ARSA Cautions FAA On Proposed 145 Changes | Aero-News Network
Aero-News Network
RSS icon RSS feed
podcast icon MP3 podcast
Subscribe Aero-News e-mail Newsletter Subscribe

Airborne Unlimited -- Recent Daily Episodes

Episode Date

AMA Drone Report

Airborne-Monday

Airborne-Tuesday

Airborne-Wednesday

Airborne-Thursday

Airborne-Friday

Airborne On ANN

ADR 02.13.17

Airborne 02.13.17

Airborne 02.14.17

Airborne 02.15.17

Airborne 02.16.17

Airborne 02.17.17

Airborne-HD On YouTube

ADR 02.13.17

Airborne 02.13.17

Airborne 02.14.17

Airborne 02.15.17

Airborne 02.16.17

Airborne 02.17.17

Wed, Nov 21, 2012

ARSA Cautions FAA On Proposed 145 Changes

Association Is Concerned The Proposed Rules Mean Unnecessary Regulatory Complications

In comments submitted Nov. 19 to the FAA’s rewrite of 14 CFR part 145, the Aeronautical Repair Station Association (ARSA) warned the FAA against further muddying the rules governing aviation maintenance. The association expressed concerns the agency’s proposed rulemaking unnecessarily complicates the regulatory framework.

While the FAA has said it wants to align regulations, current business models, and future safety management system requirements, the Association pointed out several instances where the proposed rule deviates from that purpose:

  • Absence of line maintenance rating—unlike the Canadian and European systems and current business arrangements, the FAA is not contemplating a line maintenance rating. The lack of such a rating is not conducive to business practices, in the past, now or in the future.
  • Permanent housing requirement—contract maintenance with mobility is necessary and certainly part of past, current, and future business models. To demand that a repair station have permanent “housing” belies reality and the ability of a company to ensure its system is under the control of a civil aviation authority.
  • Separating the operations specifications from the certificate—this would essentially allow the agency to unilaterally change operations specifications. The Association vehemently opposes the creation of separate operations specifications for repair stations. The FAA is merely necessitating an unnecessary burden on its own workforce and the industry.
  • Preventing certain “persons” from “controlling” a certificate—the FAA is attempting to prevent “bad actors” from “controlling” the quality of a repair station’s work. Since the FAA does not have or will not expend the resources to keep a list of “bad actors”, its workforce will have no objective criterion on which to investigation ownership of these corporate applicants. Further, ARSA pointed out that there is already a federal law prohibiting similar action (see 49 U.S.C. §§ 44726 and 44711).
  • Preventing the voluntary surrender of a certificate—the agency’s claim that it wants to prevent “bad actors” from obtaining and maintaining a certificate is laudable; its ability to prevent that action in a fair and uniform manner is nonexistent. The increase in safety that may result from the proposed requirements is well outweighed by the agency and industry burden.

The Association is also concerned about the agency’s cost estimates for implementing the proposed changes as they do not accurately reflect the true costs repair stations will bear.

Given these concerns, ARSA believes that the FAA should issue a supplemental notice of proposed rulemaking that incorporates the substantive comments made by the Association and other interested parties that will help the agency more ably meet industry needs and maintain the highest standards of safety.

FMI: ARSA Comments
 

Advertisement

More News

Airborne 02.17.17: Privatization Fight Is ON, X-37B Stays Up, TSA Arrests

Also: HeliTrak PMA, Aviation’s Next Big Fight, New KC Airport, Verifly, CFM Orders, Purdue Aviation, P&W Expansion Some of the aviation industry’s worst fears appea>[...]

Aero-News: Quote of the Day (02.19.17)

Aero-News Quote of the Day "Although our navigation algorithms can get even better, and we need to test them in many other parts of the world, this is a positive sign for Loon&rsqu>[...]

ANN's Daily Aero-Term (02.19.17): Takeoff Hold Lights (THL)

Takeoff Hold Lights (THL) The THL system is composed of in-pavement lighting in a double, longitudinal row of lights aligned either side of the runway centerline. The lights are fo>[...]

ANN's Daily Aero-Linx (02.19.17)

Aero Linx: Modification and Replacement Parts Association (MARPA) MARPA is the non-profit trade association that represents the Parts Manufacturer Approval (PMA) community. A PMA i>[...]

ANN FAQ: What Does The Airborne Partnership Initiative Mean For Your Business

Get Your Breaking News Out To The Industry A partnership between ANN and others in the aviation/aerospace industry offers more exposure, a greatly lessened strain on individual res>[...]

blog comments powered by Disqus



Advertisement

Advertisement

Podcasts

Advertisement

© 2007 - 2017 Web Development & Design by Pauli Systems, LC