[Peetwo]

The importance of strong Alphabet advocacy.

The following JDA article provides a classic example of the advantages a strong, professional industry association can provide to industry stakeholders in their dealings with the regulator: 

NATA’s excellent service to the PC-12 operators


Posted By: Sandy Murdock August 15, 2017

NATA’s PC-12 Compliance Resolution

Guidance for Air Charter Operators

Washington, DC, August 4, 2017 – Today, the National Air Transportation Association (NATA) announced the resolution of a compliance issue stopping air charter operators from adding certain Pilatus PC-12 aircraft to their certificates. Guidance documents published today now offer charter operators a clear pathway to utilizing these aircraft.

Many people may wonder what trade associations really do. All dues paying members know the exact amount of the dues. Some may realize that the association executives are frequently testify in hearings, but those unfamiliar with Washington are not aware of the direct benefits of such activities. Good associations create training programs, attract group discounts for relevant services and hold informative meetings. All are good benefits, but the above-linked article demonstrates the best of association work.



The National Air Transportation Association heard from its members that “that a local FAA office had denied requests to add to their operating certificate several PC-12 aircraft intended for passenger operations.” Because the Pilatus PC-12 is a single-engine aircraft, passenger operations require compliance with certain additional Part 135 regulations, including specific electrical system requirements (14 CFR 135.163(f)). It held a series of meeting with other Part 135 members and learned that the problem was broader than one FSDO.
Then, John McGraw, NATA Director of Regulatory Affairs, took the right action; he met with the FAA headquarters staff with jurisdiction over this issue. He brought the Pilatus technical experts to these discussions. The electrical loads of the PC-12 was reviewed and after sharing important information, they were able to come to a practical resolution. McGraw commented “the FAA has published an information for operators document, InFO 170011, clarifying the process for evaluating certain older PC-12 aircraft for passenger-carrying operations under Part 135. Concurrently, the FAA issued new inspector guidance reflecting the same information and procedures as outlined in the InFO.”

First, this is a classic example of the leverage which NATA provides. Having learned that members had encountered field opposition, McGraw and the OEM representatives were able to show the FAA headquarters staff exactly how the PC-12 complies with §135.163(f). Instead of 5-20 individual Part 135 operators working through the regulatory maze, one initiative resulted in a practical solution. If the individual certificate holders each pursued relief through a number of FSDOs, it is quite possible that some would have succeeded and others might have failed—and the reasons for the yes’s and the no’s might not have been consistent.


Second, the NATA tactic increased the likelihood of a positive result. By bringing the private sector subject matter experts to meet directly with the FAA Washington staff most knowledgeable on regulatory and technical issues, the discussion would be focused on the critical points. The FAA staff in the field, who did not write the FARs and are not as educated on airworthiness, do not feel comfortable making these sorts of decisions.



Third, the path through your FSDO or ACHDO to a successful outcome involves risks. If your PMI insists that the PC-12 is non-compliant and if you then tell her/him that you want to appeal, there may be consequences. FAA senior staff have implemented processes to ensure consistency, and ostensibly to minimize the sting of a reversal, it is quite possible that your PMI will resent being found wrong. Having been exposed as not THE expert on 14 CFR §135.__ does not reflect well on that person’s future promotability. Given the penumbra of a PMI’s power, there may be consequences for showing him/her up.



The NATA to headquarters route does not link PMI#! to the error; multiple PMIs were involved: the omniscient Washington folks made the decision; thus, PMI#1 is less likely to later find some fault.

This is one of the primary reasons why NATA and other trade associations with staff familiar with the FAA are worth those dues. They can resolve common issues for members with the above-described interventions.

MTF...P2