NATA PROVIDES POINTED COMMENTS WHY IMPLEMENTATION OF PROPOSED P145 WOULD BE DELETERIOUS TO AVIATION SAFETY

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ARTICLE: NATA Comments on Repair Stations NPRM

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The National Air Transportation Association has submitted articulately written comments to FAA Docket #FAA 2006-26408 and in so doing added to the long list (300 submissions) of uniformly negative comments on the FAA’s proposed revision to Part 145. The voice of aviation business has called for the withdrawal of the NPRM and cites some extraordinarily damning criticisms of the rules designed to regulate the repair station industry (full document).

The central argument of NATA is that the new regulations failed to meet the stated purpose—to modernize Part 145 to regulate the industry as it exists in 2012 and beyond. The revamping of the MRO rules, according to the FAA, mandates the recertification of all 5,000 certificate holders. The NATA notes that there are not enough inspectors to complete the recertification within the FAA’s own deadline.

The purported purpose of the revision of Part 145 is to match the rules to the current requirements of these facilities. NATA makes a criticism that shows that the FAA failed in the basic premise of this exercise—to understand the business. NATA points out, in one of its multiple pointed comments, that the FAA fails to comprehend the basics of the repair station business in that the NPRM grossly underestimates the cost of having tooling and equipment in place, the cost of compliance with the new rules and the cost of the increased supervision level compelled by the proposal.

These are elementary business concepts; if the FAA alleges that it is trying to create rules relevant to the current P145 environment, it appears that they have failed to do their homework. If, for example, added managerial staffing is required for aviation safety (a valid regulatory goal), then the FAA must know exactly what the cost impact of that change will be.

A review of the twenty pages of thoughtful analysis of the proposed rules provides absolute proof for the NATA’s bottom line recommendation—the FAA must withdraw the NPRM. This is extremely disappointing in that the beginning of this process traces to 1989, but to impose a regulation, which is so out of touch with the Repair Station reality today, would be disastrous to the business and deleterious to aviation safety by harming this vital source of aircraft maintenance.

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