Comments Due Nov. 19 on FAA's Significant and Potentially Damaging Part 145 Rewrite

SUMMARY (from FAA NPRM as printed from the Federal Register): 
This action would amend the regulations for repair stations by revising the system of ratings, the repair station certification requirements and the regulations on repair stations providing maintenance for air carriers. This action is necessary because many portions of the existing repair station regulations do not reflect current repair station aircraft maintenance and business practices, or advances in aircraft technology. These changes would modernize the regulations to keep pace with current industry standards and practices. Click here to read the Repair Station NPRM.

AEA COMMENTARY:
This proposal makes wholesale changes to the avionics industry with damaging and costly repercussions. The Federal Aviation Administration proposes to remove radio and instrument ratings and allow airframe-rated repair stations to work on radio and instrument components without qualifications or ratings.

This proposal does not recognize avionics as a profession. Contrary to the FAA's claim (in its summary above), this proposal does not reflect current repair station aircraft maintenance and business practices, or advances in aircraft technology. These changes would not modernize the regulations to keep pace with current industry standards and practices.

The Aircraft Electronics Association's major concerns with this proposed rule are as follows:

• Cost to Comply: The cost to comply and transition to this new rule will impose a huge monetary investment on repair stations. This proposed rule requires revision and approval of all three repair station manuals, as well as developing and managing a list of capabilities. The FAA is not accounting for the man-hours needed for a repair station to revise its manuals and create capability lists.
• Lack of Time to Transition: The rule proposes a 24-month implementation period to reissue new certificates for all repair stations. With the current lack of FAA workforce and sequestration initiatives, how will the agency provide the resources needed to approve and reissue certifications to 4,000 repair stations in a 24-month period? If a repair station certificate is not reissued within the 24-month time period, the previous certificate is no longer valid and businesses will not be able to operate as a Part 145 repair station.
• Avionics Profession Loses Its Identity: Under this proposal, the system of ratings would be reduced from eight ratings to five ratings. The ratings definitions would be revised to indicate the type of work that a repair station is authorized to perform. But, it also removes radio and instrument ratings and allows airframe-rated repair stations to repair and alter radios and instruments without any specific ratings or obvious qualifications.
• Costly & Time-Consuming Capabilities List: This proposal does not specifically require a capability list, but does require a listing of capabilities for all repair stations. 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. Also, capabilities list, or list of capabilities, will be subject to a line-item review every 24 months. This requirement will force repair stations to hire additional staff to maintain these lists.
• No Mobility: Each certificated repair station must provide and maintain suitable permanent housing for the facilities, equipment, materials and personnel consistent with its ratings. It appears this provision would prohibit mobile operations. Currently, the regulations allow for a permanent "fixed location" but not permanent housing. In addition, the proposal would not allow "space available" contracts with landlords.

HOW TO COMMENT:

1. Go to: www.regulations.gov.
2. On the home page, in the SEARCH box, type:  faa-2006-26408-0211.
3. The FAA NPRM will appear. Click on COMMENT NOW.
4. Complete the comment form. Note: Step 3 of the form gives you the ability to attach a comment letter (document) on your repair station/company letterhead, if you prefer not to type your comments in the box provided.
5. Hit Submit.
6. That's it -- it's simple! Please take the time to do it, as it's critical to your business!

For more information, including the AEA's comparative analysis, visit www.aea.net/part145.

AEA members are urged to comment no later than Nov. 19, 2012.

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