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ARSA Action

As the voice of the aviation maintenance industry, ARSA continually works to improve the success and economic vitality of contract maintenance providers. To that end, here are just a few things the association has done for you lately.

2013

Action	Action Date	Response	Resp. Date
ARSA Praises European Legislators’ Efforts on ICAs	4/19/13	N/A
ARSA comments on Air Carrier Contract Maintenance Requirements; Proposed Rule	3/13/13	N/A

Click to view ARSA action from previous years.

2012

2012

Action	Action Date	Response	Resp. Date
ARSA comments on maintenance duty time	12/13/12	FAA response	12/26/12
ARSA letter on part marking during maintenance	12/11/12	FAA response	1/16/13
ARSA seeks clarification of FAA designee privilege	12/6/12	FAA response	4/11/13
ARSA comments to repair station NPRM	11/19/12	N/A
UAS integration must not distract FAA’s safety focus	11/8/12	FAA response	12/26/12
ARSA files comments to FAA AC 145-11	10/12/12	FAA response	10/19/12
ARSA seeks MMI clarification	10/4/12	FAA response	10/15/12
ARSA, industry allies request 145 extension	8/3/12	N/A
ARSA letter regarding SWA manual and FSDO inconsistencies	7/27/12	N/A
ARSA asks Supreme Court to intervene on ICA availability	6/11/12	N/A
ARSA recommends shedding light on federal rulemaking process	5/3/12	N/A
Comments to Docket NTSB-GC-2011-0001 (NPRM amendments to NTSB regulations)	4/9/12	N/A
Comments to Docket NTSB-GC-2011-0001 (ANPRM amendments to NTSB regulations)	3/9/12	N/A
ARSA requests FAA assistance to address MAG part tagging requirements	4/3/12	N/A
ARSA suggests changes to FAA Form 8310-3	1/23/12	N/A
ARSA weighs in on proposed FAA ICA policy	1/4/12	N/A

2011

2011

Action	Action Date	Response	Resp. Date
ARSA makes recommendations for audit review project	12/21/11	N/A
ARSA Looks for Proper FAA Interpretation of Rules for Major Repair	12/7/11	N/A
ARSA requests MAG clarification	11/10/11	EASA response	1/23/12
ARSA questions issuance of PMA for “consumables”	10/27/11	N/A
ARSA requests guidance on multiple part identification	10/19/11	FAA response	12/2/11
ARSA comments on FAA’s airworthiness directive interpretation	6/30/11	N/A
ARSA comments on FAA’s interpretation of duty & rest provisions	6/14/11	N/A
Airworthiness Directive interpretation; public comment period extension request	5/16/11	N/A
ARSA suggests changes to NTSB regulations	3/9/11	N/A
ARSA letter requesting FAA to clarify that fabrication of a part is not maintenance	3/8/11	FAA response	3/25/11
ARSA petition for writ of mandamus in drug and alcohol case	2/15/11	DC Court Of Appeals response	4/15/11
		ARSA response to petition	3/14/11
		US Court of Appeals response	3/2/11
Maintaining high-pressure cylinders under Titles 14 and 49 CFR	1/28/11	N/A

2010

2010

Action	Action Date	Response	Resp. Date
ARSA submits letter on measuring and test equipment calibration	12/13/10	FAA response	4/8/11
Letter regarding maintenance and preventive maintenance personnel duty time limitations	12/13/10	FAA response	4/14/11
		FAA Response	12/26/12
ARSA letter requesting that corrections be made to guidance regarding persons performing final inspections	11/30/10	N/A
ARSA submits recommendations for FAA’s proposed AMOC guidance	8/6/10	N/A
ARSA submits comments to FAA draft Advisory Circular 120-CMP	7/22/10	N/A
ARSA requests FAA to amend and reissue repair station Hazmat certification guidance	7/9/10	FAA response	10/15/10
ARSA welcomes Pistole to TSA	7/8/10	TSA response	8/4/10
ARSA letter to Office of Management and Budget on quarterly utilization report	4/30/10	N/A
ARSA urges EASA to clarify and adjust	4/20/10	N/A
ARSA letter on follow-up drug testing refusal to test and permanent disqualification from service	4/1/10	FAA response	7/23/10
ARSA’s comments to the 2009 TSA notice of proposed rulemaking	2/18/10	N/A
ARSA letter on alteration duties under drug and alcohol testing regulations	1/15/10	FAA response	1/19/10

2009

2009

Action	Action Date	Response	Resp. Date
ARSA letter on acceptance of common release certificate	10/27/09	EASA response	7/6/11
ARSA comments to draft AC 21.93-1 (Determining the classification of a change to type design)	10/22/09	N/A
ARSA letters regarding use of Component Maintenance Manuals (CMMs) to perform overhauls	5/29/09	FAA response	8/31/09
ARSA requests ICA legal interpretation	5/18/09	FAA response	8/9/12
ARSA request for guidance on interpretation of “current” for inspection programs	2/27/09	FAA response	6/19/09
ARSA request for legal interpretation on approval for return to service (*no document; Executive Director sent an email to FAA*)	1/7/09	FAA response	1/7/09

2008 and older

2008

Action	Action Date	Response	Resp. Date
ARSA letter requesting resolution of the issue maintaining pressure cylinders under Titles 14 and 49 CFR	12/19/08	N/A
ARSA seeks drug and alcohol exemption	11/21/08	FAA response	9/14/09
ARSA responds to EASA ICA letter	11/6/08	EASA rebuttal	6/8/09
ARSA letter on line maintenance authorization for “foreign” air carriers	8/11/08	FAA response	10/8/08
ARSA letter on Order 8300.14 — repair specifications	7/28/08	N/A
ARSA request urging swift action to protect industry from consequences of TSA Inaction	7/8/08	N/A
ARSA letter concerning the original approval of and proper procedures for refilling emergency medical kits	4/28/08
ARSA appeal for repair station preparation of airworthiness release/log entries under § 135.443	4/28/08	N/A

2007

Action	Action Date	Response	Resp. Date
ARSA support for Small Business Regulatory Improvement Act	12/13/07	N/A
ARSA notice regarding EASA NPA 2007-09	11/29/07	N/A
ARSA letter on limitations on issuance of repairman certificates	11/21/07	FAA response	12/11/07
		ARSA response	8/7/08
		ARSA second response	5/14/09
ARSA correspondence on unilateral changes to air agency operations specifications	11/21/07	N/A
ARSA letter requesting expedited issuance of repair station security regulations	11/21/07	FAA response	12/26/07
ARSA request for clarification/change to AC 65-25(D)	11/8/07	FAA response	7/11/08
ARSA request seeking clarification on compliance with AD 2003-12-07	10/27/07	FAA response	9/3/09
ARSA letter asking for clarification on contract maintenance functions	10/26/07	N/A
ARSA request on maintenance release for components	9/28/07	FAA response	10/10/07
ARSA comments on part 121 classification of major versus minor repairs and alterations	5/29/07	N/A
ARSA correspondence regarding EASA human factors training compliance	5/8/07	EASA response	8/20/07
ARSA request for assistance re: independently developed maintenance and alteration processes	5/1/07	N/A
Recording major repairs on Canadian products	4/9/07	N/A
ARSA letter to C.A.S.E., re: application of policies and procedures	4/5/07	N/A

2006

Action	Action Date	Response	Resp. Date
ARSA letter, re: EASA Instructions for Continued Airworthiness	11/6/06	N/A
ARSA requests clarification of FAA repair station human factors training requirements	7/27/06	FAA response	9/12/06

2005

Action	Action Date	Response	Resp. Date
ARSA asks FAA to amend Hazmat training rule	11/22/05	FAA response	3/13/06

2004

Action	Action Date	Response	Resp. Date
Letter asking for CSI request (technical data); letter sent by Erickson Air-Crane, Inc.	5/28/04	FAA response	2/23/10