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EAA Advocates For The Small Aircraft Owner

Seeks To Preserve Access To Repair Stations Services

April 18 , 2007 — EAA responded this week to proposed aircraft repair station certification regulations that, if implemented, would impose significant administrative and economic burdens on many small general aviation shops. Such an unintended consequence would have an adverse affect on aircraft owners seeking to maintain the airworthiness of their aircraft.

In the FAA?s repair stations notice of proposed rulemaking (NPRM), the agency estimates the cost for developing and implementing just one part of the proposed new regulations, a new quality system, at $34,500 per repair station. That would be a significant hit to small repair stations and could by itself wipe out the profitability of many shops, forcing some to close their doors.

?We fear that these requirements would ultimately result in diminished availability of qualified and experienced maintenance expertise, especially for the vintage fleet,? said Earl Lawrence, EAA vice president of industry and regulatory affairs. ?Aircraft owners could be forced to use maintenance facilities with less specialized experience on their aircraft type, making it more difficult to complete major repairs and changes to small aircraft, potentially impacting safety as well.?

The FAA also proposes that repair stations be required to maintain an approved capability list for each make, series, and model of aircraft it?s permitted to work on. This would not be feasible in practice, since small GA repair stations inspect and maintain virtually hundreds of aircraft makes and models, from amateur-built to vintage civil and former military aircraft, mass-produced aircraft, and the countless types built in small numbers over a span or many decades.

One solution provided is to exempt aircraft below a certain weight--say 12,500 pounds--from the capabilities list. EAA?s response includes a willingness to discuss how best the FAA could address its quality concerns while ensuring the owners of small aircraft continue to have ready access to repair station services. One suggestion EAA proposed is to exempt, or lessen requirements, for smaller shops with fewer than a given number of employees.

?EAA strongly urges the FAA to address the capabilities list and quality system requirements in this NPRM before it implements a final rule,? Lawrence stressed.

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