FAA solicits participation for new § 65.101 Repairman Certificate Portability Working Group

The Federal Aviation Administration has published a notice of a new task assignment for the Aviation Rulemaking Advisory Committee, and solicitation of participation for the Repairman Certificate Portability Working Group will provide advice and recommendations to ARAC on the most effective ways to allow a repairman certificate issued under § 65.101 to be more portable from one employing certificate holder to another. The working group will review all relevant materials to assist in achieving the objective.

The working group is tasked:

(1) To perform a comprehensive review of internal and external guidance material and regulations that pertain to certificating a repairmen under § 65.101. This review will include reviewing –
(a) The pertinent sections of the Part 65 preamble(s) to gain a thorough understanding of the intent of the limitation of a repairman working under an entity. 
(b) FAA Guidance as necessary: i.e. FAA Orders, Notices, Advisory Circulars, Job Aids and Data Collection Tools. 
(c) Processes and requirements by which the FAA processes the application and issues the Repairman Certificate. 

(2) Develop recommendations:
(a) That could increase the portability of repairman certification issued under § 65.101 across employing certificate holders.
(b) That maintain, or improve, the current level of safety with regard to repairman training and certification under § 65.101.
(c) That will clearly identify the need and the benefits of a portable repairman certificate while taking into consideration the costs and ramifications, if any.

(3) Provide qualitative and quantitative cost and benefits analysis and source documents for all recommendations that result in a change to either the CFR or FAA guidance.

(4) Develop a preliminary and final report containing recommendations based on the analysis and recommendations. The reports should document both majority and dissenting positions on the recommendations and the rationale for each position. Disagreements should be documented, including the reason and rationale for each position.

(5) The working group may be reinstated to assist the ARAC in responding to the FAA's questions or concerns after the recommendation report has been submitted.

The working group will be comprised of technical and regulatory experts having an interest in the assigned task. A working group member need not be a member representative of ARAC. The FAA would like a wide range of stakeholders to ensure all aspects of the tasks are considered in development of the recommendations.

Candidates are required to submit, in full, the following materials to be considered for membership. Failure to submit the required information may disqualify a candidate from the review process.

  1. A résumé or curriculum vitae.
  2. A statement describing the candidate’s interest in the task and the expertise the candidate would bring to the working group.

Nominations must be submitted electronically (by email) to Bryan Davis at bryan.davis@faa.gov. The subject line should state “§ 65.101 Repairman Certificate Portability Working Group Nomination.” The FAA must receive all requests by April 19, 2021, at 5 p.m. EDT. The ARAC and the FAA will review the requests and advise you whether or not your request is approved.

The Aircraft Electronics Association encourages individuals and businesses to participate in this vital effort. Reasonable portability of repairman certificates is a huge benefit to the avionics industry, while significantly changing the criteria for the issuance of repairman certificates to support portability could be a significant deterrent. It is important for the industry to be appropriately represented.

The AEA encourages the membership to review the FAA solicitation for the Repairman Certificate Portability Working Group.

Contact Ric Peri, AEA vice president of government and industry affairs, by email at ricp@aea.net or by phone at 202-589-1144.