2016 – Edition 6 – July 1
Table of Contents
Sarah Says
Hotline Features
ARSA Works
Legal Briefs
ARSA on the Hill
Regulatory Outlook
Quality Time
Training
Membership
AVMRO News Portal
Upcoming Events
Sarah Says – International Connections
By Sarah MacLeod, Executive Director
Every year, the FAA and EASA host a meeting of industry and multiple national aviation authorities. The location alternates between the United States and Europe. The meetings originated before the existence of EASA and have expanded to include representation from the national aviation authorities of Brazil, Canada and China, to name just a few. The association, along with almost every other aviation trade group, has participated in these gatherings to ensure the voice of aviation maintenance is actually heard and heeded.
What has become evident in the last several years is the need for representation from ARSA’s membership; large multi-national companies are not the only entities that should get international facetime. It is great to see colleagues from Lufthansa Technik, Boeing and other large corporate members, but it would be even better to see representatives of small-to-medium-size aviation-maintenance centric businesses.
At the “International Safety Conference,” as the agencies call it, the ability to interact with international regulators at high echelons is unparalleled; the interest in learning from the regulated parties is unprecedented. In other words, the connection between businesses and regulators is matchless and may be the single most important element of ensuring safety of flight worldwide – not to mention the continued health of the aviation maintenance industry.
ARSA has opened to the door and will continue to advance the maintenance community’s interests. However, the association-as-proxy is no substitute for personal interactions with the regulators that dictate the requirements of international business relationships.
Next year’s conference will be held in conjunction with the Paris Air Show. It would behoove every international business entity to ensure its people are at a conference that helps sets the price of admission to the international maintenance industry.
ARSA will certainly be there, what about you?
Building networks is a valuable piece of business survival. Check out this month’s ARSA on the Hill, and get tips on how to connect with your local congressional offices.
Hotline Features
House Committee Opens Effort to Overhaul Technical Education
By ARSA Legislative Team
On June 28, leaders of the House Committee on Education and the Workforce unveiled the “Strengthening Career and Technical Education for the 21st Century Act.” Introduced by Reps. Glenn “GT” Thompson (R-Pa.) and Katherine Clark (D-Ma.), the legislation would reauthorize and reform the Carl D. Perkins Career and Technical Education Act, which is the central federal investment mechanism for high-skill training.
Since 1984, the Perkins Act has provided federal support to state and local career and technical education (CTE) programs. Its grants have offered students the opportunity to gain the knowledge and skills necessary to compete for jobs in a broad range of fields, such as manufacturing, maintenance, health care and technology. Unaltered since 2006, the law no longer reflects the realities and challenges facing students and workers.
Through the bill, committee members seek to build on recent K-12 education reforms in order to:
- Deliver states more flexibility to use federal resources in response to changing needs.
- Ensure CTE prepares all students, including historically disadvantaged and vulnerable students, for success in high-skill, high-wage occupations and careers in nontraditional fields.
- Improve alignment with in-demand jobs by supporting innovative learning opportunities, building better community partnerships, and encouraging stronger engagement with employers.
- Enhance career and technical education through increased focus on employability skills, work-based learning opportunities, and meaningful credentialing so students are prepared to enter the workforce poised for success.
- Streamline performance measures to ensure career and technical education programs deliver results for students and taxpayers.
- Reduce administrative burdens and simplify the process for states to apply for federal resources.
- Reward success and innovation by directing federal resources to replicate promising practices that best serve students and employers.
- Provide parents, students, and stakeholders a voice in setting performance goals and evaluating the effectiveness of local programs.
- Empower state and local leaders to develop plans that improve the quality of career and technical education and take into account unique local and state needs.
On Jan. 8, ARSA joined more than 350 other organizations in a letter urging Congress to reauthorize Perkins. With businesses in all industrial sectors struggling to find technically-capable workers, responsive federal workforce policy should provide states and communities with the tools necessary to stimulate the growth of skills that put students into jobs. Congress must prioritize technical education and utilize Perkins as a tool to further empower states to support needed skills. Stay tuned as the bill – and the long-expected version from the Senate’s Health, Education, Labor and Pensions (HELP) Committee – move forward through the legislative process.
Take a moment to tell Congress that the aviation maintenance industry needs help. Click here to send a message to your elected officials, remind them that they can’t fly without us and we can’t fly without skilled workers.
Use the following links to learn more about the Strengthening CTE for the 21st Century Act:
| Fact Sheet | Bill Summary | Full Text |
Federal Register Resources: Mastering the CFR
By ARSA Communications Team
ARSA team members constantly search for resources, guides and tools that might be useful for our members as they work to ensure global aviation safety. This installment comes from the Office of the Federal Register:
Regulatory compliance demands a deep knowledge of the rules. To develop and maintain such acumen requires effective navigation of the Code of Federal Regulations (CFR). To get tips from the keepers of the code and get answers to frequently asked questions, check out the Office of the Federal Register’s video series Mastering the CFR.
Watch the video below or click here to get started.
To go directly to the Federal Register, visit: www.federalregister.gov.
To go directly to the electronic Code of Federal Regulations (eCFR) – which is linked so often in ARSA communications and training – visit: www.ecfr.gov.
Where in the World is EASA? Office Move
By ARSA Communications Team
Effective June 6, the headquarters offices of EASA relocated to:
Konrad-Adenauer-Ufer 3
D-50668 Cologne, Germany
The mailing address (post office box) and telephone contacts will remain the same:
Mailing Address
Postfach 10 12 53
D-50452 Cologne, Germany
Telephone
+49.221.8999.000
General Email
info@easa.europa.eu
For more information, visit: https://www.easa.europa.eu/can-we-help-you#we-are-moving.
ARSA Works
To see all the ways ARSA works as the voice of the aviation maintenance industry, visit the ARSA Works page.
ARSA Seeks Input on Repair Specification Guidance
By ARSA Regulatory Team
ARSA has been working for years to develop comprehensive, cohesive and coordinated guidance on developing, approving (if necessary), using and maintaining maintenance and alteration specifications. In other words, let’s create a standard process for maintenance providers to develop alternative repair and modification instructions to those fashioned by the design approval holders. The effort is equivalent in scope to obtaining “complete” sets of instructions essential to continued airworthiness required by the plain language of section 21.50(b) (see the fruits of the association’s effort on obtaining instructions for continued airworthiness by clicking here).
In 2007, ARSA introduced AC 43.XX in an effort to get “multiple” major repairs approved—the result instead was the appointment of “repair specification” designated engineering representatives and AC 21-47.
In its latest efforts to provide comprehensive processes for independently developing maintenance information, the association has teamed with Airlines for America (A4A) and other trade groups. The effort will culminate in methodologies associated with maintaining or altering completed, general aviation, non-pressurized aircraft represented by Advisory Circular (AC) 43-210 (now supposedly applicable to a much wider range or repairs and alterations), AC 120-77 for air carrier developed information and AC 43-XX for “shop” maintenance data used by the vast majority of repair stations.
ARSA and A4A are reviewing AC 120-77; the effort started with a webinar listening session, followed by a comprehensive review of the document, gathering and disseminating comments among the industry participants and will culminated in an undated version of the AC.
A similar effort will be made with AC 43-XX; please review and make comments on the draft document, then join the July 13 Online Listening Session for an open discussion of its purpose and content, provide tracked changes/comments for potential incorporation and join the final discussion before the document is submitted to the agency.
How to get involved:
(1) Download the draft AC 43-XX document:
Click here to download the draft AC.
(2) Use “tracked changes” to make comments/suggestions/edits.
(3) Return your edited version as an attachment to arsa@arsa.org.
(4) Register for the Repair Specifications Listening Session on Wednesday, July 13 at 11:00 a.m. EDT. Click here to register.
ARSA Comments on Revised Rulemaking Procedures
By ARSA Regulatory Team
On June 29, ARSA submitted comments on the FAA’s proposed revisions to 14 CFR part 11. The purpose of the rulemaking was to improve the clarity and flow of the rules; however, the proposal needed some input from the public to achieve that objective.
For instance, in § 11.27 the agency proposes to enumerate advisory committees from which the agency can receive rulemaking recommendations. This revision is unnecessary. FAA already has statutory authority to form advisory committees, making the proposed additions duplicative. Furthermore, the revision could confuse the public – and perhaps even the agency – regarding the ability to accept rulemaking recommendations from non-enumerated committees.
ARSA also believes agencies should refrain from including website addresses in regulations. If an agency feels compelled to use a web address in a rule, it should only use those that are the least likely to change. Web addresses and similar explanatory information are more appropriate for inclusion in guidance documents.
ARSA maintains that regulations should be clear, concise and free of superfluous text.
To read the association’s comments, click here.
To see the association’s perspective on simplicity in rulemaking, read this month’s Legal Briefs.
ARSA-Led Effort, FAA Response Provide Path to 8130-3 Compliance
By ARSA Regulatory Team
On June 24, the Design, Manufacturing and Airworthiness Division (AIR-100) of the FAA’s Aircraft Certification Service issued two deviation memos to FAA field offices that will help repair stations comply with the requirements of the U.S.-EU Maintenance Annex Guidance (MAG).
MAG CHG 6 (and its predecessor CHG 5) require Form 8130-3 to be issued for new parts released by a PAH on and after Oct. 1, 2016 if subsequently installed during maintenance subject to the MAG.
The deviation memoranda:
(1) Facilitate production approval holders’ (PAH) implementation of section 21.137(o) authorizing such entities to issue Form 8130-3 as an Authorized Release Document.
(2) Allow the issuance of Form 8130-3 as an export document for articles without having to mention the article complies with the importing requirements of a specific country. For engines and propellers the FAA will allow multiple countries to be referenced. Other block 12 statements referenced in Order 8130.21 or required by bilateral agreements (e.g., “This PMA part is not a critical component.”) must still be included.
As part of an ongoing effort to address issues with the MAG, an ARSA-led industry coalition worked closely with the FAA for two months ahead of memos’ issuance. The effort included both aviation trade associations and private businesses that made headway with the FAA and EASA by delivering letters, meeting with officials from both agencies and engaging in an informed public discourse about the difficulties caused by the new 8130 requirement.
While there are many challenges remaining for PAHs to modify their quality and IT systems to accommodate the changes in time for the MAG CHG 6 implementation date of Oct. 1, 2016, the memos will go a long way toward giving industry the tools needed to comply.
ARSA’s efforts regarding the 8130 requirement have been supported by: the Aerospace Industries Association, the Aircraft Electronics Association, Airlines for America, the Aviation Suppliers Association, the General Aviation Manufacturers Association, the Modification and Replacement Parts Association, MOOG Aircraft Group, Honeywell Aerospace, Gulfstream Aerospace Corporation and the Boeing Company.
Click here to download both memos (zipped file).
Stay tuned to ARSA’s website for more information on parts documentation requirements (arsa.org/production-certificates) as well as the fifth (arsa.org/mag-change-5) and sixth (arsa.org/mag-change-6) revisions to the U.S.-EU MAG.
ARSA, Industry Allies Call for Correction to “Untenable” Parts Documentation Guidance
By ARSA Regulatory Team
On June 10, seven trade associations and four aerospace companies – led by ARSA – requested the directors of flight standards for the FAA and EASA revise guidance on international parts documentation.
Since last September, the association and its allies have worked to help the agencies correct regulatory issues created by the 2015 revision of the Maintenance Annex Guidance (“MAG Change 5”) to the U.S.-EU Bilateral Aviation Safety Agreement (BASA).
The nine-month-long effort deals with the requirement that U.S. Production Approval Holders (PAH) issue FAA Form 8130-3 with all new parts for which a dual maintenance release will be issued. The privilege to issue that form was created in Title 14 Code of Federal Regulations (CFR) § 21.137(o) last October. Since that time, the FAA and EASA have issued two extensions to give both the FAA and industry time to comply. The most-recent extension was announced to ARSA in a letter dated April 14, 2016 and distributed to FAA personnel in Notice 8900.360.
Unfortunately, the extensions include a note indicating parts released by a PAH prior to Oct. 1, 2016 will remain suitable for installation on EU articles only if they have appropriately-dated documentation from the PAH containing the same technical information as an FAA Form 8130-3. That “requirement” is problematic for a host of reasons. Many articles – especially older parts – do not have dated documentation, and even fewer are from or by a PAH. Although an article’s packaging and associated documentation can identify the source, they will not have the same information as an FAA Form 8130-3. Furthermore, documents (such as certificates of conformance, airline certifications, shipping tickets, invoices, etc.) or identification markings are used to provide evidence that a part is eligible for installation. Under the extensions this information will no longer be sufficient unless it is issued by or from the PAH.
The coalition requested the agencies issue another letter and revise Notice 8900.360 to remove the dated documentation requirement for articles released from a PAH prior to Oct. 1, 2016. As is the current requirement, all new parts must be accompanied by acceptable evidence of airworthiness that meet the regulations for record keeping at the time of production and/or sale.
“The central issue is to help the FAA and EASA rely on their already-dependable systems for ensuring airworthiness,” said Marshall S. Filler, ARSA’s managing director and general counsel, who has been the industry’s point person on the issue since MAG Change 5 was signed last fall. “Regardless of the documentation that accompanies a part, it is subject to a robust quality system and careful regulatory oversight. Therefore, it’s perfectly reasonable to grandfather the parts released by a PAH prior to Oct. 1, 2016 and we greatly appreciate the agencies’ granting another six-month extension. However, the grandfathered conditions should not be so burdensome that they exclude large numbers of airworthy articles.”
The letter’s delivery coincided with the beginning of the Annual International Safety Conference, co-hosted by the FAA and EASA and featuring Filler in a plenary discussion on bilateral agreements. As industry representatives and regulators convene in Washington from June 14-16, those representing U.S. parts manufacturers have the perfect pulpit from which to pursue sensible oversight.
“This letter is part of an ongoing effort specific to the Form 8130-3 requirement,” Filler continued, noting his participation alongside representatives from the FAA, EASA and industry during the conference. “More importantly, though, it is the perfect example of hurdles that must be overcome to truly realize the benefits of bilateral relationships. When our governments sign these [bilateral aviation safety] agreements, they are endorsing the principle that each other’s technically equivalent systems will be mutually accepted. In the absence of a compelling safety justification, that should mean simpler compliance and reduced economic burdens — not the opposite. I’m glad we can discuss it this week [during the conference], but I’m determined that the parts documentation issue serve as an example of how easily things can get off track.”
Since the 2015 change to the MAG was issued, a new revision – the sixth – has been signed. Although an improvement over its predecessor, “MAG Change 6” did not resolve all the issues and perpetuated many of the problems in the agencies’ April 14th letter.
In addition to ARSA, the letter was signed by representatives from: the Aerospace Industries Association, the Aircraft Electronics Association, Airlines for America, the Aviation Suppliers Association, the General Aviation Manufacturers Association, the Modification and Replacement Parts Association, MOOG Aircraft Group, Honeywell Aerospace, Gulfstream Aerospace Corporation and the Boeing Company.
To download a copy of the letter, click here.
Visit ARSA’s website for more information on parts documentation requirements (arsa.org/production-certificates), the International Safety Conference (arsa.org/faa-easa-conference) and the fifth (arsa.org/mag-change-5) and sixth (arsa.org/mag-change-6) revisions to the U.S.-EU MAG.
ARSA Works: On Stage and Behind the Scenes at FAA-EASA Conference
By ARSA Communications Team
On June 14-16, the international aviation safety community landed In Washington, D.C., for the 2016 International Safety Conference, co-hosted by the FAA and EASA. On stage and behind the scenes, ARSA continued building its global network.
The conference’s plenary sessions began on June 14 with a panel considering a key question for international aviation: “How do we achieve the true benefits of a bilateral?” Marshall S. Filler, ARSA’s managing director and general counsel, participated alongside agency officials and industry executives, including EASA’s Executive Director Patrick Ky.
The association is committed to pursuing bilateral and multilateral agreements; a 2011 ARSA-commissioned study found repair stations enjoy considerable cost savings when working among nations with bilateral agreements. Through reciprocal acceptance, civil aviation authorities maximize the safety benefits of international oversight while minimizing compliance burdens. Such reciprocity is rare, but Filler’s participation in the panel is integral to pursuing better international agreements.
Off stage, ARSA senior staff met with Ky and EASA’s Flight Standards Director Ricardo Génova Galván. Executive Vice President Christian A. Klein and Vice President of Legislative Affairs Daniel B. Fisher joined Filler to brief the agency’s leadership on the association’s work.
ARSA representatives often join international gatherings as the maintenance community’s sole voice. For the association, this role – in the lead on behalf of the men and women who keep the world in flight – is natural. While it cultivates a growing web of allies, advocates and contacts around the world, ARSA encourages its members to seek out such events, build their own connections and add more voices to the maintenance “chorus.”
Legal Briefs
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.
Rulemaking Comments – Keep Part 11 Simple
By Ryan M. Poteet, Regulatory Affairs Manager and Kimberly R. Villiers, Regulatory Affairs Coordinator
On June 1 the FAA issued a notice of proposed rulemaking (NPRM) to consolidate general rulemaking and waiver procedures. Currently, commercial space transportation rulemaking is conducted under 14 CFR part 404, while all other FAA rulemaking is conducted under part 11. The proposal seeks to clarify which provisions from part 11 specifically apply to commercial space transportation and to update various other provisions.
ARSA maintains that regulations should be free of unnecessary language and explanatory information which is more appropriate for guidance documents. Unfortunately, when superfluous text—no matter how well intentioned—finds its way into a rule it can have unintended consequences.
For instance, the FAA proposes to enumerate the Aviation Rulemaking Advisory Committee (ARAC) and the Commercial Space Transportation Advisory Committee (COMSTAC) in § 11.27 as examples of advisory committees that can provide recommendations to the agency. The apparent purpose of § 11.27 is to explain the methods by which the FAA can obtain recommendations for rulemaking. Enumerating specific advisory committees is unnecessary because the rule already states the FAA has statutory authority to create rulemaking committees. The regulation may be misinterpreted as excluding or limiting the use of unnamed committees and therefore, for the purpose of promulgating clear regulations, specific examples of advisory committees should be avoided.
ARSA’s comments also counseled against the FAA’s inclusion of website addresses in regulatory text. Websites and webpages frequently change or disappear altogether. Including them forces the agency to undertake the long, tedious, and expensive rulemaking processes simply to update web addresses. The NPRM’s inclusion of website information in § 11.63 may assist the public in the short-term but ultimately undermines the agency’s goal of maintaining reliable and accurate information.
Critically reviewing rulemakings, while proposing viable solutions, is an integral part of the association’s work. ARSA continues to stress the importance of having clear and concise regulations that ensures proper interpretation.
ARSA on the Hill
Constituents Matter: Congressional State/District Offices
By Daniel B. Fisher, Vice President of Legislative Affairs
While ARSA’s legislative team works hard for you daily, nothing substitutes for a constituent’s personal involvement in the legislative and political process. During the next few months, ARSA on the Hill will highlight ways you can engage your lawmakers without leaving your local area.
This month we’re going to focus on the role district offices play in a congressional staff. A district office (U.S. senators and staff often refer to it as “state offices”) represents the home base for your U.S. House and Senate representatives. It employs dedicated individuals from the local community who answer constituent concerns. The staff is ready to answer questions about legislation, provide information about district activities, set up an appointment with your representative and help with other matters of importance or interest.
To find your representative and senators, visit http://ofmk.freeenterpriseaction.com/9avEPgM. On the upper right-hand side, you can find your legislators by entering your address and zip code.
The search will bring up your representatives and senators. Clicking on respective links allows you to view a background and contact information page for each of your elected officials, including websites, Twitter and Facebook pages and Washington, D.C. contract info.
To access information about their home offices, you’ll need to visit their websites for further information. Most representatives and senators have more than one district office, making your visit even more convenient. Remember your company and residence might be in different congressional districts or states; if so, you may engage multiple sets of elected officials representing your home and business.
Visit the home office to inform your lawmakers and staff of issues important to your business – let them know you are there and you represent votes! Opening the door to an ongoing dialogue through this local contact is easy, but if you are still feeling uncomfortable about making politics local, email us for assistance. Remember, your voice matters!
Stay tuned to July’s ARSA on the Hill edition to learn how to actively participate in congressional town hall meetings.
Building networks is a valuable piece of business survival. Check out this month’s Sarah Says and get insight into the value of attending events hosting by international regulators.
Regulatory Outlook
MAG Change 6 – Some Gains but a Long Way to Go
By ARSA Regulatory Team
On June 1, the FAA and EASA released Change 6 to the U.S.-EU Maintenance Annex Guidance (MAG CHG 6). MAG CHG 6 includes some amendments sought by ARSA and its industry partners relating to the need for Form 8130-3 for new parts subject to the MAG (i.e., those installed in dual release repairs). Regarding this issue, MAG CHG 6:
(1) Includes a fabricated parts exception from the Form 8130-3/EASA Form 1 requirement.
(2) Removes the term “OEM” and “PC holder” from MAG CHG 5, replacing them with the more appropriate “production approval holder” (PAH).
(3) Removes the requirement that a component must be referenced in the type certificate holder’s Illustrated Parts Catalogue for it to be acceptable for installation.
MAG CHG 6 does not affect the Oct. 1, 2016 implementation date when Form 8130-3 must accompany new parts released by a PAH. Unfortunately, MAG CHG 6 restated the following note included in the agencies’ April 14 letter to ARSA and Notice 8900.360:
NOTE: New parts that were received into inventory prior to Oct. 1, 2016 must, at a minimum, have a document or statement (containing the same technical information as an FAA Form 8130-3) issued by the PAH or supplier with direct ship authority. These parts in inventory, documented with the required information, will be grandfathered and remain suitable for installation into EU articles, provided the certification/release date of these parts is prior to Oct. 1, 2016. (emphasis added)
ARSA and its industry partners will continue to seek changes to the note, which imposes unreasonable restrictions on the use of some airworthy inventory (e.g., new airline surplus parts received without PAH documentation) in dual release repairs. In addition, the industry group is working closely with the Aircraft Certification Service to speed up the implementation of sec. 21.137(o) allowing PAHs to issue Form 8130-3 as an Authorized Release Document and clarify Order 8130.21H relating to the use of Form 8130-3 for export.
To view change 6, click here.
For more on MAG CHG 5, visit arsa.org/mag-change-5.
For more on the effort to effectively implement 21.137(o), visit arsa.org/production-certificates.
FAA Builds Reasonable, Flexible UAS Framework
By ARSA Regulatory Team
On June 21, the FAA announced the first operational rules for routine commercial use of small unmanned aircraft systems (sUAS). The rule, which has since been published in the Federal Register, establishes 14 CFR part 107 to govern the broad category of aircraft commonly referred to as “drones.” Through its first effort at such oversight, the agency effectively established a limited framework within which to regulate operations.
In 2015, ARSA submitted comments to the agency’s notice of proposed rulemaking (NPRM), adding its voice to thousands of others – 4,665 total – with an interest in UAS regulation. Efforts to integrate the aircraft into the national air space draw considerable attention from Congress and general public, with potential applications in everything from retail shopping to real estate.
ARSA’s comments implored the agency to restrain its certification and oversight responsibility. “In regulating [small UAS] and, eventually, all UAS operations, the FAA cannot afford to divert attention from its existing oversight responsibilities,” the association’s submission said. “Additionally, the agency must limit burden on small businesses and prevent obstruction of the fast-moving market for emerging unmanned technologies.”
In response, the final rule creates a basic structure for UAS operations but allows for considerable flexibility and limits burdens on both the FAA and the public. Individual users may obtain waivers from operational restrictions by approval of the administrator. The agency limited any “undue burden” on both itself and industry by exempting sUAS from airworthiness certification.
This is a significant first step in controlling the use of sUAS by serious aviators and the general public. The aviation industry has long been a small community of knowledgeable certificate holders and aviation safety inspectors carrying the responsibility for air safety. The comparatively simple requirements for sUAS represent acknowledgement of the new challenge posed by having the general population – as it will be in most sUAS users – as both operator and maintenance provider.
To review the final rule, 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. To view the list, click here.
Quality Time
Podcasts for Political Junkies
By Christian A. Klein, Executive Vice President
Podcasts have become a vital resource for business leaders. These informative, insightful and often-entertaining productions focused on specific topics or themes represent an important source of knowledge that can be tapped into while sitting in the office, relaxing at home or driving to soccer practice.
Think of podcasts as radio on demand. Podcasters record programs that you can listen to whenever you want by navigating to the program on your smartphone or computer web browser and clicking on the program’s “listen” link. There are also numerous smartphone and tablet aps – TuneIn Radio, Stitcher and iTunes built-in Podcast app to name a few – that act as a single gateway to listen to podcasts.
Some are done by professionals working for well-known news organizations, some are simply recordings of regular radio shows and some are done by amateurs with an interest in a particular subject area. Chances are that no matter what your passions, you’ll find podcasts on those topics. A “favorites list” of shows might include professional soccer, archaeology or home brewing in addition to business, news or politics.
In staying informed, political publications, email alerts and human intelligence gathered through colleagues, personal connections and ARSA’s communications are all useful tools. Listening to political podcasts can be another way to keep a finger on the pulse. There are many options, but any listener – from political novice to experienced operative – would do well to start with one of the favorites identified by the association’s team in Washington:
The Political Junkie
Ken Rudin is a seasoned journalist with decades of experience, first with ABC News and then for more than 20 years as political editor for National Public Radio (NPR). He’s also hilarious. Rudin’s weekly podcast is the most in-depth and entertaining I’ve found about what’s happening in national and state politics. His program combines analysis, history, trivia, puzzles, great interviews with insiders and a lot of humor into a must-listen package. http://krpoliticaljunkie.com/
Left, Right and Center
The program, which airs Fridays on KCRW, bills itself as “an alternative to “the screaming talking heads that dominate political debate.” LRC is hosted jointly by three political journalists: Josh Barrow (Business Insider), Rich Lowry (National Review) and Robert Scheer (San Francisco Chronicle). Although their views span the political spectrum, often (though not always) they’re able to break through the talking points and find kernels of truth at the heart of major issues. http://www.kcrw.com/news-culture/shows/left-right-center
Backstory
To understand what’s happening America today, it helps to know what happened yesterday. Each week on Backstory, “the American History Guys” – two professors from UVA and one from University of Richmond – choose a single topic and look at it through the lens of three centuries of U.S. history. Recent episodes have focused on local political powerbrokers, Cuba, contagious diseases, armed resistance, unemployment, religion, political conspiracy theories and alcohol. http://backstoryradio.org/
Planet Money
This weekly NPR podcast is a fun, quirky and intelligent place to learn more about economic history, the impact of public policy and all the weird things you never knew drove the economy. http://www.npr.org/sections/money/
Podcasts are a fun way to bolster general knowledge and maintain awareness of what’s going on in Washington and across the nation. Whether you’re stuck in the office or behind the wheel in traffic, make good use of your time by clicking “play.”
Training
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.
Live Sessions in July and August – Register Now
By ARSA Training Team
Registration for each session includes:
- Attendance for live, online class session on the scheduled date.
- Access for 90 days to the on-demand recording made 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 each class (including any test material).
Listening Session – Repair Specifications
This session provides an opportunity for the maintenance industry to share comments and concerns regarding ARSA’s draft advisory circular on development and approval of repair specifications.
Date & Time: July 13 at 11:00 a.m. EDT
Session Lead: Sarah MacLeod
Special Price: $25 for ARSA Members ($50 for non-members)
Click here to register.
Contract Maintenance – Functions and Vendors
Description: This session provides information on obtaining approval of maintenance functions and selecting and categorizing maintenance function vendors properly under 14 CFR part 145.
Date & Time: July 20 at 11:00 a.m. EDT
Instructor: Sarah MacLeod
Click here to register.
The Fourth Branch of Government – Administrative Agencies & Their Powers
Description: This session will review why federal administrative agencies are created and how they use their powers to regulate activities within their jurisdiction. The session will also cover the basic procedures agencies must follow to create or revise regulations.
Date & Time: August 3 at 11:00 a.m. EDT
Instructor: Sarah MacLeod
Click here to register.
Congressional Testimony – The When, Why and How
Description: This session provides an overview of the reasons why private individuals would want to testify before congressional committees and how to take advantage of opportunities to do so.
Date & Time: August 10 at 11:00 a.m. EDT
Instructors: Christian A. Klein & Daniel B. Fisher
Click here to register.
Full ICA Series Available On Demand
By ARSA Training Team
View ARSA’s three-part series on instructions for continued airworthiness (ICA), led by Managing Director and General Counsel Marshall S. Filler. ICA has been a key focus of ARSA’s work on behalf of the maintenance community for decades and it continues to demand attention from aviation businesses worldwide. Turn the association’s experience into your benefit.
ICA – The Basics
Description: This session overviews the regulatory basis for ICA, including what documents are considered ICA and the obligations of design approval holders to prepare, furnish and otherwise make them available under 14 CFR § 21.50(b). It also covers the related regulations that apply to operators and maintenance providers regarding the use and availability of ICA. Finally, it shows how the FAA has interpreted some of the more important ICA requirements in Order 8110.54.
On Demand – Available Anytime
Click here to register and get access for 90 days.
ICA – The Business Side
Description: This session explains the importance of ICA and describes ARSA’s efforts to strike an appropriate balance between often-competing regulatory and business considerations. It also addresses various design approval holder (DAH) business practices that affect the availability and use of ICA and explains the FAA’s policy prohibiting DAHs from engaging in certain behaviors. It also explores various FAA ICA legal interpretations and some of the issues being examined in an ongoing anti-trust inquiry by the European Commission’s Competition Directorate.
On Demand – Available Anytime
Click here to register and get access for 90 days.
ICA – Case Study: Testing Your Knowledge
Description: This session will test participants’ knowledge of ICA-related provisions in 14 CFR and FAA guidance by presenting several hypothetical case studies. Each one will focus on one or more of the significant ICA regulatory principles.
On Demand – Available Anytime
Click here to register and get access for 90 days.
Click here to purchase all three sessions together and receive a “bundle” discount.
Note: Sessions must be viewed in order. Completion of each pre-requisite – either via live session or on-demand recording – is required for access to subsequent classes.
Security Rule – Unlimited Viewing for 90 Days
By ARSA Training Team
This session covers the requirements set forth in the Transportation Security Administration’s repair station security rule. Learn from Daniel B. Fisher – who serves the maintenance community on TSA’s Aviation Security Advisory Committee – how to stay compliant with mandatory security responsibilities.
TSA’s Repair Station Security Rule – Effectively Complying with the Regulation
On-Demand – Available Anytime
Click here to register and get access for 90 days.
On Demand – Election Law Basics
By ARSA Training Team
Lead by Christian A. Klein, this session provides business leaders with a basic understanding of federal election laws and regulations. Klein reviews permissible sources of campaign funds, contribution limits, company political action committees (PAC) and corporate engagement in political activity.
On Demand – Available Anytime
Click here to register and get access for 90 days.
Regulatory Compliance Training
By ARSA Training and Regulatory Teams
Test your knowledge of 14 CFR § 43.3(g)-(i) – Persons authorized to perform maintenance, preventive maintenance, rebuilding and alterations.
Click here to download the training sheet.
Listening Session – Repair Specifications – July 13
Contract Maintenance – Functions and Vendors – July 20
The Fourth Branch of Government – Administrative Agencies & Their Powers – Aug. 3
Congressional Testimony – The When, Why and How – Aug. 10
Membership
Member Spotlight – Moog
By ARSA Communications Team
Over the past 60 years, Moog has developed a reputation throughout the world as a company whose people and products are at the forefront of the aerospace industry. In 1951, Moog took its first order – for $800 – and has since expanded into markets around the world.
Aircraft Group Markets
- Civil Aircraft
- Military Aircraft
- Navigation Aids
- Commercial Product Support
- Military Product Support
Actuation Technologies
- Integrated Flight Control Systems
- Primary Flight Controls
- Secondary Flight Controls
- High Lift Systems
- Engine Controls
- Active Vibration Controls
- Utility Actuation Systems
- Discrete Actuator and Control Products
- Navigation Aids
Moog has been an ARSA member since 2004 and has provided invaluable insight and support for the industry effort to deal with parts documentation issues in the U.S.-EU MAG.
To learn more, visit www.moog.com.
ARSA Has Seen This Person, Have You? – Patrick Ky, Executive Director, EASA
By ARSA Communications Team
Patrick Ky became Executive Director of the European Aviation Safety Agency (EASA) on Sept. 1, 2013. Building on more than 24 years of aviation experience, Ky works to make the European aviation regulatory system a fully consistent, efficient and reliable framework.
Prior to leading EASA, Ky was in charge of the SESAR program, Europe’s ambitious ATM modernization effort. He also held different managerial positions in the French Civil Aviation Authority, in a consulting company and in Eurocontrol.
In 2013 Ky was the recipient of the The Glen A. Gilbert Memorial Award of the Air Traffic Controllers Association as a recognition of his achievements in the field of aviation and for being an advocate of innovation and change in air traffic control. In 2015, he was designated “Industry Leader of the Year” by the German publication Fliegermagazin for his commitment to develop simpler, better and lighter rules for General Aviation.
Ky is a graduate of Ecole Polytechnique and the Civil Aviation Engineering School in France and also holds degrees in economics from the University of Toulouse and the Massachusetts Institute of Technology.
During the 2016 International Safety Conference, co-hosted by the FAA and EASA and held in Washington, D.C., Ky participated in a panel discussion of bilateralism alongside ARSA’s Managing Director and General Counsel Marshall S. Filler. Outside of the event, Ky and EASA’s Flight Standards Director Ricardo Génova Galván met with senior staff of the association to discuss global maintenance issues and cooperation.
Click here to learn more about Ky and his role in international regulatory compliance.
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/.
Exhibit, Sponsor the 2017 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/.
Q: The United Kingdom just voted to exit the European Union, what happens now?
A: No need to panic. The rules today are the same as they were before the “Brexit” vote, and they are likely to stay that way for at least a couple of years—if not longer. Should the British government trigger Article 50 of the Lisbon Treaty during the European Council Summit in late June, the UK and the remaining EU countries will have two years to negotiate a withdrawal agreement. Alternatively, officials may engage in informal negotiations before triggering the exiting mechanism, meaning that the real Brexit may not occur for a number of years.
In any event, aviation policy is definitely one of the topics that will be addressed during negotiations. Similar to countries like Norway and Iceland, the UK may seek to maintain its status as an EASA Member State without being a member of the EU. If this does not happen, the UK will be forced to negotiate a separate bilateral aviation safety agreement (BASA) with the US because the EU-US BASA only applies to EU member countries. The same would also be true for other EU-US bilateral agreements.
At this time it is just too early to know exactly how the Brexit will unfold. Regardless of what happens there is plenty of time to adjust to any changes.
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
EAA Airventure Oshkosh – Oshkosh, Wisconsin – July 25-31
LABACE – Sao Paolo, Brazil – Aug. 30-Sept. 1
MRO Asia-Pacific – Singapore – Sep. 27-29
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.
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