We've devoted a lot of verbiage to the topic... but as more and more of the details of FAA's current Part 145 proposal emerge, we're wondering if we've underplayed it. Short and sweet, the current version of FAA's part 145 Rule-Making is just plain bad news.
For instance... The rule proposes a 24-month transition period to reissue new certificates, and there is no implementation period. With the current lack of FAA workforce and sequestration initiatives, how will the agency approve and reissue certifications to 4,000 repair stations in a 24-month period? Without the FAA's ability to service an application in a timely manner, businesses will close.
Contrary to the FAA's claim, this proposal does not reflect current repair station aircraft maintenance and business practices, or advances in aircraft technology. It simply does not recognize avionics as a profession. These changes would not modernize the regulations to keep pace with current industry standards and practices. Rather, they would roll modern aviation back to the days of round motors and tube radios from the 1930s.
The AEA has received second-hand information that various user groups, as well as certain FAA inspectors, have incorrectly assumed and promoted that the Part 145 NPRM proposal only applies to repair stations that cater to Part 121 air carriers. This is not true and is disturbing. This proposal applies to all repair stations regardless of its customer bases.
There's more... but we'll let AEA's Peri fill you in, on the subject, better than anyone we know...
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