On August 6, 2001, the FAA issued its final rule with changes to 14 CFR §145 (Part 145), the regulations governing certification of aircraft repair stations. The Notice of Proposed Rulemaking (NPRM) published in June 1999 proposed an extensive rewrite of Part 145.
AOPA is concerned that the FAA has taken a "one size fits all" approach to the new regulations by attempting to standardize the operation of all repair stations. In the rulemaking, the FAA had proposed significantly higher standards for smaller GA-oriented repair stations. Under the new rules, most small repair stations will be faced with considerably higher operating expenses. Ultimately, the burden of these higher operating costs will have to be shouldered by aircraft owners and operators who use Part 145 certificate repair stations in the form of higher maintenance costs. AOPA is also concerned that the required advisory circular guidance and FAA training regarding the rule will not be completed before the rule's effective date, which will contribute to even higher maintenance costs.
In the NPRM:
Some of the major FAA proposals were -
In the Final Rule:
The FAA did not adopt the following major NPRM proposals -
The FAA significantly modified these major NPRM proposals:
The FAA did not significantly modify these major NPRM proposals:
AOPA maintained that the proposed changes to 14 CFR Part 145 would place a significant economic burden upon smaller GA-oriented repair stations. This increased operating cost would undoubtedly have to be passed on to the aviation consumer. AOPA contends that the proposed rule could not be applied uniformly to all repair stations without causing severe economic hardship for smaller facilities and that a "one size fits all" approach simply doesn't work.
The final rule, though far from ideal, reflects many of AOPA's comments and recommendations that were designed to significantly reduce the economic burden and address the needs of the smaller repair stations. AOPA now estimates that the average additional cost of compliance for smaller repair stations will be not more than 5% of a smaller repair station's revenue, down from the 30% estimate that was based on the NPRM.
Per the rule, repair shops must develop and submit manuals to the FAA and have FAA approval prior to the rule's implementation date. Also, the FAA must publish an advisory circular guidance document and complete internal training prior to the rule's implementation date. Though the draft advisory circular has been published for public comment, AOPA believes that the FAA will not be able to complete both the required advisory circular guidance and its employee training before the current implementation date of the rule. AOPA also believes that any manuals submitted or approved before necessary guidance and training is completed will have to undergo substantial revisions that burden the repair shops with additional costs that will be passed on to our members. AOPA has sent a letter to the FAA reflecting this concern and is asking that the FAA postpone implementation until such time as both the guidance and training is complete.
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