ARSA's blog

Legal Interpretation of 14 C.F.R. §21.9(a)(6) Concerning an Appropriately Rated Certificate Holder Fabricating Parts to be Consumed into a Repair Or Alteration

This responds to a request for a legal interpretation of 14 C.F.R. § 21.9(a)(6) concerning whether Pacific States Aviation (an appropriately-rated certificated repair station) may fabricate a replacement or modification aircraft part that is to be consumed in the repair or alteration of a product or article.

RCCB to Clarify Guidance on 100 Percent Replacement

Update: On July 11, the FAA responded via email to ARSA’s June 29 request for clarity on the ability of repair stations to replace 100 percent of an article while performing maintenance. The agency’s Regulatory Consistency Communication Board (RCCB), to which the request was submitted, “has carefully evaluated [the] issue and determined it will be accepted by the RCCB for resolution.”

Maintenance Matters in Both House and Senate FAA Bills

On June 30, ARSA issued the following statement in response to recent congressional action on FAA reauthorization legislation. The House Transportation & Infrastructure Committee marked up and passed its bill on June 27 and the Senate Commerce, Science & Transportation did the same on June 29.

Industry Helps FAA Reconstruct Recordkeeping Guidance

On June 12, an ARSA-led coalition of ten industry partners submitted a complete rewrite of the agency’s proposed Advisory Circular 43-ARTS, “Use of FAA Form 8130-3 for Approval to Return to Service Under Part 43.”

The signatories, most of whom also joined a February request for extension to the comment period, made good use of the additional time provided. They compared the draft AC as written to existing maintenance recordkeeping rules and agency guidance and determined that the draft should not be issued.