Repair Stations as Essential Services
To keep tabs on all of ARSA’s work related to the current pandemic, visit arsa.org/anti-viral-measures.
As states and localities around the United States respond to the current pandemic, many have implemented – or are considering implementing – quarantine orders and mandatory business closures. While these strategies are vital to containing the virus, orders must be tailored to ensure essential services continue.
Members and association contacts facing stop work or quarantine requirements imposed by state governments should utilize the following information in coordinating response to seek exemption under essential service requirements. When possible, engage with fellow aviation businesses or interest groups such as chambers of commerce and always review state law and business regulations.
Federal regulations require U.S.-registered aircraft and related components be maintained by FAA-approved “persons” (14 CFR § 43.3.); specifically, mechanics and repairmen certificated under 14 CFR part 65 and people working under their supervision, repair stations certificated under 14 CFR part 145, air carriers certificated under 14 CFR parts 121 and 135 and, in certain limited circumstances, pilots.
Repair stations provide the majority of maintenance, preventive maintenance, and alteration services in the United States for aircraft, airframes, aircraft engines, propellers, appliances, and component parts.
Forcing repair stations to cease operations will disrupt and prevent essential government functions (including emergency and police services and U.S. military aviation); commercial air carrier passenger and cargo operations; and general and business aviation operations, including humanitarian relief and essential health services.
In light of the foregoing, federally mandated FAA-certificated repair stations are essential businesses that must be excluded from emergency business closures.
Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency’s “Guidance on the Essential Critical infrastructure Workforce” (includes “[e]mployees who repair and maintain vehicles, aircraft, rail equipment, marine vessels, and the equipment and infrastructure that enables operations that encompass movement of cargo and passengers” and “[w]orkers who support the maintenance and operation of cargo by air transportation, including flight crews, maintenance, airport operations, and other on- and off- airport facilities workers.”)