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

Respond to “First of Kind” Survey on Female Aerospace Leadership

ARSA partner Oliver Wyman has invited association members to support its survey updating the “Lift off to Leadership” report published in 2021 as a joint initiative with the International Aerospace…Read More

FAA Confirms SMS Compliance Dates Under U.S./EU Bilateral

On July 8, the FAA published InFO 24007 confirming the compliance dates for U.S. repair stations either applying for or holding EASA approval under the bilateral agreement between the United…Read More

Grantham Gets Cycle’s First ARSA PAC Contribution

Air Force and aviation industry veteran Travis Grantham, a candidate for Arizona’s fifth congressional district, has received the first ARSA Political Action Committee (PAC) contribution of the 2026 election cycle.…Read More

Review FAA’s Methods, Techniques, and Practices

The FAA has engaged industry to help review AC 43.13-1B Acceptable Methods, Techniques, and Practices—Aircraft Inspection and Repair that is applicable to aircraft inspection and repair. The AC primarily supports…Read More

Drafting Regulatory Purpose into Order 8130.21

On June 17, ARSA and the Aircraft Electronics Association (AEA) jointly submitted a rewrite of the FAA’s Draft Order 8130.21J, “Completion of FAA Form 8130-3 under 14 CFR part 21.”…Read More
ARSA