ARSA requested that the Federal Aviation Administration (FAA) reconsider its position regarding the applicability of “automatically defined” major repairs listed in Title 14 of the Code of Federal Regulations (14 CFR) part 43, Appendix A. To remedy the issue, ARSA’s Dec. 7 letter asks the agency to issue a new legal interpretation to resolve existing confusion and reverse misunderstandings resulting from the FAA’s previous denials of air carrier petitions on the matter.

Specifically, ARSA points out the relationship between the rules for part 121 and part 135 air carriers with continuous airworthiness maintenance programs (CAMP) to the maintenance requirements in part 43. Namely, that the elevated safety standards for those carriers and the rigid structure provided by a CAMP obviate the need for Appendix A, as reflected in the plain language of part 43. The result is a plain direction to follow the CAMP, without considering the Appendix.

In practical terms, ARSA stressed the “over-classification” that results from forcing such carriers to follow the outdated Appendix, which dilutes the intended value of the major repair classification and therefore reduces safety. (That is, “if everything is important, then nothing is important”.)

ARSA looks forward to the FAA Chief Counsel’s response.

~~~ posted 12/20/11 ~~~

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