2015 – Edition 11 – December 4
Table of Contents
Sarah Says
Something is Still on the Wing
By Sarah MacLeod, Executive Director
In 1963, an iconic episode of The Twilight Zone shook the nerves of travelers everywhere with a haunting suggestion: There’s something on the wing. Passenger Bob Wilson spent his “nightmare at 20,000 feet” desperately trying to alert others to a wing-walking gremlin bent on destroying the aircraft and dooming its passengers.
The aviation maintenance community’s gremlin is not a physical (or hallucinated) being, but rather the uninformed, hackneyed and all-too-well publicized fears that the “rise” of contract maintenance has a negative impact on aviation safety. The association has long battled with forces bent on dooming the entire industry. It has, despite extremely limited resources, repeatedly repelled false safety and economic campaigns designed to denigrate “outsourced” labor.
ARSA’s positive publicity campaign, media relations and communications efforts have succeeded in counteracting negative press. Similarly, ARSA’s legislative effectiveness has dissuaded lawmakers from openly micromanaging repair stations. However, the industry can’t take the association’s recent feats for granted. Contract maintenance’s opponents are well-funded and politically connected. They, just like ARSA, understand that media (whether factual or not) drives Capitol Hill action and reaction.
It is no coincidence that with the FAA reauthorization process underway in Congress, the aviation maintenance gremlin has returned in full force. In November, Vanity Fair (the same publication that promises the ultimate holiday gift guide, from cashmere to kayaks) took a strong interest in aviation safety. It published James B. Steele’s “Disturbing Truth About How Airplanes are Maintained Today.” Disturbing is putting it mildly.
As a work of fiction, Mr. Steele’s story is entertaining. Unfortunately, when his “investigation” of contract maintenance stumbles upon actual truth, it is repeatedly presented mendaciously: misleading, incomplete and designed to arouse popular passions rather than accurately assess a vital industry. It’s a shame to miss an opportunity for a frank discussion about the men and women who keep the world safely in flight; in its place we got a lazy, half-hearted exposé that scores useless points based on old or inadequate references.
Christian A. Klein, ARSA’s executive vice president and a fellow managing member of Obadal, Filler, MacLeod and Klein, PLC, wrote an incisive and direct response to Mr. Steele’s bile. To paraphrase Christian’s assessment: the author is either ignorant or dishonest. Either way, he has underscored the need for repair stations to have a strong voice.
By replacing Mr. Steele’s skewed narrative with the truth – the world can’t fly without the hard working, safety conscious, talented men and women who turn wrenches and run tests every day – ARSA and its allies provide an invaluable service. For maintenance providers, the association’s efforts translate into a more-favorable regulatory and business climate. For the flying public, this work means open access to the safest era in the history of air transport.
To continue to combat opponents, the association needs your financial support. It is time for you to get new ARSA members, attend and sponsor the annual symposium, and participate in ARSA training. While the association does champagne work, it is on a beer budget. Without resources, success won’t continue; the better funded will inevitably prevail. In other words, ARSA will continue fighting; but, without financial resources, that thing on the wing can bring us all down.
Hotline Features
2016 Symposium Registration Open
By ARSA Communications Staff
Registration is open for ARSA’s 2016 Legislative Day and Annual Repair Symposium. Join aviation professionals from around the world and tackle issues that matter to the maintenance industry.
Dates
Legislative Day: Wednesday, March 16, 2016
Annual Repair Symposium: Thursday & Friday, March 17-18, 2016
Location and Accommodations
The 2016 Legislative Day and Symposium will be hosted at the Ritz Carlton, Pentagon City in Arlington, Virgina. Individual guest rooms may be reserved online using the group code MYSMYSA (book by Friday, Feb. 26).
To Register and For More Information
Please visit the registration page at http://arsa.org/news-media/events/arsa-symposium/2016-symposium-registration/. If you have any questions, contact us via email or at 703 739 9543.
Sponsorships Available
Promote your company while showing support for ARSA – sponsor the maintenance industry’s premier event.
Click here to see what sponsorship opportunities are still available.
ARSA Introduces Ramco Systems as Preferred Provider
By ARSA Communications Staff
On Nov. 18, ARSA announced the selection of its newest preferred provider: Ramco Systems. Scheduled to coincide with Ramco’s appearance at NBAA 2015, the announcement followed the company’s new cooperation with Air France Industries (AFI) KLM E&M on a new co-innovation center – The MRO Lab – in Singapore.
Ramco is a leading enterprise software provider with systems that operate on the cloud, mobile platforms and tablets. Recognized for its innovative IT offerings by rotorcraft operators, airlines and repair stations, in addition to recent expansion into aviation manufacturing, the company has deep roots in the aviation marketplace.
“Aircraft maintenance providers have a great responsibility to the flying public,” said Brett Levanto, ARSA’s vice president of communications. “It is our responsibility, then, to help them make informed choices about the tools and resources on which their business operations depend. Our detailed review of Ramco made clear that its aviation offerings are truly ‘Next-Gen’ and deserving of the association’s endorsement. When repair stations harness the power of these great IT products, we all benefit.”
Commenting on ARSA’s recognition, Ramco’s CEO Virender Aggarwal said, “After being chosen as the technology partner for the MRO Innovation Lab by AFI KLM E&M, I am happy to note that ARSA, an autonomous body for [the aviation maintenance] industry has recognized Ramco as an approved Next-Gen IT vendor. This recognition further underscores our commitment to building industry-focused innovation. Our focus on mobility, in-memory computing and adaptability to wearable devices has aided us in transforming into the frontrunners in this industry. We are truly thrilled that our efforts are paying off and we will strive to retain this honor, year after year.”
For more information about Ramco Systems, its products and customer services, please visit www.ramco.com.
To see all of ARSA’s preferred providers, and to learn how they can serve your business, visit arsa.org/membership/benefits/arsa-preferred-providers.
Jet Center MFR’s Hudnall Announced as New ARSA President
By Sarah Hartley, Communications Coordinator
ARSA’s board of directors has announced the election of its new president: Gary Hudnall, general manager of Jet Center MFR in Medford, Oregon. The selection was made during the board’s October meeting in Washington, D.C.
Hudnall represents a full service family-owned repair station in Southern Oregon which began handling aviation needs throughout the Pacific Northwest and Northern California in 1967. He most recently served the ARSA board as vice president and secretary before ascending to the top leadership position of the volunteer body. The 2014 board president and SONICO, Inc. Vice President, Jim Perdue, continues on as a board member and valuable resource to the association’s leadership.
“With the support of my fellow board members, including [past president] Jim [Perdue], ARSA will continue to be a strong voice of the aviation maintenance industry in 2016.“ said Hudnall. “We will advocate for the industry as Congress reauthorizes the FAA, help repair stations bridge the skills gap as they build their workforces of the future and continue to offer world-class support and resources to association members. This is important work: The world can’t fly without us.”
Warner Calvo, quality and safety director of Coopesa, R.L. in Alajuela, Costa Rica, is now board vice president, while Basil Barimo, executive vice president of NORDAM in Tulsa, Oklahoma serves as board treasurer.
The ARSA board of directors represents a broad range of international maintenance interests. To learn more about the 2016 directorship, visit http://arsa.org/about-us/board-of-directors/.
Bonus Depreciation, Sec. 179 Caught Up in Year-End Extenders Drama
By Daniel Fisher, Vice President of Legislative Affairs
The conventional wisdom in the nation’s capital is that lawmakers are still on track to ink a final deal before years’ end to reinstate and possibly extend expired business tax provisions, including 50 percent bonus depreciation and higher Sec. 179 expensing levels. However, with just six weeks left in the year, pressure is mounting on House and Senate tax committee leaders to roll up their sleeves and get a deal done.
With the leadership of the House Ways & Means Committee definitively resolved (the House GOP conference gave Rep. Kevin Brady [R-Texas] the gavel earlier this month) negotiations can finally get underway. The House will likely push for several extenders – including bonus depreciation and increased Sec. 179 – to be permanently restored. However, the Senate Finance Committee’s consensus bill would simply extend all of the 50+ expired tax provisions for 2015 and 2016.
It’s currently uncertain how differences will be resolved. An extenders package could move on its own, be attached to an omnibus spending bill that needs to be approved by Dec. 11, or be part of an even bigger year-end package that includes a highway bill.
Help lawmakers make the right choices to benefit American businesses – including repair stations. Let ARSA show you how to get involved.
Help ARSA Help You: Sponsor the 2016 Annual Repair Symposium
By ARSA Communications Staff
As the maintenance industry’s top event devoted exclusively to regulatory compliance, ARSA’s Annual Repair Symposium attracts a highly qualified professional audience. Use this opportunity to promote your company while showing support for the association.
ARSA depends on sponsorship dollars and in-kind donations to make the symposium a valuable experience for industry members. These contributions enable hundreds of attendees to engage with legislators, regulators and industry professionals. Sponsors receive a number of important benefits, including:
(1) Recognition on ARSA’s home page, in the hotline newsletter, weekly email bulletins, attendee materials and multi-media material displayed during the event.
(2) The exclusive opportunity to distribute sales literature at the symposium registration table.
(3) One complimentary registration per $5,000 sponsored (registration discounts will be prorated for sponsorships made in increments less than $5,000).
ARSA encourages you to consider sponsoring the 2016 Symposium. The sponsorship team is accepting partial (starting at $250) and full sponsorships to support receptions, dinners and activities occurring throughout the event, as well as bus transportation, room keys and other opportunities to get a branded product into the hands of industry attendees (visit the sponsorship page for more information).
An exciting new opportunity is available this year to support ARSA’s first-ever silent auction. Proceeds will benefit the association’s scholarship awarded through the Northrop Rice Foundation. Donated items will be available for bid during Thursday night’s reception. To sponsor the event, or to donate items to the auction, simply indicate your sponsorship or donations on the Sponsorship Request Form.
ARSA Works
To see all the ways ARSA works as the voice of the aviation maintenance industry, visit our ARSA Works page.
Contract Aviation Maintenance: Safer, More Efficient
By Christian A. Klein, Executive Vice President
James B. Steele missed the opportunity to tell about a thriving, technologically-sophisticated industry that employs hundreds of thousands of Americans. Instead, his “Disturbing Truth About How Airplanes Are Maintained Today” (Dec. 2015) relied on the hackneyed narrative that contract aviation maintenance means lost jobs and unsafe planes.
Contracting isn’t a trend; it’s the way almost all maintenance and alteration work is done on every type of aircraft flying—from large air transport to small private jets. There’s a good reason: Highly-specialized Federal Aviation Administration (FAA) certificated companies and individuals can perform the work more efficiently and effectively than owners and operators can themselves. Repair stations have, for example, helped air carriers reduce costs and become more competitive without compromising safety. And contracting isn’t unique to maintenance; every part of the aviation industry from manufacturing to operations relies on contractors.
Steele’s premise – that we should be “disturbed” about contract maintenance – collapses under the weight of a simple fact: The use of contract maintenance has coincided with the safest period in the history of U.S. civil aviation. This impressive safety record isn’t an accident. It’s the result of an effective and ever improving network of industry controls working in concert with government regulations.
Aside from a borrowed and discredited storyline, Steele’s article is rife with other omissions, inaccuracies and inconsistencies. Steele points to lost jobs but fails to mention that the thousands of repair stations in the United States employ 200,000 people, four times more than work as U.S. airline mechanics. Nor does he mention that the civil aviation maintenance industry contributes $43 billion per year to the U.S. economy.
He cites variations in the numbers of FAA-certificated mechanics at various types of facilities but neglects that an FAA-certificated person or entity always approves all maintenance work for return to service. Further, regardless of where work is done, all U.S.-registered aircraft are maintained to stringent FAA standards.
He points to the FAA’s limited resources and concerns about oversight but fails to describe the other scrutiny and inspections repair stations receive from airline customers, third-party accreditation bodies, other civil aviation authorities and repair stations’ own internal quality assurance teams.
In years past, labor organizations representing airline mechanics successfully planted alarmist stories like Steele’s to build support for legislation to make it harder for airlines to use repair stations and unnecessarily drive up costs for the maintenance industry. With another FAA reauthorization bill on the horizon, it’s not surprising forces wedded to old ways of doing business should try to revive those storylines.
What is surprising and disappointing is that Vanity Fair allowed itself to become a propaganda tool. Steele’s article is either poorly researched or intentionally one-sided. Either way, to use his own words, it’s “as wrong as it is possible to be.”
To learn – or show others – more about the real world of contract aviation maintenance, visit AVMRO.arsa.org.
MAG Change 5 – FAA, EASA Assist with International Parts Documentation
By ARSA Regulatory Staff
On Nov. 20, the FAA and EASA announced a joint strategy for implementing the most-recent update to the international safety agreement between the two bodies. That document, which was signed in September and was scheduled to become effective on Dec. 8, included a major complication regarding documentation requirements for new aircraft parts that will be installed in articles subject to the jurisdiction of both the European Union (EU) and the United States.
Change 5 to the Maintenance Annex Guidance (MAG) issued under the U.S.-EU Bilateral Aviation Safety Agreement (BASA) created a clear requirement for a specific FAA Form – the 8130-3 – to be issued by production approval holders (PAH). The form must accompany all new parts to be installed on articles for which a dual FAA-EASA maintenance release will be issued. A BASA is a government-to-government agreement meant to simplify regulatory oversight across borders. However, under current FAA rules only the agency or its designees can issue the document for a new part.
The FAA addressed that problem in a final rule published Oct. 1 that will allow U.S. PAHs to issue Form 8130-3 without needing an FAA designee. Unfortunately, aerospace manufacturers cannot implement the new privilege until the final rule’s March 29, 2016 effective date, with longer timelines required for FAA regulatory review and approval.
On Oct. 7, a coalition of aviation trade associations sent a letter to both agencies offering a solution: delay implementation of the MAG’s new documentation requirements until the effective date of FAA’s new rule. U.S. aviation businesses would then be able to install these parts on European articles, and remain in compliance, without disruption.
“Even though the U.S. and EU regulatory systems are equivalent, our members’ hands were effectively tied,” said Marshall S. Filler, managing director and general counsel for ARSA, about the industry-wide effort. “As things stood in October, in order to serve European customers many U.S. repair stations would be legally obligated to possess parts documentation that U.S. manufacturers cannot issue.”
In response the agencies agreed to delay implementation of the FAA Form 8130-3 requirement until April 1, 2016. The FAA issued a notice, effective Nov. 17, providing additional time for U.S. PAHs to update their internal procedures and issue the forms for parts released from their quality systems. They also clarified the requirement would not be applied retroactively to parts released by the PAH prior to the new effective date, whether in a repair station’s inventory or in the distribution pipeline.
“After the FAA’s new rule was published [on Oct. 1], the way ahead was pretty clear,” Filler concluded. “Giving U.S. industry the time it needed to align systems and procedures with the new MAG requirement was the simple, common sense solution. The agencies saw that, with a little help, and made the right decision. Fortunately, the aviation community will not be penalized because of an unworkable regulatory burden.”
On Nov. 25, ARSA received a letter from the FAA and EASA, sent as an official response to the original Oct. 7 request. The letter, which was signed by the flight standards and aircraft certification directors of both agencies, was consistent with the Nov. 20 notice. In addition to delaying implementation of the FAA Form 8130-3 requirement until April 1, 2016, the letter indicated the FAA will also consider action to allow early compliance with certain provisions of the new rule. (To access a copy of the letter, click here.)
ARSA Comments on Draft ICA Guidance
By ARSA Regulatory Staff
On Nov. 5 ARSA filed comments analyzing Draft Order 8110.54B, Instructions for Continued Airworthiness Responsibilities, Requirements, and Contents and Draft Advisory Circular 20-ICA, Instructions for Continued Airworthiness.
ARSA’s founding mission was to ensure that basic safety information (ICAs, including component maintenance manuals [CMMs]) is made available at a fair and reasonable price to operators, maintenance providers and any other person required by to comply with those instructions. While the draft guidance is a step in the right direction by the FAA, it fails to address some of the most fundamental ICA-related issues.
ARSA’s comments reiterate that aviation products are only as airworthy as their constituent components. The applicable airworthiness standards emphasize that ICA requirements apply to all articles that are eligible for installation on all type-certificated products and therefore must be made available by all design approval holders (DAHs). The draft guidance, however, only requires basic safety information be developed and made available at the product-level (TCs, ATCs and STCs). Even in the limited instances when component maintenance data must be disclosed, existing policy enables DAHs to circumvent that obligation by instructing that the component be removed and replaced. That policy ignores the realities of the maintenance process in that a component is typically replaced with one removed from another aircraft. This makes basic component maintenance information essential to maintaining the overall airworthiness of an aircraft.
ARSA’s comments echo the position taken by ARSA and industry stakeholders in a Joint Industry Policysubmitted to the FAA in 2004. Specifically, component-level ICAs should be required and they should contain only the most basic information necessary to perform an overhaul under § 43.2. This successfully balances the need for safety information without requiring the disclosure of all repair data.
The draft guidance incorporates prior policy regarding DAH restrictions on the use and availability of ICAs. Again, while we acknowledge that the guidance is a step in the right direction, it must expand the list of practices that constitute a per se violation of the ICA requirements, particularly with respect to removing repairs form ICAs and directing the part be sent to a DAH authorized maintenance provider.
ARSA will continue to follow this issue and provide updates as they occur.
For more on ARSA’s ICA efforts, click here.
Legal Briefs
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
More on the MAG Change – Section C
By Crystal Maguire, Vice President of Operations
This is the last of a three-part series focused on change 5 to the United States (U.S.)-European Union (EU) Maintenance Annex Guidance (MAG). So far we’ve covered Section A (pages 10-73), which provides instruction to repair stations located in the United States for obtaining and maintaining an EASA Part-145 certificate, and Section A (pages 10-73), which provides the framework for EASA and FAA coordinated oversight of certificated entities.
The MAG’s Section C (pages 121-165) is directed at EU-based approved maintenance organizations (AMO) that have or wish to obtain an FAA part 145 air agency certificate.
See ARSA’s comparison document for a full, red-lined version of the revised document.
Relative to the extensive change in Section B which created reverberations throughout the industry (read more on the FAA Form 8130-3 requirement for new parts), Section C’s revisions were anticlimactic. A summary of the notable modifications to that section follow, many of which do not directly impact repair stations. Specifically, change 5 modified Section C as follows—
- Renamed and replaced references to “EASA Form 6” with “Audit Report 2” throughout. The revised Audit Report 2: Aviation Authority (AA) Recommendation of an FAA-certificated maintenance organization (to be completed by the AA) is located in Section A (page 60).
- Replaced references to FAA “PMI,” “PAI” and “PI” with “ASI” to align the MAG with current FAA job titles.
- Added a provision requiring the FAA to notify TSA when a new FAA certificate has been issued (page 128). This ensures proper implementation of the recent repair station security rule which provides for TSA inspection authority over FAA part 145 repair stations.
- Added various time limits for AA actions, including notification to the FAA of changes to or issuance of a part 145 certificate (three and ten business days, respectively) (pages 135 and 136). The change addresses authority interaction and does not directly affect repair stations.
- Set a time limit by which the FAA must deliver the air agency certificate and operation specifications to the EU-based repair station, specifically, within five days of its review of the AA’s recommendation (page 136). Interestingly, the agreement is silent on the timetable by which the agency must review the documentation!
- Provided the process by which a repair station may continue to issue dual releases while changing its name (page 135). This is a welcome revision and consistent with revisions to Section B (directed at U.S.-based repair stations).
- Replaced the word “should” with the word “must” when referring to documentation requirements for new and used components installed during maintenance (page 150). Unlike their U.S.-based counterparts, this was not a “new” requirement for EU-based repair stations that hold an EASA certificate.
- Provided “clarification of instructions” for issuing an approval for return to service document when the article being maintained is eligible to be installed only on an EU- or U.S.-registered aircraft (i.e., not eligible for a dual release) (page 152). MAG CHG 5 revises language first inserted in MAG CHG 1 (11/22/2011) and provides instructions for completing release documentation when a dual release is impossible (i.e., when products or articles with a single release are installed in the “final” assembly undergoing maintenance).
- Revised section addressing procedures for reporting unairworthy conditions to the FAA (page 153). The AMO has always had to report serious failures, malfunctions, or defects on a component or part of an aircraft that occur as a result of aircraft/system operation. The MAG revision identifies additional ways the maintenance organization may submit reports (i.e., letter, e-mail, or the online reporting systems). AMOs should ensure their manual procedures reflect the process it follows to report unairworthy conditions.
- Made clarifying revisions to sections addressing the AMO’s compliance with and deviation from an air carrier’s continuous airworthiness maintenance program (CAMP) (page 159 and 161). Most notably, the MAG clarifies that deviations from the air carrier’s CAMP be identified in a written agreement between the air carrier and the maintenance organization, and accepted if determined to be equivalent. AMOs should ensure their manuals take this nuance into account.
- Removed prescriptive paragraphs requiring a description of how the organization will comply with manufacturers’ maintenance manuals or ICA, including procedures that the organization will use when an air carrier’s manual deviates from the procedures specified in the corresponding manufacturer’s manual (see page 160-161).
- Revised the FAA eVID information form (page 164) that AMOs are required to submit along with their pre-application statement of intent. The form’s previous version requested the number of FAA certificated and non-certificated mechanics employed by the repair station. The amended version requests the number of EASA “certifying” staff employed.
Excepting the delayed implementation of the FAA Form 8130-3 requirement until April 1, 2016 for U.S.-based repair stations, MAG change 5 goes into effect Dec. 8, 2015.
ARSA on the Hill
ARSA periodically invites lawmakers and other policy leaders to provide commentary on issues that effect the aviation community and the businesses that inhabit it. The views expressed are those of the commentator, not necessarily ARSA.
Taxes: Ten Million Words
By Congressman Joe Pitts
How long is ten million words?
The longest novel, according to The Guinness Book of World Records, is Proust’s A la Recherche de Temps Perdu, which is 1.5 million words long. The King James Bible contains only 774,746 words.
Reading our federal tax laws would take more than four times longer than reading both of those books.
Our tax laws are so complicated that it would take the average college student 15 days to read them, and 20,000 single-spaced pages to print them.
No wonder it takes Americans a total of 7.6 billion hours to do their taxes—the equivalent of 3.6 million full-time jobs, or 867,084 years. That is more than 11,000 lifetimes per year!
This month, federal tax laws reached their ten-millionth word. That’s three times as many words as they comprised in 1965, and twice as many as in 1986. There have been 14,000 changes to federal tax law in the past 30 years, since Ronald Reagan and Tip O’Neill worked together for comprehensive reform.
Every single change to our tax code makes compliance that much harder for American People with better things to do. Every dime that the government takes out of the economy means less investment, less spending, less saving and less in charitable donations. Every minute spent on tax compliance is a minute of time that could have been used for work, for volunteering or for any number of more useful activities. Americans, in effect, work over one day per week for free.
Why would anyone want a tax code so complicated, so difficult to implement and to enforce? Tax lawyers probably like it, because Americans spend another $31 billion on compliance costs.
But even more so, it is politicians and special interests who benefit from such a system: our tax laws are complicated largely because big government plays favorites.
Right now, federal tax revenues are at record highs: Americans gave a staggering $3.1 trillion to the federal government this year, and, according to the White House, this number will only skyrocket to $3.5 trillion next year. Federal tax revenue is larger than the fifth-largest economy on Earth.
But even this astonishing quantity of money is not enough for Washington. The federal government will borrow an additional $400 billion this year, adding to our $18.4 trillion in national debt. The proposition that we should spend only the $3.1 trillion we take in is widely demonized, attacked, and labeled with every kind of insult, but I believe that $3.1 trillion is more than enough government, and $18.4 trillion is more than enough debt.
Even this sum of $3.5 trillion is not enough for some politicians. President Obama says “we can afford it” to spend even more. Senator Sanders wants to spend another $18 trillion on new federal programs.
Despite all of this revenue, there are over $1.3 trillion in deductions taken every year in the United States, and this is the reason that our tax code has been turned to Swiss cheese. It is used for all manner of purposes other than paying for worthwhile government activities, which is supposed to be its purpose. For example, President Obama’s health reform law created another 1,000 pages of tax regulations and led to the hiring of up to 9,000 IRS agents. It didn’t hire a single doctor or nurse, but it did make taxes more numerous, more burdensome and more complicated. That just isn’t serious health reform; that’s doubling down on an already big problem.
The complexity of our tax system is also troubling for Constitutional reasons: of these ten million words, 2.4 million were written by Congress, and 7.6 million were written by unelected, unaccountable Washington bureaucrats. No one voted for three-quarters of these laws.
Our tax laws are so complicated that the federal government spends $10.9 billion just to pay for the IRS. At a certain point, a government—or any other entity—becomes too large and complicated to manage. Such complexity is self-defeating, like a Rube Goldberg machine, because taking up time and resources detracts from people’s ability to create the wealth to pay for government. Ronald Reagan said in 1975 (when tax laws were 3.9 million words) that “we live in the only country in the world where it takes more brains to figure out your income tax than it does to earn the income.” How much more true is this statement now?
We can do better, and I am confident that we will. Consensus is building across the country that these latest words in our tax laws ought to be their epitaph.
Rep. Joe Pitts (R-Pa.) is in his tenth term in Congress. He represents Pennsylvania’s 16th congressional district and serves on the House Energy & Commerce Committee, where he chairs the Health Subcommittee.
Quality Time
By Jennifer M. McNelly, President, The Manufacturing Institute
Jennifer M. McNelly, President, The Manufacturing Institute
Manufacturing matters in the United States. The manufacturing industry has the largest multiplier effect of any sector, with every dollar in manufacturing supporting $1.37 in other sectors. According to our most recent public perception report, if given an opportunity to create 1,000 new jobs in their community, Americans ranked manufacturing first.
At the same time, only about one third of these respondents said they would encourage their own children to pursue a career in manufacturing. The manufacturing industry is well aware of the image issue we are facing when trying to attract new talent. The Manufacturing Institute has worked to address this through three key pillars: changing the perception of careers in manufacturing, re-establishing the United States as the global leader of manufacturing education and advocating for education and job training policies that strengthen the U.S. manufacturing workforce.
The Manufacturing Institute is focusing on the following best practices to strengthen career and technical education (CTE) and science, technology, engineering and math (STEM) careers and education pathways and make them more attractive to students:
(1) Increase the number of industry recognized credentials awarded at the secondary and postsecondary levels.
(2) Increase industry partnerships to better align curriculum and apprenticeship, internship and work based learning opportunities.
(3) Better articulate credit transfers from high school to community colleges and from community colleges to four-year institutions.
(4) Increase access and incentives for dual enrollment.
(5) Develop Comprehensive State Strategies to include each of these elements.
States like Kansas have taken steps to utilize existing resources to better align incentives to attract students into manufacturing education pathways by providing incentives to enroll in college level CTE courses while still in high school. Tennessee has gone a step further by better aligning their College of Applied Technologies (T-CAT) system to bring better course equivalencies to their CTE programs when compared to college level programs. These state-led fixes using existing resources can be brought to federal policy as well and the upcoming reauthorization of the Higher Education Act (HEA) and the Carl D. Perkins Career and Technical Education Act (Perkins) are perfect opportunities for manufacturers and their partners to push for change.
The Higher Education Act is the largest federally funded training program in the United States, yet our community and technical colleges’ workforce training programs aren’t able to fully access the $130 billion dollars in federal financial aid and Pell grants because of policy limitations. With the recent reauthorization of the Workforce Innovation and Opportunity Act (WIOA), we have seen that bi-partisan support exists for recognizing the value of industry recognized credentials and high quality job training. However, a disconnect remains between policies being promoted by the labor market and those in place in education.
In the United States, only 30 percent of the population holds a bachelor’s degree, yet we have continued to frame our higher education policies around that small population. Policies at the state and federal level that control higher education funding are largely out of line with what is needed at our nation’s community and technical colleges to prepare our future workforce. The unemployment rate is at a seven year low, yet about 29 million “middle-skills jobs” – positions that require more than a high school diploma but less than a bachelor’s degree – remain unfilled. Of these 29 million jobs, 14 million of them have a starting pay of at least $50,000 a year, with four million paying a starting salary of $75,000 or more a year. These job vacancies put a strain on American competitiveness and our nation’s manufacturers.
The most frustrating part of this scenario is that it doesn’t have to be the case. Community and technical colleges provide the bulk of the training to fill these job vacancies, yet headline after headline seek to condemn these schools for not hitting metrics designed without their programs in mind. It’s time for the conversation around higher education to change.
The way today’s education policy is constructed, a student graduating from a four-year institution with an average of just under $30,000 in debt and uncertain job prospects is a better education outcome than a student who receives an industry recognized certification but no degree and leaves with one of those middle skill jobs paying upwards of $50,000 … and no debt. In many states, the latter scenario would be a blight on an institution’s completion rates, despite the student completing the necessary courses and credentials needed to gain a middle-wage job. Policies like these need to better reflect both student and employer expectations.
Students are entering postsecondary education expecting to receive the education and training needed to thrive in today’s job market, yet only 11 percent of employers say that recent graduates are well prepared for the labor market. This is unacceptable and unsustainable for the future of our economy. We need to revisit the purpose of higher education in the United States and to make it a priority to improve quality education pathways and incorporating work-based learning opportunities. Manufacturers and their partners need to be more active in this conversation because building a high quality talent pipeline is critical for both the future of manufacturing as well as the broad economic needs in the United States.
Jennifer McNelly is the president of The Manufacturing Institute, which focuses on the qualification and development of world-class manufacturing talent. With a diverse membership and strong representation from aviation firms, the Institute provides research, resources and advocacy for developing the next generation of skilled workers.
Training
By ARSA Communications Staff
Just like a wrench or testing device, memory is an important tool for any aviation professional. Unfortunately, effective working memory – information that is stored for short term, ready access – is dramatically limited. Under stress or a high workload situation, this precious resource can become ever more limited.
This two minute, FAA-produced training video delivers valuable information regarding both formal and informal memory aids, their use and application and their importance to effective performance. While the video uses ATC operations for reference, the general principles it presents represent vital resources for the entire aviation community.
Invest two minutes in yourself. Click here now to begin, so you won’t forget.
ARSA Online Training Series: Part 145
By Brett Levanto, Vice President of Communications
Join ARSA Executive Director Sarah MacLeod for a three-session training series covering part 145. This holiday season give yourself the gift of useful knowledge: what does the regulation governing repair stations really say about your business.
Register now for individual sessions ($75 each for members) or bundle all three together and save.
Part 145 – The Business End
Real world implications of aviation safety requirements.
On Demand – Available Anytime
Click here to register and get 90 days’ access.
Part 145 – Get Your House In Order
Housing, facility and equipment requirements in aviation safety regulations.
Date: Dec 9, 2015
Time: 11:00 am EST
Click here to register.
Part 145 – Friends in Certificated Places
Maintenance personnel requirements in aviation safety regulations.
Date: Dec. 16, 2015
Time: 11:00 am EST
Click here to register.
Registration for each class includes:
- Attendance for the live, online class session on the scheduled date.
- Access to the on-demand recording available after the live session is complete.
- Digital copies of the presentation and all reference material with links to relevant resources and citations.
- A certificate upon completion of the class (including 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.
Regulatory Compliance Training
Membership
Member Spotlight – Jet Center MFR
By Sarah Hartley, Communications Coordinator
As a full-service, independently operated FBO, Jet Center MFR has provided customers with aircraft management, aircraft maintenance and parts, avionics services and aircraft sales support in a state-of-the-art facility and aircraft hangar in Southern Oregon since 1967.
This family-owned FAA certificated repair station prides itself on being small enough to know its customers and large enough to serve them. Jet Center MFR meets aviation maintenance needs throughout the Pacific Northwest and Northern California. Its team has more than 200 years combined experience in aviation maintenance, including 100 years avionics experience both on bench and install.
Just as Jet Center MFR serves the aviation industry in its region, General Manager Gary Hudnall serves the entire maintenance community on ARSA’s board of directors. Following his time as vice president and secretary, Hudnall was elected board president at its October meeting in Washington, D.C. ARSA is grateful for Hudnall and the rest of the board for their commitment to repair stations worldwide.
To learn more about Jet Center MFR, visit: http://jetcentermfr.com/.
Have You Seen These People? AMT Magazine Next Gen Award Winners
By ARSA Communications Staff
The future of the aviation community depends on finding and retaining a world class workforce. A key piece of that effort is to celebrate excellent young men and women already serving the flying public every day. To that end, AMT Magazine has announced its inaugural class of Next Gen Award Winners: individuals under 40-years-old who have committed their talents and time to maintaining civil aircraft.
Help ARSA celebrate the winners. Get to know each of them in this month’s edition of AMT Magazine.
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/.
Target Your Message: Advertise Today in ARSA’s Newsletters and Website!
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 http://arsa.org/advertise/
Q: As a component MRO, we don´t have access to the operator’s continuous airworthiness maintenance program (CAMP). So, may we proceed with the overhaul of a component if we receive a repair order from our customer indicating that it wants the component to be overhauled?
A: Most often an “overhaul” is requested as a work scope whether or not the customer actually needs to “overhaul” the article (i.e., when an article is “hard-timed” by an operator under a CAMP).
Thus, it rarely matters whether an overhaul is “required” by a CAMP; rather, it matters that the repair station performs the greatest work scope available under the appropriate manufacturer’s maintenance instructions or other methods, techniques and practices acceptable to or approved by the FAA (see § 43.2).
So, yes, the repair station may proceed with overhaul when it receives a request to perform that work scope.
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.
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.
Upcoming Events
Industry Calendar
Aerospace Meetings Brazil – Sao Paulo, Brazil – December 8-10
MRO Latin America – Lima, Peru – January 21-22
MRO Middle East – Dubai, UAE – February 3-4
HAI Heli-Expo – Louisville, Kentucky – Februrary 29-March 3
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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. 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.
© 2015 Aeronautical Repair Station Association
