Rex Prickett

I am a one person Certificated Repair Station CRS#3MTR418B, limited airframe, limited radio, limited instrument. I am a mobile repair station and conduct biennial certifications to comply with FAR 91.411 and FAR 91.413 on most general aviation aircraft I/A/W a compliance list. I have great concurns about the proposed requirement for housing. I conduct my business at the customers home hanger OR the facility where the customer has his aircraft for annual. I complete between 10 and 35 aircraft each month and frequently bring aircraft into compliance that have lapsed. This proposal would be an expense to the customer in transportation to the repair facility, storage at the facility if the aircraft needed repair, transportation back from the facility. This proposal would also be a detrimental expense for my repair station in acquiring and renting a space for my services in a location with VERY limited hanger facilities. Also, time will be lost to cerifications due to a rewrite of my repair station manual, accepted only three years ago. My service provides for inspection and repair in the customers own hanger as all hangers where the aircraft is parked is adequate for the repair that I provide. Everyone in aviation understands broken equipment, but when it is broken in their own hanger and they don't lose control over their aircraft, with it in the snow or the hail at someone else's ramp, they feel much better about the situation. All of my equipment is called ramp equipment, due to the fact that it can be readily used on a ramp. The proposal that I obtain a facility for housing the aircraft that I work on has no merit. My customers use my service because it is convienient for them and they can get the biennial required inspection and certification completed in their own facility. This proposal would cost them more to get the certification completed and therefore I believe I would find even more aircraft out of compliance.