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FAA Ready to Publish Study on Repair, Alteration and Fabrication

The FAA has published for comment their study on the state of the rules that govern aftermarket activities. The Study is best known as the Repair, Alteration and Fabrication Team Report, or RAFT Report. The report has been made available for public comment before it is released in final form.

The report was originally commissioned in response to concerns raised by large manufacturers. The large manufacturers complained that their smaller competitors were able to use rule permitting PMA, repair and alteration in order to compete in the aftermarket. The large manufacturers asked the FAA to look into these practices.

The FAA looked into the practices and compiled a report, but the results of the report were probably not what the large manufacturers wanted to hear. The report concludes that where the existing regulations are followed, repair, alteration and fabrication remain viable ways to extend the life of aircraft and to keep them airworthy.

The FAA is now inviting industry to review the draft report and offer our comments on the draft. This is a marvelous opportunity for industry to help shape the final language and recommendations of the report.
The draft report can be found online at

Comments should be emailed to The deadline for filing comments on the report is September 15, 2008.

About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.


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