Last June, ARSA submitted comments to the Federal Aviation Administration (FAA) draft order 8300.X that provided guidance for the approval of technical data associated with major repairs or alterations. ARSA’s comments pointed out the order’s inconsistencies with Advisory Circular 120-77, the FAA’s response to a letter submitted under the Consistency and Standardization Initiative (CSI) by Erickson Air-Crane, Inc., and Title 14 of the Code of Federal Regulations (CFR).
On April 18, 2014, the FAA issued Order 8300.16 without resolving these inconsistencies; it continues to use different definitions of technical and substantiating data than those provided in AC 120-77. While some AC 120-77 definitions are in an appendix, the chapter discussing these terms makes no reference to the appendix. Indeed, the Consistency and Regulatory Interpretation (CRI) Aviation Rulemaking Committee (ARC) recommended the FAA refrain from using multiple definitions of the same term in different guidance documents because of the potential ambiguity it creates.
In addition, one of the fundamental principles explained in the FAA’s CSI letter is the distinction between the performance standards in part 43.13(a)—requiring work be performed using “methods, techniques, and practices acceptable to the [FAA]”—and technical data (i.e., engineering information). Nevertheless, Order 8300.16 continues to use the term “acceptable data” interchangeably with “acceptable methods, techniques, and practices.”
ARSA suggested the FAA remove various items from a table listing potential sources of data relevant to major repairs or alterations because they were contrary to the FAA’s CSI letter and Title 14 CFR. While the FAA failed to remove these items, it did incorporate ARSA’s comments into a note to the table. The note indicates that maintenance manuals and certain supplier manuals developed using part 21 technical data remain FAA-approved. As such, unless there is a deviation from the maintenance manual when performing a major alteration or repair, the technical data supporting the action does not require re-approval by the FAA.
ARSA will continue to work with the FAA to provide consistent guidance on this issue.
To view ARSA’s past regulatory advocacy efforts for the aviation maintenance industry, visitwww.arsa.org/arsa-action.
