Objections Over Rule
EAA critical of TSA repair station plan
February 19, 2010 — EAA's raised several objections to the Transportation Security Administration's proposed Aircraft Repair Station Security Program in comments submitted to the TSA's notice of proposed rulemaking (NPRM) on Friday, February 19. The new rule would require 4,227 FAA-certificated repair stations in the U.S. as well as 694 foreign shops to implement strict access controls, provide security awareness training, and allow for Department of Homeland Security (DHS) inspections.
Chief among EAA's objections is the economic harm the proposal would create for many of the small repair stations that are the backbone of general aviation aircraft maintenance. Repair station owners have consistently indicated they would be faced with one of two choices if the program became law: Avoid the regulation by surrendering their repair station certificate to the FAA and continue maintaining aircraft as an A&P mechanic and/or Inspection Authorization; or, more commonly, go out of business.
That scenario could be especially devastating to GA, as there is often only one existing repair station authorized to maintain a particular product or component. The loss of a single repair station could in some instances ground entire fleets of aircraft for lack of available maintenance.
"The cost to implement this proposal, combined with the potential risk to flight safety through loss of maintenance infrastructure, far exceeds any potential benefit that could be derived under the proposed repair station security program," wrote Doug Macnair, EAA vice president of government relations.
As proposed, the repair station security program satisfies a mandate of the Vision 100 - Century of Aviation Reauthorization Act, but EAA argues that Congress intended new regulations to apply specifically to foreign repair stations performing work on large commercial air carrier aircraft.
Read the full text of EAA's submitted comments here.