2016 – Edition 7 – August 5
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 – Welcome to Our World
By Sarah MacLeod, Executive Director
A working paper from the Mercatus Center at George Mason University reveals that “[f]ully 49 percent of prescriptive, economically significant regulations proposed from 2008 through 2013 were required by statute.” This is certainly true in aviation safety regulations—many troublesome rulemaking activities are mandated by the micromanagement of lawmakers.
The executive agencies were meant to be the experts for health and safety requirements; that job has been usurped by Congress. When lawmakers mandate passage of regulations without regard to the Administrative Procedure Act or other laws that control the rulemaking process, the agencies cannot apply cost benefit analysis, study alternative methods of accomplishing an objective or consider the unique impact on small businesses.
The white paper concludes with the obvious: “If Congress insists on writing regulatory mandates into statutes, it should have an organized process for obtaining critical information before decisions are made.” That is unlikely to happen—what can be done must be accomplished by direct involvement from voters and constituents. The deliberative rulemaking process can be frustrating and time consuming, but mandating without regard for health, safety or economic impact must cease.
We all must be proactive in getting the government’s hands off. It starts at the top: learn about how to engage with your lawmakers (Daniel’s continuing series in ARSA on the Hill is a great help). Educate them and show your support for restraint and deliberation.
Get involved, demand better—you deserve better.
Hotline Features
2016 Strategic Leadership Conference – Registration Open
By ARSA Membership Team
Registration is now open for ARSA’s 2016 Strategic Leadership Conference, held Oct. 5-6 and hosted in Montréal at the headquarters of the International Air Transport Association (IATA). For the first time, ARSA has opened the previously invitation-only event to the broader aviation maintenance community. Space is extremely limited to facilitate discussion between attendees; register now to ensure you have a seat at the table.
The SLC provides industry leaders from around the world an informal setting to discuss important issues facing aviation maintenance. Topics on the 2016 agenda include international regulatory cooperation, technical workforce development and global political risk. ARSA’s executive team will be joined by industry members as well as representatives of ICAO, the FAA, EASA and other international aviation bodies. Plan to get in early and meet Michael Lawson, the U.S. ambassador to ICAO, at the opening reception on Wednesday, Oct. 5.
2016 Strategic Leadership Conference
Wednesday, Oct. 5 and Thursday, Oct. 6 (Click here to add the SLC to your Microsoft Outlook Calendar.)
IATA Head Office
800 Place Victoria
Montréal, Quebec, H4Z 1M, Canada
Hotel accommodations have been arranged at the W Montreal, just across Square Victoria from IATA.
W Hotel Montréal
901 Square Victoria
Montréal, Quebec, H2Z 1R1, Canada
Group rate for SLC attendees available until Sept. 5, 2016.
Click here to register, review the agenda, book your hotel and get more information.
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Secretive FAA Extension Becomes Law
By ARSA Legislative Team
On July 15, the president signed a bill reauthorizing the FAA through Sept. 30, 2017, which included policy riders that target the aviation maintenance industry.
For a comparison of how the recently-enacted repair station-specific language alters current law click here.
House Transportation & Infrastructure Committee and Senate Commerce, Science & Transportation Committee leadership elected – through secretive, backroom negotiations – to impose unnecessary, burdensome mandates on the international maintenance community and the FAA.
Of specific concern to maintenance providers and their customers:
(1) Foreign drug and alcohol testing.
The legislation reiterates a provision in the FAA Modernization & Reform Act (P.L. 112-95) requiring the FAA issue a proposed rule mandating all part 145 repair station employees responsible for safety sensitive maintenance functions on part 121 air carrier aircraft be subject to an alcohol and controlled substances testing program consistent with the laws of the country in which the repair station is located. Unfortunately, the new bill includes arbitrary deadlines (requiring a notice of proposed rulemaking within 90 days of enactment and a final rule within a year) that will result in a hurried rulemaking with detrimental effects on the international aviation community, including the U.S. air carriers and the business and general aviation operators that benefit from the safe and efficient worldwide maintenance network.
(2) Mandatory pre-employment background checks.
The legislation mandates the FAA require pre-employment background investigations for all part 145 repair station employees performing safety-sensitive functions on an air carrier aircraft. This would significantly expand current Transportation Security Administration (TSA) requirements, lacks a safety and security justification, and is contrary to accepted risk-based oversight principles.
(3) Risk-Based Inspections.
The bill requires the FAA, in the context of its risk-based oversight of foreign repair stations, to focus on facilities performing scheduled heavy maintenance on part 121 air carrier aircraft and ensure the agency accounts for the frequency and seriousness of any corrective actions that part 121 air carriers must implement to aircraft following such work.
As business leaders and citizens, maintenance providers should be appalled that lawmakers used clandestine discussions to negotiate controversial policy additions to a “must-pass” FAA extension without opportunity for amendment. ARSA urges you to contact your representatives to express your dissatisfaction with the process and that Congress chose to impose new burdens on the aviation maintenance industry without any safety justification.
To find your representative and senators, visit ofmk.freeenterpriseaction.com/9avEPgM. On the upper right-hand side, you can find your legislators by entering your address and zip code. On the results page, you may view background and contact information for each of your elected officials, including websites, Twitter and Facebook pages and Washington, D.C. contact info. Use these means to remind those chosen to represent your interest that they’ve conspicuously forgotten a $100 billion global industry.
For more information check out arsa.org/faa-reauthorization.
Boeing’s Annual Outlook Highlights Expanding Workforce Need
By ARSA Communications Team
Boeing’s 2016 Pilot and Technician Outlook has provided the aviation community with its annual midsummer reminder that the industry’s workforce needs are growing faster than its ability to fill vacancies. The report forecasts the global commercial aviation industry will need more than two million new pilots, technicians and cabin crew members by 2035.
Future demand for maintenance will be affected by improved airplane reliability and a resulting expansion of check intervals, but expanding fleets – driven by economic growth – and market globalization will push the need for more aircraft mechanics. As a result, Boeing indicates the industry will need 679,000 new technicians over the next two decades.
The report’s findings, including both expected demand for new workers and the global dispersion of that demand, are consistent with ARSA’s 2016 Global Fleet and MRO Market Assessment. Such forecasts are common and all point to a basic point: As the global civil aviation market continues to grow, keeping the flying public safely aloft will require the dedicated effort of well-trained men and women supported by a healthy and cooperative international industry.
Get Involved
In the United States – click here to tell American lawmakers to support training programs and regulatory structures that foster technical skills.
Around the world – learn about ICAO’s Next Generation of Aviation Professionals Task Force (ARSA is a member) and the work it performs on behalf of the global industry.
At home – show a friend or colleague You Can’t Fly Without Us – The World of Aviation Maintenance.
ARSA Works
To see all the ways ARSA works as the voice of the aviation maintenance industry, visit the ARSA Works page.
ARSA Works: Housing Requirements
By ARSA Regulatory Team
On July 26, the Federal Register published the FAA’s intent to issue an interim rule to update the “suitable permanent housing” requirements in part 145 for repair stations with airframe ratings. The agency’s action is in response to ARSA’s December 2015 letter requesting clarification of 14 CFR § 145.103‘s applicability.
To review the interim rule as published by the agency, click here or go directly to the Federal Register’s docket page.
To view the changes in a red-lined document format prepared by ARSA’s regulatory team, click here.
To see the association’s efforts to correct an “outrageous” requirement, visit arsa.org/component-housing.
At Asia-Pacific Conference, ARSA’s Filler Highlights Need for Risk-Based Oversight
By ARSA Regulatory Team
On July 19, regulators and industry stakeholders touched down in Washington D.C. for the FAA’s second annual Asia-Pacific Flight Standards Conference. Marshall Filler, ARSA’s Managing Director and General Counsel, joined members of the FAA, other CAAs and their industry counterparts to discuss risk-based oversight of aviation maintenance organizations (AMOs).
Filler highlighted that AMOs accomplish and receive more audits from more parties than any other entity in the aviation industry. Unfortunately, the current system has resulted in more duplication of oversight as more states have exercised their ICAO State of Registry rights and obligations in the last decade.
In order for the risk-based Safety Assurance System (SAS) and Safety Management System (SMS) to realize the potential of minimizing regulatory burdens, Filler noted that the surveillance model for AMOs must fundamentally change. In particular, aviation authorities should start sharing and accepting audit results and should encourage mutual recognition of AMOs through validation. If bilateral agreements truly mean that the signatories recognize and accept the other’s regulatory system as equivalent, the number of special conditions must be minimized. Finally, Filler explained that ICAO must continue its work to develop standards, recommended practices and associated guidance for stand-alone AMOs that encourage their mutual acceptance or at least the reciprocal acceptance of audit data.
ARSA Gets More time for AC 145-9A Comments
By ARSA Regulatory Team
On July 14, ARSA requested additional time to analyze and comment on Draft Advisory Circular 145-9A, “Guide for Developing and Evaluating Repair Station and Quality Control Manuals.” In response, the agency provided the association until October.
The association is deeply concerned that the proposed guidance is not supported by the plain language of the regulation. Furthermore, the apparent aim of the revisions is to force all repair stations to utilize industry “best practices,” which will have a significant impact on small-to-medium sized enterprises with limited resources.
ARSA is currently reviewing the guidance. Repair stations are encouraged to review the draft and submit comments using the Draft Document Comment Grid provided by the agency.
Repair Specifications Listening Session & Draft AC Review
By ARSA Training Team
On July 13, ARSA hosted an online listening session to discuss the repair specifications AC. The recording of that session is available to all registrants. For those who could not attend the live session but would like access to the recording, please click here.
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.
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.
A Government for the People? The Rules for Making Government Work for You
By Christian A. Klein, Executive Vice President and Ryan M. Poteet, Regulatory Affairs Manager
A common refrain is that the federal government is crushing a business’s ability to earn an honest living. In particular, that federal agencies issue endless regulations that impose countless burdens on employers. To add insult to injury, many regulations—if not most—fail to achieve any policy objective.
The aviation community flocks to the Washington hoping to enlist the help of elected officials. Stories of how the American dream is rapidly vanishing are recounted in one congressional office after another. Staffers and members alike shake their heads in disbelief and remark that federal agencies are not supposed to be an impediment to running a business. Incredulity is commonly followed by exasperation and lip service that the overreaching by regulatory agencies must be stopped. Unfortunately, this is typical Washington hypocrisy at its best because, as one working paper indicates (see this month’s Sarah Says), half of all economically significant regulations are mandated by those same lawmakers.
Making government work means ensuring your voice is heard. As the presidential election rapidly approaches and primary season is still in full swing, it’s a good bet that you are receiving multitudes of fundraising requests from candidates for office. Contributing to those who share your values is an important way to engage politically and political fundraising events are great places to build relationships and educate potential lawmakers about issues.
When participating in the electoral process, it’s important to keep some of the most important federal campaign finance laws in mind.
No corporate contributions. Generally, all direct contributions to federal candidates must be from personal funds.
Corporations, banks, and unions are prohibited from using general treasury funds to make contributions.
However, partnerships and LLCs can contribute to candidates as long as the donation is attributed to a specific company owner both for purposes of contribution limits (see below) and income tax reporting.
Contributions are limited. Federal law establishes limits for how much an individual can contribute. The limits are indexed for inflation and change every two-year election cycle.
For 2015-2016 an individual can contribute:
- $2,700 per candidate per election. Primary and general elections count as two separate elections. Assuming a candidate wins the primary, you can effectively contribute $5,400 for the cycle (known in political circles as “maxing out”). The same limit applies to presidential and congressional candidates except that federally-funded presidential candidates can’t accept contributions for the general election campaign.
- $5,000 per calendar year to political action committees (PACs) that contribute directly to federal candidates. There are no limits on contributions to “super PACs,” which engage only in independent expenditures. Super PACs can also accept corporate and union support.
- $33,400 per year to a national party committee.
- $10,000 per year to a state, district, or local political party committee.
- $100,200 per year to national party accounts.
Same limits apply to non-working spouses. Those contribution limits apply on an individual basis to each spouse, even if one doesn’t have income. That means a married couple can contribute double the amounts indicated above.
Special rules for federal government contractors. Campaigns can’t accept contributions from LLCs or partnerships with federal contracts. Federal law also prohibits individuals and sole proprietors with federal contracts from making federal contributions.
No contributions from foreign nationals. Foreign citizens can’t make contributions to federal candidates; however, lawful permanent residents (green card holders) and dual U.S. citizens are permitted to do so.
No more aggregate limits. In 2014, the Supreme Court struck down limits on aggregate contributions (i.e., the total amount an individual could contribute to all candidates and causes during an election cycle or calendar year). In other words, you’re now free to support as many candidates, PACs and party committees as you want (subject to the contribution limits above).
No reimbursements for contributions. One of the overarching goals of the federal election laws is transparency (the idea that voters should know exactly where candidates get financial support). Contributions in the name of another are prohibited. Among other things, that means federal law prohibits companies from reimbursing owners and employees (e.g., through expense reports, bonuses, etc.) for individual political contributions.
Volunteer time isn’t a contribution. Generally, time spent volunteering for a campaign isn’t a contribution as long as you’re not being paid for that time. Also, company owners and employees can spend a de minis amount of time at work (an hour a week or four hours a month) doing volunteer campaign work without the work being counted as an illegal contribution by the company.
These are just some of the many federal election rules. For more information, please visit the Federal Election Commission website (http://www.fec.gov).
ARSA on the Hill
How to Be an Involved Constituent: Town Hall Meetings
By Daniel B. Fisher, Vice President of Legislative Affairs
In last month’s hotline, we looked at the role of the district office in communications with your congressional representative. This month, we look at another opportunity to get involved on the local level: town hall meetings.
Many representatives or their supporters host town hall or other community meetings. These forums provide an opportunity to gain insight into your representative’s priorities as well as his or her position on national, international and community issues and. Most importantly, these events are a chance to initiate meaningful dialogue.
To get information on events scheduled or occurring in your area, contact the staff at the district office. You may also learn of an event through your local paper, newscast or congressional office’s newsletter or website.
When attending a town hall meeting, be prepared to make the most of the event. Here are a few suggestions:
- Speak Up and Be Prepared. Be ready to ask thoughtful, concise questions. Have data to support your concerns and positions. This will ensure you are remembered by the representative and staff.
- Make it Personal. It is important to establish yourself not just as a constituent but as a representative of other voters. Tell your representative about your company – the type of work it does and number employees. Know how a policy will affect you or your family, business or community and provide firsthand accounts of that impact.
- Talk to Staff. Members usually bring several members of their staff to meetings. Be sure to interact with them, particularly if you are unable to interact with the representative. In all cases, obtain their business cards or at write down names, titles and contact information.
- Leave Paper. Create a company profile from ARSA’s Legislative Page (download the template: http://arsa.org/wp-content/uploads/2013/07/ARSA-CompanyProfile-20130722.docx). Provide it along with any documents that support your position or concerns, including ARSA’s legislative priorities brochure, to the representative or staff member.
- Follow Up. Be persistent (but also polite) in following up with your representative after an in-person event. Remember that creating a dialogue is only the first step, maintaining that dialogue is key.
- Attend Multiple Events. Also have other people from your company attend meetings, so that the representative can hear about the issue from multiple voices with the same concerns.
Use in-person events to form a relationship with your representative and staff. The more often you are seen and heard, the more likely the member will heed your concerns. Town hall meetings are a good way to stay in touch with your elected officials and keep yourself updated on what action being taken by your government, be it local, state or federal.
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.
Regulatory Outlook
GAO Again Misunderstands Foreign Repair Station Oversight
By ARSA Regulatory Team
On July 28, the Government Accountability Office (GAO) released a report reviewing the FAA’s oversight of foreign repair stations at the request of House Transportation & Infrastructure Committee Ranking Member Peter DeFazio (D-Ore.) and House Aviation Subcommittee Ranking Member Rick Larsen (D-Wash.).
Unfortunately, Aviation Safety: FAA’s Risk-Based Oversight for Repair Stations Could Benefit from Additional Airline Data and Performance Metrics (GAO-16-679), is yet another attempt to scrutinize part 145 certificate holders located outside the United States to support false safety arguments (often leading to hostile legislation and ultimately unnecessary regulations). Similar to past reports, the GAO once again alleged deficiencies in the FAA’s foreign repair station oversight, but didn’t find any specific violations or safety issues with contract maintenance providers.
Specifically, the GAO found that FAA inspectors were often unable to conduct unannounced inspections at foreign repair stations. ARSA has continually reminded lawmakers that international sovereignty prevents U.S. government officials from conducting “surprise” inspections (similar to “foreign” officials entering the United States without notice to the government). Furthermore, repair stations worldwide are safe and effective because good safety is good business, and no amount of “notice” will allow a maintenance provider to suddenly become compliant to satisfy an inspector. Non-compliance with safety regulations will be evident regardless of advance notice of a government inspection.
The GAO also specified that more data collection is required on the volume of work being done at these facilities in order to determine risk. It failed to connect the dots between global aviation safety, aircraft maintenance and the effort to build a truly “risk based” system. For contract maintenance providers and their customers, the reality is simple: Risk is not about volume of work, it’s about the type of work. Collecting more data may be useful, but only if the system is comprehensive enough to focus on the actual maintenance performed.
The report demonstrates that government auditors still fail to grasp the realities of the global aviation maintenance industry. While that is frustrating for business, to ARSA it is another opportunity to illustrate for the GAO, the Department of Transportation, the White House and even some stubborn members of Congress that they cannot fly safely without us.
For a GAO provided “highlight” document visit: www.gao.gov/assets/680/678736.pdf
Update: The U.S.-EU MAG and Parts Documentation
By ARSA Regulatory Team
This special edition of “a member asked” – a popular component of each hotline – was provided mid-month as a service to ARSA members eagerly awaiting word from the FAA and EASA on documentation requirements for new parts already in inventory ahead of the effective date of the “new” 8130-3 requirement. In addition to reading this exchange, be sure to check out the member question and response in the Membership section of this edition.
Q: What is the status of efforts to have the FAA and EASA change the statement below, which the agencies first sent to ARSA in an April 14 letter and then reiterated both in Notice 8900.360 and the newly-released MAG Change 6. This will affect the whole industry in a huge way if they leave it status quo.
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)
A: On June 17, ARSA joined representatives from the aviation maintenance community at a meeting with the FAA, EASA and ANAC. (Transport Canada Civil Aviation was invited but did not attend.) This was the first annual Maintenance Management Team (MMT) meeting modeled after the Certification Management Team (CMT) formed several years ago to address international certification issues.
During the discussion, industry coalition members requested the FAA and EASA remove the “NOTE” from their April 14th letter to ARSA (and later included in Notice 8900.360 and MAG Change 6) requiring that parts in inventory prior to Oct. 1 be accompanied by a document containing the same technical information as FAA Form 8130-3. Unfortunately, agency representatives indicated this requirement will not change.
For new parts in inventory prior to Oct. 1, a dated certificate of conformance or similar document from the production approval holder (or its supplier with direct ship authority) should be sufficient to comply with this requirement. As for the meaning of the phrase “same technical information as on Form 8130-3,” FAA and EASA representatives advised that they are looking for the part name, serial number (if applicable) and nomenclature.
With regard to new parts for which you don’t have the required documentation (either the grandfathered parts per the above Note or those released by the PAH on and after Oct. 1), the agencies agreed during the June 17th meeting to allow a repair station to perform an inspection in accordance with criteria that it develops and approve the article for return to service with a right side signature on the 8130-3. This is an administrative burden but it provides a safety valve for qualifying a part for use in a repair subject to the MAG. (On a related matter and in accordance with the FAA’s letter to ARSA dated August 25, 2015, repair stations that hold an appropriate rating for the top assembly being maintained are also rated to perform maintenance on sub-articles [i.e., piece parts] associated with that top assembly.)
These agreements will be formalized by their inclusion in the June 17 joint agency-industry meeting minutes. Industry representatives have prepared draft minutes which have been sent to agency representatives for comment and eventual adoption.
Listening Session & Update: U.S.-EU MAG Parts Documentation Requirements
By ARSA Regulatory Team
Join ARSA’s regulatory team and industry members for a compliance update and discussion of the parts documentation requirements created by changes 5 and 6 to the U.S.-EU Maintenance Annex Guidance (MAG).
Date & Time: August 17 at 11:00 a.m. EDT
Session Lead: Marshall S. Filler
Special Price: $25 for members ($50 for non members)
Registration for the session includes:
- Access to the live session on the scheduled date
- Access to the on-demand, recorded version to be made available after the live session is complete.
- A copy of the presentation and all reference material with links to relevant resources and citations.
The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit PotomacLaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.
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.
Quality Time
2016 MRO Survey Performed by Oliver Wyman
By Christopher Doan, Vice President, CAVOK – A Division of Oliver Wyman
The latest aircraft designs now entering fleets are equipped with technologies that can deliver unprecedented collection and transmission of data at the system and part level. We estimate that the global fleet could generate 98 million terabytes of data by 2026. This surge of data, in the hands of a new breed of data scientists and innovative management teams, could lead to major changes in how modern aircraft are cared for and perform.
In this year’s MRO Survey, Oliver Wyman examines a variety of technology and innovation themes, including how operators, repair stations and manufacturers are adopting, utilizing and investing in big data capabilities – particularly relating to aircraft health monitoring and predictive maintenance systems.
In addition, our 2016-2026 Fleet and MRO Market Forecast anticipates a 3.4% growth in the in-service fleet, to bring the global fleet to 34,437 aircraft. However, it also outlines possible alternative scenarios given volatility in fuel prices, world GDP projections, passenger traffic growth expectations, and interest rates. So, in addition to the survey findings, we’ve also integrated an extract of our forecast into presentation materials to highlight how the growth trends for the industry marry up with these new technologies and innovation trends.
I hope you find this interesting and useful as you plan for your business over the next months and years. If you have any questions regarding these materials, contact the MRO research team.
Click here to access the full report.
Click here to access a video presentation of the report’s results or here to go directly to the presentation slides.
Oliver Wyman is a global consultation and analysis firm, performing a wide range of services across 13 different industries. In partnership with ARSA, the firm’s aviation experts perform an annual analysis of the international market for civil aviation maintenance. To learn more, visit: www.oliverwyman.com or arsa.org/market-assessment.
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 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).
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.
Listening Session & Regulatory Update – The U.S.-EU MAG’s Parts Documentation Requirements
Description: Join ARSA’s regulatory team and other members for a compliance update and discussion of the parts documentation requirements created by changes 5 and 6 to the U.S.-EU Maintenance Annex Guidance (MAG).
Date & Time: August 17 at 11:00 a.m. EDT
Session Lead: Marshall S. Filler
Special Price: $25 for members ($50 for non members)
Click here to register.
The Fourth Branch of Government – Administrative Agencies: The FAA & NTSB
Description: This course will review the creation and powers of the two agencies most prominent in civil aviation – the Federal Aviation Administration (FAA) and the National Transportation Safety Board (NTSB).
Date & Time: August 24 at 11:00 a.m. EDT
Instructor: Sarah MacLeod
Click here to register.
Going Global – Bilateral Agreements
Description: International markets mean expanded business opportunities that require an understanding of international regulatory requirements. This session focuses on bilateral airworthiness agreements (BAA) and bilateral aviation safety agreements (BASA). Topics include the purpose and scope of these agreements, the process required to obtain a BASA and how BASAs are structured. The presentation explains specific activities covered in a typical BASA including design approvals and post-design approvals, production and surveillance, export airworthiness approvals, technical assistance between authorities and special arrangements.
Date & Time: August 31 at 11:00 a.m. EDT
Instructor: Marshall S. Filler
Click here to register.
Contract Maintenance – Functions and Vendors
By ARSA Training Team
This session provides information on obtaining approval of maintenance functions and selecting and categorizing maintenance function vendors properly under 14 CFR part 145.
Instructor: Sarah MacLeod
On Demand – Available Anytime
Click here to register and get access for 90 days.
Administrative Agencies and Their Powers
By ARSA Training Team
Maintenance providers invest valuable resources dealing with the FAA, an administrative agency of the U.S. government. In order to make the most of these interactions and ensure a balance between regulatory requirements and business needs, all ARSA members should understand the basic structure and functions of “the fourth branch of government.”
This session reviews why federal administrative agencies are created and how they use their powers to regulate activities within their jurisdiction. The course will also cover the basic procedures agencies must follow to create or revise regulations.
Instructor: Sarah MacLeod
On Demand – Available Anytime
Click here to register and get access for 90 days.
Click here to register for the follow-up session on the FAA and NTSB.
By The FAA, AIR-130
Aug. 24-25, 2016, Silver Spring, MarylandThis workshop will improve aviation safety oversight, facilitate the creation of guidance documentation, better enable implementation of that guidance, and enhance the performance of both ACO and headquarters personnel.
Standardized communication and training via a workshop is one of the most effective tools to ensure policy dissemination and consistent interpretation. This workshop increases interaction between ACO and headquarters personnel and reduces communication barriers from purpose and intent, which can exist between publishing policy and implementing policy.
The workshop will address current issues with industry groups pertaining to Advisory Circular and Technical Standard Order terminology being interpreted as rulemaking by guidance. The scope of the workshop will cover topics including, but not limited to TSOs, TSO installation, and associated policy/guidance in the Aircraft Cabin Interior, Electrical/Mechanical, additive manufacturing and composites and other related topics.
For registration and more information, click here. For more information, contact Michelle Swearingen.
Regulatory Compliance Training
By ARSA Training and Regulatory Teams
Test your knowledge of 14 CFR § 43.3(j)-(k) – Persons authorized to perform maintenance, preventive maintenance, rebuilding and alterations.
Click here to download the training sheet.
Congressional Testimony – The When, Why and How – Aug. 10
Listening Session & Regulatory Update – The U.S.-EU MAG’s Parts Documentation Requirements – Aug. 17
The Fourth Branch of Government – Administrative Agencies: The FAA & NTSB – Aug. 24
Going Global – Bilateral Agreements – Aug. 31
Membership
Member Spotlight – CAVOK, A Division of Oliver Wyman
By ARSA Communications Team
CAVOK, a division of Oliver Wyman, is an aviation services and consulting firm that supports certification and maintenance programs for clients worldwide. Its deep expertise and proprietary tools help customers incorporate the latest safety standards, improve process efficiency, and streamline maintenance processes, to reap significant economic benefit.
CAVOK subject matter experts have more than 1,300 years of combined airline operations expertise, culled from more than 30 different airlines globally, including military and government agencies. More than 70 percent of employees hold FAA certification and licenses.
Founded in 1996, CAVOK was acquired by Oliver Wyman in 2007 and draws on the consulting firm’s strategic and operational expertise in aviation. By combining CAVOK’s operational expertise with Oliver Wyman’s management consulting experience in the aviation industry, clients gain access to unique depth and breadth of experience, tools, and acumen.
CAVOK’s core capabilities are split across six primary areas:
- Certification
- Program Development and Redesign
- Compliance, Quality, and Safety
- Technical Data Auditing and Validation
- Maintenance Programs and Reliability
- Technical Publications Management
ARSA’s exchange relationship with CAVOK provides both sides with unparalleled access to industry insight and expertise. Analysts from CAVOK annually perform the association’s Global Fleet and MRO Market Assessment, which has become a central tool in illustrating the worldwide economic impact of the aviation maintenance industry.
To learn more, visit www.oliverwyman.com or check out this month’s Quality Time to see some of CAVOK’s work.
ARSA Has Seen This Person, Have You? – Gerald L. Dillingham, Ph.D.
By ARSA Communications Team
Dr. Gerald Dillingham is currently the director of civil aviation issues at the U.S. Government Accountability Office (GAO) in Washington, D.C. The GAO is the investigative arm of the U.S. Congress, the agency tasked with analyzing the effectiveness of government programs.
In his role, Dr. Dillingham oversees all program evaluation and policy analysis related commercial and general aviation safety, airport and airline finance, the environment, air traffic control, airport development, and international aviation issues. He led the research team that prepared the recently-released report on foreign repair station oversight.
Dr. Dillingham has long experience with aviation issues, program evaluation and policy analysis. He has appeared as an expert witness before numerous committees of the U.S. Congress. He also served on the National Commission on Terrorist Attacks Upon the United States (The 9/11 Commission). While the GAO’s reports on aviation maintenance have not fully expressed the realities of the commercial aviation market, Dr. Dillingham’s openness to input from the repair station community as well as his long relationship with ARSA make him a great potential ally in educating the world this community.
Dr. Dillingham holds a Ph.D. and master’s degree from the University of Chicago in Sociology, and a postdoctoral certificate in Evaluation Research from the University of California-Los Angeles.
To learn more about the GAO’s report on foreign repair station oversight, click here or check out this month’s hotline features section.
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: Last month the FAA issued guidance (AC 120-78A for the public, and Order 8900.1, Vol 3, Ch. 18, Sec. 3 and Order 8900.1 Vol. 3, Ch 31, Sec. 2 for FAA employees) updating information on use of electronic signatures, recordkeeping, and manual systems. The FAA also revised A025 OpsSpec templates.
My aviation safety inspector just told me that I needed to review my repair station’s Operations Specifications (OpsSpec) paragraph A025 and let him/her know if any changes needed to be made. Do I have to do this?
A: As usual, the agency has placed the certificate holder in a “catch-22” situation. Although it admits a part 145’s use of electronic manuals need only be “accepted,” the agency’s method of issuing its acceptance is by OpsSpecs paragraph. Since the OpsSpecs are part of the repair station’s certificate, it must ensure compliance with that document (see § 145.5(a)).
The revised guidance (announced to agency personnel in personnel in Notice 8900.368 (June, 22, 2016)) revised the template for most, but not all, OpsSpecs paragraph A025. Fortunately, the template for part 145 repair stations did not change; unfortunately, the guidance did.
Notice 8900.368 gives aviation safety inspectors six months (November 22, 2016) to review a repair station’s A025 OpsSpec and determine whether it conforms to the new standards. If the repair station’s existing electronic/digital process or system does not meet the new standards for signatures, recordkeeping or manuals, the CHDO must inform the repair station and provide a written explanation that includes a list of deficiencies or required corrections. Notice 8900.368, Para 7(b).
Unless your facility changed its processes/procedures with respect to electronic or digital process controlled by that paragraph, no change should be required. Best practice would be to review the new guidance carefully to ensure your OpsSpecs paragraph A025 is accurate. If it is, notify the agency and if it is not, make appropriate adjustments to your procedures and/or ask for adjustments to the OpsSpecs paragraph.
AVMRO News Portal
ARSA strives to provide resources to educate the general public about the work of the association’s member organizations; should you need to provide a quick reference or introductory overview to the global MRO industry, please utilize AVMRO.ARSA.org.
AVMRO Industry Roundup
ARSA monitors media coverage on aviation maintenance to spread the word about the valuable role repair stations play globally by providing jobs and economic opportunities and in civic engagement. These are some of this month’s top stories highlighting the industry’s contributions.
You can explore these stories through ARSA’s Dispatch news portal.
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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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