How’s Marshall?
July 26, 2021 | Categories:
ARSA News & Updates
On July 8, ARSA Managing Director & General Counsel Marshall S. Filler underwent successful heart surgery. He is recovering at home and is on track to continue his passion as…Read More
ARSA Comments on FAA’s Interpretation of Duty & Rest Provisions
June 17, 2011
On June 14, ARSA submitted comments to the FAA’s “proposed” interpretation of duty and rest provisions for maintenance personnel. The agency’s new position effectively eliminates the language in 14 CFR § 121.377 that requires one day off during any seven consecutive days “or the equivalent thereof within any one calendar month”.
Although characterized as a proposal, the FAA had previously issued the interpretation on May 18, 2010. In fact, the FAA’s stated basis for requesting comments was ARSA’s December 13, 2010 letter calling for withdrawal of the new interpretation.
ARSA’s letter noted that the interpretation conflicted with earlier FAA interpretations, long-standing policy and the plain language of the existing rule. The association noted that the new interpretation was, in effect, rulemaking without public notice and comment required by the Administrative Procedure Act. The FAA responded that it would not withdraw the interpretation, but would instead seek comments before deciding to modify or rescind the May 18 interpretation.
ARSA’s latest comments point out that the FAA’s interpretation impermissibly creates a de facto new duty time regulation under the cover of interpreting an existing rule, and therefore circumvents the rulemaking process. As a result, the association again asks for withdrawal of the May 18 interpretation.
~~~ posted 06/17/11 ~~~
More from ARSA
FAA to Restart Global Leadership Meeting
On July 20, the FAA announced plans to host its 8th Annual Global Leadership Meeting in Washington, D.C. on Sept. 22-23. The event will have both in-person and online attendance…Read MoreLawmakers Explore Aviation Workforce Diversity
July 21, 2021 | Categories:
ARSA News & Updates, FAA
The House Aviation Subcommittee held a hearing July 20 to discuss enhancing diversity in the aviation workforce.
The witnesses were (click a name to download their written testimony):
Rebecca Lutte,…Read More
Unpacking AD Authority
July 20, 2021 | Categories:
ARSA News & Updates, ARSA Works, FAA, Maintenance, Operations, Regulatory, Training
On July 2, ARSA requested clarification of the FAA’s authority to issue an Airworthiness Directive, questioning the April 22 posting of an AD against certain Uninsured United Parachute Technologies, LLC…Read More
