In a quick turnaround, the Aircraft Maintenance Division responded within two days to ARSA’s question about airframe-rated repair stations with line maintenance authorization performing major repairs and alterations. The agency agreed with the association’s interpretation that the CFR’s definition of line maintenance does not imply a prohibition against non-specified activities.

The response concluded: “The provisions of 14 CFR section 145.205(d) allow an appropriately certificated and rated repair station to perform continuous line maintenance at the air carrier locations list on paragraph D-107 of its OpsSpecs.”

Previously from ARSA…

July 24, 2014

On July 23, ARSA sent a letter to the FAA to address and rectify controversy surrounding the right of a limited airframe repair station with line maintenance authorization to perform major repairs and alterations.

The agency has failed to differentiate the separate aspects of part 145 pertaining to ratings and authorizations. Instead, it has depended on the definition of line maintenance in 14 Code of Federal Regulations (CFR) 145.3(d) as implying a prohibition against non-specified activities. Whether an appropriately rated repair station can perform line maintenance goes beyond the 145.3(d) definition.

Once a rating is issued under 145.53, it helps to dictate the repair station’s general privileges and limitations along with the certificate and operations specifications according to 145.201. Line maintenance authorized by the operations specifications can be performed in accordance with the air carrier’s program and manual.

Once again, regulatory complexities demand that industry and regulators partner to find the “right” answer so that repair stations can continue to work on behalf of the flying public. To see more about how ARSA works on behalf of the aviation maintenance industry, visit our ARSA Works page.

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