FAA Repair Station Rule Revamp Ignores Key Issues

A version of this article appears in the September 8 issue of Aviation Week & Space Technology. The current ratings system for U.S.-approved repair stations, introduced in 1962 and in FAA’s crosshairs since the late 1980s, has received yet another lifeline.

A version of this article appears in the September 8 issue of Aviation Week & Space Technology.

The current ratings system for U.S.-approved repair stations, introduced in 1962 and in FAA’s crosshairs since the late 1980s, has received yet another lifeline.

On Aug. 12, the agency pushed through its second notable tweak to its Part 145 repair station regulations since 2000, but like a 2001 final rule and a failed attempt to change the classifications, which was abandoned in 2009, its iconic—and most would say archaic—ratings system again escaped unscathed, despite the FAA’s best effort.

“Many commenters argued that the proposed ratings system would not be satisfactory for current and future repair stations,” the agency noted in its final rule. “Although commenters recognized that the system of ratings is outdated, there was general dissatisfaction with the proposed new system of ratings and the transition process.”

The new rule’s substantive changes include a new amendment on records falsification and a provision that allows FAA to consider an applicant’s enforcement history when evaluating a new certificate application. The latter addresses a National Transportation Safety Board recommendation.

But the more notable aspects of the new rule are what FAA left out.

The revamped ratings system was the most controversial proposed change. While practically everyone agrees that the system needs updating—FAA has had an industry-led advisory committee’s blueprint on what new ratings should look like since 2002—industry and the agency have not been able to reach common ground. 

Among the 50-year-old system’s signs of age: It differentiates between “radios” and “instruments,” meaning today’s repair stations must hold both ratings to work on a modern flight- management system. The system does include “composite” classes in its airframe ratings, but back in the early 1960s this referred to wood, fabric or dope—not materials combinations like carbon fiber and epoxy used in today’s designs.

The FAA’s proposal attempted to streamline and broaden the classifications, reducing the number of ratings from eight to five and redefining them. One example: replacing the radio, instrument, and accessory ratings with a single component rating. But industry objected, arguing that the existing system is better than what the agency proposed.

“The proposed deletion of the radio and instrument ratings is not consistent with modern maintenance practices,” the Aircraft Electronics Association argued in its comments on the May 2012 notice of proposed rulemaking (NPRM). “While there is a need to address technologies that don’t clearly fit within specific radio or instrument categories but rather are hybrid systems, this can be accomplished by better definitions and maintenance scopes rather than elimination of the ratings.” 

The agency also pulled a proposed requirement that would have required repair stations to have tooling and equipment needed to earn certifications or rating approvals. Repair stations argued that the current requirement of having contracts in place to obtain the tools is sufficient, and the FAA agreed.

“By having a contract acceptable to the FAA, an applicant would be able to demonstrate that the required equipment could be made available when needed,” the agency reasoned. “In some cases this ‘contract’ may actually be a letter of intent from an air carrier  for which the repair station intends to perform work, or something similar from an equipment supplier.”

The FAA also dropped proposals that would have required both supervisors and inspection personnel to speak English, and that supervisors be present to oversee work being done by their staffs. 

In the NPRM, the agency reasoned that adding the fluency requirement would serve as a cross-check to confirm that key repair station personnel meet the current requirements to read and understand English. But several foreign repair station certificate-holders disagreed, arguing that while some employees—like line mechanics—need to speak English to perform their jobs, many who work in back shops do not, and requiring them to learn it would not improve safety.

Several in the industry argued that having a supervisor directly overseeing all work “would have required industry to hire numerous additional supervisory personnel at great cost to cover eventualities such as night work, emergency field maintenance, line maintenance, and work conducted at additional fixed locations,” FAA said. “[A] clear unintended consequence of this proposed language would have been a substantial increase in the cost of maintenance services to compensate additional supervisory positions, as well as a corresponding decrease in availability of maintenance services due to limited availability of supervisory personnel.” 

The Aeronautical Repair Station Association (ARSA) suggested the 2012 draft rule should, like the 2006 proposal dropped in 2009, be scrapped in favor of a new version that factors in the latest industry feedback. While the agency stopped short of scrapping the rule entirely, the number of key issues—such as new ratings—left out of this round suggests that the FAA will take another crack at the process. 

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