Author Topic: This proposal may be of concern  (Read 351 times)

tailhook

This proposal may be of concern
« on: January 16, 2019, 05:38:56 AM »
We have a serious issue with FAA guidance letter 8100.19. It will allow a single FAA inspector remove many aircraft from service that are completely repairable utilizing FAA PMA parts and assemblies. Please read the attached document and contact your Senators and Representatives in Washington today. I am attaching a copy of my letter to Scott Leathard in Alaska Senator Dan Sullivan’s office. I spoke with the Senator Saturday in person. He was very receptive and concerned.

My letter follows-

“Mr Leathard,

I met with Senator Sullivan this morning in Reno at Safari Club. Sen. Sullivan directed me to contact you concerning FAA Order 8100.19 – Destroyed and Scrapped Aircraft.

I am attaching a .pdf of the document as well as the schedule for the FAA Inspection Authorization meeting in Anchorage at Change Point Church January 25, 2019 where it is to be presented.

This Guidance doc authorizes and attempts to provide guidance to certain FAA inspectors on determining if and aircraft is damaged to the point of being considered scrapped or destroyed. Without the consent of the registered owner the aircraft can be deregistered and the data tag required to be surrendered. At this juncture the aircraft is just gone. Many of the aircraft we rely upon in Alaska for our day to day livelihood are no longer in production. Examples are Piper Super Cubs, Cessna 180 and 185, Beavers, Otters, just to give a few examples.

Many of these aircraft have aftermarket current production parts from FAA approved PMA sources. Super Cubs are a great example there is a large local cottage industry surrounding the overhaul, repair, and reconstruction of these aircraft. I have personally repaired aircraft as old as 1947 with a new manufactured FAA/PMA fuselage frame and all new parts to equal, and in many cases better than when they left the factory. In a large part due to modern manufacturing and metallurgy,

Concerns:
1. Commercial and private sectors will be impacted dramatically from the implications of the power granted to individual inspectors by 8100.19. Rural remote Alaska depends upon the “Bush Pilot” to deliver groceries, fuel, food, emergency evacuation, tourism from flight seeing, hunting, fishing, eco tours all will be impacted from the loss of aircraft no longer in production do to surrender of paperwork and data plates for aircraft that could be reconditioned/overhauled at the owners discretion.
2. Usurping private owners rights. If a government employed inspector can effectively condemn someones private property without them having a say I believe that is wrong. So long as the aircraft can be reconditioned to original or properly altered, approved condition who is to determine what is “too much” damage. This is the choice of the owner. There is an appeal process, however, I personally feel this is unethical abuse of power and a violation of public trust.

Should the owner of a damaged aircraft wish to repair/overhaul the aircraft requiring an FAA authorized inspector to perform a conformity inspection would be an acceptable method of insuring the safety of the public and assuring the aircraft in question was returned to the original manufactured or approved and altered state.

Thank you for your help in considering this matter.

We have a serious issue with FAA guidance letter 8100.19. It will allow a single FAA inspector remove many aircraft from service that are completely repairable utilizing FAA PMA parts and assemblies. Please read the attached document and contact your Senators and Representatives in Washington today. I am attaching a copy of my letter to Scott Leathard in Alaska Senator Dan Sullivan’s office. I spoke with the Senator Saturday in person. He was very receptive and concerned.

My letter follows-

“Mr Leathard,

I met with Senator Sullivan this morning in Reno at Safari Club. Sen. Sullivan directed me to contact you concerning FAA Order 8100.19 – Destroyed and Scrapped Aircraft.

I am attaching a .pdf of the document as well as the schedule for the FAA Inspection Authorization meeting in Anchorage at Change Point Church January 25, 2019 where it is to be presented.

This Guidance doc authorizes and attempts to provide guidance to certain FAA inspectors on determining if and aircraft is damaged to the point of being considered scrapped or destroyed. Without the consent of the registered owner the aircraft can be deregistered and the data tag required to be surrendered. At this juncture the aircraft is just gone. Many of the aircraft we rely upon in Alaska for our day to day livelihood are no longer in production. Examples are Piper Super Cubs, Cessna 180 and 185, Beavers, Otters, just to give a few examples.

Many of these aircraft have aftermarket current production parts from FAA approved PMA sources. Super Cubs are a great example there is a large local cottage industry surrounding the overhaul, repair, and reconstruction of these aircraft. I have personally repaired aircraft as old as 1947 with a new manufactured FAA/PMA fuselage frame and all new parts to equal, and in many cases better than when they left the factory. In a large part due to modern manufacturing and metallurgy,

Concerns:
1. Commercial and private sectors will be impacted dramatically from the implications of the power granted to individual inspectors by 8100.19. Rural remote Alaska depends upon the “Bush Pilot” to deliver groceries, fuel, food, emergency evacuation, tourism from flight seeing, hunting, fishing, eco tours all will be impacted from the loss of aircraft no longer in production do to surrender of paperwork and data plates for aircraft that could be reconditioned/overhauled at the owners discretion.
2. Usurping private owners rights. If a government employed inspector can effectively condemn someones private property without them having a say I believe that is wrong. So long as the aircraft can be reconditioned to original or properly altered, approved condition who is to determine what is “too much” damage. This is the choice of the owner. There is an appeal process, however, I personally feel this is unethical abuse of power and a violation of public trust.

Should the owner of a damaged aircraft wish to repair/overhaul the aircraft requiring an FAA authorized inspector to perform a conformity inspection would be an acceptable method of insuring the safety of the public and assuring the aircraft in question was returned to the original manufactured or approved and altered state.

Thank you for your help in considering this matter.

We have a serious issue with FAA guidance letter 8100.19. It will allow a single FAA inspector remove many aircraft from service that are completely repairable utilizing FAA PMA parts and assemblies. Please read the attached document and contact your Senators and Representatives in Washington today. I am attaching a copy of my letter to Scott Leathard in Alaska Senator Dan Sullivan’s office. I spoke with the Senator Saturday in person. He was very receptive and concerned.

My letter follows-

“Mr Leathard,

I met with Senator Sullivan this morning in Reno at Safari Club. Sen. Sullivan directed me to contact you concerning FAA Order 8100.19 – Destroyed and Scrapped Aircraft.

I am attaching a .pdf of the document as well as the schedule for the FAA Inspection Authorization meeting in Anchorage at Change Point Church January 25, 2019 where it is to be presented.

This Guidance doc authorizes and attempts to provide guidance to certain FAA inspectors on determining if and aircraft is damaged to the point of being considered scrapped or destroyed. Without the consent of the registered owner the aircraft can be deregistered and the data tag required to be surrendered. At this juncture the aircraft is just gone. Many of the aircraft we rely upon in Alaska for our day to day livelihood are no longer in production. Examples are Piper Super Cubs, Cessna 180 and 185, Beavers, Otters, just to give a few examples.

Many of these aircraft have aftermarket current production parts from FAA approved PMA sources. Super Cubs are a great example there is a large local cottage industry surrounding the overhaul, repair, and reconstruction of these aircraft. I have personally repaired aircraft as old as 1947 with a new manufactured FAA/PMA fuselage frame and all new parts to equal, and in many cases better than when they left the factory. In a large part due to modern manufacturing and metallurgy,

Concerns:
1. Commercial and private sectors will be impacted dramatically from the implications of the power granted to individual inspectors by 8100.19. Rural remote Alaska depends upon the “Bush Pilot” to deliver groceries, fuel, food, emergency evacuation, tourism from flight seeing, hunting, fishing, eco tours all will be impacted from the loss of aircraft no longer in production do to surrender of paperwork and data plates for aircraft that could be reconditioned/overhauled at the owners discretion.
2. Usurping private owners rights. If a government employed inspector can effectively condemn someones private property without them having a say I believe that is wrong. So long as the aircraft can be reconditioned to original or properly altered, approved condition who is to determine what is “too much” damage. This is the choice of the owner. There is an appeal process, however, I personally feel this is unethical abuse of power and a violation of public trust.

Should the owner of a damaged aircraft wish to repair/overhaul the aircraft requiring an FAA authorized inspector to perform a conformity inspection would be an acceptable method of insuring the safety of the public and assuring the aircraft in question was returned to the original manufactured or approved and altered state.

Thank you for your help in considering this matter.



« Last Edit: January 16, 2019, 05:43:01 AM by tailhook »