Industry Seeks Objective Criteria for Operations Specifications

On April 13, a coalition of aviation industry organizations delivered a letter to the FAA seeking objective criteria for adding and reviewing paragraphs to any certificate holder’s operations specifications.

The letter was coordinated by the Aeronautical Repair Station and sent to Flight Standards Service Executive Director John Duncan. It described a series of issues related to the government’s failure to differentiate between air carrier and air agency certificates in applying operations specifications paragraphs. The signatories noted that the agency lacks defined standards for the working group advising on promulgation of these paragraphs under 14 CFR part 119, which includes air carriers and commercial operators, but does not seek any kind of industry input from repair stations or other air agency certificate holders.

The timing of the group’s submission takes advantage of language in this year’s omnibus appropriations bill signed into law in March. The legislation included a provision restricting the FAA from promulgating any operations specification, policy or guidance that imposes more burdensome restrictions than those defined in the rules. The letter was delivered “to assist the agency in complying with the congressional mandate.”

Specifically, the letter suggests the agency establish a committee of government and industry personnel that would review the FAA’s management of operations specifications for every type of certificate holder. The regulatory experts on the new body would establish criteria for promulgation of new paragraphs and review existing ones to ensure currency and consistency with specified regulations.

“The legislative language was a helpful reference for encouraging the agency to act,” said ARSA Executive Director Sarah MacLeod, noting how the provision in the spending bill coincided with an already-developing effort to address the issues outlined in the letter. “The truth is that the regulators shouldn’t need Congress to tell them to apply objective standards. Regardless of what the law says, the FAA can and should coordinate with the industry to make sense of how it applies operations specifications paragraphs.”

To read the full letter, click here.
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In addition to ATEC, the letter was signed by:
​Aircraft Electronics Association
Aircraft Owners and Pilots Association
Airlines for America
Aviation Suppliers Association
General Aviation Manufacturers Association
Helicopter Association International
Modification and Replacement Parts Association
National Air Carrier Association
National Air Transportation Association
Regional Airline Association
The Boeing Company
Gulfstream Aerospace Corporation
MOOG Aircraft Group