Walt is right on here. We run a Repair Station at work, and the amount of hoops we have to jump through to keep the feds happy is borderline ridiculous.
What you really need to complaining about is why this needs to be done by a Repair Station in the first place. As an A&P/IA I can perform and/or sign off annuals, overhauls, major structural repairs, mods, etc.... including some really critical, invasive stuff. But once every 2 years I have to bring my plane to a Repair Station where they take the newest kid in the shop, who may not even be an A&P, and have him perform what is essentially basic, routine inspections and maintenance.
The FAA really ought to consider letting A&P's, or at least IA's, do these checks. I'm fine with requiring equipment cals (my torque wrench requires one also), and special training.
I know that trying to answer questions that start with "why does the FAA..." is right up there with Kremlinology and can drive one absolutely mad, and I had a whole long post in works stepping through history... but I think it boils down to a few observations I've made over the years.
1. The FAA likes to be prescriptive. That is, it tends to gravitate towards rules (and ways of showing you meet the rules) that specify exactly
how something is to be done--
especially if, at the time said rule or guidance material is written, there is either only one known way of doing it, or pretty much everybody only does it one particular way. I can't decide if it's out of expediency ("are they doing it exactly the way it says?" is a lot easier to determine than "is what they're doing, doing what we want?") or an assumption that things won't appreciably change in the future. This is not new--go back to the original
CAR 52 from 11/1/1937 and it lays out (in some detail) the various tools repair stations need to keep on hand, even down to the weight of sand bags used to ballast down the tail when tailwheel airplanes are leveled.
2. The FAA does not like to change or update its assumptions; therefore whenever possible new things and changes will be forced into the metaphysical "box" of what came before even if it takes a lot of squinting. Once something is assumed to require super-specialized equipment and extra special skill (e.g. tuning and checking first-generation analog radio equipment, for our case) it will
always be assumed to require that--and if we look at (for example) the preamble/discussion to
CAR 24 amendment 24-49-7, it more or less says "things that take special equipment and tools can only be done at repair stations, because repair stations are the only places where you could get the special tools and equipment". Reaching back to the original CAR 52, work on "instruments" was considered one of those things. By
1952 radio and navigation equipment were included as "things that repair stations do".
So, even if it is now simple and at least
technically feasible for anyone with some mechanical sense and the ability to read to simply do the task, and well within the actual capability of any A&P, and
shouldn't realistically require all the paperwork and garbage of Repair Station certification to do... the government said 70+ years ago that stuff like this requires a Repair Station because back then it was complex and difficult and took special tools. And so, it has to be done by a Repair Station, with all the paperwork, manuals, org charts, additional recordkeeping, designated fixed facilities, and more, no matter how different the actual work is today vs. 70+ years ago... because 70+ years ago, it wasn't that way.
Unfortunately, as we all know it often literally takes an act of Congress to get the FAA to revisit old assumptions and remove/loosen restrictions. Whether it's innate conservatism ("it's still working so it doesn't need fixing"), resource limitations ("we don't have the time/manpower/budget to deal with that, and it's still working, so don't bother us till it isn't"), laziness ("I don't want to have to figure out and document new rules; besides it's still working") or what, I don't know. I've previously had conversations regarding regulatory changes and been told things like "we agree it doesn't make sense, but we don't know why it's written that way so we aren't changing it" and "we can't change that rule, because it's the rule and if we changed it, it wouldn't be the rule any more" and "that rule was carved on the third tablet, the one Moses dropped coming down the mountain... so we aren't changing it".
That's not to say changes
can't happen, but you have to show more than "the rule isn't doing any good and costs a lot of money" if you want to loosen a rule. Only if you can show "the rule now makes things worse" will it change. Unfortunately, trying to convince the FAA to pull transponder checks out from under the Repair Station umbrella because it's expensive and makes for a lot of paperwork will probably just generate a response along the lines of "sounds like a 'you' problem, not a 'me' problem".
