I have received many inquiries about opening FAA repair stations in the USA and have had the pleasure of working with clients on many such projects. I have also worked with clients to open a Canadian AMO and Brasilian repair station, but those are ideas for another article someday.

Since this has become a topic of consideration in many a business plan, I thought I’d share some practical nuggets from experience for you to better develop your implementation and execution strategy. This information is an introductory overview and by no means a detailed listing of the process. In this article the following will be discussed:

• Business options to consider.
• Availability of maintenance manuals.
• Key personnel and Licenses.
• EASA and UK CAA Approval.
• Time and expense.
• The actual process.
• Do It Yourself (DIY)?
• Your relationship with the FAA.

Business options to consider:

Three options exist for most firms considering entry to the MRO (Maintenance, Repair & Overhaul) market.

• Buy an existing repair station.
• Partner with an existing repair station.
• Start a repair station from scratch.

If you’re considering buying or partnering, start your research at this FAA website:

https://www.faa.gov/av-info/facility-dashboard

When I last looked, there were 5,857 FAA repair stations globally. If you’re based outside the USA, consider that there may be an option in your locale.

Most of this article will be expressed from the point of view of starting from scratch.

Availability of maintenance manuals.

Before investing a penny in any venture, Royboy asks that you critically examine this issue.

If you can’t obtain the manuals, for example the applicable CMMs, Component Maintenance Manuals, then you can’t add those parts to your Capabilities List or Operations Specifications. For more information on this thorny issue, read my article on this topic.

https://www.aviationsuppliers.org/will-oems-make-manuals-available-to-independent-mros-industry-coalition-asks-for-faa-involvement

Key personnel and Licenses:

The two critical positions you must immediately give thought to are those of the Accountable Manager and Chief Inspector. Finding qualified people to fill these positions is difficult, so start your search early. If you’re challenged in this search yourself, this is a good time to consider the services of a headhunter, AKA Recruiter.

Think of the Accountable Manager as the person who will be the General Manager; the person who will run and be accountable for operations. This position does not require the person to be a licensed Technician. The actual title of the Person can be anything, for example, President, CEO, GM, Director, Manager, etc., but a person must be designated as the Accountable Manager.

‘Chief Inspector’ is now a dated title for repair stations which is no longer officially recognized in FAR 145 but continues to be used descriptively if not literally on organization charts and Rosters. Airlines do, however, continue to use the title officially per FAR 119. The Chief Inspector (or Quality Director, or Quality Manager, etc.) will have to be a certificated Mechanic. In the USA this means having:

• An FAA A&P Mechanic certificate. This is actually two certificates, Airframe and Powerplant. Depending on the work performed by the repair station, either an Airframe or Powerplant may suffice. For example, if you only work on engines, the Powerplant certificate will be adequate, or
• Be eligible for a Repairman certificate. This is only effective as long as the person is employed by the repair station, and a key requirement is 18 months’ experience in the area being applied for. The person can either bring this experience with them in the form of documented work at a previous repair station or have gained it within the existing repair station.

Can one person in my small repair station fill both positions? The answer is yes, but he/she must have the Mechanic or Repairman certificate.

EASA, UK CAA, and/or Brasil ANAC Approval:

Due to business considerations many of you will seek to have your USA based repair station approved by EASA, UK CAA, and/or Brasil ANAC. If so:

• You cannot apply for any of these until you have your FAA 145 Certificate. I usually counsel that the day after you are awarded your FAA Certificate is when to apply for these.
• Aviation authorities will only consider issuing these if there is a need. For example, to demonstrate this, you will have to present letters from aviation firms in those nations attesting to their intention to use you upon your certification.
• Aiding in these certifications is a key document called the MAG (Maintenance Annex Guidance) which is used as a primary guide telling you how to apply, renew, and what the contents of your manual called a Supplement, should address. There is a MAG for each of these Aviation Authorities, and fortunately there is much in common between the three.
• Note that each approval lasts 2 years and there is a fee for each one from the Aviation Authority.

Time and expense:

Timewise, budget at least a year. The FAA has been whittling away at the backlog that was created during the covid period, but even without such a backlog it remains a long and careful process for good reasons.

• Note that the FAA does not charge anything for domestic applications.
• If you choose to use consultants to assist you be prepared to budget between $20-45K depending on the scope of assistance you need.
• Additional investment costs will be associated with the work you intend to perform and may include:
  • Hand tools.
  • Measuring and testing equipment.
  • Calibration program.
  • Spare parts.
  • An ERP system.
  • Stands, jacks, power, air compressors.
  • Shelving, cranes, forklifts.
  • Subscriptions to OEM manuals. Most manuals have a listing of required tools and equipment including any consumables in the back of, for example, the CMM. This should give you a pretty good idea of what’s needed.

The actual process:

The FAA has pretty good website information on the process which consists of 5 Phases. Start your familiarization journey here:

https://www.faa.gov/licenses_certificates/airline_certification/part145_certification

The minute you decide you want to launch, submit the simple Preapplication Statement of Intent (PASI) FAA Form 8400-6 as soon as possible. This does not commit you to anything but places you in a queue; an important step given the backlog of applicants. Your bonafide commitment comes later when you submit the Formal Application.

If the process seems overly bureaucratic and time-consuming keep in mind that it really should be. The FAA is vetting you and your system. You are about to be certificated to perform work, which if improperly accomplished could lead to loss of life, accidents, or incidents.

Do It Yourself (DIY)?

If you decide you want to take on this project yourself here’s what I recommend:

• Get training on FAR 145 Repair Stations. There’s a good number of sources for this including:
  • https://arsa.org/training-2/
  • https://aea.net/training/
  • https://aerolearn.com/
  • https://myfaa.com/

• You will need to have customized manuals stating how you comply with the regulations. This is mainly for your employees but is especially important during your certification effort. Expect to spend a surprising amount of time negotiating with the FAA on the adequacy of your drafts given the scope of your operations; no two are alike. A good source for a template and if needed additional assistance is at:
  • https://arsa.org/publications-2/

Your Relationship with the FAA:

From day one you must focus on developing a relationship of mutual trust and respect.

• If you don’t understand something, ask.
• If you need help, reach out. The FAA has a great deal of resources and expertise.
• Be humble, expect to learn. Each project I have worked on I learned and learned and learned.
• Do not lie about anything! If you are asked anything potentially embarrassing, admit it, come clean, and get on with it.
• Communicate. You can’t overcommunicate during the certification process. During lulls in the process drop your contact an email saying you just hired some more employees, obtained more equipment, accomplished training, etc.
• The FAA won’t accept gifts or even allow you to pay for lunch.
• Don’t be afraid to push back. If you feel you’re unreasonably being asked to do something, respectfully state your case and ask for a second opinion. I have won some and lost some. Not once has this jeopardized the project.
• Don’t expect the FAA to be experts on the components, aircraft, or engines you’re working on. Instead, they’ll be looking to see that you are carefully following your repair station processes and procedures and meticulously accomplishing the tasks in the maintenance manual. That’s on you.

In this article I tried not to simply restate rules and regulations, but to focus on the practical aspects of this important process based on my experiences of working on more than a few certification projects. Best wishes to you!

Over ‘n out

Roy ‘Royboy’ Resto

www.aimsolutionsconsulting.com

This article was written without the use of AI.