Compliance Date Extension - U.S. DOT/FAA

Comments of the Aerospace Industries Association (AIA) and the General Aviation Manufacturers Association (GAMA) to Docket No. FAA-2004-17681, Aging Airplane Program Update: New Approach for Requirements for Design Approval Holders The Aerospace Industries Association (AIA) and General Aviation Manufacturers Association (GAMA) appreciates the opportunity to provide comments on the general Aging Aircraft Program update which was published within the Fuel Tank Safety Compliance Extension final rule in the July 30, 2004 Federal Register. Although this was ¿provided mainly for informational purposes,¿ one of the proposed changes represents a significant shift in FAA¿s philosophy as to regulatory responsibility of manufacturers and operators for continued airworthiness and the construct of the Federal Aviation Regulations. AIA and GAMA support the results of FAA¿s review of the Aging Airplane Program and its efforts to improve continued airworthiness by facilitating compliance with operational rules. However, industry does not have a clear enough understanding of the problem that FAA is attempting to address in the new approach for requirements for design approval holders. This proposal represents a significant shift in FAA¿s philosophy regarding certificate holder responsibilities for continued airworthiness and a significant change in regulatory structure of the Federal Aviation Regulations. The following provides general comments regarding the basic philosophy of the new approach for requirements for design approval holders and specific comments on considerations that should be made before implementing any new requirements.