Is the Definition of Vintage going to be 20 years old?

[TedK]

Ted,

VAA as well as EAA are very much in support of the Small Aircraft Revitalization Act, and actively worked for its passage. Right now the FAA feels that this is a Part 23 issue and does not extend to Part 21. Meaning that this only applies to new production aircraft, but it does allow operators of vintage aircraft to install AOAs, autopilots, and the like in their aircraft. Expanding this policy to include vintage aircraft is a high priority for EAA and VAA Government Advocacy. We are currently working to get this hangup in the legislation resolved and make SARA much more useful to those operating vintage aircraft.

-Max Platts
VAA Administrator

Max- thank you for the update. I find it interesting that the FAA commissioned the study as a Part 23 study, the study group included FAA participants and made recommendations outside of Part 23, the Law directs implementation of the Recommendations, and the FAA is pushing back.

Do you have sufficient congressional support to get a letter to FAA that says "what part of implement the study recommendations...all the study recommendation...don't you understand?" I would hope so since this is the only thing lately that has unanimously passed in the House.

What can the membership do to help get the PNC portion into the initial NPRM?

thanks!

Ted

[Tom Charpentier]

Ted and all,

EAA participated in the Part 23 ARC and is in large part responsible for the inclusion of the Primary Non-Commercial Category recommendation in its final report. Unfortunately, as you may know the implementation of the report was stymied in the rulemaking process, forcing the industry to resort to legislation.

The legislation, however, does not force the FAA to adopt the ARC recommendations, only specific ones related to new production (read the full text here: https://www.govtrack.us/congress/bills/113/hr1848/text). It is also very broad, giving significant discretion to the FAA over how to implement it. While they have jumped on this to allow the quick and simplified installation of non-required safety equipment such as AoA, the full recommendation of the Primary Non-Commercial category (owner maintenance, non-PMA parts, etc...) is currently not being implemented (part of the Agency's argument, as Max stated, is that what we want actually concerns Part 21, not Part 23).

We're obviously not very happy about this. Owner maintenance and keeping vintage aircraft flying has long been a major goal of ours, and we're not there yet. We're currently addressing the "low hanging fruit" of safety equipment installations before moving onto what we (and I'm sure you) see as the big prize of an owner maintenance category. I would say that behind medical reform this is our next most important advocacy priority. While progress up till now has been tough, the ARC report got the conversation turned up a few notches, and we'll find a way to get it done. And yes, as soon as there is a way for the community to help, we'll absolutely let you know.

[TedK]

Ok, so what is your Strategy for getting to PNC and Owner Maintenance?

SARA is Law. Passed unanimously in the House. When are you ever going to get that kind of political capital again? If you let FAA do it solely as a Part 23 rewrite, you will never ever get the issued opened again.

Let GAMA carry the freight for the Part 23 rewrite, EAA and AOPA ought to be busting their humps to ensure that the appendix G (PNC) portions are in the NRPM.

There is a way for the community to help now, we can write Congress requesting that they clarify that we they tell something they mean all of something.

Or alternatively, you could wait for the NRPM and have the members carpet bomb it with comments to get the Appendix G comments put back it.

It appears you are doing what you individually can, but can't you get more traction and leverage by getting the membership involved?

PS: Is AOPA involved and helping?