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Speak Now! Only Days Remain to File 145 Comments

Only days remain for repair stations to file comments with the FAA on the impact of the agency’s rewrite of 14 CFR part 145, the federal regulations governing repair stations. The Association urges all certificated repair stations to let the FAA know how the changes will impact operations before the Nov. 19 deadline.

ARSA is finalizing its comments to ensure that the Association’s response comprehensively addresses the concerns and interests of repair stations. Based on its initial analysis, ARSA worries that the agency may be needlessly complicating the rule at a time when simplification would enhance compliance and the FAA’s enforcement posture.  The Association also shares in the industry’s concerns the the agency’s cost determination of the new rule may significantly underestimate the burden to repair stations.

The FAA proposes retaining the current regulations (with revisions to accommodate the transition), appended with the proposed regulations, for 24 months after the rule’s effective date. New applicants, or those that apply for a certificate change after the effective date, would have to comply with the new rule; repair stations already certificated would have 24 months to show compliance.

ARSA has prepared a side-by-side comparison and a red-lined version of the current vs. proposed rule. Additionally, the NPRM would—

  • Reduce the ratings system from eight to five by combining “radio”, “instrument” and “accessory” ratings into one “component” rating.
  • Add a question to the repair station application inquiring whether the applicant held a repair station certificate that had been or is currently in the process of being revoked.
  • Require that applicants have equipment in place and available for inspection during the certification process. (Currently, the repair station can meet the equipment requirement by having a contract ensuring the equipment is available when the relevant work is performed.)
  • Require that the FAA “accept” a certificate for surrender (otherwise, the certificate would remain effective for administrative and enforcement purposes, even if the certificate holder ceased operations).
  • Define capability list requirements, institute new processes for adding articles to the capability list, and require repair stations with a capability list to review it at least every two years.
  • Revise the definition of line maintenance (according to the NPRM’s preamble, the new definition would reinforce that line maintenance is performed for air carriers, is generally performed at the ramp, parking area, or gate and typically does not exceed 24 continuous hours per aircraft).
  • Add a section prohibiting fraudulent or intentionally false entries in repair station records or the fraudulent reproduction or alteration of records or reports.
  • Add sections to define operations specifications, provide procedures for initiating changes to operations specifications, and clarify that repair station operations specifications are not part of the repair station certificate.
  • Require both “suitable and permanent” housing and provide an exception to facilitate repair stations with a limitation to perform line maintenance for air carriers.
  • Allow a repair station to use multiple fixed locations if appropriate criteria are met.
  • Allow a satellite repair station to hold a rating not held by the certificated repair station with managerial control.
  • Require a satellite repair station to submit the same repair station manuals as the repair station with managerial control and identify any processes or procedures unique to the satellite.
  • Require supervisory personnel, inspection personnel, and personnel authorized to approve an article for return to service to understand, read, write, and speak English.
  • Require that the repair station roster include the types of maintenance performed in past positions for each employee listed.
  • Require human factors and part 145 regulatory training.

Click here to comment on the proposed rulemaking.



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