Well fellow mechanics and repairmen, here is your first opportunity to get involved. After 10 years of festering and bubbling in the bureaucratic rule making cauldron in the bowels of the FAA building in downtown D.C., the sometimes dead, sometimes alive, Notice of Proposed Rulemaking (NPRM) on Part 145 Repair Stations is finally out for public comment. For those among us who cruise the information super highway with a certain level of self-satisfaction and disdain for the electronically challenged, the Part 145 NPRM is available at www.faa.gov/avr/arm/N99-09.doc.
For the rest of us, you can call the FAA at (202) 267-9680 and request the FAA Office of Rulemaking to send you a copy. Or you can write the Office of Rulemaking, ARM-1, 800 Independence Ave. S.W., Washington, D.C. 20591. Whether you call or write, you must identify the NPRM with its docket number: FAA-1999-5836.
The devil you do know. . .
This NPRM is not a namby-pamby; nip and tuck revision of a couple of rules here and there in Part 145. This is a full-blown revision of the Part that takes 185 double-spaced, 8 x 11 pages to explain. This folks, is a super nova of regulatory change and change of any kind usually can scare the heck out of people. My Irish ancestors have a saying about change: "The devil you do know (old Part 145) is better than the devil you don't know (NPRM on Part 145)." The moral of the adage is, "Get to know the new devil and then you can decide to be scared or not."
Before I introduce you to the new devil, I want you to understand how important it is to you personally and to our profession to participate in the FAA's rulemaking process. This year, many of you commented on the Part 66 NPRM. But out of a population of 125,000 "active" mechanics, the FAA only received 2,200 comments on the Part 66 NPRM. While I was personally delighted with the number of comments in comparison to other NPRM dealing with maintenance, in reality, less than 2 percent of us commented on the rule that would change our profession and ultimately impact on our career.
The NPRM on Part 145 is another one of those career-changing rules. While you may not work for a repair station now, chances are very good that in this crazy aviation maintenance job market, that before you close your tool box for the last time, you will work in a repair station, or at the very least, you will contract work out to one. So don't blow off this NPRM as something the repair station guys have to deal with. This is a devil you know all about. One last thought: Comments do not have to be negative all the time. FAA would also like to hear what you like about the NPRM, but if you have a negative comment please tells us how you would "fix" it. And yes, all your comments will be read, it's the law.
Interested persons can comment on the NPRM in writing by sending them to U.S. Department of Transportation Dockets, Docket No. FAA-1999-5836, 400 Seventh St. SW., Room Plaza 401, Washington, DC 20590. Comments can also be sent electronically to the following e-mail address: 99-NPRM-CMTS@faa.gov. However, this comment period closes on October 19, 1999, so time is a-wasting.
What follows is a brief overview of the NPRM. This outline should be considered a "horse-de-over" of information only and not the main meal. However, I will take the time to caution you not to be to quick in adopting the opinion of others, be they FAA, or a trade society, or aviation maintenance organizations. Read, and ponder the NPRM carefully because the rest of your career may depend on it.
Part 145 is being revised so U.S. FAA certificated Repair Stations can compete in a more global market place. Some of the major changes are:
1. Limited ratings for Manufacturers' Maintenance Facilities (MMF) will be eliminated and require MMF to obtain the appropriate repair station certificate rating.
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