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 respec tfully request the Federal Aviation Administration (FAA) to extend the comm ent period for the Notice of Proposed Rulemaking (NPRM) titled “Repair St ations” docketed at FAA-2006-26408. 1 Specifically, we ask for an additional ninety (90) days from the present A ug. 20, 2012 deadline.

The undersigned associations represent a larg e 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 provi ded for NPRM review and comment development. The good cause and need for an extended comm ent period arises from the scope and extent of the proposed changes , coupled with effects it will have between and among the individual companies represent ed by the undersigned associations.

Additionally, a final rule will have significant operational an d 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 de partments dedicated to reviewing regulatory changes; their focus, necessarily, is complia nce with current regulat ions and day-to-day operations. More time is needed to reach t hese small businesses and gather their input

on the NPRM.

We have alerted our organizati ons’ members of the proposed changes and, in return, have heard some concerns over the plann ed modifications. Among those concerns is the impact the proposal would have on cu stomer and repair station interfaces (particularly repair stations with airline clientele), making coordination among and between the undersigned associat ions invaluable to this rulemaking process.

To the extent possible, each undersigned organi zation intends to consolidate comments

received from the individual member com panies, 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 inte rest to lengthen the comment; doing so will enable the full participation of co mpanies directly impacted.

We look forward to the agency’s favor able 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