ARSA Suggests Changes to FAA Form 8310-3
January 24, 2012
The FAA recently solicited comments on Form 8310-3, Application for Repair Station Certificate and/or Rating, as it seeks renewed approval from the Office of Management and Budget (OMB) to collect that information. ARSA submitted comments noting that the current form does not accurately reflect regulatory requirements applicable to the sale or transfer of repair station assets.
As provided in Title 14 of the Code of Federal Regulations (14 CFR) § 145.57(b): “if the holder of a repair station certificate sells or transfers its assets, the new owner must apply for an amended certificate in accordance with § 145.51.” However, verbiage in Form 8310-3 suggests that any change in ownershiprequires an amended certificate. This discrepancy between the rule and the Form creates confusion when an incorporated repair station merely transfers stock, not assets. Section 145.57(b) does not apply to such transactions.
ARSA therefore suggested the Form be changed to state “Sale or Transfer of Assets” instead of “Change in Ownership”. The Association also recommended that the FAA clarify differences between a stock and asset transfer, and provide a statement regarding the inapplicability of § 145.57(b) to company stock transactions, in the pertinent section of Order 8900.1.
More from ARSA
On April 26, the FAA published to the Federal Register its new rule expanding Safety Management Systems (SMS) requirements to all operators of commuter and on-demand service and commercial air…
Read More
April 23, 2024 | Categories:
ARSA News & Updates
ARSA has been approached by a government contractor preparing a Commercialization Readiness Assessment Report for a product developed through the Small Business Innovation Research (SBIR) Program. The product being assessed…
Read More
April 16, 2024 | Categories:
Act Now,
ARSA News & Updates
March 12-15, 2024
Sponsors | Information
Arlington, Virginia and Washington, D.C. with Livestream Options for Conference Ambassadors
Conference Highlight – In the Fire with AVS-1
On March 14, ARSA Executive Director…
Read More
On April 8, ARSA and four other industry trade associations commented on an FAA notice of proposed rulemaking to consolidate the many falsification sections across 14 CFR into a single…
Read More
April 09, 2024 | Categories:
ARSA News & Updates,
ARSA Works,
Aviation Policy,
Drug and Alcohol,
EASA,
FAA,
Legislative,
Operations,
Press Releases,
Regulatory,
Rulemaking
On April 5, a group of seven aviation trade associations submitted joint comments to the FAA’s notice of proposed rulemaking to extend drug and alcohol testing requirements to repair station…
Read More