FAA Rule changes 8130.2j certification

I want to share my current experience with the Fsdo. The issue I have encountered can affect all jet owners. First, there does not appear to be a written policy for handling either (a) relocating your jet from one fsdo to another or (b) a sale of the aircraft that would involve a relocation to another fsdo jurisdiction. The Operating Limitations clearly list a home base airport and a need to amend the Operating Limitations to support any change of operation base involving a different fsdo. Each fsdo seems to handle this differently. In my current experience, the fsdo basically wants to recertify the aircraft as a result Only of a location change. In my case the jet has been certified since 2004. Only a location change is happening. This takes me to the main point of this open letter. As a part of the process of transferring to a new fsdo they want to update the Operating Limitations to comply with the latest Certification guideline. Currently that is 8130.2j. The rewrite of the guideline in 2017 apparently added NEW language that requires the fsdo to determine whether to place the jet into a "High Risk" category. The Appendix D item F lists five criteria. The item 2 is new and a real problem. It states that any aircraft manual that requires a bailout or ejection for any failure including a fire should be classified as high risk. Every warbird emergency check list I have ever seen would Fall into this category based upon the FAA loose arbitrary interpretation. Ive appealed this and lost with no faa explanation. The wording of this f.2 needs to be expanded and clarified or removed all together. As this slowly becomes enforced fsdo to fsdo,everyone can become a victim. High Risk means no passengers, no night, no ifr and more. This organization needs to make a stand on this issue.

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