Association Is Reviewing Verbiage Added Without Notice Or Comment

The Aeronautical Repair Station Association (ARSA) is less than enthusiastic about the FAA's changes in repair station regulations under 14 CFR part 145 announced Tuesday.

The association issued a statement saying that there are potential flaws in the final rule. “Besides the expected changes that were based upon the notice of proposed rulemaking, the association is reviewing the more innocuous verbiage added to the final rule without notice or comment,” said Sarah MacLeod, ARSA’s executive director. “The agency often underestimates the impact of innocuous changes; for example, adding the words ‘or new’ to the section on transferring a repair station’s assets. The agency does not explain when the new owner wishing to continue repair station operations would have to apply for an amended ‘or new’ certificate.

“ARSA is still vehemently opposed to the adopted proposals to prevent bad actors from owning or controlling a repair station. The elimination of poor quality is the goal of all good business and government; however to over-regulate is a more egregious action. To prevent a repair station from voluntarily surrendering its air agency certificate without providing objective criteria for refusing the submission will disproportionately impact small businesses that legitimately need to cease operations without undue expenditure of time and money. The vast majority of surrenders or cessations of operations is not to avoid certificate action; rather it is a simple business decision based upon economic reality. To be forced to await ‘acceptance’ of a valid surrender unnecessarily burdens the industry and the government. It is analogous to killing a flea with an atomic bomb — the fallout creates more problems than it solves. The agency could have taken a much less onerous approach to achieve the same end.”

FMI: www.arsa.org