2015 – Edition 1 – February 5

Hindsight is 20/20, but successful trade associations must see forward with the same clarity. ARSA works by looking ahead and getting its members on course for destinations not yet mapped.

ARSA 20/20, the association’s strategic plan, is the central tool in this work. Strategic planning is a regular process for determining (and changing) priorities, establishing goals and plotting strategies for improving services to our members. A good strategic plan tells us where the organization is going and how it gets there.

Still, there’s a more important component: Why? The goals and objectives we outline means little if we fail to capture the underlying purpose being served. The answer to this all-consuming question is the vision.

ARSA’s vision is to ensure its members can perfectly manage the intersection of business and government. The association seeks to find the exact boundary between professional responsibility and government oversight. We know good safety is good business; we seek the point of good government, too.

In this pursuit, we’ve updated our strategic plan – a “living document” needs constant attention to stay valid. The new ARSA 20/20 will continue to bolster the association in four key areas:

• Advocacy and compliance assistance to manage an increasingly complex regulatory environment.
• Lobbying and media relations to affect the uncertain—and in many cases, hostile—legislative environment.
• Business programs to reduce costs and improve competitiveness in an erratic global economy.
• Workforce development to attract and train the next generation of skilled workers to the aviation maintenance industry.

In short, every day we’re building an efficient, effective organization with a broad reach and international impact. It has many goals, but one purpose: to serve a vision for you.

In aviation, clear vision is a beautiful sight.

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Hotline Features

ARSA on the Road: Landing at COOPESA in San Jose, Costa Rica

By ARSA Communications Staff

Every year, countless tourists from all over the world descend upon Costa Rica searching for “Pura Vida” (the pure life), the beautiful weather and the country’s natural beauty. Upon arrival, most visitors to Juan Santamaria International Airport won’t notice that less than an American football field away from the main terminal sits one of the preeminent aviation maintenance companies in the world— Cooperativa Autogestionaria de Servicios Aeroindustriales (COOPESA).

While undetected by the untrained eye, the citizens of Costa Rica and the aviation maintenance community are keenly aware of the company’s well-deserved reputation. Established in 1963, COOPESA employs 750 highly-skilled workers and has FAA and EASA certifications, among others. On Jan. 20, ARSA’s Vice President of Legislative Affairs Daniel B. Fisher visited the company’s headquarters and was treated to a tour by ARSA Board Member and COOPESA Quality and Safety Director Warner Calvo.

“It’s an invaluable experience for ARSA staff to visit member companies,” said Fisher upon returning to Washington, D.C. (though not as tan as we hoped). “While foreign repair stations have a unique set of challenges, interestingly many of the issues are very similar to U.S. MRO companies, such as managing relationships with local inspectors and customers, finding and retaining skilled workers and navigating an overly burdensome regulatory climate. And just as in the United States, there are no shortcuts—safety is the absolute top priority.”

While some in Washington, D.C., and in the media demonize contract maintenance, in particular foreign repair stations, Fisher invites them to visit companies like COOPESA. “Security was top notch. The shop floor is clean and the employees are courteous, dedicated professionals. Customers oversee repairs and maintenance directly. As with every repair station I’ve visited, a culture of safety and security was pervasive throughout the company,” Fisher commented.

A highlight from the visit was a briefing by Calvo and his team on COOPESA’s planned expansion. Ground will be broken soon on a new facility, not far from the current location, that will allow it to service more customers with increased efficiency. “The excitement exuded by Warner and his colleagues was evident when discussing the new facility. COOPESA is growing and the employees are eager to be a part of the company during expansion,” said Fisher.

“It’s important for ARSA staff to get out and visit aviation maintenance companies,” said ARSA Board Member Calvo. “I know Daniel learned a great deal about COOPESA while in Costa Rica, but it was an educational experience for us too.  Calvo added, “Despite vacationing, Daniel took the time to visit COOPESA and meet with our staff.  A hands-on approach is one of the many reasons that ARSA is so valuable and further evidence that the association’s work on our behalf never rests.”

Thank you to Warner Calvo and the COOPESA team for opening their doors to ARSA. Do you want an ARSA staff member to visit your facility?  Please let us know at arsa@ARSA.org.

Daniel Fisher, vice president of legislative affairs for the Aeronautical Repair Station Association (ARSA), issued the following statement in response to President Obama’s Federal Aviation Administration (FAA) fiscal year 2016 budget proposal.  The administration has requested $15.8 billion, including $9.915 billion for agency operations, a slight increase over current funding levels. However, the White House also proposes once again to alter business aircraft depreciation schedules.

“ARSA commends the administration for requesting Congress provide the FAA more resources to do its job. For repair stations, good safety is good business and the maintenance sector is dedicated to continuing its impeccable safety record regardless of government oversight. However, since aviation maintenance companies rely on the FAA for congressionally-mandated certifications and inspections, any shortfall results in administrative delays and ultimately undermines American competitiveness.

“Unfortunately, the administration’s call to reduce the depreciation schedule for general aviation aircraft is an unnecessary political gambit. It will impact the entire aviation industry – a sector that lifts the American economy, creating jobs for millions of people in communities across the country – from parts suppliers to repair stations. ARSA encourages lawmakers to reject measures that would hurt the hardworking men and women who keep the nation safely in flight.”

ARSA to FAA: “Or New” Unacceptable

By Laura Vlieg, Regulatory Affairs Manager

On Jan. 29, ARSA asked the FAA to clarify when the new owner of a repair station can apply for an amended versus a new certificate.

The change to the repair station rule, which became effective Nov.10, 2014, revised Title 14 Code of Federal Regulations (CFR) section 145.57(b). That section states the new owner of repair station assets “…must apply for an amended or new certificate in accordance with § 145.51.” (Emphasis added).

The addition of the words “or new” was not even mentioned in the notice of proposed rulemaking, but the FAA reasoning is that “[t]he revision clarifies that a new owner will need to apply for a new certificate only if the new owner chooses to operate as a repair station.”

The change was totally unnecessary, and creates confusion rather than clarity. While ARSA appreciates that a repair station certificate cannot be transferred, amending one takes fewer resources for both industry and agency. Considering the current waiting time for a new certificate can be up to two-years, any uncertainty regarding the application is unacceptable.

“It should be very clear by now how much trouble can be caused by a misplaced or unnecessary word in the regulations,” said Sarah MacLeod, ARSA’s executive director. “I say that because ARSA has been making exactly that point for months: Since the new repair station rule was announced last year this association has been working to scrap every one of these ‘broken parts,’ since they offer no safety benefit to the flying public and represent immeasurable administrative burden for repair stations.”

Along with its letter, ARSA submitted suggested changes to guidance material. The association asked the agency make clear an application for a new certificate is only required where the new owner opts for a new certificate number. And even then, the processing interval should depend upon the changes the new owner makes to the location, housing, facilities, equipment and personnel.

ARSA to FAA: Nothing Generic About AD Info Collection

By Laura Vlieg, Regulatory Affairs Manager

On Jan. 29, ARSA objected to the generic clearance of information collections contained in Airworthiness Directives (ADs). Although the practice has been going on for years, the recent request for renewal of the generic collection prompted the association to take action.

The Paperwork Reduction Act (PRA) mandates that federal agencies obtain the Office of Management and Budget’s (OMB) authorization to collect information from the public. Each request must be evaluated according to criteria including the requirement for “a specific, objectively supported estimate of burden.”

Generic information collection approvals are not specified in the PRA; rather they are allowed by an OMB memorandum that sanctions them for activities that are “usually voluntary, low-burden, and uncontroversial.” Where the OMB provides generic approval, the requesting agency outlines a plan providing an estimate of the average burden imposed on respondents, but does not need to seek public comment on each specific collection.

ARSA provided evidence that generic clearance is ill-suited for ADs where each information collection is unique and requires the individualized approval mandated by law. Additionally, the association pointed out that the FAA’s estimate of a five minute burden per response was inaccurate and misleading.

ARSA, ATEC Capitalize on Update to O’Brien Awards

By Brett Levanto, Director of Operations

On Jan. 21, ARSA and the Aviation Technician Education Council (ATEC) submitted joint comments on FAA Draft Advisory Circular (AC) 65-25F, “William (Bill) O’Brien Aviation Maintenance Technician Awards Program.”

The O’Brien Awards
Through the William (Bill) O’Brien Awards Program, the FAA recognizes eligible technicians who receive and businesses that promote professional development. The program was founded in 1991 to create an incentive for AMT employees and employers to participate aggressively in maintenance training courses.

Updating AC 65-25
The agency’s purpose for updating the AC was to provide a general overview of the program and direct potential participants online for further information. To ARSA and ATEC, the update represents an opportunity to improve the document in other ways. Most notably:

• Adding part 147 Aviation Maintenance Technical Schools (AMTSs) to the list of acceptable instruction or course providers. Individuals should be encouraged to take refresher courses from these FAA-controlled institutions. For their part, the schools should have an incentive to provide classes (and many do as IA renewal seminars) that do not meet the definition of “college level course” in the AC.
• Removing the three-employee requirement from eligible companies. Any company that engages in aviation services should be supported by this program, no matter the size.

To view the entire submission, including a suggested version of the AC with red-lined changes, please click here.

Government Can’t Work in ISO-lation – ARSA Submits FOIA Request

By Zach F. Bruckenstein, Advocacy Manager

ARSA works to ensure consistent application and enforcement by holding the FAA accountable to its policies and procedures. To do this, the association and its members need access to the most current documents, guidance and resources used by the government.

In 2006, FAA Aviation Safety (AVS) implemented an International Organization for Standardization (ISO) 9001:2000 compliant Quality Management System (QMS). The agency is certified under the updated 9001:2008 accreditation, but has failed to make its QMS documents available so the public can understand the way government is currently conducting business.

So what do all of these numbers and acronyms mean? The QMS helps an organization provide consistent and effective service to its customers. In the FAA’s case, the public (including certificate holders) is the customer and every regulation, guidance or enforcement action is the service. While the agency’s website has an older version of its QMS guidance, the latest is not available nor are the policies and procedures used to show compliance to the standard. So, on Thursday, Jan. 22 ARSA submitted a Freedom of Information Act Request (FOIA) seeking the records and manuals pertaining to the AVS QMS.

Once ARSA receives these materials, it will conduct a thorough review to ensure it understands how the AVS QMS is supposed to be working. Understanding how the government has promised to conduct its business will allow customers to provide meaningful feedback.

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Legal Briefs

The Right Stuff: Working for a Better 145

By Laura Vlieg, Regulatory Affairs Manager

The latest changes to the repair station rule became effective in November 2014. ARSA is still working to make the regulation better. In September, a coalition of aviation trade groups successfully petitioned the FAA to reinsert the word “serious” into the service difficulty reporting requirement (14 CFR § 145.221). While a major victory saving incalculable cost, there is more being done.

ARSA is spearheading efforts to reinstate a repair station’s ability to voluntarily surrender its certificate. Since implementation of the repair station rule, surrendered certificates are subject to FAA “acceptance for cancellation.” The agency has yet to give guidance on how or when it will use its newly minted discretionary authority to accept or reject surrendered certificates. This administrative uncertainty creates confusion and additional expenses when selling assets and winding up a business – the normal reasons for surrendering a certificate.

On Jan. 9, a coalition of trade groups submitted a petition for rulemaking asking the FAA to reinstate a repair station’s ability to voluntarily surrender its certificate and put those certificates back on equal footing with other certificate holders. That coalition includes the Aerospace Industries Association, Aircraft Electronics Association, Aviation Suppliers Association, General Aviation Manufacturers Association, Helicopter Association International, Modification and Replacement Parts Association, National Air Carrier Association, National Air Transportation Association and Regional Airline Association.

In the final rule, the FAA claimed that requiring its acceptance of a voluntarily surrendered certificate “will prevent a repair station under investigation from attempting to circumvent a possible enforcement action.” That reasoning confuses individual bad actors with the repair station. The FAA already has the authority to deny a repair station certificate where key positions will be filled by individuals who materially contributed to the revocation of a certificate or the initiation of revocation proceedings for a current certificate holder. Thus requiring agency acceptance of a voluntarily surrendered certificate is without reason and imposes an unnecessary administrative burden on industry and the agency.  After the repair station surrenders its certificate, the agency can still investigate and take action against individual bad actors and deny repair station certificates with bad actors in key positions.

Ultimately, the requirement for affirmative agency acceptance of a repair station certificate runs counter to interests in aviation safety. When individual bad actors are using a repair station certificate, the agency’s primary concern is the immediate cessation of work that could potentially jeopardize safety. That concern is evident in the context of air carriers and other certificates where no agency acceptance of surrender is required. By requiring an “acceptance for cancellation” of a voluntarily surrendered certificate, work (or operations) may continue, potentially jeopardizing safety.

These and other concerns are articulated in the submitted petition, which ARSA members should support. The ultimate aim of the agency is to set standards for and oversee aviation safety; it need not expend resources on unnecessary actions. The petition merely requests that repair stations retain the same ability all other certificate holders enjoy, to voluntarily surrender a certificate.

To submit comments in support of the petition, go to the docket and click the “comment now” button.

Click here to download a customized comment template.

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.

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ARSA on the Hill

Regulatory Outlook

What We Do – FAA’s Continued Operational Safety Policy Section

By Keith Lardie, Aerospace Engineer, FAA Operational Oversight Policy Branch (AIR-140)

How do I make it so it doesn’t sound so bureaucratic? Never mind, too late.

Since you haven’t skipped ahead to the next article and decided to read on, I’d like to introduce you to the roles and responsibilities of my office ahead of our presentation and discussion at the 2015 Annual Repair Symposium.

Within the Aviation Safety’s Aircraft Certification headquarters’ division, the office for our Continued Operational Safety Policy Section is located in Oklahoma City. We are responsible for standardizing policies FAA offices use when:

• Developing airworthiness directives (including the supporting regulations).
• Engineering acceptance data for repairs and alterations.
• Assessing potential risk to a product’s design.

We also maintain the Regulatory and Guidance Library (http://rgl.faa.gov) where you can find information on FAA regulations (Title 14 Code of Federal Regulations), design approvals, advisory circulars and other policy documents.

Over the last few years, we have implemented policies that move away from using individual qualitative information, often called “engineering judgment,” to a more structured and consistent data-driven approach to assessing risk. This risk-based decision making approach is dependent on the availability of good data. In that capacity, we are a part of the internal FAA team that has been reaching out to many aviation industry organizations to help shape our concept for the service that will upgrade and absorb our current safety defect reporting systems, including our Service Difficulty Reporting System.

Our approach is basic: we need to make it faster and easier to communicate potential safety information, both submitting information about possible safety problems as well as providing the necessary fleet-wide information to those responsible for maintaining safe and airworthy aircraft.

Join Mr. Lardie and his team at this year’s Annual Repair Symposium in Alexandria, Virginia. Register now.

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.

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Quality Time

Many Signs of New Life – For Industry, ARSA and Its Partners

Membership

Member Spotlight: Aviation Institute of Maintenance – Nationwide

By Kelsi Oliver, Communications Coordinator

Aviation Institute of Maintenance (AIM) is an FAA part 147-certificated Aviation Maintenance Training School (AMTS) with locations across the United States. Offering training to become maintenance technical engineers, maintenance technicians and avionics technicians, AIM features accreditations, association memberships and strong graduation rates.

In addition to its ARSA membership, the Institute is a central part of the Aviation Technician Education Council, a valuable partner in the work of providing repair stations with a world class technical workforce. To include educational members like AIM under the association’s broad base of support means resources and insight into the needs of the institutions that supply the aviation maintenance industry with the human capital it needs to thrive.

For more information concerning the Aviation Institute of Maintenance, please visit http://www.aviation.edu.

Are you an ARSA member who would like to be in the “Member Spotlight?” If so, please contact Kelsi Oliver at Kelsi.Oliver@arsa.org.

Have You Seen this Person?

Each month, the hotline spotlights key regulatory, legislative, and business leaders making important contributions to the aviation industry. This month we look at U.S. Frank A. Lobiondo (R-N.J.).

Congressman Lobiondo serves as chairman for the U.S. House of Representatives Subcommittee on Aviation. Built inside the Transportation and Infrastructure Committee (T & I), the subcommittee counts the FAA as one of the few agencies within its jurisdiction. In addition to these agencies, the group also oversees all aspects of civil aviation, including labor, safety, infrastructure, commerce and international aviation issues, as well as unmanned aircraft systems.

Lobiondo displayed his interest in FAA reauthorization during the Jan. 21 hearing of the Full Committee on Transportation and Infrastructure: “FAA Reauthorization: Reforming and Streamlining the FAA’s Regulatory Certification Process.” Thanking T&I Committee Chairman Bill Shuster for “elevating the issue to the full committee level because of its critical importance,” Lobiondo made use of the witnesses before him. His main concern seemed to be the FAA’s certification process’s effect on the represented businesses (Boeing and Duncan), questioning the impact it has on aviation companies’ ability to compete and innovate.  He also demonstrated his alertness to other countries’ regulatory processes, asking whether or not the agency’s methods are hindering their advancement with “global competition that is dealing with some different standards.”

Lobiondo grew up in southern New Jersey and has served the region on the county, state and federal levels ever since. He takes great pride in his role on the Subcommittee of Aviation given its critical importance to his district and home.

Take Advantage of ARSA’s Members Getting Members Program, Get 10% Off on Membership Dues

The best form of advertising is word of mouth. Use the Members Getting Members Toolkit to recruit an ARSA member and your company will receive a discounted membership rate for your next membership term. Get more information at http://arsa.org/membership/members-getting-members/

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Target Your Message: Advertise Today in ARSA’s Newsletters and Website!
ARSA recently updated its 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 http://arsa.org/advertise/

Exhibit, Sponsor the 2015 Repair Symposium
As the maintenance industry’s top event devoted exclusively to regulatory compliance, the ARSA Symposium attracts a highly qualified professional audience. Use this opportunity to promote your company while showing support for ARSA. Get more information at http://arsa.org/news-media/events/arsa-symposium/arsa-annual-repair-symposium-sponsorship/

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A Member Asked…

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AVMRO News Portal

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.

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Upcoming Events

Previous issues:

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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 http://arsa.org/membership/join/.

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.

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© 2015 Aeronautical Repair Station Association