ARSA Submits Recommendations for FAA’s Proposed AMOC Guidance

ALEXANDRIA, VIRGINIA, August 17, 2010 – The Aeronautical Repair Station Association (ARSA) submitted a number of recommended changes to Federal Aviation Administration (FAA) draft Order 8110.103A, which outlines the agency’s process for issuing or denying Alternative Means of Compliance (AMOC) requests to Airworthiness Directives (ADs).

"As a member of the FAA’s Airworthiness Directive Implementation Aviation Rulemaking Committee, ARSA is committed to working with the FAA to strengthen all aspects of AD compliance, including the AMOC process," said Sarah MacLeod, ARSA executive director.

Time to Play Host

Strange people may be lurking on the corner asking for your vote. Don’t be scared, it’s an election year. Those individuals are just candidates for office spending time courting your vote. Before a major election is a chance to get in touch with voters and travel the district.

This is the best time to introduce yourself, your company, your employees, and your issues.

The most effective way to educate office seekers about your industry is through a facility visit. It presents an opportunity to demonstrate the impact your business has on the community. The personal interaction allows you to explain the repercussions of governmental micromanagement on your company, while giving candidates the opportunity to interact with voters that care.

Keep it Clean!

The most recent Federal Aviation Administration (FAA) extension (H.R. 5900, P.L. 111-216) was atypical. Provisions related to pilot fatigue and training were attached to what is usually a "clean" continuation of funding. Including policy priorities in the extension sets a disturbing precedent.

What is stopping lawmakers from doing it again? You must tell Congress that micromanaging our industry is unacceptable and that the next extension should not contain policy priorities.

Safety Provisions Include Airline Mandates

Unfortunately, it seems that every bill passed by Congress imposes burdens on business. Such is the case with the recently enacted Federal Aviation Administration (FAA) authorization extension (H.R. 5900, P.L. 111-216).

The legislation, signed into law on Aug. 1, continued taxes and funding authorizations for the FAA through Sept. 30. Additionally, it included "safety" provisions due to a highly effective public lobbying campaign waged by the Colgan crash victims’ families.

ARSA Submits Comments to FAA Draft Advisory Circular 120-CMP

Last month, in draft Advisory Circular (AC) 120-CMP, the Federal Aviation Administration (FAA) proposed guidance outlining the regulatory interface between air carriers and their maintenance providers. In its comments to the draft, ARSA recommended a number of substantive changes in the form of a largely rewritten AC.

The association sought to clarify the fact that although an air carrier is responsible for ensuring that the work on its aircraft and other articles is performed in accordance with its program and the applicable sections of its manual, a certificated repair station is responsible for the actual performance of the work when it has been contracted by the carrier to provide those services. Other major points ARSA rectified in its rewrite of the draft include the removal of language regarding the proposition that an air carrier needs to "approve" sub-contractors of a certificated repair station, and eliminating the idea that appropriately certificated and authorized repair stations are not able to complete a logbook entry or airworthiness release.

ARSA Requests FAA to Amend and Reissue Repair Station Hazmat Certification Guidance

On July 9, 2010, ARSA submitted a request to the Federal Aviation Administration (FAA) asking for the agency to correct and reissue Notice 8900.88 ("Letter Certifying HAZMAT Training for Employees of Part 145 Repair Stations" published August 20, 2009).

Regulations require repair stations to certify, in writing, that all "hazmat employees" are properly trained. However, such documentation is only required during a repair station’s initial certification, and when a repair station amends its certificate or changes a rating. ARSA submitted the request because, in contrast to current regulations, Notice 8900.88 required repair stations to retroactively provide written certification of compliance with hazmat training requirements.