Jeffrey Jensen

Question four addresses potential impossibilities in AD’s, due to changes related to previous alterations, repairs and/or modifications. The suggested response is to have the operator seek out an AMOC for each AD in which a change of the affected part or area will not allow the AD to be accomplished. I have a few serious concerns as I am responsible for maintaining a fleet of aging aircraft that have many years of repairs, modification and manufacture service bulletins complied with. The first concern is the volume of AMOCs that would need to be applied for, have the consequences of this proposed legal interpretation been considered? I can think of far reaching affects such as further burdening already overburdened FAA personnel by processing numerous AMOCs and increased aircraft downtime to operators waiting for an AMOC to be issued. I recently submitted a request for AMOC and waited over 90 days for a response, in that circumstance we were forced to do additional inspections until we received the AMOC. Consider the affects of circumstance that would force a part or component to be unnecessarily changed, the cost of the part or the downtime awaiting the AMOC could detrimental to the livelihood of the operator. I would also like to question the safety aspect of the interpretation. I feel that licensed technicians and repair stations are better suited to review the application of an individual AD on an individual aircraft and make the airworthiness decision than an FAA representative whom is looking at paper work alone. I feel most in the aviation industry would agree that this interpretation takes away from the licenses, authorizations and certificates that we have worked hard to earn and maintain.