Join ARSA Ask ARSA Pay ARSA

ARSA Comments on Proposed Change to Standard Airworthiness Regulation

In a Notice of Proposed Rulemaking issued on February 15, 2005, the FAA proposed a change to 14 CFR section 21.183 that would limit the issuance of standard airworthiness certificates for “new” aircraft to those situations where (1) the applicant is (a) the type certificate (TC) holder (or its licensee) and (b) holds a production approval (production certificate or approved production inspection system), or (2) the aircraft is an import aircraft type-certificated under section 21.29.

Beyond those applicants described, the FAA would only issue a standard airworthiness certificate for used or surplus military aircraft.

As proposed, the regulation does not directly address standard airworthiness certification for aircraft built from spare or surplus military parts or maintained parts approved for return to service by entities authorized under Part 43.

In its comments to the FAA, the Association took the position that preventing such aircraft from obtaining standard airworthiness certification exceeds the reasonable measures necessary to address the FAA’s expressed concern with oversight of aircraft manufacturing. The Association recommended that the final regulations include specific language allowing standard airworthiness certification for aircraft built from spare, surplus or used parts.

The FAA has also proposed regulations based on federal laws regarding the use of TC or STC data. Without the express permission of the design approval holder, the regulations bar parties from using the TC or STC data under certain circumstances. Under the proposed rule, the FAA requires a “licensing agreement” between the TC holder and the user of the TC data; however, the FAA requires that the STC holder merely provide “written permission” to use the data.

To provide consistency and avoid exalting form over substance, the Association recommended that the FAA adopt the “written permission” standard for both STCs and TCs.



More from ARSA

White House Directs Technical Career Strategy Development

On April 23, the White House issued an executive order supporting efforts to boost the U.S.’s skilled employee pipeline. The order directs government agencies to examine current federal programs and…Read More

Championing the Industry at MRO Americas

On stage and behind the scenes at the Georgia World Congress Center, ARSA leaned into the 2025 MRO Americas convention theme: Shaping the future of aviation maintenance. Brett Levanto, association…Read More

Weston Award Recognizes Crowley’s Commitment to Learning

On March 20, ARSA recognized Jerry Crowley with its Leo Weston Award for Excellence in Government Service. Crowley is a long time FAA aviation safety inspector who was a professional…Read More

Industry Requests More Time to Comment on FAA Order 8130.21J

Update: On April 17, the FAA notified the industry signatories that it had extended the comment deadline to June 6, 2025. On March 28, ARSA joined 11 ally trade associations…Read More

Small Biz Recruitment by Repair Stations

The National Skills Coalition and its partner organization Business Leaders United invite the repair station community to support a study of small and mid-sized business recruiting practices. The study seeks…Read More
ARSA