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Most repair stations surrendering certificates are doing so because they (1) sold the assets to someone else that did not want to amend the certificate, (2) have decided to go out of business or (3) have legitimate business reasons not to serve the aviation industry.
Investigations and enforcement rarely seek beyond the contractor level but when they do, uneven and often unfair results become evident.
Unfortunately, there are few choices on how actions by an executive agency can be challenged: It is either in the courts or in Congress.
ARSA’s legislative team worked tirelessly to get an amendment introduced to FAA reauthorization legislation that would return the repair station’s right to unilaterally and voluntarily surrender its certificate.
Convincing lawmakers that a safety agency is wrong is no small task – the FAA has “justified” its position by stating it is trying to keep “bad actors” out of the industry.
To treat one type of certificate holder different than another – for example, an air carrier can unilaterally decide to surrender its certificate – is also unacceptable.
To have to demand action from Congress to get an executive branch agency to see the light is certainly not the preferred way of getting policy work done, but it can be a necessary step.Our current effort is similar to the lawsuit the association filed against the FAA over drug and alcohol testing “at any tier in the maintenance contract.” ARSA attempted to explain to the FAA that its desire to test for drug and alcohol use beyond “aircraft maintenance” was arbitrary and would not result in any increase in safety. Making matters worse, inspectors enforced their own definitions of of what was covered by the term “aircraft maintenance.” ARSA’ predictions have generally come true, but the courts would not reverse the agency’s action.As a result, the industry faces continued uncertainty about what contractors, subcontractors, sub-subcontractors, sub-sub-subcontractors (you get the idea) need to be tested.I am also an infantry company commander so I freely admit that my property knowledge is more limited than say an FSC or Mech company commander.My company will be RIPing soon so we are getting all of our TPE ready to transfer to the new unit.So the end item description would be PRC-148 MBITR, and quantity would be 48, and the alpha column would reflect the quanity of each BII piece on hand(ie 48 handmics, 48 antennas, 48 spare batteries).