The FAA has eliminated growing confusion over interpretations of its rules that led some agency offices to conclude that component repair shops were required to have hangars large enough to house the aircraft they support.
The confusion started with a 2014 request from a component repair specialist with a limited airframe rating. The company’s operations specifications (ops-specs) include Boeing 747s, indicating it can service 747 airframe parts. The shop asked the FAA if a section of the agency’s Part 145 repair station rule that stipulates component shops with limited airframe ratings “must provide suitable permanent housing to enclose the largest type and model aircraft listed” on their ops-specs meant that it needed to have a hangar large enough for a 747. The FAA’s Office of the Chief Counsel said “yes.”
That interpretation led some FAA regional offices to warn airframe component shops that they either needed to secure exemptions or start building hangars.
The Aeronautical Repair Station Association (ARSA) soon jumped in, writing the FAA in December 2015 and demanding that the agency come to its senses.
“For years, the agency has recognized the difference between component-level maintenance and work performed on an aircraft,” the ARSA reasoned. “Surely the chief counsel’s office cannot be contemplating certification action against current holders of airframe component ratings that do not have hangars, which is the only method by which the agency could reconcile the [interpretation] with reality.”
The FAA agreed, and in July issued changes to its rules. The amendments clarify that housing requirements must match both a repair station’s ratings and its limitations.
“For example, a repair station with a limited powerplant rating may list a certain make and model of powerplant under its limited rating, but intend to maintain or repair only specified component parts of the engine, such as blade or vane repairs,” the FAA explained in the rule. “The repair station would only need to provide housing, equipment, materials and personnel to perform maintenance on blades and vanes if it does not perform work on the entire engine.”
The FAA also restored a general “limited rating” category to cover parts such as interior components not listed in the 12 existing ratings categories. The agency removed a similar category in a 2001 rules revamp.