2019 – Edition 2 – March 1
Table of Contents
Note: The order of material varies in hotline emails, but is always presented the same on this landing page. Readers scrolling through content on or printing this page will find it organized consistent with the table of contents.
2019 Annual Conference
ARSA Works
Legal Brief
ARSA on the Hill
Regulatory Update
Getting Facetime
Training
Membership
Resources
Industry Calendar
2019 Annual Conference
Advocacy
Registration is still open for ARSA’s 2019 Annual Conference. Make sure you’ve got the dates in your calendar (and that they are correct): March 12-15, 2019 in Arlington, Virginia and Washington, D.C.
Click here to register…or here for more information…then register.
Legislative Day – Telling the Industry’s Story
With less than two weeks to go until Legislative Day, which will take place on March 13 as part of the four-day Annual Conference, registrants should be at work scheduling personal meetings with their elected officials (ARSA EVP Christian Klein has been sending instructions and reference material to assist registrants and anyone needing assistance should contact Klein).
If you haven’t yet registered to take part, invest two minutes in the thoughts of past attendees – both first-timers and experienced participants – about the value of engaging with elected officials and the opportunity to do so with the repair station community:
The conference’s public agenda can be reviewed – and will continue to be updated – on the event page. Keep track of who will be featured at the conference, share your thoughts on what should be discussed and reserve your spot to take part with them.
Knowledge
Registration is still open for ARSA’s 2019 Annual Conference. Make sure you’ve got the dates in your calendar (and that they are correct): March 12-15, 2019 in Arlington, Virginia and Washington, D.C.
Click here to register…or here for more information…then register.
Networking at the Annual Conference – A “Priceless” Knowledge Base
Hear from some attendees at ARSA’s Annual Repair Symposium – both first-timers and experienced participants – about the value of networking at the repair station community’s premier event.
The conference’s public agenda can be reviewed – and will continue to be updated – on the event page. Keep track of who will be featured at the conference, share your thoughts on what should be discussed and reserve your spot to take part with them.
Opportunity
Registration is still open for ARSA’s 2019 Annual Conference. Make sure you’ve got the dates in your calendar (and that they are correct): March 12-15, 2019 in Arlington, Virginia and Washington, D.C.
Click here to register…or here for more information…then register.
The Symposium – A “Treasure of Opportunity”
Hear from some attendees at ARSA’s Annual Repair Symposium – both first-timers and experienced participants – why aviation professions should never miss the repair station community’s premier event.
The conference’s public agenda can be reviewed – and will continue to be updated – on the event page. Keep track of who will be featured at the conference, share your thoughts on what should be discussed and reserve your spot to take part with them.
The Platinum Sponsors
Lufthansa Technik & Getting Out of the Hangar
Special thanks to Lufthansa Technik for its Platinum Level Sponsorship of ARSA’s 2019 Annual Conference, which will be held in and around Washington, D.C. from March 12-15. The company has once again committed its support to the “Club Lounge Happy Hour,” a reception held on Thursday, March 14 after a full day of substantive content.
Lufthansa Technik is a worldwide enterprise with a long history of supporting ARSA’s work on behalf of the global industry. On its website, the 21,000+ employee company proclaims: “We are not an organization of people working in remote hangars, our heads stuffed with technical details, avoiding fresh air.”
Conference participants will experience this commitment to getting out of the hangar (with food, drinks and discussion in addition to fresh air) at the “Club Lounge.” And just like last year’s reception, which Lufthansa Technik also sponsored, the doors will open on time, precisely at 5:00 p.m. with expected German efficiency.
The conference’s public agenda can be reviewed – and will continue to be updated – on the event page. Keep track of who will be featured at the conference, share your thoughts on what should be discussed and reserve your spot to take part with them.
Moog Aircraft Group & Executive Engagement
Special thanks to Moog Aircraft Group for its Platinum Level Sponsorship of ARSA’s 2019 Annual Conference, which will be held in and around Washington, D.C. from March 12-15. The company has committed its support to the direct engagement between the association’s strongest supporters and senior executive branch officials during the second annual Executive to Executive Briefings Day on March 12.
Moog prides itself on being a company “whose people and products are at the forefront of the aerospace industry.” As a longtime support of ARSA’s events as well as a partner in its advocacy on behalf of certificate holders, Moog has invested in keeping the aviation maintenance community at the forefront of the policy process.
The “E2E” day was established in 2018 to provide a unique venue for members of the repair station community to personally impact that process. This year’s participants, all of whom represent sponsoring companies, will spend time with representatives from the Departments of State and Transportation as well as the FAA, then receive a briefing from IATA’s counsel for the 2018 settlement with CFM International, with a possible stop at the White House before lunch.
The conference’s public agenda can be reviewed – and will continue to be updated – on the event page. Keep track of who will be featured at the conference, share your thoughts on what should be discussed and reserve your spot to take part with them.
AeroKool & Warm Welcome
Special thanks to AeroKool for its Platinum Level Sponsorship of ARSA’s 2019 Annual Conference, which will be held in and around Washington, D.C. from March 12-15. To appropriately commemorate the company’s arrival as an event sponsor, it will provide a warm welcome during the Ice Breaker Reception on Wednesday, March 13.
Since its founding in 1959, AeroKool has grown into a world-class aviation organization. It holds numerous approvals and certifications – proudly displaying its ARSA membership among them on its website – and provides a range of services for both military and civilian customers.
In the midst of the week-long conference’s many meetings, discussions and presentations, the ARSA team recognizes personal connection as the foundation of a successful participant experience. This year, AeroKool’s commitment to the Ice Breaker Reception (which begins at 5:30 p.m.) will help provide time for considerable collegial bonding.
The conference’s public agenda can be reviewed – and will continue to be updated – on the event page. Keep track of who will be featured at the conference, share your thoughts on what should be discussed and reserve your spot to take part with them.
HAECO Americas & Good Policy
Special thanks to HAECO Americas for its Platinum Level Sponsorship of ARSA’s 2019 Annual Conference, which will be held in and around Washington, D.C. from March 12-15. The company chose to continue its enduring support for the association by committing its 2019 sponsorship to a successful Legislative Day.
A key component of ARSA’s spring event since the early 2000s, Legislative Day enables members of the aviation maintenance community – from technicians to C-level executives – to spend time on Capitol Hill. Throughout the day, participants meet with elected officials as well as congressional staff in order to describe, face-to-face, the impact of the repair station industry and the ways we can work together to help it thrive.
When ARSA’s team is on the Hill, it often reminds representatives and senators that in aviation “good safety is good business.” Thank you to HAECO for helping turn the good engagement of conference attendees into good policy from Washington.
The conference’s public agenda can be reviewed – and will continue to be updated – on the event page. Keep track of who will be featured at the conference, share your thoughts on what should be discussed and reserve your spot to take part with them.
ARSA Works
New DCT Notice Without New DCT Policy
On Feb. 22, the FAA issued Notice 8900.503, Policy Change for Applicants/Certificate Holders Submitting Information Using the SAS External Portal and Data Collection Tools (DCTs).
The Notice was issued because Notice 8900.451 (see below) with the same title expired on Feb. 20, 2019. The new Notice, which expires on Feb. 22, 2020, is substantially the same as the original and reiterated that the use of the SAS External Portal and DCTs remain voluntary.
FAA Lifts DCT Burden from Industry
Original Publication: February 23, 2018
On Feb. 20, FAA Notice 8900.451 became effective, setting the policy for completing data collection tools (DCTs) associated with the agency’s Safety Assurance System (SAS). The notice states that applicants and certificate holders shall not be required to complete any component of the DCTs until the FAA Flight Standards Service obtains approval from the Office of Management and Budget (OMB).
The policy update was issued in response to ARSA’s Feb. 1 letter on the subject. Citing the common practice of aviation safety inspectors requiring applicants and certificate holders to answer the DCTs’ numerous questions, the association highlighted the Paperwork Reduction Act’s (PRA) prohibition against federal agency information collection without OMB approval. Considering the substantial time and expense demanded, the association’s letter reminded the FAA of its statutory obligations.
“We recognize that the agency has instituted the SAS to implement a risk-based approach to its safety oversight responsibilities,” the letter said, noting the demand placed on the FAA by Congress as well as executive branch auditors to implement reasonable safety oversight with limited resources. “However, those pressures do not relieve the agency of its obligations under the laws passed by Congress; particularly those that reduce the burdens on small businesses.”
Notice 8900.451 acknowledges that the PRA applies to all Federal agencies and that the FAA must seek OMB approval “regardless of whether the collection is mandatory, voluntary, or required to obtain or retain a benefit”. Ironically, the document then states that “use of the external portal to collect [listed information] will be voluntary.” Finally, the policy attempts to make clear that the DCTs, “are intended for inspector use only and should not be given to the certificate holder to complete.”
“Regardless whether the agency obtains OMB approval, we expect to see some fundamental changes,” said ARSA Managing Director & General Counsel Marshall S. Filler, who signed the Feb. 1 letter. “As currently constituted we find it hard to believe the OMB would countenance a paperwork burden of the magnitude dropped on applicants and certificate holders under the current DCTs.”
To read the notice, click here. To read ARSA’s Feb. 1 letter,click here.
Any ARSA member that is told by an inspector to complete any portion of a DCT should contact the association immediately.
Editor’s Note: On Aug. 28, 2018, the agency sent ARSA a letter confirming the information provided in this update. The letter can be viewed by clicking here. For the sake of the record, the posting date of this update has not been altered despite this later addition.
IATA-CFMI Agreement Review
As reported by MRO Network, the commercial agreement between IATA and CFMI took effect on Feb. 28, seven months after its signature.
The resources linked from the following piece have been updated to help participants in ARSA’s 2019 Executive to Executive Briefings, which will kick off the association’s Annual Conference on March 12, prepare for a special presentation on the IATA-CFMI agreement.
Even for those not attending “E2E” day – attendance is limited only to event sponsors – reviewing the content below will provide useful reference.
IATA-CFMI Agreement Shows Market Cooperation, Not Complete Safety Solution
Original Publication: August 1, 2018
On July 31, the International Air Transport Association (IATA) announced an agreement with CFM International (CFMI) to increase engine maintenance competition. As a result, IATA has withdrawn its formal complaint filed with the Competition Directorate of the European Commission (EC) in March 2016.
CFMI, a 50/50 partnership between General Electric and Safran Aircraft Engines, agreed to adopt a set of “conduct policies” and associated implementation measures to enhance opportunities available to third-party providers of engine parts and maintenance services on the CFM and LEAP series engines. As described by IATA, CFMI has agreed to:
- License its Engine Shop Manual to an MRO facility even if it uses non-CFM parts.
- Permit the use of non-CFM parts or repairs by any licensee of the CFM Engine Shop Manual.
- Honor warranty coverage of the CFM components and repairs on a CFM engine even when the engine contains non-CFM parts or repairs.
- Grant airlines and third-party overhaul facilities the right to use the CFM Engine Shop Manual without a fee.
- Sell CFM parts and perform all parts repairs even when non-CFM parts or repairs are present in the engine.
“This agreement shows how powerful the global airline community can be when it is determined,” said Sarah MacLeod, ARSA executive director. “The airlines applied pressure and contractual obligations to address problems that go beyond minimum safety regulations. IATA ensured the contract ‘beneficiaries’ included airlines, lessors, parts manufacturers and independent repair stations. Aviation safety agencies grappling with maintenance data availability issues should not take this agreement as an answer to their obligations to establish and ensure compliance with basic safety requirements.”
ARSA assisted the EC in its initial investigation of IATA’s 2016 complaint by responding to a questionnaire seeking in-depth information on certain practices of specific design approval holders. The association’s responses focused on aviation safety rules and how the national aviation authorities’ failure to enforce regulations even-handedly directly affected competition.
“This agreement is an important lesson,” said Marshall S. Filler, ARSA managing director and general counsel. “IATA and CFMI deserve a lot of credit for its comprehensive nature – it establishes a model for future contract negotiations between aircraft purchasers and the entire manufacturing community.”
To see all of ARSA’s work related to instructions for continued airworthiness, click here.
To read IATA’s complete release on the CFMI agreement, click here.
To access the agreement via CFMI’s website, click here.
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.
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.
Guarding the Hen House
By Christian A. Klein, Executive Vice President
There’s an old adage that you shouldn’t let the fox guard the henhouse. Our founding fathers took that bit of farmers’ wisdom to heart in designing the way the federal government spends money. Article 1, Sec. 9, Clause 7 of the U.S. Constitution provides that: “No Money shall be drawn from the Treasury, but in Consequence of Appropriations made by Law.”
That provision was intended to be a check on the power of the executive branch. The president is constitutionally prohibited from spending money unless Congress has appropriated it. Over the years, the congressional power (and responsibility) to control federal spending has evolved into a budget process with two key components: authorization and appropriation.
Most of the committees on Capitol Hill are authorizing committees. ARSA pays particular attention to the Senate Commerce, Science and Transportation and House Transportation and Infrastructure Committees, which are the authorizing panels for the FAA. Reauthorization bills like the one enacted for the FAA last year establish priorities and inform agencies where Congress wants resources expended. They do that by “authorizing” money to be spent for one or more fiscal years (the FAA bill was a five-year authorization).
However, an authorization bill doesn’t actually provide any money to do what’s directed in the legislation. That’s the job of the House and Senate Appropriations Committees, which decide on an annual basis how much actually gets spent and where. Just as Congress’s constitutional appropriations power checks the power of the president, the appropriations committees act as a check on the authorizing committees. Appropriators make sure the discretionary spending of limited federal dollars is prioritized and reevaluated on an annual basis.
Not surprisingly, because they control the purse strings, the appropriations committees have traditionally been among the most powerful on Capitol Hill. At one time, appropriations subcommittee chairmen were referred to as the “cardinals” of the Capitol by D.C. insiders because they had so much influence. Some of that mystique has faded in recent years with the death of earmarks, a more disjointed annual appropriations process and the consolidation of more power in the hands of the speaker of the House. However, the appropriations committees are still very important.
The annual appropriations process generally starts with the release of the president’s budget. This year, it’s been delayed because of the government shutdown. Once the Trump administration has made its funding requests to Congress, the various appropriations subcommittees will get to work drafting their individual bills. At least in theory, the next step is for each of the bills to follow the process we all learned about in civics class (and celebrated on ARSA’s legislative webpage): subcommittee to full committee to House or Senate floor to conference committee back to the House and Senate for approval of the conference report and then to the White House for president’s signature. In practice, the process is much less systematic. If all the conferenced bills aren’t done by the end of the current fiscal year on Sept. 30, Congress must pass an omnibus bill to keep money flowing (either for a short time while a final spending deal is worked out or for the entire next fiscal year).
ARSA has long made FAA appropriations a priority. Our message to Congress for many years has been that given the highly-regulated nature of our industry, if the FAA doesn’t have the resources it needs to do its job, the industry’s efficiency will be undermined (for evidence, look no further than the recent government shutdown). But this year we’ll be delving deeper than ever before into the appropriations process, not just to make sure the FAA gets its money, but to ensure Congress appropriates funds for the new workforce development grant program created by last year’s FAA bill.
Conceiving and leading the coalition to create the new grant program was ARSA’s signature legislative achievement of 2018. The association, its members and allies in the aviation lobbying community all worked extremely hard to get the program enacted into law. Ultimately, Congress authorized $5 million per year to support efforts to recruit and train aviation maintenance technicians.
The coalition ARSA built to establish the grant program is now focused on getting money appropriated for it. Because Congress created a separate grant program for pilot education, the group has grown in recent weeks and is now advocating for full funding for both initiatives.
ARSA member participation in the effort is critical. This month, the legislative team completely revamped the association’s Workforce Legislation Action Center with new resources to help you help us move the ball forward. The site includes background on the programs, a draft email to send to congressional offices in support of our requested appropriation and a database of congressional contacts to help you identify the congressional staffers in your representative and senators’ offices responsible for transportation, workforce and appropriations issues. If you’re in the state or district of a member of Congress on the House Transportation and Housing and Urban Development appropriations subcommittee or its Senate counterpart (which have jurisdiction over our program), your involvement is especially critical.
On March 13, ARSA members will head to Capitol Hill for ARSA’s 2019 Legislative Day to lobby personally for workforce grant money. If you can’t be with us in person, you can still be in spirit. Please visit the Action Center and take a moment to send a note to the Hill in support of our efforts.
When it comes to the federal budget, there are a lot of foxes prowling and a limited number of chickens to go around. It’s up to us to make sure the money gets spent to help recruit and train the next generation of repair station industry leaders.
ARSA on the Hill
Engaging Through the Annual Conference
By Christian A. Klein, Executive Vice President
February is always a busy time for ARSA. The new congressional session is in full swing and the association’s dedicated team is hard at work preparing for the ARSA Annual Conference (March 12 to 15). What started decades ago as a symposium focused on regulatory issues has blossomed into a four-day gathering of maintenance sector leaders.
Regulatory advocacy and compliance are still central to ARSA’s mission and the content presented via the Symposium portion of the conference (this year on March 14 and 15) is still the core of the event. But as the association and its members have become more sophisticated, we’ve added a full day on Capitol Hill (Legislative Day on March 13) and a full day of meetings with various executive branch agencies and departments (Executive-to-Executive or “E2E” day on March 12). Those parts of the conference are opportunities for our members to build connections with policymakers and personally advance the industry’s agenda.
But what is that agenda? One of my tasks at the beginning of each year is to update ARSA’s legislative priorities. With FAA reauthorization complete and the emergence of new issues, this year I gave our priorities a complete overhaul. (In case you’re wondering, yes, I “disassembled, cleaned, inspected, repaired as necessary, and reassembled” it in accordance with 14 CFR § 43.2).
Our goal in crafting the legislative agenda is to reflect the policy objectives ARSA members (through the annual survey), the Board and government affairs committee members have told us are most important. The issues that ARSA is prioritizing in the first session of the 116th Congress and that will be the basis of conversations at this year’s Legislative Day and E2E are as follows:
Fully-Fund New Aviation Workforce Development Programs:
The aircraft maintenance technician shortage threatens to undermine the efficiency and competitiveness of the entire industry. To address the problem, as part of the 2018 FAA reauthorization law Congress created a new ARSA-proposed workforce development grant program supported by more than 30 national, state and local aviation organizations and labor organizations. Sec. 625 of the FAA law authorizes $5 million per year for five years to support initiatives to recruit and train the next generation of aviation maintenance technicians and $5 million per year to improve pilot education and address the pilot shortage. To be eligible for consideration, a maintenance-related grant application must be jointly submitted by an aviation business or union, school and local governmental entity.
ARSA is urging Congress to fully fund the workforce development grant programs as part of the appropriations process and use its oversight authority to ensure that the Department of Transportation rapidly initiates the programs to maximize their impact.
| Tell Congress to Make Aviation Workforce a Priority ARSA’s signature legislative victory in 2018 was convincing Congress to create a new grant program help repair stations recruit and train aviation maintenance technicians. Our priority now is getting the program funded … and we need your help.
ARSA has completely revamped our grant program action center to help you learn more about the issue and urge your members of Congress to appropriate the money we need. It’s quick and easy. Take a second now the tell your elected represents to make aviation workforce a priority! |
FAA Funding and Reauthorization Implementation:
In 2018, Congress enacted a new, long-term FAA authorization law to provide near-term certainty for the agency’s budget and enhance the quality of oversight. The legislation included several provisions to improve FAA operations and employee training.
ARSA is urging Congress to appropriate the funds necessary for the FAA to conduct efficient oversight of the industry. Congress must also fulfill its oversight responsibility and ensure that FAA implements the new law in a timely manner.
Insulating FAA and the Aviation Industry from Future Government Shutdowns:
Because of the strict regulatory oversight regime for the maintenance industry, our members’ work is intrinsically intertwined with that of the FAA. More than three quarters (77 percent) of respondents to a 2019 ARSA survey indicated their operations were negatively affected by suspension of the agency’s activities during the recent federal government shutdown. Delays in processing certificate applications, renewals and other approvals left repair stations, employees and customers in limbo.
ARSA believes Congress should enact legislation to protect the nation’s aviation system and the agencies that regulate it from the consequences any future appropriations lapse.
Refrain from Imposing Unnecessary Regulatory Mandates:
One of biggest long-term threats to the aviation maintenance sector is government intrusion through overregulation. The basic nature of the aviation industry demands that, for a company to be successful, safety and security must be the paramount concerns. Operators and airlines will not do business with companies that put passengers and valuable business assets (i.e., aircraft) at risk. Put simply: safety is good business.
A priority for ARSA is ensuring that Congress and FAA understand that government and the industry share the same safety goals. Legislators and regulators should refrain from micromanaging through unnecessary agency action.
Encourage Bilateral Aviation Safety Agreement (BASAs):
BASAs are government-to-government agreements that reduce regulatory compliance costs for businesses by allowing cooperation between aviation safety regulators to enhance efficiencies and limit duplicative oversight. BASAs also give U.S. companies access to foreign customers.
More than 1,400 U.S. repair stations are approved to work on European-registered aircraft and related components under the U.S.-European Union BASA. According to a recent ARSA study, American repair stations pay a 300 percent mark-up when applying for certification by “foreign” civil aviation authorities (CAAs) when the home country does not have a BASA with the United States. This additional cost burden undermines profitability, particularly for smaller companies.
ARSA believes Congress should encourage the FAA to enter into more BASAs to reduce compliance costs, improve access to foreign customers and make oversight more efficient. ARSA believes Congress should refrain from enacting legislation that disrupts current international aviation accords.
Consistent Enforcement of FAA Maintenance Manual Rules:
The FAA aggressively enforces the requirement that repair stations possess “current” versions of maintenance manuals (14 CFR § 145.109(d)) while the agency fails to enforce the regulation requiring design approval holders to create and make that same maintenance data available (14 CFR § 21.50(b)). As a result, many repair station small businesses face unnecessary administrative and financial burdens and loss of business opportunities.
ARSA believes Congress should encourage the FAA to either enforce the rules consistently and fairly or update them to relieve undue burdens on industry.
Invest in Airport Infrastructure:
The American Society of Civil Engineers has given the nation’s airport infrastructure a grade of “D.” The Airports Council International has estimated that airports will require almost $100 billion for capital improvements over the next half decade. With infrastructure at the top of the legislative agenda, ARSA believes Congress must look for fiscally-responsible ways to expand America’s airport capacity to improve passenger mobility, enhance efficiency, and ensure the continued growth, safety and health of our aviation system.
Improve Competition for Department of Defense (DoD) Maintenance Contracts:
DoD can save hundreds of millions – if not billions – of dollars by more widely adopting commercial best practices. ARSA is lobbying Congress to encourage DoD to improve competition for maintenance on DoD’s fleet of civilian derivative aircraft by more-readily accepting FAA approvals (e.g., Parts Manufacturer Approval (PMA) parts and Designated Engineering Representative (DER) repairs). Doing so will reduce maintenance costs, improve readiness, reduce bureaucratic duplication and expand government contracting opportunities for small and medium aviation maintenance businesses.
So, what do you think? Is ARSA’s legislative program focused on the right issues? Is there anything else that should be on the list? Is there anything you disagree with? Shoot me a note at christian.klein@arsa.org and let me know.
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Want to Learn More About ARSA PAC? ARSA’s Political Action Committee helps elect congressional candidates who share ARSA’s commitment to better regulation and a strong aviation maintenance sector. In this critical election year, ARSA PAC has never been more important. But ARSA is prohibited from sending PAC information to members who haven’t opted in to receive it. Please take a second to give us prior approval to talk to you about ARSA PAC. Doing so in no way obligates you to support PAC. It just opens the lines of communication. Click here to give ARSA your consent today. |
ARSA Joins Effort to Limit Shutdown Impacts
Even as Congress worked to finalize an agreement to prevent another shutdown and fund the federal government through the end of September, lawmakers were considering ways to insulate the aviation sector from a future FAA appropriations lapse.
ARSA joined with industry allies on a Feb. 12 letter to the leaders of the House Transportation & Infrastructure (T&I) Committee coordinated by the General Aviation Manufacturers Association expressing support for the Aviation Funding Stability Act of 2019 (H.R. 1108). The bipartisan bill introduced by T&I Chairman Peter DeFazio would authorize the FAA to draw from the Airport and Airway Trust Fund (AATF) in the event of a future government shutdown, preventing disruptions to agency operations.
To build the case for the legislation, the House Aviation Subcommittee held a hearing Feb. 13 to document the shutdown’s impact on the nation’s aviation system. ARSA’s statement for the hearing record detailed how repair stations were affected during the shutdown and drew from information provided by members in response to an ARSA “quick question” survey conducted in January. More than three quarters of respondents said the shutdown negatively impacted their companies, either directly or indirectly.
To read the full industry letter, click here.
To read ARSA’s complete statement, click here.
From the Market
Editor’s note: The views and opinions expressed by contributing authors do not state or reflect those of ARSA and shall not be used for endorsement purposes.
Aviation’s New Era –Remote Connectivity
By Genevieve Pfeiffer, Content Marketing Manager, CLOUDVISIT
Maintenance, preventive maintenance and alteration activities are essential to airworthiness, in turn the “human element” – each technician and inspector – is vital. The technician must perform multiple high-skill tasks and the inspector confirm these tasks are completed properly. For both, not to mention their employer, time is of the essence.
Sure, you say. Tell me something new!
Well, in 2018, ARSA and 15 industry allies proposed guidelines to the FAA on remote connectivity technology and tools through a draft Advisory Circular titled ‘Guidance for Using Remote Connectivity Technology and Tools.’ While the FAA consults these guidelines and potentially issues policies or other guidance, remote connectivity is currently acceptable under the U.S. aviation safety rules governing maintenance activities. So, for aviation businesses it is important to know how this technology can increase accuracy and efficiency while saving time and without compromising safety.
What Is Remote Connectivity, And How Does It Affect The Maintenance Provider?
As described by the FAA in an April 2018 presentation regarding certification projects, remote connectivity “enable[s] an FAA-authorized witness to remotely witness engineering tests, conformity inspections, and issue airworthiness approvals using video.” This allows the inspector to validate actions remotely and efficiently.
According to the industry’s draft AC, remote witnessing can be conducted through “video, live-stream and other visual and audio delivery methods.” Depending on the technology or tool, the technician may need only uses a common smart phone or tablet with a broad-band connection as long as the technology provides “the same (or better) visual acuity as would be the case of an in-person-on-premise observation.” Using an appropriate device and connection, the inspector can view the parts serviced to confirm correct actions were taken. The inspector can use the device and connectivity to view a live-stream video, and advise the technician as necessary.
What You Need To Know About Remote Connectivity Guidelines
Section 5 of the draft AC explains the general requirements for using remote connectivity: it covers the individuals using the tools as well as the equipment and technology.
As with any technology or tool, the technician must be trained to ensure proper usage. Ultimately, the combination “provides the same level of acumen and capability” as if the inspector was in-person-on-premise to provide the assurance that the activity is accomplished correctly.
Depending on the task or activity, items such as the field of view, the accuracy of the display, and whether two-way communication is consistent must be satisfied. While the ability of equipment to produce digital records without degradation is not a regulatory requirement, its value does support the activity and business requirements.
Environmental conditions are another important factor. “Weather, environment, and/or special lighting conditions,” must be taken into account so that viewability and integrity is ensured. The inspector must be able to view the action or activity without impairment. If the tool or technology malfunctions, or if the quality of the recording does not enable the inspector to determine the necessary tasks were accomplished properly, then “the non-compliance aspects must be repeated” so the resulting live-stream provides the same quality as in-person-on-premise.
Requirements of the Inspector
The inspector must be able to use tools, technology, or equipment properly. The tools and technology must enable the inspector to “verify required elements” and “properly address any non-compliance or anomalies” in order to assure tasks or activities have been properly accomplished and that the “results are valid and documented as required by regulations.”
All personnel involved in the use of the equipment and technology should be aware of how to properly utilize enhanced functionalities within existing regulatory requirements. Remote technology, when utilized properly, can assist maintenance personnel in performing work with greater speed and efficiency while ensuring optimal safety.
CloudVisit MRO software provides Aviation Maintenance Software for remote inspection activities. Aviation Maintenance Software enables users to remotely inspect and document completed work to maximize safety, efficiency, and accuracy. For more information about the company and its tools, visit www.cloudvisit.site or call 845-809-5770.
Training
ARSA Human Factors Training Accepted for IA Renewal Credit
ARSA is growing its library of human factors-related training sessions. The first three, which introduce key aspects of human factors in aviation maintenance, are now available for immediate on-demand viewing and have been accepted by the FAA Safety Team for credit towards Inspection Authorization renewal under § 65.93(a)(4):
Human Factors in Context
IA Course Acceptance: C-IND-IM-190130-K-012-003
Instructors: Sarah MacLeod, Christian A. Klein & Brett Levanto
Description: This session provides a general introduction to “human factors” and puts their consideration into an aviation context. It reviews the general definitions and key components of human factors understanding and reviews the rules and guidance on the subject from various aviation regulatory and oversight organizations.
Click here to register and get access for 90 days.
The Dirty Dozen – Human Factors Overview
IA Course Acceptance: C-IND-IM-190130-K-012-004
Instructors: Sarah MacLeod, Christian A. Klein & Brett Levanto
Description: This session introduces the “Dirty Dozen,” 12 common factors that impact human performance. It discusses these in the context of the aviation maintenance industry, describes how they lead to problems, suggests ways to mitigate consequences and explains how all 12 are interconnected.
Click here to register and get access for 90 days.
The Dirty Dozen In Depth – Communication
IA Course Acceptance: C-IND-IM-190130-K-012-005
Instructors: Sarah MacLeod, Christian A. Klein & Brett Levanto
Description: This course discusses communication in the aviation maintenance environment, factors that can interfere with communication and ways to mitigate those factors.
Click here to register and get access for 90 days.
Click here to purchase all human factors content together and save.
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.
From the FAA – IA Renewal Credit
In March of each year, certificated mechanics holding inspection authorization must confirm to the agency that they have completed necessary activities as defined in § 65.93. A key option provided in the section is to have: “Attended and successfully completed a refresher course, acceptable to the Administrator, of not less than 8 hours of instruction.”
A number of industry organizations, including ARSA, have produced training material and dealt with the agency’s process for gaining acceptability under § 65.93. Mechanics wishing to avail themselves of these sessions need a way to figure out what options are available.
ARSA members need not look far, as the association currently has 11 hours of acceptable training available (more than the eight required to maintain an IA). Each session is available for immediate access, unlimited viewing for 90 days and can be found on the association’s training page:
For readers curious about what else might be available, the agency produces and regularly updates (twice monthly) its list of courses accepted for IA renewal credit.
Click here to access the searchable list.
Regulatory Compliance Training
Test your knowledge of 14 CFR § 65.93 – Inspection authorization renewal.
Click here to download the training sheet.
Membership
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 February:
New Members (Member Category)
Silver Sky Aviation, R01
LAUNCH Technical Workforce Solutions, R01
Aero Products Component Services, Inc., R03
Aircraft Armature Inc. dba TSA Rewinds Florida, Inc., R02
Sumitomo Precision USA Repair Station, R01
Rocky Mountain Propellers, Inc., R01
Renewing Members (Member Category, Member Since)
AerSale, Inc.-Aero Mechanical Industries, R04, 2011
Air-Cert, Inc., R01, 1990
Aircraft & Component Technical Services, R01, 2009
Airgroup Dynamics, Inc., R03, 2007
AIRTOMIC, LLC, R03, 2018
BBA Aviation, Corp, 2013
C&S Propeller, LLC, R01, 2016
Cobalt Aero Services, R01, 2012
Consolidated Turbine Specialists, LLC, R03, 2018
E.B. Airfoils, LLC., R03, 2001
Erickson Incorporated dba Erickson Air-Crane, R05, 1997
Genesis Aviation, Inc., R04, 1994
JAS Services/Team J.A.S., R01, 2004
Lufthansa Technik AG, Corp, 2001
Moog, Inc., Corp, 1997
North Star Aerospace, Inc., R01, 2006
PAS MRO, Inc., R01, 2013
Rapco, Inc., Assoc, 1990
Southwest Airlines, R06, 2005
The Giles Group, Affil, 2013
Quick Question [Extended] – “The Opening Salvo”
Each year during the symposium portion of ARSA’s Annual Conference, Managing Director & General Counsel Marshall S. Filler and Executive Director Sarah MacLeod moderate an “opening salvo” session on maintenance and certification issues. The discussions, which have evolved into a two-plus hour intensive exploration of all regulatory matters impacting the maintenance community, is the cornerstone of the symposium’s value to the repair station community: direct engagement with international aviation authorities.
Filler and MacLeod have once again 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 should take a moment to help the association prepare by providing insight:
If the embedded survey does not appear/load, open the survey independently by visiting https://www.surveymonkey.com/r/ARSAConf-OS:
Click here to see what questions have been asked and answered…and keep a lookout for more.
For more information about this or any other question, contact Brett Levanto (brett.levanto@arsa.org).
2019 NextGen Awards – Celebrate Young Talent
ARSA’s commitment to building the aviation maintenance workforce of the future means celebrating the excellence of the men and women who already keep the world safely in flight. The association encourages its members to celebrate outstanding young personnel through Aircraft Maintenance Technology Magazine’s 2019 Next Gen Awards, which recognizes young aviation professionals on whom the flying world will depend for decades.
Criteria for selection include job commitment, industry involvement and contribution, professional achievement and innovation. Anyone working in any aviation maintenance field who will be 39 years old or younger on June 30, 2019 is eligible for nomination. Winners will be featured in the magazine’s August/September issue and celebrated on AviationPros.com.
Click here to learn more and nominate someone today. The deadline for submissions is June 15, 2019.
Anyone submitting a nomination is encouraged to contact ARSA’s Vice President of Operations Brett Levanto, so the association can join AMT Magazine in celebrating the best of this community’s young talent. Through its experience with the awards program in 2015, ARSA saw first-hand the vital importance of celebrating the maintenance industry’s most valuable resource: its people.
While celebrating [the NextGen honorees’] hard work, let’s consider how to help them move ahead,” Levanto said, encouraging broader industry action. “Nurture their careers while attracting new applicants to work and learn alongside them.”
Past NextGen awards…
Click the cover image to jump into the edition.
Click the cover image to access the full edition.
Making Good
This year's AMT Magazine annual class of Next Gen Award winners includes young professionals from five ARSA member companies.
Click here to view the August/September 2018 issue of AMT Magazine.
Click to Access the November 2017 Editorial "Don't Hold for Applause" by ARSA VP of Communications Brett Levanto
November 29, 2016
On Nov. 28, AMT Magazine announced its 2016 class of NextGen Award winners. For the second year, the publication honored up-and-coming talent by recognizing maintenance engineers, technicians and support staff under 40 years old.
The list includes eight winners from seven different ARSA member organizations:
- Kevin Easley, Maintenance Supervisor, AAR Aircraft Services
- Hilary Kerkstra, Turbine Engine Technician, Pratt & Whitney Engine Services
- Carolyn Rena Kincaid, Manager of Training and Records Dept., AAR Aircraft Services
- Joshua Krotec, Senior Vice President, First Aviation Services
- Tony Oggs, Field Service Lead Technician, StandardAero
- Josh Riehle, Director of Quality, HAECO Cabin Solutions
- John Wing, Program Manager, PEMCO World Air Services
- Xiang Yao, Lead Aviation Maintenance Technician, FedEx
“Taking pride in this group is easy,” said Brett Levanto, ARSA’s vice president of communications and 2015 NextGen honoree. “Every person – yes, even those whose employers aren’t ARSA members – represents the best in the aviation maintenance community. From diverse backgrounds, with different experiences and performing a wide range of needed tasks, each one keeps the world safely in flight. We can’t fly without them and we wouldn’t want to.”
Finding and retaining world class talent – like the names listed in AMT’s awards – has become a pressing challenge for repair stations and a key policy focus for the association. While celebrating the best and brightest is a great way to attract attention, ARSA also provides tools for building the aviation workforce of the future:
(1) Aerojobs.org. The web-based recruitment tool specifically targets individuals with the skills needed to maintain aircraft (regardless of what industry they’re in now).
(2) AVMRO.arsa.org. The industry’s information portal introduces the world of maintenance, repair and overhaul. The site has information useful to everyone from job seekers to the media to elected officials to nervous fliers.
(3) Propaganda. “You Can’t Fly Without Us,” a seven-minute documentary on the maintenance industry produced for public television. ARSA provides license for use of the film as an informational or recruitment tool. (Visit arsa.org/documentary to see how you can use the video.)
(4) Training. In addition to a growing library of on-demand recordings, live sessions are hosted weekly on regulatory compliance, government affairs, legal and business development topics. Everything you need to get better at your job and get ready for the next one. (Visit arsa.org/training for course information and to register.)
“While celebrating [the NextGen honorees’] hard work, let’s consider how to help them move ahead,” Levanto said, encouraging broader industry action. “Nurture their careers while attracting new applicants to work and learn alongside them.”
To see all of the winners, visit: www.aviationpros.com/article/12278511/2016-amt-next-gen-40-under-40-award-winners.
Are you from one of the organization's represented on the list of winners? Click here to contact ARSA to share how you're celebrating your young talent.
Click to Access the November 2015 Editorial "Singing for the Unsung" by ARSA VP of Communications Brett Levanto and VP of Operations Crystal Maguire (NextGen Honorees)
A Member Asked…The Conference Agenda
Q: We are looking to attend this year’s ARSA Conference in mid-March. As a 145 repair station and ARSA Member, would you please provide some details or a syllabus on what will be covered during the two days of the Annual Repair Symposium?
Thanks.
A: First of all, the terminology of your question was very well put: ARSA has re-named the expansive series of briefings, discussions and content it hosts each March as the Annual Conference. For those long-standing members who’ve come to rely on the regulatory and business content of the Annual Repair Symposium, it still exists as a component of the larger event – the “symposium” portion of the week is on Thursday and Friday, March 14 and 15.
To your question regarding its content, the current agenda – with confirmed speakers – is available on the event page at arsa.org/news-media/events/arsa-conference. Scroll down below the sponsors (thank you, sponsors) and click the drop-down marked “2019 Agenda.” There you can see the content and events related to the entire week, including the Executive to Executive Briefings on March 12, Legislative Day on March 13 and then the Annual Repair Symposium, Member Meeting and Breakout Sessions on March 14 and 15.
If you have colleagues who are unable to attend, they can follow along with ARSA and its participants throughout the week by keeping an eye on arsa.org/conference.
Member questions should be submitted through the inquiry system run through ARSA’s new online member portal. Members can use their portal access to submit inquiries by logging in through arsa.member365.com/sharingnetwork.
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 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, contact Vice President of Communications Brett Levanto (brett.levanto@arsa.org).
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.
ICA Issue Page
Since its inception, ARSA has worked to ensure that basic safety information (i.e., Instructions for Continued Airworthiness [ICA], including component maintenance manuals [CMM]) is made available at a fair and reasonable price to operators, maintenance providers, and any other person required by 14 CFR to comply with those instructions. ICA Issue Page (Updated)
Brexit Resource Page
On June 23, 2016, citizens of the United Kingdom voted to withdraw from the European Union in a national referendum. This page is provided as a resource for the aviation maintenance community regarding transition negotiations between the British government and the European Commission. Brexit Resource Page (Updated)
Careers In Aviation Maintenance
Every year, more people are flying. The expansion of the global middle class and improvements in technology have opened aviation markets – for passengers and cargo – to a broader public than ever before. As the the flying public gets larger, more men and women are desperately needed to keep the world safely in flight.
Quick Question Portal
See what ARSA has asked and what’s been answered and participate in the conversation about what’s going on in the aviation maintenance world.
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.
Industry Calendar
HAI HELI-EXPO – Atlanta, Georgia – March 4-7, 2019
MRO Southeast Asia – Kuala Lampur – March 6-7, 2019
U.S. Chamber Aviation Summit – Washington, D.C. – March 7, 2019
ARSA Annual Conference – Washington, D.C. – March 12-15, 2019
ATEC Annual Conference – Wichita, Kansas – March 17-20, 2019
AEA Convention & Trade Show – Palm Springs, California – March 25-28, 2019
MRO Americas – Atlanta, Georgia – April 9-11, 2019
2019 Asia-Pacific Bilateral Partners Dialogue Meeting – Queenstown, New Zealand – April 16-18, 2019
MRO BEER – Vilnius, Lithuania – May 21-22, 2019
the hotline is the monthly publication of the Aeronautical Repair Station Association (ARSA), the not-for-profit international trade association for certificated repair stations. It is for the exclusive use of ARSA members and federal employees on the ARSA mailing list. For a membership application, please call 703.739.9543 or visit arsa.org/membership/join. For information about previous editions, submit a request through arsa.org/contact. This material is provided for educational and informational purposes only. It does not constitute legal, consulting, tax or any other type of professional advice. Law, regulations, guidance and government policies change frequently. While ARSA updates this material, we do not guarantee its accuracy. In addition, the application of this material to a particular situation is always dependent on the facts and circumstances involved. The use of this material is therefore at your own risk. All content in the hotline, except where indicated otherwise, is the property of ARSA. This content may not be reproduced, distributed or displayed, nor may derivatives or presentations be created from it in whole or in part, in any manner without the prior written consent of ARSA. ARSA grants its members a non-exclusive license to reproduce the content of the hotline. Employees of member organizations are the only parties authorized to receive a duplicate of the hotline. ARSA reserves all remaining rights and will use any means necessary to protect its intellectual property.
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