On Nov. 17, ARSA submitted a document to the White House identifying an important opportunity for the Department of Defense (DoD) to enhance efficiency and reduce costs related to maintaining its fleet of commercial derivative aircraft (CDA). The association’s white paper was sent to White House Director of Policy and Interagency Coordination Carlos Diaz-Rosillo as a follow-up to discussions with maintenance industry leaders during the 2017 ARSA Strategic Leadership Conference executive branch briefing.
ARSA’s position is the FAA, through its civil aviation oversight, already determines whether Parts Manufacturer Approval (PMA) parts and Designated Engineering Representative (DER) repairs are compliant and fit for use on the aircraft from which CDA are derived. Forcing previously-approved parts and repairs to go through the cumbersome SAR process costs government resources and wastes taxpayers’ money while ignoring the civil aviation sector’s outstanding safety and reliability record. Since SARs are rarely granted, DoD is not benefiting from the cost savings associated with PMA parts and DER repairs.
“By law, DoD has broad authority to make airworthiness determinations in any manner it chooses,” the submission said, citing Title 10 of the U.S. Code and a template from the Defense Logistics Agency. “Unfortunately, this department has translated this authority into an extraordinarily burdensome series of policies and instructions that require aircraft parts manufacturers and maintenance contractors – including those with Commercial Off-the-Shelf (COTS) solutions already approved for use in civil aviation by the FAA – to go through a redundant, expensive, slow and burdensome SAR process to gain DoD approval.”
ARSA recommended the government revise its policies to trust its own aviation safety agency, the FAA. The association urged the White House to work with DoD to recognize “any approval issued by the FAA for a product, material, part, component, process or appliance as eligible for use on a CDA.”
To read the full ARSA submission, click here.
For more information regarding ARSA’s support for its members with military business, contact Executive Vice President Christian A. Klein (christian.klein@arsa.org).
