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. My general comment is that this is the best piece of proposed
regulation to come out of the FAA in my 45 years in the aircraft maintenance
field. It will result in an increased level of safety concomitant with a
reduced workload on local FAA FSDO personnel. This reduced workload will
allow them to concentrate on true safety of flight programs and eliminate
the paperwork blizzard generated by minor maintenance on light single engine
aircraft.

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."

The proposed 6000 pound max gross limit is reasonable. This encompasses
virtually every nonpressurized single engine aircraft in the fleet.
However, restricting the engine to 200 horsepower eliminates a very large
segment of the fleet, including such popular models as the Beech 35/36
series, all Cessnas from the 182 through the 210, a large segment of the
Piper mark, and others. Instead of encompassing these aging aircraft and
allowing an increased level of proper maintenance on them, it forces them
into what I foresee as a heightened level of restriction on them.

As a less onerous provision, the restriction to 4 seats or less eliminates
such aircraft as the Cherokee 6, the 182-210 Cessnas with the permanently
mounted "kiddie seat", and other aircraft that have 5 or 6 seats.

Therefore, I propose that you eliminate the horsepower restriction (or at
least raise it to encompass the vast majority of the fleet) and raise the
restriction on seats to 6.

Again, my compliments on a particularly good proposed regulation.

Jim Weir
A&P, IA
CFI, CGI, Airplane and Glider






If you want to change how the maintenance game is played, now is your
chance. Either comment on this NPRM or forever hold your peace.