ARSA Receives Clarification

On Jan. 5, 2009 ARSA received a reply from the Federal Aviation Administration (FAA) to the Association's request for legal clarification regarding 14 CFR §§ 121.709(b) and 135.443(b). Specifically, ARSA questioned whether a certificated part 145 repair station may issue an airworthiness release or log entry approving the work it performs on an aircraft for return to service on behalf of a certificate holder operating under part 121 or 135.

In its response, the FAA stated that a repair station, as a company, qualifies as a "person" and could prepare, or "cause to be prepared" an airworthiness release or an appropriate entry in the aircraft log. Such a release or aircraft log entry is limited to the work the repair station is rated to perform and actually performs on an aircraft for certificate holders operating under parts 121,125, and 135, as well as for foreign carriers or foreign carriers
operating U.S.-registered aircraft in common carriage under part 129.

However, the FAA continued, in preparing the airworthiness release or aircraft log entry, the part 145 repair station must comply with the procedures set forth in the part 121 or 135 certificate holder's manual for preparing the entry.

The FAA's response may be found here.

ARSA’s letter to the FAA is available here.