NATA’s Maintenance Committee Assists FAA with Standardized Compliance Checklist Continued from page 17 the company elected to move the charter certificate back to the original location. The original FSDO inspector then required that some of the changes that had already been made be reversed. As a result of these bad experi- ences, there are well-known repair stations that will no longer perform “Part 135 audits” because it is impos- sible to anticipate each region’s or inspector’s individual standard. Confronted with these frustra- tions, in 2013 the members of NATA’s Maintenance and Technology Committee decided to tackle the problem. The committee members consist of repair stations and other maintenance-related individuals from across the country that had all experienced major difficul- ties in conforming aircraft. The Committee’s initiative had the support of Congress, which in the 2012 FAA reauthoriza- tion bill had accepted an NATA recommendation to create a Regulatory Consistency ARC. The Maintenance Committee approached the Aircraft Maintenance Division of Flight Standards Service (AFS-300) with the concept of creat- ing a single checklist to be used across all regions. The Committee focused on aircraft of less than 20 passenger seats used in Part 91k or Part 135 operations since those make up the bulk of the charter fleet. Working from a variety of examples, and draw- ing from the broad range of expertise, the committee members drafted a recommended conformity checklist. The checklist was presented to AFS-300 which reviewed it internally, agreed that it was a good step toward consistency, and recommended using the checklist to create a job aid. A job aid is a FAA-issued docu- ment that provides inspectors with detailed guidance of how to perform a job function. Flight standards and AFS-300 have published a num- ber of job aids to assist inspectors in a wide variety of subjects, such as: assessment of nondestructive inspection organizations, use of electronic flight bag use, and oceanic and remote airspace operations. In cooperation with AFS-300, a finalized version of the checklist and job aid was finished in 2015. Another benefit of job aids is that they are also available to certificate holders as guidance in meeting the regulations. The FAA often publishes advisory circulars to be used in conjunction with job aids. The FAA has agreed to write an advisory circular explain- ing and utilizing the NATA confor- mity checklist. The goal is to release the job aid and advisory circular concurrently. While the use of a job aid or advisory circular is not mandated, inspectors and certificate holders can use the guidance and detailed instructions as one accept- able method of complying with the regulations. Use of the job aid and advisory circular will decrease the amount of inconsistency between individual FSDOs and regions. At this point, the next step is for the FAA to release the job aid, then write and release the advisory circular. Although the reorganiza- tion of the Flight Standards Service which took effect in August 2017 has eliminated individual FSDOs in favor of organization by functional divisions, the reorganization itself does not necessarily address the issue of individual inspector stan- dards and lack of consistency. The Committee is continuing to work with AFS-300 to release the job aid and advisory circular and to complete this important initiative in improv- ing consistency across the nation. Shelley A. Ewalt, Partner, is based in Princeton, New Jersey. Shelley’s prac- tice focuses on aviation and airport law, and a comprehensive range of transportation and aviation regula- tory compliance issues. Represented clients include FBOs, repair sta- tions, flight departments, charter and scheduled air carriers, and aviation service support providers. Her career in aviation spans over 25 years, with experience ranging from front-line MRO operations and management roles to legal roles. She is an active general aviation pilot with a commer- cial pilot’s license with multi-engine and instrument ratings. Shelley can be reached at [email protected] or +1.703.399.6078. Aviation Business Journal | 3rd Quarter 2017 19
