The Aeronautical Repair Station Association (ARSA) has issued a follow-up letter to the FAA’s directors of the aircraft certification service and the Flight Standards Service, requesting action on a request filed in February to resolve international regulatory issues associated with commercial parts and commercial off-the-shelf parts (COTS). Currently these parts must be accompanied by an FAA Form 8130-3 or EASA Form 1 when used in work subject to the Maintenance Annex Guidance.

The association, along with several other industry interest groups and private businesses, has been working for the past 19 months to mitigate problems related to parts documentation resulting from the U.S.-EU Bilateral Aviation Safety Agreement (BASA), which ARSA claims fails to acknowledge the equivalency of each system and generates “imposing paperwork requirements with no attendant safety benefit.” According to the association, certificate holders on both sides of the Atlantic must negotiate system differences between the two sides to avoid "untenable situations."