145 Group Gets Working
On Dec. 11-12, the working group tasked by the FAA through the Aviation Rulemaking Advisory Committee (ARAC) to review and reconcile FAA repair station regulations and guidance convened for its first meeting.
ARSA Executive Director Sarah MacLeod co-chaired the session alongside Ric Peri, vice president of government and industry affairs for the Aircraft Electronics Association. The association was a staunch proponent of ARAC’s December 2017 adoption of the tasking and has spent most of 2018 awaiting the agency’s selection of working group participants. With the group, MacLeod and Peri have set a proactive timeline for producing them.
As reported to the ARAC during its full meeting on Dec. 13, the working group will comprehensively review all internal and external guidance material related to 14 CFR part 145. Based on the study, the body will recommend improvements to ensure all guidance documents:
(1) Align with the regulations as well as U.S. law and applicable executive orders.
(2) Are numbered to establish a relationship between the guidance and the applicable regulation.
(3) Consistently communicate compliance expectations to agency personnel as well as the public.
(4) Consider repair station oversight in the context of the size and work of each certificate holder.
The working group will deliver its preliminary report no later than Friday, Dec.11, 2020 – 24 months after its first meeting – and its final report no more than 12 months after that report has been accepted by the FAA. The group will have monthly conference calls/online meetings and meet face-to-face twice yearly.
In addition to ARSA and AEA, the following organizations represent the directly impacted industry segments on the working group:
|Repair stations in general||AEA, ARSA & GAMA|
|Part 121 airline WITH a part 145||Delta TechOps|
|Part 121 and 135 (10 and over) airline W/O a part 145||United & Kalitta|
|Corporate operator using part 65 mechanics/ a limited rated repair station to perform work only on its own aircraft||Air Methods|
|Foreign repair station from a non-bilateral country||Boeing|
|Large, multi-dimensional independent repair station for|
|(1) A “large” aircraft||ATS|
|(2) A “business—small turbine powered” aircraft||GAMA|
|Large, multi-dimensional captive repair station||Gulfstream|
|Small focused repair station(s)|
|–Avionics shop||Green Mountain|
|–Completion center for rotorcraft||Sikorsky & Wysong|
|—-Independent—works on a multitude of manufacturers||Triumph|
|—-Captive—only works on its own articles (PMA manufacturer for example)||Collins Aerospace|
|–Propeller—captive and/or independent||GE (Dowty)|
|Unions (airline mechanics)||AMFA|
Anyone not participating in the working group should rest assured ARSA will represent the interests of all repair stations in this endeavor. The association is determined to ensure its members and other part 145 maintenance providers understand the difference between minimum standards in aviation safety regulations and best practices so appropriate business decisions can be made.
Stay tuned as the group continues working.
Previous updates on ARAC's 145 task...
January 18, 2018
During its December 2017 meeting, the Aviation Rulemaking Advisory Committee (ARAC), of which ARSA has been a member since its founding, accepted a task to review and reconcile the regulations and guidance respecting part 145 repair stations.
The Federal Register notice posted on Jan. 18 outlines the accepted task and requests interested parties to submit information for inclusion in the working group. If an individual is not accepted onto the working group, rest assured that ARSA will represent the interests of all repair stations in ensuring the agency’s guidance is fully aligned with the plain language of the regulation. The association is determined to ensure its members and other part 145 maintenance providers understand the difference between minimum standards in aviation safety regulations and best practices so appropriate business decisions can be made.
To review the notice, see the information below. Stay tuned to ARSA for more information…
Notice Title: Aviation Rulemaking Advisory Committee-New Task (Part 145 Working Group)
Document #: 2018-00819
Introduction: The FAA has assigned the Aviation Rulemaking Advisory Committee (ARAC) a new task to provide recommendations regarding the agency’s guidance on the certification and oversight of all part 145 repair stations. This notice informs the public of the new ARAC activity and solicits membership for the new Part 145 Working Group.
To see all the ways ARSA works on behalf of the aviation community, visit the ARSA Works page.