B. Mobile Maintenance Units

1. B. Mobile Maintenance Units

2. Mobile Maintenance Units • Mobile Maintenance Unit Concept Overview • Not a new and novel concept (current amendment was published in 2001) • Industry has had robust operations in place since 2001 (although concept was in place long before) • 2001 FAA § 145.203(b) establishes rule for mobile maintenance units • Guidance material developed in 2003 (AC 145-9) was first and only published guidance for Industry regarding MMU acceptable methods of compliance • Defined permanent vs temporary • Issue Statement - As FAA guidance (Orders) were developed and revised over the years it improperly established additional requirements on industry and contradicted acceptable methods of compliance • Interpretation of what constitutes continuous, uninterrupted operations shifted over time • Added more restrictive criteria than originally intended without just cause • Resulted in inconsistent interpretation/application from FSDO and Industry • Some FAA inspectors refused to recognize and permit MMUs

3. Regulatory Requirement §145.203 • 2001 - § 145.203 Work performed at another location • A certificated repair station may temporarily transport material, equipment, and personnel needed to perform maintenance, preventive maintenance, alterations, or certain specialized services on an article for which it is rated to a place other than the repair station's fixed location if the following requirements are met: (a) The work is necessary due to a special circumstance, as determined by the FAA; or (b) It is necessary to perform such work on a recurring basis, and the repair station's manual includes the procedures for accomplishing maintenance, preventive maintenance, alterations, or specialized services at a place other than the repair station's fixed location.

4. AC 145-9 Work Performed at Another Location • 2003 FAA Publishes AC 145-9 Guide for Developing and Evaluating Repair Station and Quality Control Manuals • Guidance material developed in 2003 (AC 145-9) was first and only published guidance for Industry regarding MMU acceptable methods of compliance

5. AC 145-9 Work Performed at Another Location • Establishes definition for continuous, uninterrupted operation • Must be combination of having materials and personnel permanently positioned • Change 1 to AC in 2007 does not remove or edit this definition

6. 8900.1 Para 2-1320 RS Inspection • 2007 - FAA Order clarifies that Mobile Repair Stations (non units) should not be permitted • Some Inspectors have interpreted this to mean no mobile operations

7. 8900.1 V6 Ch9 section 2 6-1654 • 2007 FAA Order includes language to require the same team that inspected main base should conduct inspection at work away locations • Also first example within FAA Orders where authorization is approved via OpSpec • Does not specify D100

8. 8900.1 Volume 6 chapter 9 section 13 • 2010 start to see shift in requirements

9. FAA Order 8900.1 Para. 2-1182 • 4/15/13 Paragraph F. Maintenance Performed at Another Location (Extended Special Circumstances)

10. 2-1182 Cont. (Recurring basis – aka mobile field service)

11. 145 NPRM as PROPOSED § 145.1203 Work performed at another location. (as amended) • Proposed Regulatory 145 Language NPRM • Comments submitted in 2012

12. Mobile Maintenance Units • MMU Next Steps • FAA is currently drafting Mobile Maintenance Unit Advisory Circular • Expecting a briefing by the FAA policy writer (Darcy Reed) • Should include MMU limitations, RSM/QCM requirements, quality control requirements and communication requirements • Likely it will copy restrictive language from FAA Orders and put it in the AC • AMP should Establish working group (industry lead) • Upon publication of FAA AC, develop industry best practice document for compliance to FAA expectations • Document will be recognized as acceptable method of compliance