Registration is open for ARSA’s 2018 Executive to Executive Briefings, Legislative Day and Annual Repair Symposium. (Click here to learn more and register now.)

Why You Should Be There – “A Treasure of Opportunity”

If you haven’t yet planned your trip to the nation’s capital from March 13-16, take a lesson from past attendees – both first-timers and experienced participants – about why you need to be at this year’s Annual Repair Symposium. The association’s premier event is part of an expansive week of executive branch briefings, legislative advocacy, regulatory engagement and professional networking. Don’t miss out on this “treasure of opportunity.”

To see what’s planned — an expanded, four-day schedule of meetings, presentations and interaction — to register and submit your sponsorship commitment, click here.

High-Level Access

Registration is officially open for ARSA’s 2018 Executive to Executive Briefings, Legislative Day and Annual Repair Symposium. (Click here to learn more and register now.)

The E2E

This year, ARSA’s team is planning a series of executive branch meetings on Tuesday, March 13 for senior industry executives. Modeled on the association’s successful Strategic Leadership Conference, the “Executive to Executive” (E2E) briefings will further raise visibility among policymakers and expand the scope of the repair station community’s premier event.

The association has requested secretary or administrator-level meetings at the FAA as well as the larger Department of Transportation in addition to the Departments of Commerce and State. E2E participants will spend their day moving among these agencies, getting face time with senior leaders and key policymakers within offices that impact the global aviation industry. While this additional day is open to any interested registrant, priority access is given to sponsors at the Platinum and Gold levels (for information about sponsorship opportunities, visit the event page).

Accommodations

A block of rooms is available at the preferred federal government rate for event participants at the Ritz-Carlton Pentagon City in Arlington, Virginia (where conference sessions will take place on Wednesday, Thursday and Friday). Attendees seeking accommodations for the night of Tuesday, March 12, should contact the reservation desk directly at 703.415.5000 (different rates apply).

Click here to reserve your room(s) by Feb. 27.

To see what’s planned — an expanded, four-day schedule of meetings, presentations and interaction — and to register, click here.

Book Your Room

Registration is officially open for ARSA’s 2018 Executive to Executive Briefings, Legislative Day and Annual Repair Symposium. (Click here to learn more and register now.)

A block of rooms is available at the preferred federal government rate for event participants at the Ritz-Carlton Pentagon City in Arlington, Virginia (where conference sessions will take place on Wednesday, Thursday and Friday). 

Click here to reserve your room(s) by Feb. 27.

This year, ARSA’s team is planning a series of executive branch meetings on Tuesday, March 13 for senior industry executives. Modeled on the association’s successful Strategic Leadership Conference, the “Executive to Executive” (E2E) briefings will further raise visibility among policymakers and expand the scope of the repair station community’s premier event. (Priority registration for this additional day is available to event sponsors at the Platinum and Gold levels.) Attendees seeking accommodations for the night of Tuesday, March 12, should contact the reservation desk directly at 703.415.5000.

To see what’s planned — an expanded, four-day schedule of meetings, presentations and interaction — and to register, click here.

Register Now

Registration is officially open for ARSA’s 2018 Executive to Executive Briefings, Legislative Day and Annual Repair Symposium.

Click here to reserve your spot now.

This year, ARSA’s team is planning a series of executive branch meetings on Tuesday, March 13 for senior industry executives. Modeled on the association’s successful Strategic Leadership Conference, the “Executive to Executive” (E2E) briefings will further raise visibility among policymakers and expand the scope of the repair station community’s premier event. (Priority registration for this additional day is available to event sponsors at the Platinum and Gold levels.)

To see what’s planned — an expanded, four-day schedule of meetings, presentations and interaction — and to register, click here.

A block of rooms has been reserved at the preferred federal government rate for event participants at the Ritz-Carlton Pentagon City in Arlington, Virginia (where conference sessions will take place on Wednesday, Thursday and Friday). Click here to reserve your room(s) by Feb. 27.

Annual Member Meeting Notification

ARSA bylaws require the association hold an annual member meeting at such time and place as determined by the Board of Directors. This important session is held annually in conjunction with the Annual Repair Symposium; this year it will take place during the Breakfast and Annual Report on Friday, March 16 at 8:00 a.m. at the Ritz Carlton, Pentagon City in Arlington, Virginia.

ARSA President Basil Barimo will address members regarding the state of the association. After Barimo’s presentation, attendees are welcomed and encouraged to discuss matters relevant to the association.

If you are unable to attend – click here to register for symposium – but would like to submit comments/questions to ARSA’s board, please use the form on arsa.org/contact.

Return to Top of Page

ARSA Works

What ARSA Has Done Lately – Fourth Quarter 2017

Each quarter ARSA’s executive team reports to the board of directors about the association’s broad efforts on behalf of the industry. Step into a board member’s shoes and review the “operations report” to see a sampling of what was going on at the end of 2017:

Communications and Surveys

• Conducted “Quick Question” Surveys on:
  • Meeting attendance
  • Business breakdown (sources of revenue)
  • Drone maintenance
• Began development of 2018 member survey (expected launch Feb. 5) (2017 report)
• Selected media coverage (from 16 total hits):
  • New ARSA Guidance Clarifies Duty-Free Aviation Parts Importation Rules
  • Component Warranty Claim Denial Common For Airlines
  • STCs and PMAs in aircraft maintenance – Aviation Maintenance Magazine
  • Don’t Hold for Applause

Events, Meetings and Training

• Executed successful Strategic Leadership Conference (Oct. 18 & 19). Highlights included:
• Keynote address by FAA Administrator Huerta, White House briefing, meeting with Sen. James Inhofe (R-Okla.) and congressional committee staff.
  • Began planning for Legislative Day & Symposium (March 13-16). Agenda includes:
    • New Executive to Executive (E2E) Forum on March 13 (meetings requested with FAA and Departments of State, Commerce, and Transportation)
    • Legislative Day on March 14 with lunch speaker Sen. Inhofe in Russell Senate Office Building and set piece meetings w/ key offices and committee staff
    • Symposium Keynote by FAA Associate Administrator Ali Bahrami (invited) and panels on Maintenance, Certification, Workforce, and Doing Business with Government
    • Training/breakout sessions on Repair Stations and SAS, Coordinated Inspection Policy
  • Christian Klein participated in a Department of Commerce meeting on EASA fees (Oct. 4).
  • Sarah MacLeod participated in FAA InfoShare (Oct. 17-20).
  • Christian Klein participated in teleconference meetings with partner organizations on the Remanufacturing Industries Council MOU Committee (Oct. 25).
  • Christian Klein, Brett Levanto and Sarah MacLeod were interviewed by Henry Canaday/AvWeek about 2018 ARSA priorities (Nov. 1).
  • Marshall Filler participated in the Maintenance Management Team (MMT) meeting in Ottawa (Nov. 9 and 10).
  • Marshall Filler participated in the initial meeting of the Stakeholder Collaboration Team (SCT) established by the FAA as part of the AIR Transformation Initiative (Nov. 13).
  • Christian Klein met with Sharon Pinkerton (A4A) to discuss shared legislative aviation priorities (Nov. 28).
  • Marshall Filler participated in the EASA EM.TEC meeting in Koln, Germany (Nov. 30)
  • Christian Klein, Brett Levanto and Sarah MacLeod meet with then-FAA Deputy Administrator Dan Elwell to discuss regulatory priorities (Nov. 29).
  • Several members of ARSA’s team attended the oral argument in U.S. Court of Appeals for the D.C. in a case involving ARSA member Airmotive Engineering (Dec. 4).
  • Christian Klein attended a meeting of the TSA’s Aviation Security Advisory Committee (Dec. 7).
  • Christian Klein met with Jim Roberts, Washington representative for ARSA member HEICO to discuss DOD procurement policy (Dec. 12)
  • Christian Klein met with ARSA Government Affairs Chairman Josh Krotec (First Aviation) to discuss legislative priorities (Dec. 13).
  • Sarah MacLeod participated in ARAC (Dec. 14).
  • Submitted draft training plan to FAA (Dorenda Baker) and continuing to work with agency to develop more sensible approach to acceptance of training providers.
  • Recorded four new online training sessions:
    • Importing Aircraft Parts for Maintenance – Establishing Duty Free Rates
    • Investigation & Enforcement Under Part 13
    • Part 39 (Airworthiness Directives) – Overview
    • Part 65 – Getting a Repairman’s Certificate

Regulatory

• Released Advisory 2017-01 (and associated training session) to help members import parts for repair and avoid unnecessary import duties. The document delves into relevant Customs regulations and legal opinions to answer a basic question: Must parts be airworthy to qualify for duty-free treatment? As a result, Christian Klien was invited to participate in and help coordinate a January 18^th webinar with the Commerce Department.
• Submitted white paper to White House recommending the Department of Defense revise policies to automatically accept FAA PMA parts and DER repairs for use on commercial derivative aircraft. Current DoD policy requires a cumbersome and duplicative source approval process. ARSA believes the policy change would give more ARSA members opportunities to do business with the DoD while saving the government money, improving efficiency, and enhancing readiness.
• Attended first meeting of EASA’s Engineering & Maintenance Technical Committee (EM.TEC).
• Supported development and execution of industry day agenda corresponding with quadrilateral Maintenance Management Team (MMT) meeting.
• Organized FAA-provided training session (held in January) on U.S.-China Implementation Procedures for Airworthiness.
• Publicized, at the request of the FAA, open industry enrollment for 2018 instances of agency training session “Certification and Surveillance of Part 145 Repair Stations.”

Legislative

• Continued campaign to include ARSA priorities in FAA reauthorization bill (see “box score” in ARSA on the Hill section)
• Tracked and reported on tax legislation.
• Christian Klein hosted a meet and greet with transportation lobbyists for House Education & Workforce Committee Member Ron Estes (R-Kan.).

ARAC Officially Forming Working Group on Part 145

During its December 2017 meeting, the Aviation Rulemaking Advisory Committee (ARAC), of which ARSA has been a member since its founding, accepted a task to review and reconcile the regulations and guidance respecting part 145 repair stations.

The Federal Register notice posted on Jan. 18 outlines the accepted task and requests interested parties to submit information for inclusion in the working group. If an individual is not accepted onto the working group, rest assured that ARSA will represent the interests of all repair stations in ensuring the agency’s guidance is fully aligned with the plain language of the regulation. The association is determined to ensure its members and other part 145 maintenance providers understand the difference between minimum standards in aviation safety regulations and best practices so appropriate business decisions can be made.

To review the notice, see the information below. Stay tuned to ARSA for more information…

Notice Title: Aviation Rulemaking Advisory Committee-New Task (Part 145 Working Group)
Published: 01/18/2018
Document #: 2018-00819
Introduction: The FAA has assigned the Aviation Rulemaking Advisory Committee (ARAC) a new task to provide recommendations regarding the agency’s guidance on the certification and oversight of all part 145 repair stations. This notice informs the public of the new ARAC activity and solicits membership for the new Part 145 Working Group.

To see all the ways ARSA works on behalf of the aviation community, visit the ARSA Works page.

Return to Top of Page

Regulatory Outlook

What Does Government Shutdown Mean for Repair Stations?

On Jan. 22, the president signed a short-term deal to end the three-day old federal government shutdown. The current bill reinstates funds for government programs only through Feb. 8, meaning the White House and Congress will be in the same position in just three weeks’ time. Considering this state of affairs and relative instability, it behooves anyone working in a regulated industry – businesses that regularly deal directly with the government – to understand how services will change during times when regulators may not be able to go to work (or at least have a full workforce).

For the aviation maintenance community, what is the impact of a government shutdown?

Given the large number of services considered “essential” – those related to security and public safety – some parts of the government that deal with aviation matters will remain open. Air traffic control and TSA security at airports won’t be affected. However, more 17,000 FAA personnel will be furloughed. 

The Department of Transportation has released a document that provides a comprehensive overview of how it and its subsidiaries will be affected by the shutdown. The following activities at FAA will be suspended until normal government operations resume:

• Development of new air traffic control specialists not certified to work a position.
• Issuance of airmen certificates.
• Approval of exemptions for unmanned aerial systems operations.
• The FAA’s aircraft registry will close, delaying deliveries of new aircraft, and stopping the sale of used planes.
• Aviation rulemaking.
• Facility security inspections, evaluations, audits and inspections.
• Routine personnel security background investigations.
• Development, operational testing, and evaluation of NextGen technologies.
• Development of NextGen safety standards.
• Air traffic performance analysis.
• Capital planning for FAA facilities and equipment.
• Investment planning and financial analysis.
• Dispute resolution.
• Audit and evaluation.
• Financial operations, controls, reporting and accountability.
• Most budgeting functions (except those necessary to provide necessary services to offices funded with multi-year appropriations and contract authority).
• Employee drug testing program.
• Law enforcement assistance support.
• Most administrative support functions not required for support of life and safety “excepted” positions.
• Congressional liaison services.

The following FAA activities are exempted and will continue during the shutdown:

• Air traffic control services.
• Maintenance and operation of navigational aids and other facilities, including support to reimbursable Department of Defense and Department of Homeland Security activities.
• Flight Standards field inspections (limited).
• Airmen medical certifications.
• Aircraft certification services (limited).
• Hazardous materials safety inspections.
• Security information communication services.
• Continuity of Operations Planning.
• Air Traffic Control Specialist (ATCS) medical clearances.
• Air traffic safety oversight (limited).
• On-call accident investigations.
• Commercial space launch oversight.
• Command, control, and communications (i.e., Regions and HQ Operations Centers).
• Foreign relations on aviation safety-related matters.

As part of our on-going advocacy on the industry’s behalf, ARSA is in constant contact with policymakers in the administration and Congress. Be ready to help the association provide real-life feedback on impacts of government work stoppages. If (or when) the government shuts down again, send emails to Executive Vice President Christian A. Klein (christian.klein@arsa.org) advising about the impact on your company and its ability to serve customers.

Final Documents/Your Two Cents

This list includes Federal Register publications, such as final rules, Advisory Circulars and policy statements, as well as proposed rules and policies of interest to ARSA members.

To view the list, click here.

Return to Top of Page

Legal Brief

Editor’s note: This material is provided as a service to association members for educational and informational purposes only. It does not constitute legal or professional advice and is not privileged or confidential.

Speaking the Same Language

By Sarah MacLeod, Executive Director

On Dec. 12, 2017, the FAA issued guidance on how its representatives should assess whether an airman or applicant has the necessary English language proficiency to hold or obtain an individual certificate. The guidance is based upon the standards issued by the International Civil Aviation Organization (ICAO) and states the FAA expects its applicants or certificate holders to have a ICAO Language Proficiency Ratings Scale Operational Level 4 English proficiency level.

This information is instructive for repair stations that must under 14 CFR § 145.151 have qualified personnel to perform work. This means all repair stations must ensure supervisors (§ 145.153), inspectors (§ 145.155) and persons authorized to approve work for return to service (§ 145.157) can “understand, read and write” English. For domestic repair stations, supervisors and those individuals having authority to issue approvals for return to service must be appropriately certificated under part 65 as a mechanic or repairman, which means those persons must also be able to speak English (§§ 65.71(a)(2) and 65.101(a)(6)).

It behooves all repair stations to have hiring and evaluation practices that ensure inspectors, supervisors and persons authorized to issue approvals for return to service are capable of understanding, reading and writing English. Thus, during the hiring or authorization process, the company needs to:

• Ask the individual to read from English-written aviation materials and have her/him write an explanation of the materials in English.
• Provide the individual with verbal instructions in normal-paced English and have her/him write down the instructions provided in English.

From the responses, a repair station can determine whether the individual provided an appropriate explanation of verbal and written information in the English language. The individual’s answers need to demonstrate the ability to read, write and understand aviation related material(s), instructions given, and questions asked in that language.

Repair stations in the United States also need to determine whether the mechanic or person recommended for a repairman certificate can speak and be understood in English “without undue focus on the pronunciation and speech.” In other words, will the individual’s verbal English skills enable effective communication within the repair station and with its customers and regulators? To make that assessment, the repair station needs to determine whether the individual can understand and participate in a normally-paced verbal exchange or conversation in English. Can the individual’s verbal explanation of what was read or heard be understood by a native English-speaking individual without undue concentration?

These determinations can be made during the hiring or authorization process by ensuring the individual is required to fill out an application that is provided in English, that must be completed in English. To ensure it is the individual that is actually completing the application, the repair station can provide those documents and make sure they are filled out “in person.” The ability to verbalize (i.e., speak) in understandable English can also be done in a systematic manner through normal conversation or during an in-person interview among and between other individuals that are either native English speaking or with various degrees of proficiency (as set forth in the ICAO standard referenced above).

English has always been the language of aviation and it should not be an undue burden on persons in the industry to ensure it is read, written and understood by persons performing key positions in a repair station. The ability to speak English clearly and concisely is a bit more problematic. Aviation is an international industry where English is a second language for many, even in countries where that language is supposedly “native.” Indeed, persons in the United States do not speak the “Queen’s” English and the pronunciation of “mandatory” can create heated discussion! Nonetheless, if we are open-minded during our evaluations, the ability to understand each other when discussing aviation-related materials can be determined fairly and equitably under the ICAO proficiency standard.

See the Guidance…

Return to Top of Page

ARSA on the Hill

FAA Authorization Approaches Red Zone, Get It Across the Goal Line at Legislative Day

By Christian A. Klein, Executive Vice President

With the current short-term authorization of the FAA set to expire on March 31, ARSA is ramping up its lobbying efforts and asking members to help us get a multi-year bill across the finish line.

Aviation-specific issues have also delayed action in both chambers. The House bill includes controversial language to privatize the nation’s Air Traffic Control (ATC) system, a policy change sought by the airline industry and strongly supported by T&I Chairman Bill Shuster (R-Pa.) but opposed by the business and general aviation community, as well as by many members of Congress from rural areas.The FAA bills pending in the House and Senate would provide budget certainty for the agency for the next several years and include important regulatory and workforce provisions sought by ARSA (see box score). Although both the House Transportation & Infrastructure Committee and Senate Commerce Committee passed separate versions of the FAA bill last June, they were overcome by other priorities – including tax reform.

FAA Bill Maintenance Amendments Box Score

The Senate bill doesn’t address ATC reform, but includes a provision sought by Commerce Committee Chairman John Thune (R-S.D.) and opposed by Senate Minority Leader Chuck Schumer (D-N.Y.) that would make pilot training rules more flexible. Schumer is preventing the bill from moving forward until the pilot training issue is resolved.

Chairman Thune told Politico in late January that other Senate priorities may prevent him from bringing the FAA bill to Senate floor before the end of February, as he’d hoped to do. “I really don’t want to do another extension, and I’ve made it very clear that I’d prefer that not be an option,” Thune said. “But I also understand with the pileup of stuff that we’re going to have in the month of February to deal with that it could get pushed.” Thune also appeared willing compromise on the pilot training issue to get a bill to the floor.

On the House side, Chairman Shuster is still trying to round up votes in support of his ATC reform idea. President Trump supports privatization and will likely have to engage personally on the issue to help Shuster get the votes he needs, particularly from skeptical rural state Republicans. Some have suggested that the ATC provisions might be removed from the bill and dealt with in the context of the broader infrastructure package Congress and the White House are expected to develop in the coming weeks.

Get to DC and Get Active!

With the uncertainty surrounding the FAA bill, ARSA’s advocacy is critical, both to moving the process forward and making sure the provisions we’ve fought so hard for remain in the bill. We need your help!

ARSA’s team is standing by to help attendees set up congressional meetings with key offices to make the time you invest as valuable as possible. For more information about Legislative Day or for advice on setting up Hill meetings, please contact ARSA Executive Vice President Christian Klein at christian.klein@arsa.org or 703.739.9543 ex. 106.

Rep. Estes Visits Wichita ARSA Member

Ask ARSA Government Affairs Vice Chairman Josh Krotec (First Aviation Services, Inc.) why hosting members of Congress at your facility is so important and you’ll get an earful. He also practices what he preaches and in January hosted Rep. Ron Estes (R-Kansas) at Aerospace Turbine Rotables, Inc., his company’s facility in Witchita.

The visit gave Rep. Estes, a member of the House Homeland Security and Education & Workforce Committees, an opportunity to learn more about the company and the maintenance industry and meet employees working on shop floor.

U.S. Rep. Ron Estes (center) tours Aerospace Turbine Rotables’ facility in Wichita during a January site visit. Estes visit to the facility was organized by ARSA Government Affairs Chairman Josh Krotec (far right).

Dave Seavey (left), vice president and general manager of Aerospace Turbine Rotables in Wichita, explains the facility’s work to U.S. Rep. Ron Estes as ARSA Government Affairs Chairman Josh Krotec looks on.

“This visit was an excellent opportunity both to showcase what our company and industry do and for our employees to gain a better understanding of how important engagement at all levels of government is to our – and their – success,” Krotec said.  “I encourage all our members to take advantage of the resources and assistance ARSA provides to build bridges between the maintenance industry and our elected officials.”

Congressional visits are important opportunity to help members of Congress understand how repair stations impact the local economy and contribute to the aviation industry’s outstanding safety record. As ARSA continues its work to build our sectors political visibility and muscle, we standing by to help members set up facility visits by current and prospective members of Congress. Contact ARSA Executive Vice President Christian Klein for more information.

Big Aviation Policy Leadership Changes Ahead in House

When the new Congress is gaveled into session in early 2019, there will be some big changes on the House Transportation Committee. Chairman Bill Shuster (R-Pa.) recently announced he would retire at the end of 2018. House GOP rules limit chairman to three two-year terms and Shuster has maxed out his time wielding the T&I gavel. A likely successor to Shuster is Rep. Sam Graves (R-Mo.), a senior member of the committee and enthusiastic private pilot. Also retiring at the end of this Congress is Aviation Subcommittee Chairman Frank LoBiondo (R-N.J.).

The changes at the top T&I underscore the need to build relationships up and down the committee roster, particularly with newer members of Congress.  

Return to Top of Page

Quality Time

Editor’s note: The views and opinions expressed by contributing authors do not necessarily state or reflect those of ARSA and shall not be used for endorsement purposes. 

Will Trump Infrastructure Plan Include One Million Missing Apprentices?

By Kermit Kaleba, Federal Policy Director, National Skills Coalition

On Jan. 30, President Trump offered his second “State of the Union” address. He talked about workforce development, promoting career and technical education, job training and vocational schools. He also used the opportunity to outline his case for new federal investment in infrastructure. It marked a return to a favorite theme from the 2016 campaign – where he repeatedly promised $1 trillion in new investments – and, given his historically low approval ratings, a chance to lead on an issue that has strong public support.

One thing the speech left us wondering about, though, is the mystery of the one million missing apprentices.

Last week, a number of news outlets reported on a leaked memo that outlined some of the key “funding principles” of the administration’s infrastructure plan, including new infrastructure “incentive” grants for state and local governments, funding for rural infrastructure projects and other priorities. However, the memo made no mention of investments in the skilled workforce that would be needed to support these projects, which is puzzling because back in June the administration released a short set of infrastructure principles that clearly identified a goal of supporting one million apprentices over two years.    

There’s a good case to be made for new public investments in roads, transit and other infrastructure projects. Last year, the American Society of Civil Engineers gave the nation’s overall infrastructure a D+ based on capacity, condition, resilience and other factors, highlighting the economic and public safety risks associated with a long history of deferred maintenance and neglect.  A major new investment in infrastructure would help the United States keep up with our international competitors in addition to helping our economy grow: One recent estimate indicated that a $1 trillion investment would create as many as 11 million new direct and indirect jobs.

But as NSC has argued, we can’t just invest in physical infrastructure and hope the jobs take care of themselves. If we’re going to take full advantage of this potential opportunity, we also need to invest in our human capital to ensure that workers have the skills they need to fill these jobs and employers can find the talent to stay on schedule.

Nearly half of all the jobs that would be created by a $1 trillion infrastructure package would require some form of postsecondary education or training, meaning that our community colleges, apprenticeship programs and other training providers would need to significantly ramp up to make sure we had the skilled workers to meet new demand. And that’s just to address new demand; a 2015 government report indicated that we need to increase our infrastructure workforce by 4.6 million workers by 2022 just to keep pace with current and projected hiring needs – a gap that would be exacerbated with a major new federal investments.

Unfortunately, the Trump administration’s record on skills hasn’t been very strong: In his most recent budget proposal, the President proposed huge cuts to job training programs, and while he has talked about the importance of apprenticeship, his Department of Labor still hasn’t announced how it will use more than $90 million in federal funds Congress set aside for this proven strategy last year. The administration also has not done much to ensure that communities hit hard by natural disasters – from Houston to Florida to Puerto Rico – have the construction and other infrastructure workers they need to rebuild.

Fortunately, there are some bipartisan solutions that could address these shortages and help ensure that infrastructure investments are coupled with new funding for targeted training. The BUILDS Act, introduced last year by Sen. Rob Portman (R-Ohio) and Tim Kaine (D-Va.) would provide dedicated funding to partnerships between infrastructure employers, community colleges and other stakeholders to ensure that any project receiving federal funding also has the resources to upskill workers and keep projects on track. The BUILDS Act is particularly focused on apprenticeship and other work-based learning strategies – which would fall right in line with the administration’s one million apprentice goal.

Let’s hope that the President follows through on his commitments to expand job opportunities as part of his infrastructure proposal and works with Congressional leaders to lift up ideas like the BUILDS Act.

As Federal Policy Director, Kermit directs NSC’s Washington-based efforts to advance a national skills strategy within federal legislation, agency regulation and national funding initiatives. Kermit assists state and local leaders in federal policy advocacy both within Washington and in their home districts and works with National Skills Coalition field staff and partner organizations to help improve state and local implementation of federal programs. To learn more, visit https://www.nationalskillscoalition.org.

Return to Top of Page

Training

ARSA, Barfield Team with Commerce Department for Civil Aviation Webinar

ARSA Executive Vice President Christian A. Klein and Bryan King of association member Barfield Precision Electronics participate in a special Department of Commerce webinar on the World Trade Organization Agreement on Trade in Civil Aircraft on Jan. 18. 

The webinar built on the work ARSA has done over the past year to clarify the applicability of the treaty to aircraft parts imported into the United States for repair (see below).  The session covered:

• What aircraft and aircraft parts are covered the agreement.
• What countries signed it and what are their obligations.
• How U.S. aerospace exporters benefit.
• How U.S. importers, including repair stations, can bring aircraft parts into the United States duty-free under the agreement.

The webinar is part of an effort by the Commerce Department’s International Trade Administration (ITA) to improve understanding about the opportunities and obligations created by the treaty within the government and among customs brokers, freight handlers and aviation companies. Klein discussed guidance ARSA created to help members navigate customs rules and take advantage of the agreement (order your copy below); King discussed his company’s experiences with the agreement and best practices to ensure compliance.  Commerce official Fred Elliot provided background on the civil aircraft agreement and ways in which it benefits importers and exporters.

“We sincerely appreciate both the opportunity to participate in the webinar and all the work ITA has done over the past year to help us resolve questions about the application of duties to imported parts,” Klein said.  “ITA’s work will help save U.S. repair station from paying customs duties they don’t owe and eliminate a lot of unnecessary administrative headaches.”

To listen to the Webinar, go to: www.mymeetings.com/nc/join.php?i=PWXW6334311&p=9228746&t=r   You will be required to install the Webex plug-in to listen.  The link will be active through mid-February.

The guidance is available for free to ARSA members and may be ordered by visiting arsa.org/publications or completing the form below.

To see all of the association’s resources for establishing duty-free rates, visit  arsa.org/regulatory/customs.

Access ARSA's Duty-Free Parts Importation Training On-Demand

On Oct. 11, Executive Vice President Christian A. Klein hosted an hour-long session on parts importation requirements. Klein reviewed the issues surrounding duty-free import of civil aviation parts and articles and introduced the association’s resources for managing the process. Attendees will be given access to the ARSA Advisory 2017-01, “Importing Parts for Repair Duty Free Under 19 CFR § 10.183.”

More information on the issue can be found at: arsa.org/regulatory/customs.

Session Information: Importing Aircraft Parts for Maintenance – Establishing Duty Free Rates

The session reviews the World Trade Organization’s exemption of civil aviation products and parts from import duties and describes the U.S. implementation of rules and guidance to support duty-free importation. It then walks through the association’s resources for ensuring that eligible imports are made free of Customs tariffs.

Click here to register and get access for 90 days.

Registration for an ARSA-provided training session includes:

• Unlimited access for 90 days to the recording made available after the live session is complete.
• A copy of the presentation and all reference material with links to relevant resources and citations.
• A certificate upon completion of the class, as well as any test material.

The association’s training program is provided through Obadal, Filler, MacLeod & Klein, PLC, the firm that manages ARSA. To go directly to OFMK’s online training portal, visit potomaclaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.

On Demand – FAA Training on China IPA

Click the image to register for the training session.

On Jan. 17, ARSA hosted an online training session led by FAA personnel on the Implementation Procedures for Airworthiness (IPA) established under the Bilateral Aviation Safety Agreement between the United States and China. This session mirrored the presentation delivered to FAA staff in November 2017, focusing on the use of the IPA when the FAA is acting as the certifying authority.  It was intended to provide industry with the background and major concepts of the agreement, and highlight specific areas relevant to CAAC validation of U.S. products.

The on-demand version of the session is available for registration and immediate access (registrants for the live session also get access to the recording for 90 days). The presenters are working on additional content based on questions asked during the live session. When this information is available, it will be uploaded along with the original session materials PDF.

Presenters

Tom Groves is a Supervisory Aerospace Engineer in the FAA’s Aircraft Certification Service Transport Standards Branch.  He is currently working on temporary assignment with the International Division, providing technical expertise to support development of high-priority bilateral agreements such as the EASA TIP and the IPAs with both China and Brazil.

Daniel Commins is a Foreign Affairs Specialist in the FAA’s Aircraft Certification Service International Division.  As the focal point for AIR’s international engagement with China, he manages the bilateral relationship and manages projects such as IPA development and other bilateral activity.

Agenda

(1) FAA – CAAC IPA Status and Background
(2) FAA – CAAC IPA Change Management Plan
(3) Q&A
(4) FAA – CAAC IPA Key Validation Concepts
(5) Validation Process Overview – FAA as the Certifying Authority
(6) Summary
(7) Q&A

Target Audience

Aviation industry professionals and stakeholders with interest in the FAA’s administration of international aviation agreements.

Registration

Special Session Price: $30 (ARSA Members and Non-Members)

Click here to register and get unlimited access for 90 days.

Registration for this ARSA-provided training session includes:

• Unlimited access to the recording for 90 days.
• A copy of the presentation and all reference material with links to relevant resources and citations.

The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit PotomacLaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.

Eight ARSA Training Sessions Acceptable for IA Renewal Credit

Eight of ARSA’s on-demand training sessions have been accepted by the FAA for Inspection Authorization renewal credit under 14 CFR § 65.93. Each session is currently available for registration and immediate access:

Click here to purchase all eight sessions (plus one required prerequisite) at a “bundled” discount – let ARSA take care of your IA renewal requirements this year.

ICA – The Basics
IA Course Acceptance: C-IND-IM-170830-K-010-002
This session provides an overview of the regulatory basis for ICA, including what documents are considered ICA and the obligations of design approval holders to prepare, furnish and otherwise make them available under 14 CFR § 21.50(b). It also covers the related regulations that apply to operators and maintenance providers regarding the use of ICA and their availability. Finally, it shows how the FAA has interpreted some of the more important ICA requirements in Order 8110.54.

ICA – Case Study: Testing Your Knowledge
IA Course Acceptance: C-IND-IM-170830-K-010-001
This session tests the participants’ knowledge of the ICA regulations in Title 14 CFR and FAA guidance by presenting several hypothetical case studies. Each one will focus on one or more of the significant ICA regulatory principles. 

Major/Minor – Major Pain Over a Minor Issue
IA Course Acceptance: C-IND-IM-170830-K-010-003
This session reviews the regulations that govern the terms “major” and “minor” in the world of civil aviation repairs and alterations. Learn the regulatory facts and how to train your FAA inspector so this minor issue doesn’t become a major pain in the derrière.

Part 21 – Overview
IA Course Acceptance: C-IND-IM-170830-K-010-004
This session provides an overview of the aviation safety regulations governing design and production of civil aviation products and articles as well as airworthiness certification of civil aircraft.

Part 65 – Getting a Mechanic’s Certificate
IA Course Acceptance: C-IND-IM-170830-K-010-005
This session reviews the requirements of 14 CFR part 65 subpart D, which concerns aviation mechanics. It walks through the requirements for an individual to apply for a mechanic’s certificate, then defines the privileges and limitations bestowed on that individual by his or her certificate. Finally, it covers the enhancements to a mechanic’s privileges produced by obtaining Inspection Authorization.

Recordkeeping for Mechanics
IA Course Acceptance: C-IND-IM-170830-K-010-006
This session defines the regulatory responsibilities of the operator versus the maintenance provider in creating and maintaining maintenance records, including how obligations can be shifted by contract, but not under aviation safety regulations. It also covers maintenance recordkeeping regulations; the documents essential to making airworthiness determinations.

Regulations Impacting the Purchase of Aircraft Parts
IA Course Acceptance: C-IND-IM-170830-K-010-007
This session reviews the civil aviation regulations in Title 14 Code of Federal Regulations that impact the purchase of civil aviation parts, as well as other requirements that should be considered.

What is “Acceptable to the Administrator”? – The Performance Rules of § 43.13
IA Course Acceptance: C-IND-IM-170830-K-010-008
This session provides an overview of the regulations that use the language “acceptable to” the Federal Aviation Administration and how to determine what makes something acceptable to the agency.

Registration for an ARSA-provided training session includes:

• Unlimited access for 90 days to the recording made available after the live session is complete.
• A copy of the presentation and all reference material with links to relevant resources and citations.
• A certificate upon completion of the class, as well as any test material.

The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit PotomacLaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.

Regulatory Compliance Training

Test your knowledge of 14 CFR § 65.16 – Change of name: Replacement of lost or destroyed certificate.

Click here to download the training sheet.

Return to Top of Page

Membership

Serving Through Survey Responses – Oliver Wyman and ARSA

On Jan. 22, Oliver Wyman opened its annual MRO survey. The global consulting firm has surveyed members of the maintenance, manufacturing, airline and aviation finance communities for more than a decade.  Through its partnership with ARSA – which produces the association’s annual market assessment – the survey team is inviting repair stations to participate.

The survey is open for responses until Feb. 2. Use the link below to access it and submit your response today.

Responding to Oliver Wyman’s questionnaire is the perfect warmup for ARSA’s Annual Member Survey – the first invitation will be delivered to the inboxes of all primary contacts on Feb. 5.

The entire aviation community, including ARSA and its members, benefits from good data. The time taken to respond is an investment that moves the industry forward:

(1) To access Oliver Wyman’s MRO Survey and submit your response, visit: https://oliverwyman.co1.qualtrics.com/jfe/form/SV_aW5LtIEMVwBWCdD. Direct any questions to the research team at MROsurvey@oliverwyman.com.

(2) Ensure the invitation for ARSA’s member survey will make it to your primary contact and that it gets the attention it deserves. (If you don’t know who the primary contact is, we can help.) Help your company submit its response Direct any questions to brett.levanto@arsa.org.

The 2018 Global Fleet & MRO Market Assessment, prepared by Oliver Wyman, will be unveiled in March during ARSA’s Executive to Executive Briefings, Legislative Day & Annual Repair Symposium. Click here to register now.

Welcome & Welcome Back – New & Renewing Members

ARSA’s members give the association life – its work on behalf of the maintenance community depends on the commitment of these organizations. Here’s to the companies that joined or renewed in January:

New Members

Carpe Diem Training Academy
First Aviation Services (Headquarters)
Helicopter Accessory Service East

Renewing Members (Member Since)

1st Choice Aerospace, Inc. (2006)
Aerosource, Inc.-SAFRAN (2006)
Air Shunt Instruments, Inc. (1999)
Airgroup Dynamics, Inc. (2007)
AvidAir Helicopter Supply, Inc. (2011)
Component Repair Technologies, Inc.   (1995)
Gulf Aerospace, Inc. (2005)
Ikhana Aircraft Services (2003)
Southern Air Repair Corp. (2016)

Quick Question – Symposium Opening Salvos

Each year at ARSA’s Annual Repair Symposium, Managing Director & General Counsel Marshall S. Filler and Executive Director Sarah MacLeod moderate a pair of “opening salvo” sessions on maintenance and certification issues. The discussions have become the cornerstone of the symposium’s value to the repair station community: direct engagement with international regulators.

Filler and MacLeod have confirmed participation from the FAA, EASA, ANAC and Transport Canada – the aviation world’s quadrilateral group will be represented with ARSA in the nation’s capital. Aviation professionals should be planning their attendance (click here to register and for accommodation information), and should take a moment to help the association prepare by providing insight: 

Note: The question is displayed in its own, embedded window. If the “Done” button is not visible on the screen, you must scroll within the survey window in order to submit your response .

For more information about this or any other question, contact Brett Levanto (brett.levanto@arsa.org).

Click here to see what questions have been asked and answered…and keep a lookout for more.

Quick Question Answered – Drone Maintenance Opportunity

Repair stations must plan carefully in order to perform work on existing aircraft fleets while meeting needs presented to the market by new equipment. Over the past few years, enhancing technical competencies and commercial demand have introduced unmanned aircraft systems into the airspace system.

International regulatory regimes are trying to catch up with quickly-advancing “drone” technology, but how are these aircraft making their way into maintenance facilities? ARSA asked and 19 repair stations answered:

Click the graphic to enlarge, then download.

For more information about this or any other question, contact Brett Levanto (brett.levanto@arsa.org).

Click here to see what questions have been asked and answered…and keep a lookout for more.

Don’t Let Technology Keep You from ARSA

Thanks to spam filters, firewalls and quarantines, it can sometimes be difficult for organizations like ARSA to get messages into your inbox. To ensure you have access to every newsletter, alert and update, ensure that the following domains are on your “safe list”:

@arsa.org
@potomac-law.com
@multibriefs.com

To know what to look for:

Weekly: The Dispatch newsletter is distributed every Wednesday.
Monthly: The hotline newsletter is distributed the first week of each month.
Various:  Member alerts are distributed as necessary – usually the association sends two or three each month.

To learn more about ARSA’s communications efforts – including how to advertise – visit arsa.org/news-media. For assistance with technical issues, consult your organization’s IT department/assistant as necessary.

A Member Asked…

Q: We are a European repair station having trouble with acceptance of so-called “expendable parts” during our incoming goods inspection.

EASA Part 145 doesn’t give us much on expendable parts. The company officially distinguishes between “parts” and “standard parts and raw/consumable parts and materials” as follows:

• Parts must be accompanied with required documentation, i.e., EASA Form 1, FAA 8130.
• Standard parts and raw/consumable parts and materials are acceptable with a Certificate of Conformity (CofC) with traceability to fabrication or OEM specifications.

“Expendable parts”, on the other hand, is a name given by the industry to parts for which no authorized repair procedure exists, and for which cost of repair would normally exceed that of a replacement, e.g., batteries, gauges, filters, switches, hoses. It’s not clear where these fall in the classification scheme identified above.

According EASA 145.A.42 these parts cannot be delivered other than with EASA Form 1 or FAA 8130-3. However, I have recent examples (a “standard” aircraft seat bottom gas spring unit or a USB power port supply) of these parts being delivered with a CofC.  Part suppliers (in these examples from the United States) remain steadfast in their opinion that an FAA 8130-3 is unnecessary.

These units enter our facility with CofC and are subsequently put in quarantine. Contrary to the EASA regulations, a CofC would be acceptable to me, based on eligibility for installation in the aircraft. This is a dilemma, and every day we have one or two examples to investigate and give our verdict.

My question is: do you recognize this issue and can you help in our understanding of the problem.  Ultimately, I’m looking for the proper tools to help my personnel make the right decisions whenever facing this “dilemma.”

A: As you know, ARSA is attempting to deal with the “commercial parts” versus “commercial-off-the-shelf” issue with the regulators.

Unfortunately, we will always have to deal with the difference between commercial terms and aviation terms.

For example, the term “expendable part” in the commercial world does not mean the item meets a standard or is a commercial off-the-shelf part. Your examples of “expendable parts” clearly would need a design and production approval in the United States and yes, an FAA Form 8130-3 if “exported” under the bilateral.

In fact, batteries have TSOs on both sides of the pond. “Consumable parts” have no regulatory meaning in the United States; at one time SOME were considered “commercial off-the-shelf parts” in the United States, but now even those parts are to have a design and production approval to be sold into aviation.

So, let’s be clear under the aviation safety regulations. Under the EASA rules and now under the FAA regulations, all parts that are may be installed on type certificated aircraft must be made under a design and production approval unless they fall into a specific exception. The only parts that fall under a specific exception in Europe are standard parts and some maintenance fabrication items. The only parts that fall under specific exceptions in the United States are items deemed “commercial” by the design approval holder (and listed as such in the applicable instructions for continued airworthiness), standard parts, owner and maintenance fabricated parts. All other items, including those termed as “commercial-off-the-shelf” or “expendable” or “consumable” or any other terminology used by the “aviation industry” are not excepted.

Standard parts must meet a specification recognized by the aviation authorities; normally, these are set by third-party standard setting organizations, with the specification readily available to the public (so the part can be inspected). Items designed as “standard” by the design approval holder are not recognized as such by the civil aviation authorities, thus “Airbus-” or “Boeing-” standard parts need the required documents (FAA Form 8130-3 or EASA Form 1) when being “exported” under the bilateral.

To confuse things even more, materials can be “proprietary” and designated specifically by the design approval holder as being “required” for maintenance or alteration purposes. Take for example, Henkel changing the name for its chromate conversion coating from Alodine to Bonderite. Under most aviation safety regulations, a material can be substituted if the maintenance provider determines that the same result will be obtained as that which is referenced in the manufacturer’s maintenance or alteration information. That ability disappears when the brand-named material is incorporated by reference in an Airworthiness Directive (AD). Unfortunately, Alodine, which is not a process but a brand name, is called out in numerous ADs. While there are only a few other companies making chromate conversion coatings, by calling out the brand name in a rule, the FAA looks for alternative means of compliance to use the “new name” along with an assurance that the chemical compound did not change along with the designation. This seems to be the case even though Bonderite says “known as Alodine.” European regulators are not quite as specific about changes to maintenance documents referenced in rules requiring a change to the rule—however, that only adds to the confusion.

The bottom line is that part 21 dictates the requirements for obtaining design and production approvals for any item that will be “installed” in a type certificate product. Materials that are used in maintenance may also need an approval, but since they are not “installed” in aircraft, the method for ensuring the proper item is used depends upon the result required—that the action return the item worked on to at least its original condition. Finally, terms used by the “industry” that do not meet or match the words used in the regulation tend to confuse rather than illuminate.

Make ARSA’s Voice Your Own: Advertise

ARSA has a menu of advertising opportunities for arsa.org, the hotline and the ARSA Dispatch.

Take advantage of these great opportunities today to showcase your company, a new product or event. For more information go to arsa.org/advertise.

Stand Up for ARSA by Sponsoring in 2018

In order to provide world-class resources for its members, the association depends on the commitment of the aviation community. By sponsoring events and activities, supporters can help ARSA’s work on behalf of repair stations to endure.

Need a place to start? For information about opportunities, including sponsorship of the 2018 Annual Repair Symposium (click here for info), contact Vice President of Communications Brett Levanto (brett.levanto@arsa.org).

Return to Top of Page

Resources

ARSA strives to provide resources to educate the general public about the work of the association’s member organizations; should you need to provide a quick reference or introductory overview to the global MRO industry, please utilize AVMRO.ARSA.org.

AVMRO Industry Roundup

ARSA monitors media coverage on aviation maintenance to spread the word about the valuable role repair stations play globally by providing jobs and economic opportunities and in civic engagement. These are some of this month’s top stories highlighting the industry’s contributions.

You can explore these stories through ARSA’s Dispatch news portal.

Return to Top of Page

Industry Calendar