On Aug. 1, 21 representatives of the Instructions for Continued Airworthiness Aviation Rulemaking Committee requested the FAA withdraw Draft Advisory Circular 43-18A.

The group’s letter to Associate Administrator for Aviation Safety David Boulter highlighted multiple policy issues in the draft guidance on fabrication by maintenance personnel that fell under FAA tasks given to the ARAC committee considering ICA compliance and enforcement. Those issues include ARC tasks to—

(1) Propose a clear baseline standard defining ICA, recommending performance-based requirements for applicability, content, and availability as necessary to address specific areas of controversy.

(2) Address the requirement that a design approval holder must furnish or make available ICA while a maintenance provided does not.

(3) Propose the role of repair source approval and criticality of parts and repairs.

“Since the ARC recommendations are to address the information in the draft AC, the members represented below ask the FAA to withdraw it from public comment and provide any comments received to the ARC, whose final report will provide direction to the agency as part of its complete review of the issue,” the group said.

In addition to ARSA, the following aviation trade associations and private businesses joined the letter:

Aerospace Industries Association
Aircraft Electronics Association
Aircraft Owners and Pilots Association
Airlines for America
Cargo Airline Association
Chromalloy
Collins Aerospace
First Aviation Services
HAECO Americas
HEICO Corporation
Honeywell Aerospace
International Air Transportation Association
Modification and Replacement Parts Association
National Air Carrier Association
National Air Transportation Association
National Business Aviation Association
Pratt & Whitney
Professional Aviation Maintenance Association
Regional Airline Association
Vertical Aviation International

To read the complete letter, click here.

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