Anonymous

Cost to Comply: The cost to comply and transition to this new rule will impose a huge monetary investment on repair stations. This proposed rule requires revision and approval of all three repair station manuals, as well as developing and managing a list of capabilities. The FAA is not accounting for the man-hours needed for a repair station to revise its manuals and create capability lists. Lack of Time to Transition: The rule proposes a 24-month implementation period to reissue new certificates for all repair stations. With the current lack of FAA workforce and sequestration initiatives, how will the agency provide the resources needed to approve and reissue certifications to 4,000 repair stations in a 24-month period? If a repair station certificate is not reissued within the 24-month time period, the previous certificate is no longer valid and businesses will not be able to operate as a Part 145 repair station. Avionics Profession Loses Its Identity: Under this proposal, the system of ratings would be reduced from eight ratings to five ratings. The ratings definitions would be revised to indicate the type of work that a repair station is authorized to perform. But, it also removes radio and instrument ratings and allows airframe-rated repair stations to repair and alter radios and instruments without any specific ratings or obvious qualifications. Costly & Time-Consuming Capabilities List: This proposal does not specifically require a capability list, but does require a listing of capabilities for all repair stations. This is a potentially marked change for repair stations with class ratings that do not currently have a capability list of the items they maintain. Also, capabilities list, or list of capabilities, will be subject to a line-item review every 24 months. This requirement will force repair stations to hire additional staff to maintain these lists. No Mobility: Each certifica