The Aeronautical Repair Station Association (ARSA) welcomed the FAA’s issuance of a policy statement clarifying when manufacturers must make instructions for continued airworthiness (ICA) available to maintenance providers. However, in comments submitted to the FAA about the policy, ARSA noted that the FAA “must address the fundamental issues associated with ICA before tackling their ‘availability.’” ARSA identified four key issues that the FAA should address: “Set the standard for the nature and extent of information that is ‘essential’ to the continued airworthiness of an aviation product; set the standard for content of ICA documents; determine exactly who is ‘required to comply’ with the ICA; and determine exactly how ICA should be ‘made available.’” While ARSA recognizes that the FAA policy seeks to help maintenance providers obtain correct ICA and reduce the possibility of maintenance error, ARSA noted, “It is unclear how the policy achieves those purposes.” To help the FAA, ARSA wrote its own version of the draft policy, which “establishes the agency’s position that its regulations will not be used to justify unnecessary contractual restrictions, and it strongly discourages such practices.”