LOC Is NOT Required As Part Of The Part 145 Rewrite

The Aircraft Electronics Association (AEA) informs us the FAA has recommended that Part 145 certificate holders review their Letter of Compliance (LOC) or update it as a means to verify their compliance posture with respect to the new Part 145 rule.

This FAA recommendation is a request and has been left up to the discretion of the certificate holder to determine if it is, in fact, necessary.  If they choose not to update or submit an LOC, it will not affect the accomplishment of the FAA's review of manuals or other documents submitted to comply with the rule requirements.

The following is a letter from the FAA's Diana L. Frohn, Manager, AFS-340 to Ric Peri, AEA’s Vice President, Government and Industry Affairs, clarifying the LOC issue:

"As you know, the part 145 rule will finally be implemented on January 31, 2004. There is a lot of activity going on to transition IPMs to repair station and quality control manuals, to write any new procedures for new provisions offered by the rule, and to develop new processes and procedures to comply with the changing regulation.

Although there are several new requirements with this rule, updating or developing a new letter of compliance or compliance statement is not one of them. That being said, the FAA has recommended that certificate holders review their LOC or update it as a means to verify their compliance posture with respect to the
new rule. This has only been a request and has been left up to the discretion of the certificate holder to determine if it is, in fact, necessary.

If they choose not to update or submit an LOC, it will not affect the accomplishment of the FAA's review of manuals or other documents submitted to comply with the rule requirements."

The Association recommends that repair station’s review their original LOC for applicability, however, the additional administrative burden placed on repair stations by their local FAA office (inspector) is not acceptable.

FMI:  www.aea.net