EAA Tells FAA to Abandon Proposed Repair Station Rules
November 21, 2012 - EAA has joined several aviation organizations in criticizing the FAA's new proposal for aviation repair stations, stating that the new rules create such cost and regulatory burden that many small repair shops could be forced to shut down.
In comments submitted to the FAA prior to Monday's deadline, EAA wrote that the added burdens vastly exceed the minimal safety benefit the rules would provide. EAA also noted that FAA's cost-benefit analysis used as the foundation for the rule change was flawed, as it underestimated the industry's labor costs and time necessary to rewrite manuals and apply for recertification, which would be required under the new rules.
"We appreciate and can agree with FAA's stated goal of bringing repair station rules into harmony with existing business practices, but this proposal doesn't do it," said Doug Macnair, EAA's vice president of government relations. "Instead of creating flexibility and the ability to adapt to new technology in the marketplace, the proposal does the opposite. In addition, the costs and administrative burdens that would come with these new rules would put many smaller repair shops out of business. In this case, it's best the FAA withdraw this entire proposal."
EAA's comments mirror those of the National Air Transportation Association (NATA), General Aviation Manufacturers Association (GAMA), Aircraft Electronics Association (AEA), and Aeronautical Repair Station Association (ARSA), which have also strongly criticized the proposal. Macnair also said the latest attempt to modernize regulations in this area largely ignored an FAA-created advisory committee of aviation industry experts that made recommendations toward that goal 20 years ago.
Under the new proposal all of the nation's nearly 5,000 aviation repair stations would be required to apply for recertification within a 24-month period after the new rules took effect. Macnair noted that FAA currently experiences certification delays for new repair stations due to a lack of staff and other resources, so re-certifying 5,000 such businesses would be impossible for the agency to accomplish.
"Any new regulations must first focus on safety objectives, but this proposal does not enhance safety in any meaningful way," Macnair said. "At a time when the aviation industry and the national economy are in poor condition, it hardly seems appropriate to impose costs of hundreds of millions of dollars on aviation businesses for little or no safety benefit."