This memorandum authorizes deviation to existing policy for management of 14 CFR
Part 145 repair stations outside of the United States due to safety concerns associated
with the coronavirus.
14 CFR Part 145.55 and FAA Order 8900.1, Volume 2, Chapter 11, Paragraph 2-1335
states that repair stations located outside the United States have a limited duration. Initial
certification is limited to 12 months from the date the certificate is issued. Thereafter, the
FAA may renew the certificate or rating for a 24 month period if the repair station has
operated in compliance with the applicable requirements of part 145 within the preceding
(12 month) period. In addition, the FAA must conduct annual surveillance of the facility.
Due to the unique dilemma surrounding the renewal of Air Agency Certificates outside of
the United States that is beyond FAA control we have made the determination to deviate
from FAA Order 8900.1, Volume 2, Chapter 11, Paragraph 2-1335 when certificates
cannot be renewed due to travel restrictions associated with the Coronavirus. Specifically
the note, which states; “Although the regulation indicates a 24-month renewal period,
inspectors must perform annual surveillance of repair stations, per current policy.”

The intent of this policy deviation is to provide for extensions of Air Agency Certificate
duration within the parameters addressed in 14 CFR Part 145.55. This policy deviation
does not provide for extensions of certificate durations for newly certificated repair
stations that are limited to an initial 12-month duration.

This memorandum supersedes the deviation dated 10 Dec 2019 to FAA Order 8130.2J,
AIR600-19-6C0-DM128, extending the date for mandatory use of the ASKME AWC
application tool to 30 Jun 2020.
Additionally, this memorandum authorizes an additional deviation to 8130.2J, Appendix
B, paragraph B-4, allowing an extension of the forwarding of completed airworthiness
certification files to AFB-710 to 60 calendar days after issuance of the certificate. It will
also remain in effect until 30 June 2020.

This memorandum clarifies that the FAA has broad authority to sign documents using digital
signatures in accordance with FAA Order 1370.121, FAA Information Security and Privacy
Program & Policy. This includes using digital signatures to sign type certificates, supplemental
type certificates, and letters of design approval, undue burden determinations, and other letters
to applicants/approval holders.

This memorandum also authorizes a deviation to FAA Order 8120.22A, Production Approval
Procedures to allow the use of digital signatures to sign production certificates, production
limitation records, technical standard order authorizations, parts manufacturer approval letters
and supplements. Until now, Order 8120.22A prohibited the use of “electronic” signatures to
sign these documents.

This memorandum authorizes a deviation to individual and organizational designee oversight
and training requirements that cannot be met due to widespread federal, state, and local
government and Centers for Disease Control and Prevention (CDC) precautions taken to limit
the spread of COVID-19.

This memorandum authorizes a deviation to FAA Order 8120.23A for FAA offices and FAA
personnel responsible for on-site certificate management (CM) oversight of production approval
holders’ (PAH) manufacturing facilities. This memo addresses requirements that cannot be met
due to federal, state, and local government and Centers for D