What an exciting time to be in aviation! We are witnessing the dawn of a new era with the emergence of everything from autonomous advanced air mobility to “quiet supersonic” aircraft—advances with the potential to make our lives better, transportation quicker, and the world cleaner.
What do those exciting innovations have to do with something as mundane as regulations? Quite a lot, in fact. Regulations are minimums that become expectations, which then drive industry to establish processes that ensure safe transportation. Most of these regulations were hard fought and some were borne as a result of terrible tragedies. All must be examined for industry application and implementation. The bottom line: regulations matter and NATA, as always, is here to help you navigate the aviation business regulatory environment.
So, please join me and the NATA Regulatory Affairs team in this new column discussing the regulatory matters that impact your operational efficiency and safety. Currently, a number of our members’ pressing issues have our attention, from Safety Management Systems (SMS), Public Charter Operations (CFR Part 380/Part 135), and illegal charter activities to pilot age, Part 135 fatigue, and the Pilot Records Database.
With all these interests, what are we moving out of our peripheral vision and into focus? As of this writing, the SMS NPRM has taken lead for our attention and we have established interactive communication with our members to learn about potential impacts and unintended consequences of FAA expanding the Part 5 requirement for SMS to Part 135 operators, Part 91 air tour operators, and certain Part 21 design and manufacturing organizations. NATA will respond in our members’ interests to the FAA’s following requests:
- “How SMS might present unique opportunities or challenges for smaller organizations,”
- “Supporting information and data regarding whether this applicability should be limited to a certain subset of § 91.147 LOA holders and part 135 operators, and if so, how,” and
- “Whether part 5 should apply to all holders of TCs, PCs, supplemental type certificates, technical standard order authorizations, or parts manufacturer approvals.”
In addition to proposed changes to Part 5, the FAA intends to publish an updated version of Advisory Circular 120-92 with details to help organizations comply with the regulatory requirements, such as SMS worksheet examples and other key information.
Ultimately, NATA believes that an active, well-thought-out SMS will continually improve the level of safety in any organization, large or small. The key for our membership will be the ability to scale the SMS efficiently and effectively to the operation. NATA advocated for and was granted an extension of the NPRM comment period to April 12, 2023. We encourage our members to take full advantage of this additional time to add to the public discourse on proposed SMS changes. NATA will provide our members with an update once our comments are submitted for consideration.
Please keep your feedback coming our way so we maintain focus on regulatory matters that mean the most to our industry. To that end, we will host several Business Aviation Roundtables this year to take advantage of face-to-face interactions and discussion. Thank you for your time, attention, and engagement in advancing the success of NATA’s “Regulatory Matters.