A maintenance-related rulemaking docket without a filing from ARSA is like Mardi Gras without the beads.
ARSA earlier today submitted its comments on FAA's proposed contract maintenance requirements rule. In a nutshell, the repair station advocacy group dings FAA for over-complicating the Congressional mandate that drove the rulemaking and duplicating existing rules without adding any clear safety benefit.
ARSA also argues that the law called for a rule that focused on contracted work on aircraft, not all articles, while FAA's proposal would touch all Part 145 repair stations doing work for Part 121s or Part 135s
The proposed rule, required by Section 319 of the FAA Modernization and Reform Act of 2012, would have operators that outsource work create more contractor-centric maintenance instructions and include them in their maintenance manuals. Operators would then be required to provide the relevant parts of their manuals to contractors performing the work. Operators also would be required to keep an updated lists of their maintenance contractors.
Both Part 121 and Part 135 already include provisions that require maintenance providers to follow a certificate holder's maintenance manual (121.367(a); 135.413). In FAA's view, however, the manuals are too often geared toward in-house maintenance providers--hence the need for improvement.
The proposed rule also calls on each carrier to keep an updated list of maintenance providers it uses. Again, this is already required (121.369(a); 135.427(a)), but FAA says the lists aren't accurate enough. The new rule would require monthly updates to local CHDOs.
The Congressional mandate discussed only Part 121 operators, but FAA's proposed rule covers Part 135 operators if their aircraft can have 10 or more seats. (ARSA argues that FAA "provided no safety justification" for the Part 135 expansion, so it should be tossed out.) Under the law, FAA has three years--or until February 14, 2015--to issue a final rule.