does need the tools, equipment, and adequate facilities to work on the components that the repair station is certified to work on. There should be no question about that. In August 2015, the FAA’s Lubbock Flight Standards District Office, or FSDO, added some insight to this is- sue when it asked headquarters, in this case, the Aircraft Maintenance Division (AFS-300), “What rating should a repair station be given when it repairs airframe components and yet does not have the facility to enclose the largest air- craft under the rating?” When the rules are not really and truly clear, and there’s no policy statement or other guidance that addresses the topic, it’s reasonable that an inspector in West Texas may not understand policy developed in downtown Washington, D.C. And, when the FAA Inspector reads an unclear rule literally without injecting common sense, you get trouble in River City, or in this case, in Lubbock, Texas, and quite possibly across the rest of the industry, especially if the FAA doesn’t quickly clarify the rule and policy. AFS-300 did respond to Lubbock. However, the response did not go far enough in explaining the regulation and may have made it even more confusing, or certainly not any clearer. The response affirmed that a limited rating may be issued to a repair station that maintains or alters a particular type of airframe, powerplant, propeller radio, instrument, etc. The response went on to say, if the repair station has the capability to work on flight controls, composite panels, and interior components, then these parts are considered airframe parts and the repair station would need a limited rating to maintain these parts. So far so good. Then, they dropped the bomb. In the next paragraph, AFS-300 stated that a repair station must meet the requirements of §145.103 to be certified with an airframe rating; but did not provide any follow up or further expla- nation. The natural reaction, then, is for the local office to require the repair station to have housing consistent with its rating, in this case an airframe rating. To clarify the policy, perhaps the policy office’s response should have explained that, yes, the regulations require a repair station to have an airframe rating to work on airframe components; and, yes, limitations are placed on its operation as outlined in the repair station’s operations specifications. These limitations describe what kind of maintenance the repair station can perform. For example, a limitation for particular maintenance function or a list of the type of air- craft it can work on (limited airframe rating with a capability list of types of aircraft). Finally, that these limitations dictate how the repair station complies with the housing require- ment. If a repair station is rated to repair airframe parts, then the housing required should be adequate to support the parts the repair station maintains. Part 145 does not define an airframe part. However, the FAA Inspector’s Handbook, 8900.1, Vol. 2, Chap. 11, Section 1 paragraph 2-1188 and Table 2-19 provides a list as an example of part or articles that would be considered airframe parts. Class Class 1 Class 2 Class 3 Class 4 Definitions Composite construction of small aircraft. Gross takeoff weight (GTOW) 12,500 lbs or less, of which a major por- tion of the airframe is of composite construction. Composite construction of large aircraft. GTOW more than 12,500 lbs, of which a major portion of the airframe is constructed of composite material (e.g. Boeing 787, Airbus A380). All-metal construction of small aircraft. GTOW 12,500 or less, of which a major portion of the airframe is all metal construction. All-metal construction of large aircraft. GTOW more than 12,500 lbs, of which a major portion of the airframe is all metal construction. Through the rating system in the regulations, the FAA has established the difference between component-level airframe maintenance and maintenance performed on the airframe. Based on those regulations, the FAA has issued many certificates and ratings that limit maintenance to airframe components without requiring the repair station to have a hangar. In late 2015, industry joined Lubbock in highlighting this issue by writing to the FAA about enforcing the housing reg- ulation, §145.103(b), on repair stations with airframe ratings that perform maintenance on airframe parts. Both AFS-300 and the FAA General Counsel are taking steps to propose a rule change. I hope, between the time I drafted this article and when it’s published, there will be a Notice of Proposed Rulemaking (NPRM) for us to review. My advice: Give the NPRM close review and make your voice heard through the comment process. We all play a role in making sure there’s common sense in the regula- tions. Aviation Business Journal | 1st Quarter 2016 53
