March 9, 2016
Docket Management Facility
U.S. Department of Transportation
400 Seventh Street, SW
Nassif Building, Room PL-401
Washington, DC 20590-001
Subject:
Aerospace Industries Association Comments to Federal Aviation
Administration (FAA) Notice of Proposed Rulemaking (NPRM) for 14 CFR
Parts 145 Repair Stations; Proposed Rule
Reference:
Docket No. FAA–2006–26408
The Aerospace Industries Association of America (AIA) represents the nation’s leading
manufacturers and suppliers of civil, military, and business aircraft, helicopters,
Unmanned Aerial Systems, space systems, aircraft engines, missiles, materiel, and related
components, equipment, services, and information technology. Our over 270 member
companies, a significant number of which are smaller businesses and suppliers, employ
more than 600,000 workers in the U.S. alone.
The subject NPRM proposes to amend and/or revise appropriate sections of existing Regulation
14CFR Part 145. The AIA Manufacturing & Maintenance Subcommittee sought and obtained
the supporting member companies’ comments in response to the subject Notice of Proposed
Rulemaking (NPRM) published in the Federal Register on December 1st, 2006 as Docket
Number FAA–2006–26408. The purpose of this letter is to communicate support for the Federal
Aviation Administration (FAA) effort associated with the subject NPRM, and also to convey
general and specific comments which have been coordinated across our constituency and which
are focused upon further improving the language, clarity, and scope of the document.
Summary
Issues of Greatest Concern:
Overall, and as explained in more detail below, our review of the NPRM divulges significant
concern, in order of significance, with the following topics …

Capability List
o The list seems to require a significant of information without explicit safety
benefits. For larger repair stations and those with complex products, producing
and maintaining a non-generic list is an onerous and non-beneficial task. A part
number based list is demanding for larger repair stations and those with complex
Aerospace Industries Association of America, Inc.
1000 Wilson Blvd, Suite 1700, Arlington, VA 22209-3901 (703) 358-1000 www.aia-aerospace.org
products; and we are cognizant to instances where ASIs/PMIs have requested
such a list. Internal systems can be used to document that a repair station has the
capability to do the work.

Work away from station
o Aviation is a global business and our customers, their passengers and their
“cargoes” need and expect global responses from their maintenance providers,
particularly in emergency situations. The international requirements proposed are
not feasible nor are they well defined. They will have a detrimental effect on air
commerce and potentially safety.

Chief Inspector designation
o Particularly for large repair stations and those with complex products, we see no
value added by the creation of such a position. In such situations, it would be
difficult for the FAA to grant a Repairman certificate based on the usual criteria
of being specially qualified with 18 months of experience in all the tasks of such a
repair station with multiple specialized processes and configurations. Many
repair stations run continuous operations, and coverage by one Chief Inspector is
unrealistic. Creation of multiple Chief Inspectors creates a situation where there
is practically no one Chief Inspector and is the status quo. If such is position is
created, the FAA needs to clarify and define the requirements.
Greatest Positive Change:

Quality Control System
o AIA member companies find the Quality System requirements to be well thought
out and in agreement with those of other National Aviation Authorities, as well as
those of Industry specifications such as AS/EN/JISQ 9100/9110.
Issues Which Need to be Addressed:

For existing repair stations in good standing, there must be an acknowledgment and/or
recognition (grandfathering) of prior certifications and licenses (honoring existing
Operations Specifications and capabilities, including limitations) such that repair stations
will not be required to essentially reapply for their ratings. A purely administrative
process is needed.

It is highly recommended, both for the benefit of the FAA and Industry that there be a
phasing in of the new proposed Rules, e.g., Air Agency Certificate issue date issues, etc.
Perhaps the methodology used to transition existing repair stations into the training
program requirements could be utilized as a model

Based on some the requested clarification needed, as explained below, there is a need for
good guidance material to be developed. Further, AIA recommends that much of the
Preamble material be incorporated into the necessary Advisory Circulars and Orders. In
this way, the material remains readily and conveniently available for all.
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Specific comments to the NPRM:
Comment 1:
Section 145.51 Application for Certificate
In general, our member companies agree with the proposed changes. However, we offer the
following for your consideration:
a)
We urge the FAA to clarify that existing repair stations applying for these new ratings
will not be considered as applying for a new certificate as seems to be implied by
§145.57. Otherwise, a grandfather clause is needed such that existing repair stations will
not have to prepare Letters of Compliance as apparently all repair stations will have to
apply for new ratings.
b)
The text of §145.51(a)(4) is inconsistent with the text of §145.215(b) as revised. Suggest
that §145.51(a)(4) reference a capability list in accordance with §145.215(b).
c)
Para. (b) 2nd sentence, change “may” to “will”.
d)
The proposed language in §145.51, (a)(1) should be changed to:
“A letter of compliance detailing how the applicant will comply with the requirements of
this part.”
Rationale:
a)
A letter of compliance takes substantial effort and should not be required if a repair
station is in good standing. This is particularly true for large repair stations with multiple
products.
b)
Consistency across Regulation.
c)
The use of “may” is non-definitive and open to interpretation. Either it will be acceptable
or it will not be acceptable.
d)
The term “this chapter” is generally understood to mean Chapter 1 of CFR Title 14,
which includes parts 1 thru 199. If the FAA intends for this “letter of compliance” to
provide details on how an applicant intends to comply with part 145 then the proposed
rule language should be amended to reflect this intention.
Comment 2:
Section 145.53 Issuance of Certificate
Request clarification regarding the apparent removal of the HazMat training requirement.
Appears to be an oversight due to prior c) and d) being removed. We believe the proposed
Section 145.57 should be amended.
Rationale:
The proposed new §145.53(c) pertains to denial of a certificate. Removal of the Haz-Mat
requirement §145.53(c)(d) is not explained and would be in conflict with the intent of
§145.57(a) which has not changed (refer to current §145.57(a) below).
Current Sec. 145.57
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Amendment to or transfer of certificate.
(a)
The holder of a repair station certificate must apply for a change to its certificate in a
format acceptable to the Administrator. A change to the certificate must include
certification in compliance with Section 145.53(c) or (d), if not previously submitted.
A certificate change is necessary if the certificate holder--.
Comment 3:
Section 145.59 - Ratings
In general, the proposed changes are agreed upon. However, some member companies in the
radio, instrument and accessory rating groups have objected to the loss of their Class Rating.
Please also refer to our comments to 145.215 (Comment 14).
In light of the overall review, we offer the following for your consideration:
a)
Revise 14 CFR Part 91.411 and 91.413 to reflect appropriate repair station ratings needed
to conduct the Altimeter, Transponder tests and inspections.
b)
Suggest a change to the text of subparagraphs §145.59(a)(3), §145.59(b)(3) and
§145.59(c)(3) for clarification, as follows:
“A certificated repair station with a ZZZ rating is not required to obtain a separate
Component rating to maintain articles associated with its rating and capabilities,
including where such articles are received separately and not installed in or on a ZZZ.”
c)
Suggest that §145.59(d) Avionics Rating is renamed:
Electronics.
Avionics, Electrical, and
d)
For Component Ratings noted in §145.59(e), insert “and assemblies” after “individual
component parts.
Rationale:
a)
Currently, Radio and Instrument ratings are referenced with §91.411 and §91.413. These
ratings would be eliminated in the new rating system.
b) & c) are suggested for clarification of the proposed language.
d)
There is no definition of what a part is and this change will make it clear that “individual
component parts” can be assemblies less than the whole component.
Comment 4:
Section 145.63 Specialized Service Ratings
We concur with the proposed language as written. However, we recommend the addition of a
new paragraph §145.63(e) as follows:
“(e)
If specialized service functions are contained within the Repair Station data for
existing ratings, the Repair Station would not require an additional rating to
perform that service.”
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Aerospace Industries Association of America, Inc.
1000 Wilson Blvd, Suite 1700, Arlington, VA 22209-3901 (703) 358-1000 www.aia-aerospace.org
Rationale:
Based on past history, many PMI’s have insisted that all specialized services be listed on an
operations specification regardless if such a process was in use in the repair stations normal
course of business for its “product certifications”. This addition should make it clear that such
is not necessary. We encourage the pertinent language of the Preamble be captured in
guidance material.
Comment 5:
Section 145.101 General
Request the FAA consider rephrasing §145.101 to read:
“A certificated repair station must provide housing, facilities, equipment, tools, test
apparatus, materials, and data that meet the applicable requirements for the issuance of
the certificate and any rating the repair station holds.”
Rationale:
The preamble to the NPRM states that the FAA proposes to revise §145.101 specifically to
require repair stations to provide tools and test apparatus as already required in §145.109. We
support the addition of tools and test apparatus as required items a repair station must have to
meet the applicable requirements for the issuance of its certificate and ratings. However, we
wish to point out that in the amendment to Part 145 of Chapter 1 of title 14, Code of Federal
Regulations on page 70271 of the NPRM, under §145.101 General, there is no mention of test
apparatus.
Our interpretation of the proposed language is that tools are required, but not necessarily on
site (may be contracted). The certificate holder does not have to “own” tools, but must make
them available.
Comment 6:
Section 145.103 Housing and Facilities Requirements
In general, the majority agrees with the proposed changes. However, we offer the following
for your consideration:
a)
Strongly suggest that an exception provision be added to §145.103(a)(1). In the
powerplant area, there are specialty services such as borescope inspection, and certain
NDI operations that are performed at various locations without a need for a repair station
to physically exist.
b)
Request the FAA consider a change to the proposed language of §145.103(b) as follows:
“A certificated repair station with an Aircraft rating must provide suitable permanent
housing to enclose the largest type and model of aircraft listed on its capability list. For
repair stations with an Aircraft rating issued with limitations as described in
§ 145.61(2)(3) the required permanent housing shall be limited to housing appropriate to
those limitations.”
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Rationale:
a)
There are often needs in the industry for on-site work to be accomplished. Transporting
large engines, for example, is expensive and there are risks incurred with potential
shipping damage each instance an engine requires shipment. This makes the ability to do
work on-site extremely attractive.
Such work is carried on at either the flight line or customers facilities, or “in between”.
Logistically, this results in a need that can be filled by mobile teams. Repair stations can
establish teams to be sent to work “away from station”. A&Ps can be mobile and
perform this work on their certificates.
b)
AIA member companies believe the proposed requirement for permanent housing would
place an undue burden on some repair stations holding Aircraft ratings with limitations.
Under the proposed §145.61, the FAA may issue an Aircraft rating with limitations for a
specific maintenance function or process. In many instances these specific functions or
processes are performed on various types of aircraft at remote locations other than the
repair station’s principal base of operations. These types of tasks include processes such
as inspections of engines on-wing, and other special maintenance procedures. To avoid
the undue burden of obtaining permanent housing for repair stations that hold such
limitations to an Aircraft rating, we recommend consideration of the revised text noted in
Comment 6b above.
Comment 7:
Section 145.107 Satellite Repair Stations
a) We suggest that §145.107(a)(4) be re-worded as follows:
“May submit the same repair station and quality system manuals as the repair station that
exercises managerial control over the satellite repair station. The manuals must identify
any specific processes or procedures either unique to the satellite repair station or only
applicable to the repair station with managerial control, in appendices or additional
sections.”
b) It is suggested that the FAA retain current language of §145.107(b), or define “readily
available”. The proposed language precludes having inspection personnel available by
some means other than “readily available”.
Rationale:
a) It is likely that some data in the repair station manual will not apply to the satellite
repair station as the satellite repair station may have unique processes. We believe it
sensible, and compliant, to have a supplement to your Repair Station Manual.
b) The current language is more specific and less open to subjection interpretation.
Comment 8:
Section 145.109 Equipment, Tools, Test Apparatus, Materials, and Data Requirements
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The majority of the AIA member companies support these additions to the current language
contained in §145.109(a). However, we also believe that for purposes of additional clarity and
to further achieve consistency in this section, the FAA should include additional language that
would slightly change the current (existing) language in §145.109(b) and (c).
Our suggestion for §145.109(b):
“A certificated repair station must ensure all test apparatus, inspection equipment, and
tools used to make airworthiness determinations on articles are calibrated to a standard
acceptable to the FAA.”
And our suggestion for §145.109(c):
“The equipment, tools, test apparatus and material must be those recommended by the
manufacturer of the article or must be at least equivalent to those recommended by the
manufacturer and acceptable to the FAA.”
Rationale:
To provide clarity and improve the consistency in the section.
Comment 9:
Section 145.151 Personnel Requirements
The majority of AIA member companies cannot support the §145.151(b) requirements, as
written, for the creation of a chief inspector position in every repair station. The functional
responsibilities, accountability, and authority of this proposed position are not clear defined
and no benefits are stated.
Although we do not believe that this position should be a regulatory requirement, if the
proposed language is adopted as written, we strongly recommend that the FAA add a definition
of "chief inspector" to §145.3, Definition of Terms. The definition should be clear and precise
with regard to the duties of a chief inspector and should state that a repair station may have
more than one person designated as chief inspector based on the physical size, ratings,
capabilities and complexity of its operations.
Rationale:
In most repair stations, these responsibilities are already designated to the Inspection
Supervisor to whom the inspector is assigned. These supervisory personnel are already
required to be certificated under part 65 and are authorized to countermand inspection findings,
as appropriate. The stated duties for such a position are not sufficiently defined in order to
make it a regulatory specific requirement that can be understood by Industry and evaluated
consistently by FAA inspectors in the various regions. Many repair stations run continuous
operations and coverage by one chief inspector is unrealistic. If such is position is created, the
FAA should clarify and define those requirements of a chief inspector.
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A Supervisor is typically assigned for each site/location of a repair station particularly when
different functions are performed, for example, remote incident repair, line maintenance, and
maintenance on life support equipment, etc. In large repair stations with multiple specialties
and products, it is unlikely that one person would have the technical expertise and
organizational awareness of all areas within the repair station as implicit in the preamble
language. At a minimum, different areas of the repair station would need their own chief
inspector with that specialized expertise. Additionally, the proposal does not make allowances
for multiple shift operations.
Many repair stations, especially large ones or ones with complex products, rely on a
combination of disciplines, such as Engineering, Quality, Process Engineering and others
specific to the type of repair station. We feel the addition of “chief inspector” would not add
any value to the process, and may indeed have a negative affect.
The proposed language regarding chief inspector, as drafted, does not outline the safety benefit
as well as additional benefits to the public and thus cannot be supported. Furthermore, the
current regulations would prevent a repair station from creating such a position, as its repair
station manual would define it, if such position was beneficial to its business.
Comment 10:
Section 145.155 Inspection Personnel Requirements
Please refer to our comment to §145.151 (Comment 9). Should the FAA decline to adopt
provisions for designation of a chief inspector, the proposed changes to this section are not
necessary.
If the position of chief inspector is created, additional guidance is necessary and we believe
that provisions should be established for utilization of multiple chief inspector positions. With
this recommendation in mind, all instances of “chief inspector” should be revised to be “chief
inspector(s)”.
Rationale:
See above rational for Comment 9.
Comment 11:
Section 145.161 Records of Management, Supervisory, and Inspection Personnel
Please refer to our comment to §145.151 (Comment 9). Should the FAA decline to adopt
provisions for designation of a chief inspector, the proposed changes to this section are not
necessary.
If the position of chief inspector is created, guidance is necessary and we believe that
paragraph 145.161(a)(2) should be changed to read “chief inspector(s)” for entry into the
roster. With this recommendation in mind, all instances of “chief inspector” should be revised
to be “chief inspector(s)”.
Rationale:
See above rational for Comment 9.
Comment 12:
Section 145.203 Work Performed at another Location
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We urge the FAA to consider retaining the current Regulatory language of §145.203. Our
feeling is that the proposed §145.203(b) is unnecessary and the requirements currently in place
are sufficient. Further, we believe that the requirements of the current §145.203(b), for “work
away from station” procedures to be contained within the Certificate Holders Repair Station
Manual, needs to be included in any new regulation. It is also unclear if the apparent deletion
of these requirements was intentional or an oversight.
Aviation is a global business. The international requirements proposed are not practical nor are
they well defined and they will have a detrimental effect on air commerce and potentially
safety.
Rationale:
Non-US operators with non-US registered aircraft in foreign locations do not follow the FAA
authority, thus, working on such aircraft is not under the jurisdiction of the FAA. For aircraft,
and parts thereof, which are under FAA jurisdiction, the proposed regulation would add
unnecessary and undefined requirements to the repair station and the airline. An AOG
operation runs on a continuous, daily basis and this would negatively impact response times.
The FAA does not have the personnel available to support the “approval requirements”.
It is uncertain that adequate processes and procedures are in place at foreign regulatory
agencies to address the requirements of this proposal. Nor is it clear that the FAA can levy
such requirements on other national authorities. The jurisdictional basis for performing to the
proposed regulation is not supported. Most repair stations that perform offsite work already
have procedures in their manuals and associated operational specifications approved by the
FAA.
Response to Preamble rationale:
The “work away’ proposal would not standardize the practice used to permit repair
stations to perform work outside the country in which they are domiciled because
Geographic Authorization only applies to US registered aircraft whereas Repair Stations
routinely perform work on non-N-registered aircraft at places away from their fixed
location.
Associated extract from Preamble:
FAA policy currently allows an Aircraft-rated repair station located outside the United
States that is also an operator holding an FAA Letter of Authorization per 14 CFR
Section 129.14, to qualify for geographic authorization under its Aircraft rating. This
authorization ensures that U.S.-registered aircraft are maintained in accordance with a
program approved by the FAA.
The proposal would standardize the practice used to permit repair stations to perform
work outside the country in which they are domiciled.
The following is an extract from FAA Order 8300.10, Volume 2, Chapter 163, Page 163-5:
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A. Geographic Authorization. A geographic authorization is an approval provided to an
airframe-rated facility to perform maintenance under contract for a U.S. air carrier or for an
operator of U.S.-registered aircraft under 14 CFR part 129 at a location other than the facility.
The FAA issues a geographic authorization to respond to the maintenance needs of a U.S. air
carrier or part 129 operators at a station where the frequency and scope of that maintenance
does not warrant permanently staffing and equipping the station for its accomplishment.
There is no explanation of why this provision is necessary and why the current regulations that
apply to work away from station should not continue to apply. The proposed regulation fails to
recognize the practical aspects and current needs of the international aviation industry. Most
work away from station is a result of unplanned situations and time is of the essence. Very
expensive assets are often out of service, schedules may be interrupted, passengers (many may
be US taxpayers) are inconvenienced, and our air carriers will incur additional expenses with
more delays.
Although we do not agree with the proposed regulation and do not believe that it should be
enacted, if this regulation is enacted, Industry requests:

It should be made clear that it would be possible to obtain blanket permissions from a
country to allow maintenance to be performed rather than require permission.

We would also request that the FAA incorporate provisions in all its current and future
bilateral that would allow such activities to be automatically acceptable to foreign
countries.

That changes in workscope determined once on-site would only require notification to the
FAA rather than permission.
In closing, AIA and its member companies believe that the implementation of these
requirements would place an undue administrative burden on the affected repair stations, the
FAA, and the countries where work is to be performed. This burden results from the need to
prepare, submit, review, approve and file the necessary documentation required to fulfill these
proposed requirements. We also believe that implementation of these requirements will place
an undue financial burden on aircraft owners/operators due to delays in obtaining timely
maintenance services, caused by the proposed requirements to get authorizations, prepare
submissions and procedural documentation and obtain written FAA approval.
These delays can and are likely to result in a longer than normal loss of use of aircraft or other
equipment thereby creating the financial burden for owners/operators. These delays will be
increased if owners/operators require services outside of the country of domicile of a repair
station after normal business hours, on weekends, during holiday periods or when a repair
station’s certificate holding office is located in a different time zone such as is the case with
certain International Field offices (IFOs). In the case of these IFOs there may be as much as a
fourteen-hour time difference between the IFO and repair stations under their jurisdiction.
Comment 13:
Section 145.211 Quality System
AIA supports this proposed change. We feel strongly that the FAA has taken a noteworthy step
toward harmonization with current EASA Rules and industry standards.
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Rationale:
These Quality System changes bring greater harmonization with the regulatory requirements of
other countries and AS9100/AS9110-based quality systems. Many of these requirements have
already been incorporated into the procedures of repair stations that hold other international
certifications.
The use of internal audits and a rigorous root cause and corrective action process will improve
quality and may produce additional benefits such as lower cost of poor quality costs within a
repair station.
Required management review and action further drives quality and
airworthiness improvement.
We particularly concur with the change to §145.211(a)(1) that makes it clear that the repair
station is responsible for “articles that are airworthy with respect to the work performed”. The
scope of responsibility has often been an issue to both customers and regulators and a source of
contention.
Comment 14:
Section 145.215 Capability List
We strongly object to the proposed changes to require a capability list for “all the articles for
which it is rated to perform maintenance, preventive maintenance, and alterations”. If
capability lists must be required, a more general listing of article nomenclature should be
adequate (such as “GE CF-6 Engine HPT Blades, PW 4060 HPT Vanes, etc.”). Changes to the
general listing will be available for review. Details of articles associated with the general
listing should be available for review, evaluation, or audit immediately upon request. If
adopted, we believe that the maintenance of a “capabilities list” should be permitted to be done
electronically.
Additionally, we offer the following for your consideration:
a) Revise 145.215(b) to remove manufacturer and category, and add “, or series” after
model.
Rationale:
This suggestion aligns with Preamble explanation under Avionics and Components Ratings
(NPRM page 70260) that Avionics and Components ratings present different challenges to the
rating system due to the volume of articles addressed by the rating therefore … the name of the
manufacturer must be included in the list of articles … separated by category. Additionally,
Preamble descriptions for Aircraft, Powerplant, and Propeller capability lists indicate that
repair station must “list the type, make, model, or series….”
For repair stations with extensive product lines or complex products, a capability list for all
articles would provide a heavy burden on both the repair station and the FAA. Arguably, the
only way to meet the criterion of “all” is to list by part number. However, for large repair
stations with complex products, such as those that would carry Aircraft and Powerplant ratings,
the volume of paperwork and expense would be extraordinary. Although in the past the FAA
has recognized that listings by part number should not be a requirement, the “all” criterion
seems to drive in that direction.
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Consider that a Powerplant repair station may repair individual parts of the Powerplant, if such
are sent in for repair. A printed Illustrated Parts Catalog for one transport aircraft sized engine
is three to four inches thick. Obviously, multiple engine models are worked on in the repair
station, and part numbers change constantly. To prepare and keep such a list up to date will be
a serious resource strain on both industry and the FAA. For a major turbine airfoil repair shop,
there are hundreds of possible part numbers, frequently changing.
In closing, AIA and its member companies generally agree with the requirement for repair
stations to prepare descriptive capability lists, however in the proposed language the FAA
requires that a repair station list all the articles it may maintain under its rating. To comply
with a requirement to list all articles a repair station would need to prepare a list by part
number as well as part nomenclature. To prepare a list of all articles by part number would
place an undue burden on aircraft, powerplant, and component rated repair stations since such
lists would initially contain thousands of entries. Maintaining these lists in a current condition
would require daily updating, since manufacturers continually add new parts by part number to
their parts catalogs.
We trust that adequate information has been included to allow the FAA to make a favorable
determination in support of our member company consensus comments and recommendations.
Should you require any additional information, however, please do not hesitate to contact our
offices.
Sincerely,
Ranee Carr
Manager, Civil Aviation Programs
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