Experts under the skin
What does the title “general aviation director of maintenance” actually entail? General aviation is associated with aircraft operations that are not covered by other rules, such as air carrier or commercial operations under Parts 121, 125 and 135. During regulatory training, we use the term to define operations not for compensation or hire. In any event, in general aviation, the operation of the aircraft is covered by 14 CFR Part 91.
Part 91, subpart K for fractional ownership, generally outlines the responsibilities for a general aviation director of maintenance. The owner of a “general aviation aircraft” must sign a contract with a program manager to ensure proper operation and maintenance. The program manager must establish a continuous airworthiness maintenance program (CAMP) and/or an approved aircraft inspection program.
If the program manager chooses to establish a CAMP, a qualified director of maintenance (a certified mechanic with airframe and powerplant ratings) must be appointed. However, even if the fractional owner chooses an inspection program, the person named responsible for scheduling maintenance activities is no doubt responsible for creating the approved program, accomplishing the inspections and executing corrective actions. (Remember, inspection is included in the definition of maintenance under section 1.1.) These persons will also be responsible for hiring and firing mechanics (and other technicians), choosing and overseeing other maintenance providers and getting changes to the programs “approved.”
The need for such a position is not limited to fractional ownership operations; it is equally important for a corporate aircraft as well as an individual aircraft that enjoys high utilization. While many individual owner/operators believe having a mechanic and/or pilot’s certificate equates to understanding the advantages and disadvantages of manufacturer-recommended inspection programs versus those specifically approved by the agency for the particular operations, this view is mistaken. While there are individual owner/operators who are extremely knowledgeable in both operations and maintenance, those that fly often take full advantage of experts to develop and implement an operation-specific CAMP. In general aviation, those experts are called directors of maintenance.
Sarah MacLeod is executive director of the Aeronautical Repair Station Association (ARSA). She is a managing member at the law firm of Obadal, Filler, MacLeod & Klein P.L.C. and is engaged in the legal representation of foreign and domestic air carriers, aircraft maintenance and alteration facilities, distributors, pilots, and other individuals and companies in federal court and before federal administrative bodies. She also serves as assistant chair for Air Carrier and General Aviation Maintenance of the FAA’s Aviation Rulemaking Advisory Committee, a post she has held since 1996. She is a sought-after speaker and has appeared at numerous aviation and MRO events. She is admitted to the bar in Virginia.