FAR 135 Maintenance

FAR 135 Maintenance

Many pilots aspire to fly bigger, faster, and more complex aircraft than where they currently are. It’s this “always forward” attitude that pushes pilots to the next level of aviation. Does this same attitude apply in maintenance? If so, such things as opening a maintenance shop are the first step. This is equivocal to a private pilot’s license. For some this is all they want, for others this is just the beginning. Such is true in aviation maintenance. The maintenance shop, for many, is just the first step. This is followed possibly by becoming a repair station, upgrading to being able to do overhauls, or possibly becoming a service center for a manufacturer. One possible step is opening your maintenance facility to handle 135 charter aircraft.

135 charter aircraft is often times a way that smaller maintenance facilities use to increase business. What this means is that they work on aircraft that fly charter operations, regulated under FAR (federal aviation regulation) 135. This regulation and all FARs can be found under CFR (Code of Federal Regulations) chapter 14. So what does 135 mean? Why is it different from all other GA (general aviation) aircraft? Well, first of all these are general aviation aircraft, used as on-demand charter aircraft. Since these aircraft are used for hire on-demand they are regulated differently than the aircraft that are not for hire; those aircraft are regulated under FAR 91. As such they also contain different maintenance requirements than part 91 aircraft. This paper is an outline of some of the major differences between the two types.

If you are operating an aircraft for hire under the operational rule FAR 135, you are required to provide the FAA an adequate maintenance program for each aircraft on your certificate during the application process. For aircraft certified to carry less than 10 passengers, the FAA has historically allowed the use of the aircraft manufacturers’ recommended maintenance program to meet the requirements of FAR 135 (Hertzler, 1998). What this means is that the FAA has to give you an “Ok” to work on those aircraft, making sure that you have submitted an outline of a program for the maintenance that will be done. This is not needed for part 91 aircraft. This is just one example of how part 135 is much more strict than part 91; many more will be in this paper. This is to be expected, however, due to the fact that under part 135 passengers are being carried for hire, therefore more safety measures must be taken.

Some, however, do not believe that the manufacturer’s recommendations may be the best way to do maintenance on certain aircraft. “Recently the FAA has been concerned about the completeness of manufacturer maintenance programs and has been requiring operators to develop AAIP’s (approved aircraft inspection programs) as a solution. According to FAA officials, the inadequacy of the manufacturer programs lies in the area of equipment that has been installed since the aircraft was new that the airframe manufacturer does not address. These items should, however, be maintained as per the equipment manufacturer recommendations. One significant problem found in using AAIP’s is the separation of such inspection programs from the manufacturer’s revision system. Aircraft maintained in accordance with the manufacturer’s recommended maintenance program are constantly up to date with new manufacturer recommendations.” (Hertzler, 1998).

So what are the major differences in working part 135 aircraft than on part 91 aircraft? First of all, all service bulletins issued by manufacturers are mandatory under 135; they are advisable but not mandatory under 91. All specific overhaul periods for engines, propellers, and accessories have to be performed under 135; under 91 it is just a suggestion. These time periods are for time in use and for calendar time as well. This also pertains to fluid carrying hoses that need to be replaced on a timed schedule also. The ELT (emergency locator transmitter) operation check that has to be performed every 12 calendar months according to 91.207 (paragraph d). For 135 and 141 planes they want it done every 100 hour and annual inspection (Hinman, 2001).

So who can do this maintenance? Well, the best way to answer questions like that is to go straight to the FARs and see what they say. In FAR 135.435, Certificate Requirements, it says the following: “A) Except for maintenance, preventive maintenance, alterations, and required inspections performed by repair station certified under the provisions of subpart C of part 145 of this chapter, each person who is directly in charge of maintenance, preventive maintenance, or alterations, and each person performing required inspections must hold an appropriate airman certificate. B) For the purpose of this section, a person “directly in charge” is each person assigned to a position in which that person is responsible for the work of a shop or station that performs maintenance, preventive maintenance, alterations, or other functions affecting airworthiness. A person who is directly in charge need not physically observe and direct each worker constantly but must be available for consultation and decision on matters requiring instruction or decision from higher authority than that of the person performing the work.” (Aviation Supplies & Academics, Inc. 2000). Not to easy to understand is it? What it is saying is that a mechanic that is appropriately rated, as stated in the maintenance program that was submitted to the FAA, may perform the work.

As we just saw, the way the regulations are written out may be taken differently by different people. In fact if you talk to one FAA employee they may have a totally different opinion from another FAA employee, and this has many mechanics upset. ”Every FSDO (flight standards district office) office has there own “take” on what 135 regulations specify and so there will be differences from region to region as to how things are handled.” Says Neal Hinman, head mechanic at Hinman Aviation. “What I see a big need for is an increase in common sense among the different FAA inspectors, inspectors that have actual experience with the aircraft they are inspecting and some common ground as far as how records are kept and how inspections are to be performed. Too many inspectors that simply “interpret” a regulation one way and the next inspector a different way. How is maintenance personnel supposed to work, read minds?” (Hinman, 2001).

Understanding regulations is something that has been difficult for years. The FAA is currently in the process of making regulations easier to understand and interpret. Unfortunately people will always look at things differently than others, and that is where this friction comes from. The best way is for mechanics to contact their local FSDO. They are the FAA office that will be working with them most of the time, and they will be the ones (most likely) interpreting the regulations. By getting to know them and letting them know of the operation’s safety record and quality of work, mechanics can save themselves a lot of time and paperwork.

Part 135 charter maintenance definitely has its differences from part 91. It is all something that a properly certified mechanic must be aware of. The pilot must also have a working knowledge of the maintenance required on the aircraft he/she is flying. Even though it is up to the owner of the aircraft to make sure the aircraft is in flying condition, if the pilot flies it in un-airworthy condition the pilot will get in trouble. This could mean anywhere from a license suspension, a license revocation, or a fine. These regulations are tougher than part 91 yet as stated earlier, these stricter regulations have safety as the main concern.

Neal Hinman closed his interview with a very good comment, one I would like close this paper with, “Really nothing voodoo about 135, just a few more regulations to watch out for, you need a good working relationship with FSDO, and a little more time in the books.”

Bibliography:

Hertzler, J. V. (1998, January). Aviation maintenance regulatory report. Avtrak Inc.Compliance Management Services, 1-3, Retrieved October 20, 2001 from the World Wide Web: http://www.avtrak.com/publications/12-2.htm

Hinman, N. (personal communication, October 21, 2001).