WASHINGTON – On Dec. 27, representatives of 14 aviation industry associations urged FAA Administrator Steve Dickson to act on the agency’s enforcement of rules related to instructions for continued airworthiness (ICA).
The group, which included ARSA and many of its long-standing allies, delivered a letter requesting the administrator assign the matter to the Aviation Rulemaking Advisory Committee (ARAC). A draft ARAC tasking provided with the letter directs a study of the issue and requests a report with recommendations to address regulatory concerns.
The letter highlighted President Biden’s July 9, 2021 Executive Order (EO) “Promoting Competition in the American Economy.” Moving forward on ICA would uphold the FAA’s responsibility under the EO’s whole-of-government policy to consider and address the impact of its regulations on the industry. Aviation safety rules have long required design approval holders (DAH) to prepare ICA and make them available. The agency has been slow to enforce these obligations but has vigilantly imposed requirements that maintenance be done in accordance with instructions that are often constructively unavailable.
“The lack of clear guidance regarding DAH obligations has led to the proliferation of practices that are inconsistent with the language and intent of ICA requirements, including absolute refusals to provide data, onerous licensing policies, and economically impractical pricing,” the letter said. “The situation negatively impacts many categories of regulated stakeholders…In establishing its rules, the agency determined that access to and possession of ICA is important to safety. However, FAA’s nebulous enforcement regime represents a weak link in the airworthiness chain.”
To read the full letter, click here.
To review the draft ARAC tasking delivered with the letter, click here.
In addition to ARSA, the letter was supported by the following organizations:
- Aircraft Electronics Association
- Aircraft Owners and Pilots Association
- Airlines for America
- Aviation Suppliers Association
- Aviation Technician Education Council
- Cargo Airline Association
- Helicopter Association International
- Modification and Replacement Parts Association
- National Air Carrier Association
- National Air Transportation Association
- National Business Aviation Association
- Professional Aviation Maintenance Association
- Regional Airline Association
