airworthiness certificates for “new” aircraft to those situations where (1) the applicant is (a) the type certificate (TC) holder (or its licensee) and (b) holds a production approval (production certificate or approved production inspection system), or (2) the aircraft is an import aircraft type-certificated under section 21.29.
Beyond those applicants described, the FAA would only issue a standard airworthiness certificate for used or surplus military aircraft.
As proposed, the regulation does not directly address standard airworthiness certification for aircraft built from spare or surplus military parts or maintained parts approved for return to service by entities authorized under Part 43.
In its comments to the FAA, the Association took the position that preventing such aircraft from obtaining standard airworthiness certification exceeds the reasonable measures necessary to address the FAA’s expressed concern with oversight of aircraft manufacturing. The Association recommended that the final regulations include specific language allowing standard airworthiness certification for aircraft built from spare, surplus or used parts.
The FAA has also proposed regulations based on federal laws regarding the use of TC or STC data. Without the express permission of the design approval holder, the regulations bar parties from using the TC or STC data under certain circumstances. Under the proposed rule, the FAA requires a “licensing agreement” between the TC holder and the user of the TC data; however, the FAA requires that the STC holder merely provide “written permission” to use the data.
To provide consistency and avoid exalting form over substance, the Association recommended that the FAA adopt the “written permission” standard for both STCs and TCs.
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