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What’s On Tap for New Rules?

The Federal Government has released the latest revision of the Unified Agenda, which details the rulemaking projects that are being worked by the government.

Each of these projects could reflect challenges and/or opportunities for the MARPA community. If you recognize one of these projects that you think could affect your business (or that you think could serve as a platform for a positive change in the regulations), then please let MARPA know your concerns, so we can be sure to represent our members’ interests in our formal comments and informal communications with the FAA and other agencies.

Remember – many of the most significant changes that affect that industry are being accomplished by the FAA through non-regulatory policy changes, and this means that the FAA’s rulemaking activities will continue to be more rare; it is important for us to examine those few that are moving in order to make sure that they do not adversely affect safety, nor inappropriately affect commerce without  a correlative safety accomplishment.

Following is a list of FAA projects that may affect some of our members:


FAA Official Description


Miscellaneous Rotorcraft Regulations The FAA proposes to revise regulations in title 14 Code of Federal Regulations (14 CFR) part 27 (Airworthiness Standards: Normal Category Rotorcraft) and part 29 (Airworthiness Standards: Transport Category Rotorcraft) related to the certification of rotorcraft. The proposed changes are necessary due to the extensive application of advancing technologies to rotorcraft. Existing airworthiness standards are inadequate because they do not address increasing design complexity. To address these advances, the FAA currently issues reoccurring special conditions, equivalent level of safety findings (ELOS), and means of compliance (MOC) issue papers. This proposed rule would address these problem areas by updating those standards that cause unnecessary burdens in cost and time to both the FAA and the rotorcraft industry. By updating the affected standards, many special conditions, ELOS findings, and MOC issue papers would be unnecessary, thus reducing the burden and cost on both the FAA and industry Comment Period Open Until January 30, 2018 – 82 FR 50583
Interior Parts and Components Fire Protection for Transport Category Airplanes This rulemaking would convert flammability regulations from detailed, prescriptive requirements into simpler, performance-based standards. This would enable compliance to be shown either without conducting tests or by providing independent substantiation of the flammability characteristics of a proposed material. This rulemaking would also extend current part 25 flammability standards developed for thermal and acoustic insulation to any extensively used material located in inaccessible areas. This action is necessary due to lack of effective ways to fight the spread of fire in these areas. The intended effect for these actions is to eliminate unnecessary testing, increase standardization, and improve safety. NPRM target date has already passed
Yaw Maneuver Conditions – Rudder Reversals (Formerly Vertical Stabilizer Loads for Transport Category Airplanes) This rulemaking would incorporate a new load condition into part 25. The new load condition would be a performance-based rule that would require applicants to demonstrate the integrity of the airplane structure, including its vertical stabilizer(fin), in the presence of pilot-commanded rudder pedal reversals. Adopting the new load condition would protect the airplane from excessive loads on the vertical stabilizer due to pilot-commanded rudder pedal reversals. NPRM scheduled for 2018
Foreign Civil Aviation Authority Certifying Statement for Type Validation Projects (TPV) This action would allow the FAA to accept certifying statements for validating aircraft from Civil Aviation Authorities (CAAs) issuing the type certificate. This action would relieve the burden of needlessly duplicating the certification process from the applicant. It would also reinforce reinforcing the bilateral agreement with a foreign CAA. The intended effect of this action is to reinforce the “authority-to-authority” relationship upon which type validation principles (TVP) effectiveness relies. TVP spares the applicant needless duplication of the certification process, while ensuring continued operational safety. NPRM scheduled for 2018 – PMA companies have experienced problems with STC validation, so this could be important to those efforts
Alternative Methods of Compliance (AMOC) The FAA is proposing to revise its rules for airworthiness directives (AD) to expand who has the authority to approve an alternative method of compliance (AMOC). The current regulations limit this authority to the manager of the office identified in the AD. The proposed rule would expand the authority to include any entity identified in the AD. This would reduce the number of AMOCs required to be approved by the FAA and would expedite certain AMOC approvals that do need FAA approval. The proposed rule would also remove a section that does not contain any requirements. NPRM scheduled for 2018 – PMA companies sometimes need AMOCs for their safety improvements so this could be quite important!



About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Air Carrier Purchasing Conference, and the Modification and Replacement Parts Association. He also represents private clients drawn from the spectrum of the aviation industry.


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