  |
|
Last week, the National Air
Transportation Association (NATA)
and representatives from other
industry associations met with the
Federal Aviation Administration
(FAA) to discuss pending regulations
regarding aircraft insulation that
pose a serious threat to continued
operation after September 2, 2005,
of many in-service Part 25 aircraft.
The meeting was called in response to a letter to FAA Administrator Marion Blakey that called for an immediate 180-day extension to regulations that have the potential to ground in-service Part 25 aircraft undergoing maintenance. Industry participants in the meeting reinforced the position taken
in the letter and proposed corrective action in addition to the 180-day extension that will require rulemaking action to implement. The FAA participants in the meeting included representatives from aircraft certification and flight standards services. The letter, signed by NATA, the Aeronautical Repair Station Association, the Aircraft Electronics Association, the Aviation Suppliers Association, the Experimental Aircraft Association, the General Aviation Manufacturers Association and the National Business Aviation Association, raised concerns with a broader than originally intended application of regulations issued in 2003 addressing aircraft insulation. The associations explained, “It has long been understood that the requirements of the final rule, titled “Improved Flammability Standards for Thermal/Acoustic Insulation Materials Used in Transport Category Airplanes; Final Rule,” would apply to thermal and acoustic blankets installed in Part 121 aircraft as a result of the Swiss Air 111 accident in 1999.” However, the FAA did not release corresponding guidance material for the regulations until June 24, 2005, in the form of Advisory Circular 25.856-1 (AC). As a result of that guidance, “it became clear that the rule was being applied to every insulating material in the fuselage of every Part 25 aircraft (both old and new) to include hard components, wiring bundles, tape, hook and loop fasteners (Velcro) and every piece of installed equipment with insulation. This also includes microwave ovens, coffee makers, wiring sleeves, air ducting, avionics components and many other commercial-off-the-shelf pieces of equipment that contain insulation subject to this rule. This affects all in-service Part 25 aircraft used in Part 91 and 135 operations.”
The industry has pointed out that the AC clearly exceeds the scope of the original rulemaking that specifically referred to insulating blankets, not the many piece parts within an aircraft that happen to contain insulation. Further, the economic impact analyses did not accurately evaluate the impact of the rulemaking on the industry and the substantial costs that would be incurred in order to comply with the standards prescribed in the AC. Additionally, with the late release of the AC this expansion of the regulatory scope was completely unknown until just months prior to the compliance date. These factors have led the industry associations to join together in requesting an extension to the compliance date for in-service aircraft operated under Parts 91 and 135. Indications from the FAA participants in last week's meeting as well as follow-up email correspondence are that relief from the said rule is forthcoming but will not be issued prior to the September 2nd implementation date. Flight Standards Services is issuing guidance to the fiel that is intended to prevent the unintended consequence of the rule as written that would ground many of the Part 25 aircraft in service. In further repsonse to the said meeting, the industry has sent an additional letter to Administrator Blakey urging immediate action to implement the 180-day extension to the regulation. Click here to view the initial industry letter to Administrator Blakey. Click here to view the follow-up industry letter to the Administrator.
Subscribe |
Contact Us |
NATA.aero |
 |
 |
 |