Free Trade in the Market for Aviation Maintenance Services

ARSA Position

Repair stations are an essential element of aviation, regardless of location. Some in Congress subscribe to the belief that maintenance done outside our borders is unsafe. However, without foreign repair stations, international travel would be impossible. ARSA ensures that lawmakers and regulators realize that we are just one part of a global aviation community, and need to treat all repair stations equally.

Discussion

The U.S. aviation maintenance industry is highly-regarded worldwide. As a result, the U.S. enjoys a favorable trade balance in the market for these services. Currently, there are 708 FAA-certificated repair stations outside the U.S. At the same time, there are approximately 1,200 U.S. repair stations certificated by the European Aviation Safety Agency (EASA), and numerous other NAA-certificated repair stations inside our borders, a fact that has benefited U.S. repair stations, their employees, and the towns and states in which these maintenance facilities are located.

The House FAA reauthorization bill (H.R. 2881) contains provisions aimed at foreign repair stations that threaten to upset the international market for aviation services.
The problematic sections of H.R. 2881 are:

• Section 304 – Requiring the FAA Flight Standards Service inspect all foreign repair stations twice a year, including those in bilateral partner countries.
• Section 312 – Dramatically restricting the use of qualified non-certificated facilities such as specialized service vendors and original equipment manufacturers.
• Section 304 – Requiring anti-drug and alcohol testing of foreign repair station personnel under U.S. rules. These requirements create serious extra-territorial and privacy issues in foreign countries beyond this nation’s jurisdiction.

If these proposals are adopted, the FAA Flight Standards Service has stated that it will not perform EASA renewal inspections in the U.S. That means additional costs to U.S. repair stations for EASA to perform annual renewal inspections.

Additionally, the U.S. maintenance industry will face retaliation from our bilateral partners. In a letter dated Oct. 22, 2007, Mark Wilson, Chairman of the EASA Advisory Board stated: “Adoption of such legislative text would bring to an end any possibility to finalize a balanced, reciprocal EU-US Bilateral Aviation Safety Agreement (BASA) and association Maintenance Implementing Procedures (MIPs)…”

Congress needs to hear how these proposals directly impact your business and how important foreign customers are to your bottom line.