Maintenance professionals tell us that regulatory burden is the biggest, most consistent threat to repair station profitability. Poorly crafted rules, inconsistent enforcement and government policies that don’t align with business realities make compliance certainty problematic.
Reducing burdens by managing regulatory obligations are part of ARSA’s core. One way we accomplish the objective is by catching misguided policy before it becomes a burdensome obligation. A case in point is the “new” parts documentation requirement in change 5 (and now 6) to the US-EU Maintenance Annex Guidance (MAG).
The MAG change required an FAA Form 8130-3 from the production approval holder (PAH) to accompany all new parts installed by U.S. repair stations on articles that may be exported to the EU. Unfortunately, under then-existing FAA rules, the agency (not the manufacturer) had to issue the form, usually through a PAH’s designee.
That created a regulatory Catch-22: In order to serve European customers, many US repair stations would be legally obligated to possess parts documentation that US manufacturers could not issue without FAA designees. The designees were (and still are) in short supply, particularly considering the hundreds of thousands of parts that would need the EASA-required documentation.
Recognizing the threat to aviation maintenance efficiency and profitability, ARSA led a coalition that pressed the FAA and EASA to resolve the problem and has since kept pressure on the agencies to make workable solutions.
How much money, time and frustration this effort spared repair stations is immeasurable. What is measurable is industry participation. In the MAG mess, private businesses stood alongside the association, demonstrated the reality of aviation maintenance concerns and translated on-paper burden into out-of-pocket dollars lost.
While that member support is imperative, there’s no doubt that every certificate holder is just as frustrated by their regulatory burden whether or not they support ARSA or A4A or GAMA or any of the aviation industry’s “alphabet soup groups.”
Christian A. Klein is executive vice president of the Aeronautical Repair Station Association and a managing member of Obadal, Filler, MacLeod & Klein, the law firm that manages ARSA.