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Jay Mesinger
Questions & Answers
August
17, 2005:
Q: My company is selling its older Gulfstream IV. We
received an offer specifying that the aircraft must be
delivered 135 ready and we have never operated it on Part
135. How should we respond to this?
A: Personally, I never make offers with Part 135 as a
stipulation, but I often receive them during a sale. My
response is always the same. Our aircraft will meet Part 91
FAA regulations. I have found that to be a clear standard,
where some aspects of the 135 regulations are not.
There are several requirements that you can count on. They
require a fireblocked interior with complete burn
certification. All components in the aircraft must have
documentation that they are within limits set by the
individual manufacturers of the components, and yellow tags
for each component along with log entries evidencing
replacement and overhaul.
Emergency exits must be indicated on the exterior paint by
painting an opposing darker color around the exit. These are
just a few of the 135 requirements that are standard for
Part 135.
The differences come in because the Flight Inspection Safety
District Office (FISDO) may have their own individual
requirements. Meeting the unknown specific standards of the
area that your buyers happen to be in could become a costly
proposition.
The best way to respond would be to invite the buyer’s
technical representative to review the logs for obvious
compliance. During the pre-buy, the buyers can also instruct
the inspection facility to review the logs based on Part 135
conformity.
As an extra measure, they may even invite a representative
from their individual FISDO to come and perform a 135
conformity check while the pre-buy inspection is being
completed. These measures should allow you to avoid
committing to deliver an aircraft in a compliance standard
different than what you currently own.
Q: We are taking delivery of a pre-owned Falcon 2000
next week. The principals would like to fly the aircraft to
Hawaii three days later. The aircraft is RVSM compliant, but
a friend cautioned me that the aircraft would not be allowed
to fly above 29,000 feet until the company has completed its
own certification. Is this true?
A: Your friend is correct on this issue. There are
two parts to RVSM. First, you must meet the compliancy
standards with respect to equipment and aircraft paperwork.
For the first part, buyers will want to be certain that the
aircraft equipment, paperwork and nose area paint are
correct and ready for certification application. This means
that in your offer to purchase an aircraft, the criteria
should include RVSM compliancy.
Now for the second part that your friend advised you about.
Although the aircraft may be currently enjoying operation on
an RVSM certificate, unfortunately that doesn’t mean you can
just buy and fly.
Each time an aircraft changes ownership, the new owner must
make application with the area FISDO for RVSM certification.
The process for application and certification can take up to
four weeks.
To speed this process along, you should prepare the
application and necessary paperwork while the aircraft is
undergoing the pre-buy inspection. Then you will be ready to
file immediately upon transfer of ownership.
I’m sorry to tell you, but it looks as though you’ll need to
peruse some travel magazines and find a spot closer to home
for the owner’s first trip!
- Jay Mesinger
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