August 3, 2012 

 

Submitted electronically to: http://www.regulations.gov 

Docket Management Operations, M-30 

U.S. Department of Transportation 

1200 New Jersey Ave. SE 

Room W12-140 

West Building Ground Floor 

Washington, DC 20590-0001 

 

RE: Docket No. FAA-2006-26408 

 Repair Stations; Proposed Rule 

 Request for Extension of Comment Period 

Dear Sir or Madam: 

Pursuant to 14 CFR § 11.47, we respectfully request the Federal Aviation 

Administration (FAA) to extend the comment period for the Notice of Proposed 

Rulemaking (NPRM) titled “Repair Stations” docketed at FAA-2006-26408.1

 Specifically, 

we ask for an additional ninety (90) days from the present Aug. 20, 2012 deadline. 

The undersigned associations represent a large cross-section of the aviation industry. 

Our members will be directly and significantly impacted by the changes contemplated in 

this rulemaking. 

It is vital that additional time be provided for NPRM review and comment development. 

The good cause and need for an extended comment period arises from the scope and 

extent of the proposed changes, coupled with effects it will have between and among 

the individual companies represented by the undersigned associations. 

Additionally, a final rule will have significant operational and financial ramifications for 

small businesses. A great many repair stations are small businesses in the true sense. 

As such, they do not have personnel or departments dedicated to reviewing regulatory 

changes; their focus, necessarily, is compliance with current regulations and day-to-day 

operations. More time is needed to reach these small businesses and gather their input 

on the NPRM. 

We have alerted our organizations’ members of the proposed changes and, in return, 

have heard some concerns over the planned modifications. Among those concerns is 

the impact the proposal would have on customer and repair station interfaces 

(particularly repair stations with airline clientele), making coordination among and 

between the undersigned associations invaluable to this rulemaking process. 

To the extent possible, each undersigned organization intends to consolidate comments 

received from the individual member companies, and to further coordinate comments 

 

1

 77 Fed. Reg. 30054 (May 21, 2012) 
August 3, 2012 

Docket Management Operations, M-30 

U.S. Department of Transportation

Page 2 

 

RE: Docket No. FAA-2006-26408 Repair Stations; Proposed Rule 

 Request for Extension of Comment Period 

among the group. The value of such comprehensive industry comments will 

undoubtedly enhance the viability of the final rule. 

It is therefore squarely in the public interest to lengthen the comment; doing so will 

enable the full participation of companies directly impacted. 

We look forward to the agency’s favorable response on this issue and the enhanced 

opportunity to provide comprehensive and meaningful comments to the proposed rule. 

Sincerely, 

Sarah MacLeod 

Aeronautical Repair Station Association 

Dan Elwell 

Aerospace Industries Association 

Ric Peri 

Aircraft Electronics Association 

Robert Hackman 

Aircraft Owners and Pilots Association 

Joe White 

Airlines for America

David York 

Helicopter Association International 

Eric Byer 

National Air Transportation Association 

Oakley Brooks 

National Air Carrier Association 

Roger Cohen 

Regional Airline Association