Let Your Voice be Heard!
We in the aviation maintenance community have the opportunity to let our voices be heard on a regular basis as part of the FAA’s rulemaking process. Now is one of those times. A Notice of Proposed Rule Making (NPRM) was published in the Federal Register on May 21, 2012 regarding changes to 14 CFR Parts 43, 91 and 145 rules affecting repair stations . The original deadline for comments was August 20, 2012, but because of the efforts of several industry associations, the deadline has been extended 90 days to November 19.
If you work at a repair station, this is your opportunity to comment on the proposed changes. The FAA takes comments into consideration before publication of the final rule. Don’t think commenting matters? Think again! There have been numerous instances where the final rule published had significant changes based on comments received from the aviation community. In one instance, in the case of the proposed Part 66 rule over a decade ago (affecting certification of aircraft mechanics), the FAA received so many comments that it decided to rescind the proposed rule.
I had a chance to chat with Ric Peri at EAA AirVenture in late July. Ric is the vice president of government & industry affairs for the Aircraft Electronics Association (AEA). AEA believes that the proposal makes wholesale changes to the avionics industry with damaging and costly repercussion. It shares that the FAA proposes to remove Radio and Instrument Ratings and allow airframe rated repair station to work on radio and instrument components without qualifications or ratings. In addition, the proposal would eliminate many of the currently utilized opportunities for mobile maintenance operations.
Under this proposal, the system of ratings would be reduced from eight ratings to five ratings. The ratings definitions would be revised to clearly indicate the type of work that a repair station is authorized to perform.
This proposal would not require a capability list, but would revise the capability list recording requirements for those repair stations that choose to use one. This is a potentially marked change for repair stations with class ratings that do not currently have a capability list of the items they maintain.
A certificated repair station with an Airframe rating is not required to obtain a separate Component rating to maintain articles associated with its rating and capabilities.
Each certificated repair station must provide and maintain suitable permanent housing for the facilities, equipment, materials, and personnel consistent with its ratings.
To help the aviation industry better understand the proposed changes, AEA has posted a comparative analysis of the NPRM on its website at www.aea.net/governmentaffairs/pdf/FAAProposed145Comparison.pdf.
The Aeronautical Repair Station Association (ARSA) also shared some thoughts about the proposed rule. ARSA says that by looking at the list of proposed changes in the preamble of the NPRM, “the proposed changes will create a new regulatory regime, the consequences of which should raise serious concern in an industry as heavily regulated as aviation.”
ARSA says its initial analysis indicates that the agency is complicating a rule at a time that simplification would enhance the FAA’s compliance and enforcement program.
To aid in comments, ARSA has posted a side by side comparison of the old and new rules (www.arsa.org/files2/ARSA-145NPRMAnalysis-20120607.pdf) as well as a redlined version of the regulatory change (www.arsa.org/files2/ARSA-145NPRMRedline-20120607.pdf) on its website.
The NPRM can be read at www.gpo.gov/fdsys/pkg/FR-2012-05-21/pdf/2012-11984.pdf.
Take the time to read the NPRM. Use the industry resources available like those from AEA and ARSA to help you understand the rule. Use this knowledge to help you understand how this proposed rule will affect you and your organization. Then take the time to comment on the proposed rule.
It is time to get involved and let your voice be heard!