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ARSA, AEA Request FAA Cleanse Guidance of “Letter of Compliance”

On May 29, ARSA and the Aircraft Electronics Association (AEA) asked the FAA to withdraw all references from its guidance material requiring applicants for repair station certificates to submit a “letter of compliance.”

The submission of a “letter of compliance” was specifically rejected – a 2006 notice of proposed rulemaking (NPRM) including such a requirement was withdrawn in 2009 – but its submission is “required” by the preapplication and formal application instructions in the Flight Standards Information Management System (FSIMS).

“Considering (1) the rulemaking procedure specifically declined to impose the requirement for an applicant to submit a letter of compliance and (2) the introduction of the data collection tools of the safety assurance system eliminates the need for such a document, we request the agency withdraw all references to a letter of compliance in its guidance material as soon as possible,” ARSA and AEA said.

To read the full letter from ARSA and AEA to Flight Standards Executive Director John Duncan, click here.



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