FAA Releases Repair Station Rules

Today, the FAA issued a significant new proposed rule for repair stations.

The proposed rule would change the ratings system for repair stations. The following table comes from the new proposed rule, and it illustrates the proposed way that the ratings system is expected to changed.

Current Proposed
Airframe Class:

1. Composite Small

2. Composite Large

3. All-Metal Small

4. All-Metal Large

 

Airframe Category:

1. Aircraft certificated under part 23 or 27.

2. Aircraft certificated under part 25 or 29.

3. All other aircraft.

Powerplant Class:

1. Reciprocating Engines of 400 HP or less.

2. Reciprocating Engines of more than 400 HP

3. Turbine Engines.

Powerplant Category:

1. Reciprocating engines.

2. Turbine engines.

3. Auxiliary Power Units.

4. All other powerplants.

 

Propeller Class:

1. All Fixed and Ground-Adjustable

2. All other propellers.

 

Propeller Category:

1. Fixed-pitch and ground-adjustable propellers.

2. Variable-pitch propellers.

3. All other propellers.

 

Radio Class:

1. Communication.

2. Navigation.

3. Radar.

 

Component.
Instrument Class:

1. Mechanical.

2. Electrical.

3. Gyroscopic.

4. Electronic.

 

Component.
Accessory Class:.

1. Mechanical.

2. Electrical.

3. Electronic.

 

Component
Limited Rating Specialized Service.

 

Specialized Service.
Limited Ratings (§ 145.61(b) lists 12 possible limited ratings). Eliminated.

 

The most significant difference is that FAA is proposing a new “Component” rating that would replace the Radio, Instrument, and Accessory ratings.

The proposed “Component” rating would allow repair stations to work components that are not installed on an airframe, powerplant, or propeller (bench work).  A repair station with a Component rating would be required to have an Airframe, Powerplant, or Propeller rating to install components or appliances. The FAA expects that such a product-level rating would be limited to only installation and removal.

The preamble to the rule states that the FAA expects that Component-rated repair stations would have a list of their components in their operations specifications.  In light of the difficulty now faced by some repair stations in amending their operations specifications, keeping the component list in the op specs would likely make it very difficult for a component repair station to add new components to their list of permissible components, which in turn would probably cause many smaller component shops to stagnate as new products come out but the operations specification amendment process limited their ability to add them as capabilities.

The FAA will accept public comments on the proposed rule through August 20, 2012.  Comments should reference FAA Docket Number “FAA–2006–26408.”

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About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

One Response to FAA Releases Repair Station Rules

  1. Pingback: SBA Repair Station Meeting Postponed! « ASA Web Log

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