On July 24, ARSA received a response from the FAA regarding the association’s joint effort with the Aircraft Electronics Association (AEA) to purge agency guidance of a requirement for repair station applicants to submit a “letter of compliance.”
The agency’s letter reported that its “‘Part 145 Letter of Compliance’ policy” was removed from the Flight Safety Information Management System (FSIMS; Order 8900.1) in April 2019.
Prior to ARSA and AEA’s initial letter on the subject, which was delivered to the FAA in May 2018, the submission of a “letter of compliance” was “required” by FSIMS’ instructions for repair station certificate preapplication and formal application. At the time, the associations noted that such a letter had been specifically rejected through previous rulemaking efforts – a 2006 notice of proposed rulemaking (NPRM) including such a requirement was withdrawn in 2009.
Without the letter included in FSIMS, the FAA’s guidance to inspectors has been cleansed of an inconsistency with the certificate application requirements of § 145.51.
To review the FAA’s response, click here.
For information about a larger effort to align FAA guidance with the plain language of the repair station rule, read about the ARSA/AEA-led Part 145 Working Group at arsa.org/145-task.