November 19, 2012
Docket Operations
U.S. Department of Transportation
1200 New Jersey Avenue, SE
Washington, DC 20590
Submitted electronically via www.regulations.gov
RE: DOCKET #FAA-2006-26408 - NOTICE OF PROPOSED RULEMAKING, REPAIR STATIONS
The National Air Transportation Association (NATA), the voice of aviation business, is the public policy group representing the interests of aviation businesses before Congress, federal agencies and state governments. NATA's 2,000 member companies own, operate and service aircraft. These companies provide for the needs of the traveling public by offering services and products to aircraft operators and others, such as fuel sales, aircraft maintenance, parts sales, storage, rental, airline servicing, flight training, Part 135 on-demand air charter, fractional aircraft program management and scheduled commuter operations in smaller aircraft. NATA members are a vital link in the aviation industry providing services to the general public, airlines, general aviation and the military.
NATA’s membership consists of a significant number of repair stations certificated under Title 14 of the Code of Federal Regulations (14 CFR), Part 145 (hereafter referred to as repair stations) and an even greater number of aviation businesses that rely on the services provided by repair stations. These repair stations play a vital role in all segments of the aviation industry and contribute greatly to the overall positive impact that aviation has on our nation, economy and lives. It is for these reasons that NATA is pleased to offer these comments.
I. Rule Background and Summary
The Repair Stations NPRM is the culmination of a series of rulemaking projects, proposals and advisory committees that began in 1989. The most recent prior proposal was issued in 2006 and was withdrawn after public comment because it "did not adequately address the current repair station operating environment."
In the withdrawal notice, the FAA commented that further rulemaking had begun that would more "fully address the significant changes in the repair station business model[s]. This proposal is the result of that effort.
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