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Maintenance. Major Discussion Points. Pending FAA Authorization Done every 5 years (House completed actions, Senate has not – versions not aligned) House Bill HR 2881 requires foreign repair stations to be inspected 2 times/year Senate Bill 1300 (more favorable to industry and FAA)
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Major Discussion Points Pending FAA Authorization • Done every 5 years (House completed actions, Senate has not – versions not aligned) • House Bill HR 2881 • requires foreign repair stations to be inspected 2 times/year • Senate Bill 1300 (more favorable to industry and FAA) • No increased inspections • Impacts: • Not supported by safety data • Strain on FAA resources • Other countries may take similar actions
Major Discussion Points Contract Maintenance • OIG reports 2003 and 2005 - FAA working to improve oversight of repair stations and air carrier use of maintenance vendors • FAA Actions: • Enhanced Repair Station Oversight System (launched in September 2005) • Quarterly Utilization Report • FAA focused team inspections • Proposed Rulemaking on Air carrier manuals • Proposed rulemaking on repair stations (ratings structure/quality system/) • Inspector outsource maintenance training program (prototype completed) • Owner/operator is responsible for airworthiness.
Major Discussion Points Proposed line maintenance authorization • Article 4 of the Maintenance Annex: Implementation • Covers all additional fixed locations within EU member states • Requires appropriate FAA annex to EASA form 6 • Line maintenance in Europe has Special Conditions (Appendix 1) • Line Stations outside the EU do not fall under the agreement • Proposed Agreement does not allow EASA line stations to exist outside of US territories (EASA side of approval) under new agreement. Current MIPS with Germany, France, Ireland allow this today • Transition from old to new agreement • To assist, both FAA/EASA put together training modules describing: • How EASA and FAA work together • How a US repair station gets EASA certification • How an EASA repair stations gets US certification
Reaction from the Floor • Concerns with FAA based EASA repair stations and the alignment of privileges of certificate ratings • EASA repair stations outside the EU held to same standards as EASA repair stations outside the EU (Certificated as foreign repair stations by EASA) • Concerned with FAA rule changes (14 CFR Part 145 – ratings and quality systems) and their impact on the upcoming US/EU agreement. Authorities did consider the impact as part of the Special Conditions • Authorities need to consider impact of allowing U.S. based EASA repair stations to perform “EASA release only” on EASA based type design products when not on U.S. repair station capability list.
Outcomes/Additional Ideas • Industry personnel want the Authorities to continue to have dialogue with them on their concerns in order to minimize the impact on their operations when the transition to the new agreement comes to fruition