- Participation in the Aging Aircraft Ad Hoc Committee, which drafted and published the Best Practices Guide for Maintaining Aging General Aviation Airplanes.
- Relief from excessive documentation in maintenance records, most notably regarding the installation of some equipment such as shoulder harnesses in aircraft.
- Aircraft would not be limited in size or complexity.
- This is not a new Experimental category; Part 43 airworthiness regulations would still apply.
- The installation of parts and items that are not PMA or TSO compliant would be allowed.
- Transfer to the new category would mean the loss of any privileges to carry persons or property for hire.
- Transfer to the new category would be a one-way process; the aircraft would not be eligible for type re-certification via a conformity inspection or any other means. Because of this, it would be essential that the decision to change the certification category be made carefully by the owner/operator.
- Transfer to this new category would not be mandatory. The owner would have the opportunity either to continue to operate under the current regulations governing type certificated products, or to “op-out” and choose to have the aircraft maintained within the regulations of the new category. Subsequent owners of the aircraft transferred into the new category would be required to maintain the airplane in that vintage aircraft category.
EAA Set to Advance Vintage Aircraft Proposal Next Month
EAA briefed several other industry associations and type clubs this week on a vintage aircraft proposal it will present at the aging aircraft public meeting March 22-23 in Kansas City, Missouri. The proposal, which conceptually met with approval by key members of the FAA management team during the EAA/FAA Recreational Aviation Summit, was presented Tuesday, February 7, in Washington, D.C. to representatives from the National Air Transportation Association (NATA); General Aviation Manufacturers Association (GAMA); Professional Aviation Maintenance Association (PAMA); Aircraft Owners and Pilots Association (AOPA) and the Aircraft Electronics Association (AEA). Also present via teleconference were the American Bonanza Society and the Cessna Pilots Association. Doug Macnair, EAA vice president of government relations, presented the concept on behalf of EAA and its Vintage Aircraft Association.
EAA’s proposal is based on the following concept:
Create an aircraft certification category that will give owners and their mechanics the ability to maintain vintage aircraft using acceptable data or safety-based form, fit, and function criteria, as opposed to unavailable or outdated type-certificate data.
Over the past few years the availability of data to adequately support the restoration, modernization, and maintenance of vintage aircraft has continued to be a critical issue. It’s the subject of continual discussions between the FAA and industry groups, including yearly meetings held with EAA and numerous Type Clubs during EAA AirVenture Oshkosh. Unfortunately for both the FAA and the industry groups, there’s been precious little movement on the issue.
The FAA’s current set of rules places the vintage aircraft restorer or owner in a difficult position: the FAA requires that manufacturer’s type-specific data be used to document maintenance or restoration, yet the FAA and DOT’s own rules prohibit, in many cases, the release of the data which is available from no other source. This conflict necessitates that the FAA either rescind the requirement to have the original or factory-revised data on hand, or implement procedures that will allow for the release of the data.
EAA and its Vintage Aircraft Association (VAA) have worked with others in the aviation industry to lessen the weight of the regulations related to maintenance and alterations of aging aircraft. Key results of that activity include:
However, this effort has also reached a stage were the benefits to the aircraft owners and, more importantly, the effect on safety and continuous airworthiness, are relatively small in relation to the efforts being expended and the resources being committed.
In the past, EAA, the FAA and others have collectively looked to solve the data issue (and, therefore, the maintenance issues related to data) by attempting to create an avenue that would allow for the release of the data by the FAA or the TC holder. These efforts have failed as a result of definitive legal rulings by the Department of Transportation.
EAA and VAA believe that if significant improvements are to be made in the efforts to ensure safety and the continued airworthiness of vintage aircraft, available resources should be redirected toward efforts to make a significant change in the processes governing the continued airworthiness of vintage aircraft.
It’s time to look at the problem from a fresh perspective and with fresh new ideas.
Simply put, to make viable the continued airworthiness and modernization of vintage aircraft, the availability of approved data must be ensured, or the requirement for approved type data must be removed from the regulations governing the maintenance of the vintage fleet.
EAA’s understanding from the FAA is that there is no prospect in the near or distant future to dramatically improve the availability of approved data for vintage aircraft. Even if EAA were successful in gaining legislation to force the FAA to release type certificate engineering data, there is little assurance that the data even still exists or could be located all these decades later. That leaves only one option: revise the requirements to allow for the use of FAA-acceptable data in the maintenance of vintage aircraft, without the requirement that it be accompanied by type-approved data.
Revising the requirement for formal type-approved data is synonymous with removal of the type certification of these aircraft. If an aircraft holds a type certificate, then one must have the approved data to maintain the aircraft to that type certificate. If an aircraft does not hold a type certificate, then the owner/operator and his mechanic may complete maintenance, repairs and alterations based on general safety standards in the form of acceptable data, as opposed to FAA-approved type certificate data.
EAA believes that a major part of the solution may be in the creation of a new aircraft certification category for vintage aircraft, a category that would allow for the broader use of existing and longstanding acceptable data such as FAA’s Advisory Circular 43.13, while providing relief from many of the regulatory, cost, and paperwork burdens associated with trying to acquire or develop approved data.
Key points of our proposal include: