Avionics News February 2016 - 14

F R O M
R I C
P E R I
A EA V I C E P R ES I D E N T O F G OV E R N M E N T & I N D U ST RY A F FA I RS

The Aircraft Electronics Association's international membership continues to grow. Currently, the AEA represents avionics
businesses in more than 40 countries throughout the world. To better serve the needs of the AEA's international membership,
the "International News and Regulatory Updates" section of Avionics News offers a greater focus on international regulatory
activity, international industry news and an international "Frequently Asked Questions" column to help promote standardization.
If you have comments about this section, send emails to avionicsnews@aea.net.

FREQUENTLY ASKED
QUESTIONS
United States
Repair station operations
The following information is from the
Federal Aviation Administration
regulations and guidance.

QUESTION:

Am I required to have a capability list?

ANSWER:

Paragraph 145.215 (a) states that "A certificated
repair station with a limited rating may perform maintenance, preventive maintenance or alterations on an
article if the article is listed on a current capability list
acceptable to the FAA or on the repair station's operations specifications."
So, if you have a "limited rating," you must list your
capabilities either on a repair station-managed capability list or an FAA-managed operations specifications.
Generally, it is the repair station's choice which option
it chooses. Both have advantages and disadvantages; the
repair station should consider where it is most advantageous to maintain the list of capabilities.
If the repair station is likely to have a constant, or
near constant, need to add and remove items from its

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capabilities, then a repair station-managed capability list is the most logical. On the other hand, if the
repair station's capabilities are reasonably static, in that
there are few changes to its capabilities, then an FAAmanaged capabilities listed on the operations specification would be more cost effective.
If you need a dynamic capability list, paragraph
145.215 (c) supports this by stating:
"An article may be listed on the capability list only
if the article is within the scope of the ratings of the
repair station's certificate, and only after the repair
station has performed a self-evaluation in accordance with the procedures under § 145.209(d)(2).
The repair station must perform this self-evaluation
to determine that the repair station has all of the
housing, facilities, equipment, material, technical
data, processes, and trained personnel in place to
perform the work on the article as required by Part
145. The repair station must retain on file documentation of the evaluation."
However, as you can see by the last sentence, "The
repair station must retain on file documentation of the
evaluation," there is an administrative burden associated with the repair station-maintained capability list
that is not required for the operations specification listing. And these records of capability list evaluations are
required to be kept as long as the item is listed on the
capability list.
Like many of the choices now available in 14 CFR
Part 145 for repair stations, the repair station should
determine which option best fits its business model.
Table of Contents for the Digital Edition of Avionics News February 2016
