As usual, the professionals at ARSA know what issues deserve objection and which should be ignored; they, too, have listened to the GEICO/Kenny Loggins advertisement too many times. The below story is an excellent example of the association’s discretion. The FAA added the words “and the FAA accepts its cancellation” to a recent Part 145 rulemaking; so ARSA submitted a petition to restore the right of a Repair Station to surrender the certificate. Why?
The ARSA petition and press statements argue that the “acceptance” of the certificate is an unnecessary burden on the FAA. Really? The time it takes to stamp “cancelled” on the printed document does not really consume much time.
The real underlying concern is that the FSDO, upon receiving this incredibly valuable certificate, will suspect that something’s up. The field inspectors know how hard it is to earn this level of FAA’s confidence for issuance of a Part 145 certificate. Hours of work, development of the right handbooks, obtaining the right tools, training (and writing the underlying training manual) the technicians and finding the customers is a massive effort to create a very valuable regulatory asset. The FAA field personnel, thus, conclude that there must be a major reason to abandon the document; so they would investigate, if they did not already know, what’s wrong. The likely outcome of the investigation is revocation of the certificate.
Section 145.51(e)(1)-(3) is the reason why the right to surrender should remain. That provision precludes the granting of a new Part 145 certificate to an entity which includes any individual who was involved revocation. Surrender is not revocation.
There are valid reasons to surrender your Part 145 privileges. The existence of problems is not one of them. There may be other reasons and the record in support of the Petition for Rulemaking should include them. If not. maybe, ARSA should have folded on its new petition?
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