“The denials were not based upon whether the individuals were qualified to perform the work appropriate to the job of supervisor set forth in the rules governing repair stations. Nor were the denials based upon the individuals lacking the practical experience required. The FAA’s answer to the repairmen appellants was that an outdated advisory circular and equally stale internal guidance did not ‘allow’ such a rating. Ironically, the internal guidance upon which the FAA relies plainly states: Repairmen do not have a rating other than ‘Repairman.’”
Source: The Aeronautical Repair Station Association (ARSA), Executive Director Sarah MacLeod, commenting on an action in which ARSA took the unusual