Join ARSA Ask ARSA Pay ARSA

ARSA Submits Comments to FAA Draft Advisory Circular 120-CMP

Last month, in draft Advisory Circular (AC) 120-CMP, the Federal Aviation Administration (FAA) proposed guidance outlining the regulatory interface between air carriers and their maintenance providers. In its comments to the draft, ARSA recommended a number of substantive changes in the form of a largely rewritten AC.

The association sought to clarify the fact that although an air carrier is responsible for ensuring that the work on its aircraft and other articles is performed in accordance with its program and the applicable sections of its manual, a certificated repair station is responsible for the actual performance of the work when it has been contracted by the carrier to provide those services. Other major points ARSA rectified in its rewrite of the draft include the removal of language regarding the proposition that an air carrier needs to “approve” sub-contractors of a certificated repair station, and eliminating the idea that appropriately certificated and authorized repair stations are not able to complete a logbook entry or airworthiness release.

In addition, ARSA added language to better define the framework of a proper regulatory relationship between an air carrier and its maintenance provider. Along those lines, the rewritten draft AC includes a series of questions to help an air carrier evaluate its maintenance program and manual to ensure appropriate information is communicated to its maintenance provider, based on the specific work being performed.

ARSA’s comments are available here. The comments include links to two versions of the draft AC, one with all the tracked changes and another with those changes accepted.



More from ARSA

D&A Testing Rule Enters Key Review Stage

ARSA members are encouraged to follow the association’s example and engage the White House Office of Information and Regulatory Affairs (OIRA) as it reviews the FAA’s final rule regarding expanding…Read More

Clarifying (by Dividing) Recordkeeping Guidance

On Nov. 19, ARSA submitted a pair of draft advisory circulars for FAA consideration to replace its proposed update to AC 43-9, Maintenance Records. The documents divide overlapping responsibilities previously…Read More

ARSA Brings Long Experience to New Vertical Aviation Event

Next March, as it prepares for the 2025 ARSA Annual Conference, the association’s team will make a special appearance at the inaugural edition of VERTICON (formerly HELI-EXPO) in Dallas, Texas.…Read More

Workforce, Government Among Top Supply Chain Risks

The U.S. Department of Transportation’s Aerospace Supply Chain Resiliency Task Force delivered its final report on Nov. 4. The task force was created by Congress in 2023 to identify risks…Read More

Quick Question – 2025 Conference Planning

March 18-21, 2025 Arlington, Virginia and Washington, D.C. with Livestream Options for Online Participants Event Information | Registration Coming December 2024 The repair station community’s premier substantive event returns; help ARSA’s…Read More
ARSA