Fuel Valves, Wing Tips, And You

Federal Aviation Administration
Aircraft Maintenance Division
William O'Brien
Washington DC

Dear Mr. O'Brien

This comment is in reply to your referenced NPRM for aircraft maintenance
requirements. I want to congratulate the FAA for recognizing the need to
simplify repairs and alterations on smaller GA aircraft, by acknowledging
the
responsibility and effort of we who hold an Inspection Authorization
certificate,
thus lightening the load on local FSDO's for approval of what could under
most
circumstances be considered "minor" repair and/or alterations as per AC
43.13, albeit
maintenance restricted to authorized and duly licensed persons (i.e. A&P's,
IA's).
With over 22 years of experience in General Aviation maintenance as an A&P,
and
more recently IA, I consider this NPRM a POSITIVE step in making G.A. safer
and easier to maintain, by helping eliminate illicit maintenance by those
who "sidestep"
the regulations due to perceived restrictive, costly, and time consuming
issues
relating to an aging General Aviation fleet.

There are a couple of items that will make the proposal internally
consistent with itself. I repeat here the seminal paragraph of the entire
NPRM:

: "The FAA plans to include a new policy that would allow mechanics
: and repair stations to use acceptable data as approved data for major
: alterations to certain non-pressurized aircraft. The new policy would
: apply to a landplane, seaplane, or floatplane, fixed gear aircraft of
: 6,000 pounds or less maximum gross weight, of 4 seats or less, and with
: a reciprocating engine of 200 horsepower or less."

I consider the restrictions to applicable aircraft very reasonable, however
the
power restriction of 200 HP should be reconsidered to 300 HP limit, as this
would include a very large number of aircraft essentially the same in
weight, size,
speed, and complexity as the sub 200 HP group, to benefit from this new rule
if put in effect. As a technitian who has many many thousands of hours
flying
and maintaining aircraft in bush flying operations, I'd really like to see
some bushplane
favorites included in this benefit, simply for reasons of field repairs in
remote areas,
since they see a heavy toll in wear due to the nature of their labour,
aircraft such as the
C182, C180, C185, C205, older C210, as well as several other models of Beech
and
Piper manufacture.

Again, my compliments on one of the best rule proposals in favour of GA
aircraft maintenance in
over 20 years.

Jerry D. Witt Jr.
A&P, IA since 1978
3,000 Hours + PPI, SEL Airplane