The proposed rule is the direct result of Sec. 319 in the FAA Modernization & Reform Act of 2012 (the latest FAA reauthorization). The Association points out that the agency’s NPRM misconstrued the plain language of the legislation resulting in a confusing proposal that duplicates existing rules. ARSA further noted that the agency went beyond the bounds of the legislative provision.
“In the process of turning the congressional mandate into functional rules, the FAA exceeded the scope of the legislation,” says ARSA Vice President of Legislative Affairs Daniel Fisher. “The NPRM disregards the lawmakers’ narrow focus to impose more regulation without improving aviation safety.”
ARSA’s comments include suggested regulatory language that recognizes existing rules, narrowly targets the mandated provisions to avoid confusion, and preserves operational realities for air carriers and repair stations.
“The NPRM contained unnecessary ambiguity where the law was clear, and created administrative provisions that would shift focus away from properly accomplishing maintenance tasks. We hope the FAA will recognize the merits of ARSA’s comments and recommendations before finalizing the rule,” concludes ARSA Vice President of Regulatory Affairs & Assistant General Counsel Craig Fabian.
Setting the Record Straight on Proposed Rule
On March 13, 2013, the ARSA submitted comments on the FAA's air carrier contract maintenance requirements.