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“100-percent Replacement” Makes 1-percent Progress

On Aug. 9, the FAA ended ARSA’s two-year wait for a response to its request to the Regulatory Consistency Communications Board (RCCB) for clarity regarding the right of repair stations to replace 100 percent of an article while performing maintenance. For the most part, this “interim response” merely restated and “acknowledged” the association’s description of the issue.

“FAA regulations do not specify the amount of parts that may be replaced on an article during a single maintenance visit,” the RCCB said in its response, echoing the argument made in ARSA’s initial submission. “Accordingly, the FAA will actively explore developing guidance and whether a legal interpretation is appropriate.”

The status update, which did not claim to be the final word on the issue from the RCCB, did little to enhance consistency in regulatory communications but at least confirmed the FAA’s alignment with industry on the base issue.

To read the complete interim response, click here.

To read the association’s 2017 submission, click here.

To see all of the ways ARSA works as the voice of the aviation maintenance industry, visit the ARSA Works page.



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