Dear Secretary Foxx:

Congratulations on being sworn in as the 17^th Secretary of Transportation. I am writing to introduce you to a sector of the economy that is expanding and growing across the country—the aviation maintenance industry.

The industry comprises companies that hold repair station certificates issued by the FAA under part 145 of the Federal Aviation Regulations. These certificates are the industry’s “license to do business.” They authorize repair stations to perform maintenance and alterations on civil aviation articles, including aircraft, engines, and propellers. The certificates also permit maintenance on the components installed on these products. Certificated repair stations perform maintenance for airlines, the military, and general aviation owners and operators.

Repair stations are thriving across the country, and the aviation maintenance sector is one of the top reasons aerospace is the United States’ leading export. A recent study by ICF SH&E determined that the global Maintenance, Repair and Overhaul (MRO) market exceeded $65 billion in 2012, with North America (the United States and Canada) accounting for $23.5 billion of the total. When induced and related economic effects are considered, the maintenance industry’s impact on the U.S. economy is $47 billion per year. The industry employs 306,000 workers in the United States. Aviation maintenance in North America also enjoys a positive balance of trade of more than a half billion dollars.

The contract maintenance industry is a stable and growing sector of the economy. According to ARSA’s 2012 member survey, there is optimism about economic prospects in 2013; 65 percent of survey respondents expect business and markets to grow.

While the aviation maintenance industry continues expanding, there are many looming threats to the sector. In particular, we look forward to working with you to ensure FAA guidance, policy, and interpretations are clear, concise, and consistently applied. Additionally, U.S. competitiveness in the international arena is undermined by a congressional restriction on the FAA’s ability to certificate new foreign repair stations.

A provision in VISION-100, an FAA reauthorization law enacted in 2003, required the TSA to issue security rules for all aviation repair stations by August 2004. When the TSA failed to meet that deadline, lawmakers (in the 9/11 Recommendation Implementation Act) demanded the security regulations be completed by August 2008. The penalty for the TSA’s failure to comply: Congress prohibited the FAA from issuing new foreign repair station certifications. This ban undermines U.S. leadership in maintenance services and prohibits American companies from competing in rapidly emerging markets, ceding this work to competitors certificated by other civil aviation authorities.

Nearly five years later, the TSA has yet to issue final repair station security regulations and the FAA remains banned from issuing new foreign repair station certificates. Given the TSA’s lack of progress toward finalizing repair station security rules, the DOT and FAA should work with the industry to urge Congress to allow the FAA to certificate new foreign repair stations once again. Prohibiting one federal agency (FAA) from doing its job because another (TSA) is ignoring congressional mandates is bad policy, does not work, and is hurting the industry’s global competitiveness. We look forward to working with you to ensure the FAA is allowed to do its job and once again certificate new foreign repair stations.

Repair stations have long been, and continue to be, a vital part of the aviation industry and our nation’s economy. As the U.S. economy recovers, we should nurture small and medium-sized aviation maintenance companies, not obstruct their ability to export and compete internationally. In order for repair stations to compete globally, policymakers must refrain from micromanaging the aviation maintenance sector. ARSA looks forward to working with the Department of Transportation to ensure the global competitiveness of the aviation industry.

Sincerely,

The Aviation Maintenance Industry

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