NEWS FROM THE AERONAUTICAL REPAIR STATION ASSOCIATION
ARSA: Response To EASA Information Request - Act Now!
Dear Aviation Maintenance Professional,
The industry has taken notice that the European Aviation Safety Agency (EASA) is sending letters to part 145 repair stations in the United States with EASA approval requesting information on the number of technical staff and types of ratings held by each company.
The information is being requested in anticipation of congressionally mandated inspections by the Federal Aviation Administration (FAA) of foreign based repair stations, including those located in countries with bilateral aviation safety agreements (BASA). The European Union (EU) has made it clear that if the legislation passes without exempting BASA countries with Maintenance Implementation Procedures, EASA will be required to fully certificate all U.S. based repair under EASA part 145. The legislation is the House version of the FAA reauthorization bill (H.R. 915), which contains arbitrary twice annual inspections of all foreign repair stations by FAA personnel and requires that foreign repair station personnel be included in the Department of Transportation drug testing pool. The EU has stated that these provisions are contrary to the BASA and if they become law, the BASA will cease to operate.
However, the bill has yet to become law. The Senate version of the FAA reauthorization legislation (S.1451) contains less onerous provisions. That bill currently awaits a vote by the full Senate. After passage of S. 1451, it will be conferenced with the House version, meaning that the two bills will be compromised to create one final bill that will be voted upon by both the House and Senate before being forwarded to the president for signature. If the House language is removed in conference, the BASA will stay intact and fees associated with EASA certification will remain at current levels.
Now is the time to ensure that the measures in the House bill are defeated and access to the European market remains economically viable! Contact your representatives to let them know how trade prohibitive measures in FAA reauthorization will impact your business. ARSA has constructed a form letter for repair stations to place on company letterhead and fill in with pertinent data and fax to senators and representatives.
On April 23, FAA issued Notice 8000.362, Air Carrier Contract Maintenance Provider Oversight Responsibilities (Certificated Repair Stations/Noncertificated Facilities). The notice provides OIG recommended guidance to principal inspectors (PI) assigned to part 121 certificated air carriers who contract some or all of their maintenance to other persons. It instructs PIs to complete a review of each air carrier's contract maintenance program to verify the procedures adequately ensure compliance with its Continuous Airworthiness Maintenance Program (CAMP) and Title 14 CFR.
No later than April 30, 2007 U.S. repair stations must show compliance with the U.S.-Canada Maintenance Implementation Procedures. To assist repair stations in accomplishing that goal, ARSA has developed two new publications:
Domestic Model Canadian Supplement: This supplement is designed for U.S.-based repair stations that are required to have a supplement. Only those repair stations working on aircraft operated in commercial air service under Canadian Aviation Regulations Part IV or Part VII are required to have an FAA approved supplement.
Domestic Model Canadian Cross-Reference Table with Additional Procedures: The cross-reference table with additional procedures is designed to be part of the ARSA Domestic Model Repair Station Manual. All U.S.-based repair stations that perform maintenance, preventive maintenance and modifications on any civil aircraft, aircraft engine, propeller, subassembly, appliance, material, part or component under the regulatory authority of the Transport Canada Civil Aviation Directorate (TCCA) are required to comply with certain portions the MIP.
Based on your repair station's operations, you will need either the Supplement or the Cross-Reference Table, not both.
The FAA has issued Change 1 to Order 8130.21E, Procedures for Completion and Use of the Authorized Release Certificate, FAA Form 8130-3, Airworthiness Approval Tag. The change allows manufacturing and maintenance designated airworthiness representatives (DARs) to issue an 8130-3. It also allows the use of serial/batch numbers in Block 11 for all parts and eliminates the requirement to enter the term "approval for return to service" in Block 13 when the right side of the 8130-3 is completed.
Repair stations are in the cross hairs again on Capitol Hill.
Last week, Rep. Jim Langevin (D-RI) introduced H.R. 1981. The legislation would force the Transportation Security Administration (TSA) to issue its repair station security rules within 60 days of the bill's enactment, bar U.S. air carriers from using foreign repair stations until the security regs are finalized, and dramatically shorten the period of time that TSA has to audit foreign repair stations for compliance with the new rules. The bill would also establish costly and redundant background check requirements for repair station employees.
ARSA is helping to lead the coalition against H.R. 1981, which threatens to shut down overseas flights by U.S. air carriers, restrict foreign aviation maintenance activities by U.S. companies, subvert small business participation in the rulemaking process, undermine the pending U.S.-European Union (E.U.) bilateral aviation safety agreement (BASA), impose new and unnecessary costs on large and small aviation industry companies, and punish American businesses and their employees for TSA's failure to issue the security rules.
ARSA members are urged to contact Congress to oppose H.R. 1981 (and S. 4, the Senate's version of the legislation). To do so, visit www.ARSAaction.org.
If you have questions about this issue, please contact ARSA Legislative Counsel Christian Klein at firstname.lastname@example.org.
ASIAN AIRCRAFT MAINTENANCE CONFERENCE 2007
The Asian Aircraft Maintenance Conference will be held May 23-24, 2007 at the Marina Mandarin Hotel in Singapore. This event will focus on the many factors affecting the rapidly expanding Asian aviation industry.
ARSA members receive a 10% discount on registration.
All material contained within AIA.net, unless otherwise stated, is the property of the Aviation Instrument Association. Copyright and other intellectual property laws protect these materials. Reproduction or retransmission of the materials, in whole or in part, in any manner requires written permission from the Aviation Instrument Association. The Aviation Instrument Association is registered under Section 501(c)(6) of the Internal Revenue Code as is not organized for profit.