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Broderick, Anthony J., Associate Administrator for Regulation and Certifica-
Enforcement report data for closed enforcement actions on repair stations
Dargie, Norm, vice president maintenance engineering, Evergreen Interna-
Donohue, Dr. Peter, San Francisco State University, statement
Gallimore, Wayne, Air Transport Employees Local Lodge 1781, statement..
Responses to supplemental questions submitted by Representative Bud
Hewitt, Michael C., secretary general, Orient Airlines Association, statement..
Kerrigan, John J., director of the air transport division of the Transport
Larson, Alan, Principal Deputy Assistant Secretary of State Bureau of Economic and Business Affairs, statement.....
Peel, Robert, general manager technical affairs, Association of European
Pelosi, Hon. Nancy, a Representative in Congress from California, statement
Responses to supplemental questions submitted by Representative Bud
Powers, Linda F., Deputy Assistant Secretary of Commerce for Services, statement..
Reimer, Terry, vice president, maintenance and engineering, American Trans
Robeson, Robert E., Jr., vice president, Civil Aviation-Aerospace Industries
Shane, Jeffrey N., Assistant Secretary for Policy and International Affairs
Stuessel, Dr. Rolf, senior vice president, engineering, Lufthansa German Airlines, statement....
Vanduyne, Walter, E., program general manager, aircraft engine group field
ADDITIONS TO THE RECORD
Aerospace Technologies of Australia, letter.............
Air Transport Association:
Air Freight Association, Stephen A. Alterman, counsel, statement..
DHL Corp., Jed T. Orme, vice president, general counsel and secretary, letter.
Embassy of Australia, John McCarthy, Minister, Congressional Liaison, letter Federal Aviation Administration, letters regarding quarterly reports on the certification of foreign repair stations..
Guyard, M., transportation counselor, Ambassade De France, letter
Northwest Airlines, Terry Rendleman, vice president maintenance and engi-
Sundstrand Corp., Hills, John, corporate director of government relations,
UNC Inc., Dan A. Colussy, president and chief executive officer, letter
1 May be found in subcommittee file.
SUBCOMMITTEE ON AVIATION
REGULATION OF FOREIGN REPAIR STATIONS
TUESDAY, JUNE 27, 1989
2167 RAYBURN HOUSE OFFICE BUILDING
SUMMARY OF SUBJECT MATTER
In December 1988, new Federal Aviation Administration rules governing the FAA certification and use of foreign repair stations took effect. The hearing by the Subcommittee will receive testimony on the impact of these new regulations and on legislation that has been introduced to changes those rules.
The new regulations lift long standing limitations on the maintenance of U.S. domestic aircraft in foreign countries. Some Members of Congress, labor orgnanizations and some U.S. airlines have expressed concerns about safety under the new regulations and the FAA's ability to adequately inspect and monitor maintenance conducted abroad under this new regulatory regime. Also of concern is the impact this regulatory change may have on U.S. industry and jobs.
The FAA and other U.S. Government agencies, U.S. manufacturers, foreign aeronautical interests and some U.S. airlines believe the new regulations are required to rationalize the regulatory framework to take account of the international character of today's aviation business. There are also concerns that there is not enough maintenance capacity in the U.S. to do all the maintenance that is required on a timely basis. There are also concerns that without the regulatory change, the U.S. will be in violation of trade agreements to which it is a signatory and will invite trade retaliation against U.S. aircraft and airline companies by foreign governments. It is argued that this could result in harm to U.S. industries and jobs.
Repair stations, foreign and domestic, are regulated by the FAA under Part 145 of the Federal Air Regulations. Repair stations provide maintenance on aircraft, engines, and other parts and components. There are approximately 4,000 FAA certificated repair stations within the U.S. and approximately 200 FAA certificated foreign repairs stations. Repair stations range from small companies doing specialized work on particular components for particular aircraft to much larger companies capable of complete overhauls of large jet aircraft and engines.
Prior to the December change, the regulations pertaining to foreign repair stations had not been significantly changed since 1949. The regulation was developed at a time when the manufacture of commercial transport aircraft and engines was almost solely a United States industry and the air transport markets between the United States and foreign countries were dominated by U.S. airlines.
Reflecting the need that some U.S. aircraft had to be maintained abroad by repair facilities not then regulated by the Federal Aviation Administration, the FAA established the concept of an FAA certificated foreign repair stations. A foreign repair station was expected to meet all the requirements and standards of a domestic repair station, except for the requirements pertaining to FAA certification of personnel and maintenance of records on the qualifications and experience of supervisory and inspection personnel. Regulation of personnel was left to the aeronautical authorities of the foreign country, but the standards to which the maintenance was done were the same as maintenance conducted in the U.S. or under a U.S. operating certificate. However, the regulation did stipulate that only aircraft used in international service could be repaired by a foreign repair station. Aircraft used in U.S. domestic service could not be.
It should be noted that airlines have always been permitted to set up their own maintenance bases abroad, and for regulatory purposes, these have been viewed the same as a maintenance base located in the U.S. There is no restriction on U.S. aircraft flown in domestic service being maintained in these facilities, since these facilities are not considered foreign repair stations.
Since 1949, the aviation world has, of course, changed becoming a highly international business, particularly in the manufacture of aircraft, engines, and other components. U.S. airframes with foreign engines and other components are now routine, as are foreign airframes with U.S. engines and components. Also, foreign airlines now carry more than 50% of the passengers between the U.S. and foreign countries.
The standards to which these foreign aircraft and parts are designed and built are largely regulated by foreign aeronautical authorities. Likewise, the regulation of operations and maintenance of foreign airlines is done by foreign governments. The U.S. Government has bilateral and multilateral agreements with foreign governments under which the U.S. accepts the foreign governments' regulations in these areas as largely sufficient for the safety of the U.S. travelling public. However, until the recent regulatory change, the FAA regulations continued to take the view that foreign maintenance of U.S. domestic aircraft would not be generally acceptable and would be permissable only in special circumstances in which the FAA granted an exemption.