ARSA requested the FAA’s chief counsel clarify the applicability of 14 CFR § 145.103 housing requirements. The association questioned the agency’s position that a repair station must have a hangar to enclose the largest aircraft listed on its operations specifications – even if work is limited to airframe components and no aircraft is ever housed. An Oct. 29 memorandum citing a March legal interpretation that § 145.103(b) applies to both class and limited airframe ratings created untenable guidance to the inspector workforce. With industry-wide implications, ARSA requested immediate assistance from the chief counsel.

“The FAA is authorized to promulgate regulations in the interest of safety,” the association’s letter said. “Absolutely no safety purpose is achieved by requiring component level work be performed in housing suitable for aircraft maintenance, simply because the certificate must be issued for an airframe rating. That conclusion is simply outrageous and unsupportable.”

Considering the agency has issued thousands of certificates to hangar-less component shops, enforcing such a strict interpretation of § 145.103(b) would impose an unnecessary burden on a broad and vital sector of the maintenance industry. In the absence of a safety-based rationale, there can be no justification for requiring a maintenance facility to incur the cost of housing aircraft that will never be seen by the repair station.

The association is determined to bring the agency’s reading of the regulation back to reality.