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ARSA CORNER


SUCCESSFUL OVERSIGHT REQUIRES COLLABORATION


BY RYAN M. POTEET, REGULATORY AFFAIRS MANAGER, AERONAUTICAL REPAIR STATION ASSOCIATION


The aviation maintenance industry is complex and often requires regulators from diff erent countries to oversee and countenance a certifi cate holder’s operations. Similarly, the FAA’s highly- specialized lines of business have caused intra-agency divisions that lead to rules and guidance being created in a vacuum. As such, the development of rules and advisory materials takes signifi cantly more time and resources because the FAA is forced to reconcile duplicative or ambiguous requirements in response to public comment. What if the aviation maintenance


industry was able to provide its perspective before the FAA began drafting guidance or proposing new regulations? The FAA has long relied on the


Aviation Rulemaking Advisory Committee (ARAC) to help the agency develop more thorough and comprehensive rules and guidance materials. ARAC’s sole objective is to provide the FAA with advice and counsel by thoroughly analyzing assigned issues and developing rulemaking, guidance and policy recommendations. In consultation with the FAA, ARAC has the power to create subcommittees, which are composed of industry and agency subject matter experts, to address a specifi c segment of the aviation industry. These committees create a collaborative environment for regulators and industry representatives to reach pragmatic solutions to some of the most vexing and daunting aviation safety concerns. Indeed, for more than a decade the FAA and industry did just that.


46 DOMmagazine.com | feb 2017 From 1991 through 2002, the Air


Carrier/General Aviation Maintenance Subcommittee helped the agency address a wide range of maintenance- centric concerns. The subcommittee assisted with the development of guidance for major repairs and delineated recordkeeping requirements for maintenance providers. It also provided rulemaking recommendations for revisions to 14 CFR Parts 145 and 65. Perhaps most importantly, the subcommittee counseled the agency on how to resolve issues specifi c to providing maintenance services to air carriers. Unfortunately, over the last 14


years, the aviation maintenance industry has not been aff orded the opportunity to revisit ongoing issues or address new ones. Admittedly, industry representatives are members of the ARAC, but their voices have not been loud enough to request new assignments from the agency. The FAA continues to issue guidance and initiate rulemakings that are not properly coordinated and, in some cases, pose a serious threat to the health of businesses without any attendant benefi t to aviation safety.


A perfect example is Draft


Advisory Circular 145-9A, “Guide for Developing and Evaluating Repair Station and Quality Control Manuals” (arsa.org/ac-145-9a). The agency drafted the nearly 100-page document before seeking industry feedback. As ARSA’s comments highlight, the guidance is poorly written, fails to account for the most recent revisions to Part 145, confl icts with existing


While ARSA works to build tools for collaboration with the agency, come to the nation’s capital in March and engage face-to-face with regulators from around the world. arsa.org/sympsium


guidance, and imposes unnecessary paperwork on small maintenance organizations. Had the ARAC been tasked to assist the agency, countless hours and resources could have been spared and comprehensive guidance issued in a timely manner. ARSA’s mission in 2017 is to


resurrect the Aviation Maintenance Subcommittee through requests for tasking to the ARAC. The subcommittee’s success during the 1990s cannot be understated and the obstacles the industry faces today remain the same, if not greater. Reactivating ARAC tasking and ultimately reinstating the subcommittee will breakdown intra- agency communication barriers and create a collaborative environment where aviation safety and the success of the industry are both a priority.


Ryan M. Poteet is senior associate of Obadal, Filler, MacLeod & Klein P.L.C., advising clients in international aviation


safety regulation and government aff airs. He serves as regulatory aff airs manager for the Aeronautical Repair Station Association.


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