2020 – Edition 9 – October 2

Table of Contents

Note: The order of material varies in hotline emails, but is always presented the same on this landing page. Readers scrolling through content on or printing this page will find it organized consistent with the table of contents.

Taking Lead
Anti-Viral Measures
ARSA Works
Legal Brief
ARSA on the Hill
Training
Membership
Resources
Industry Calendar

Taking Lead

Still Working Together for the Workforce

By Christian A. Klein, Executive Vice President

There’s an old adage that legislation is like sausage: You don’t want to see either being made. From the time a bill is introduced it goes through a “meat grinder” that involves multiple phases of review, debate and amendment and emerges at the other end of the process different but (at least in theory) better.

That was the case with the legislation ARSA proposed in 2017 creating a new federal grant program to recruit and train aviation technicians. From the time we started sharing our idea with allies on the Hill and other industry groups to when bills were introduced in the House and Senate, to inclusion in the 2018 FAA reauthorization bill, the language changed. However, the core concept – giving grants to aviation companies or unions that partner with schools and government to pursue creative solutions to the skills gap – didn’t.

The requirement that grant applications be submitted jointly by a combination of entities is what made the proposal standout. ARSA based its bill on initiatives that leading members companie like HAECO Americas and AAR had already undertaken on their own at the local level. We hoped the grant program would incentivize even more collaboration and serve as an incubator for creative workforce development programs.

Of course, a lot has happened since the FAA bill was enacted into law. The industry has lost tens of thousands of workers as a result the pandemic economic disruptions and there’s very little light at the end of the tunnel. But while ARSA is staying focused on relief and recovery (see this month’s “ARSA on the Hill” section), we’re are also thinking about the future of the aviation workforce. When things do turnaround and business activity returns to pre-COVID levels, we’re almost certain to be facing an even more dire technician shortage. That’s why getting the grant program up and running and providing resources to encourage forward thinking is so important.

The good news is that FAA is finally moving forward, at least according to the Federal Register notice about the program published on Sept. 8. We’re pleased the agency is finally acting (albeit almost two years after the program was authorized and almost a year after Congress appropriated the first tranche of funding); however, by stating in the notice grant applications could be submitted by schools, governmental entities, unions or companies, it appears the FAA has missed the point.

In listing the types of eligible entities (schools, state and local government and businesses with FAA certificates, and unions representing mechanics), the FAA replaced “and” with “or” and stated that, “[i]ndividual entities, teams, and new providers are eligible to apply for a grant”. While the notice says that the agency “encourages applicants to partner” it’s apparently not a requirement.

ARSA’s comments, submitted jointly with eight other association’s on Sept. 23, explained why the association regards joint applications as so important. “One of the causes of the skills gap has been a misalignment between local industry needs and what students learn in school,” the comments said. “The program was designed to encourage industry and schools to work to together to identify necessary skills and design curricula to teach them, with government providing oversight to ensure the initiative properly served local needs. Because proposed initiatives must have buy-in from more than just the applicant, mandating collaboration will also act as a check to ensure government resources are spent effectively and that applications reflect a true consensus about local industry and community needs.”

The Federal Register notice expressed FAA’s intention to publish a Notice of Funding Opportunity (NOFO) in November with more details about the program and instructions about how to apply. Whether the FAA will take our recommendations about the joint application to heart remains to be seen. However, even if not, we continue to believe that the most successful initiatives will be those that involve joint action and that when it comes to workforce development, collaboration continues to be the key.

For a complete review of the program notice and industry comments, review this month’s “ARSA Works” section or arsa.org/grant-program.

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Anti-Viral Measures

MacLeod talks ‘Regulatory Ramifications’

To keep tabs on all of ARSA’s work related to the current pandemic, visit arsa.org/anti-viral-measures.

On Sept. 24 , ARSA Executive Director Sarah MacLeod presented for MRO Asia-Pacific Virtual. MacLeod dipped into her decades of global aviation experience to explore “Regulatory Ramifications” of current events and future development in the industry.

To review MacLeod’s presentation slides, click here. For information about event resources or recordings, visit mroasia.aviationweek.com/en/home or refer to the event app.

Any questions regarding content of the presentation should be directed to the association via arsa.org/contact.

FAA Issues Air Carrier Health and Safety Guidance SFAR-118 Update

To keep tabs on all of ARSA’s work related to the current pandemic, visit arsa.org/anti-viral-measures.

Note: ARSA has been posting guidance, exemptions and other resources to arsa.org/faa-strategy as they become available. Review below to see new content.

In late September, the FAA issued two key updates related to aviation operations during the pandemic:

Added Sept. 30: SAFO 20009 – Updated Interim Occupational Health and Safety Guidance for Air Carriers and Crews

Added Sept. 30: SFAR 118-2 – Second Limited Extension of Relief for Certain Persons and Operations during the Coronavirus Disease 2019 (COVID-19) Public Health Emergency

For regular updates from the agency on pandemic-related matters, visit www.faa.gov/coronavirus.

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ARSA Works

Seeking FAA, EASA Alignment on Minor Alterations and Single Releases

On Sept. 24, ARSA and an industry coalition of 14 other aviation trade associations delivered a letter to the FAA and EASA requesting action related to both the Technical Implementation Procedures (TIP) and Maintenance Annex Guidance (MAG) between the two agencies.

The letter, which was sent to the Flight Standards and Aircraft Certification directors at each agency, addressed two issues:

(1) Amending TIP paragraph 3.3.6 regarding minor alterations to non-critical components.
(2) Clarifying MAG language regarding the use of FAA Form 8130-3 and EASA Form 1 for single-agency releases.

The letter explained its requests were made “in the spirit of the [U.S.-EU Bilateral Aviation Safety] Agreement’s vision for easier flow of maintenance services between Europe and the United States…In [the signatory associations’] view, the requested changes will maintain the high level of safety achieved by our aviation safety regulatory systems while reducing wasteful and costly inefficiencies.”

The submission was part of ongoing work between ARSA, its association allies and the agencies. FAA and EASA personnel have been discussing the minor alteration and single release issues with industry through both the Certification and Maintenance Management Teams, which provide avenues for multilateral coordination on international aviation regulatory oversight.

To read the complete letter, click here.

In addition to ARSA, the letter was signed by representatives from the following organizations:

Aerospace Industries Association
Aircraft Electronics Association
Aircraft Owners and Pilots Association
Airlines for America
Aviation Suppliers Association
Aviation Technician Education Council
Cargo Airline Association
General Aviation Manufacturers Association
Helicopter Association International
Modification and Replacement Parts Association
National Air Carrier Association
National Air Transportation Association
National Business Aviation Association
Regional Airline Association

For more on ARSA’s work to improve collaboration between the United States and European Union aviation systems, visit arsa.org/mag.

Industry Comments on FAA Grant Program Implementation

ARSA and seven allied organizations filed comments Sept. 23 in response to the recent Federal Register notice regarding the FAA’s implementation of the new aviation workforce development grant program.

The program was created by section 625 of the 2018 FAA law, which authorized $5 million annually for grants of up to $500,000 for schools, governmental entities, aviation businesses and labor organizations that collaborate on projects to attract new technical talent to the aviation maintenance industry and train technicians. The same section of the FAA bill created a similar $5 million program to support pilot education.

On Sept. 8, the FAA published a Federal Register notice describing its plans to implement the maintenance grant program and inviting comment. The agency indicated at the time that it plans to publish a Notice of Funding Opportunity (NOFO) in November, after which time interested parties will be able to apply for grants.

ARSA led the coalition to create the maintenance grant program and is pleased the FAA is moving forward with implementation. However, the comments that ARSA submitted along with several other organizations expressed concerns about three issues in the FAA’s notice.

First, the FAA missed one of the key goals of the grant program, which is facilitate collaboration between schools, government, aviation companies and/or labor organizations. The law requires that grant applications be submitted jointly to encourage a collective approach to closing the skills gap. However, this fact is not clearly articulated in the FAA notice.

“One of the causes of the skills gap has been a misalignment between local industry needs and what students learn in school,” the comments said. “The program was designed to encourage industry and schools to work to together to identify necessary skills and design curricula to teach them, with government providing oversight to ensure the initiative properly served local needs. Because proposed initiatives must have buy-in from more than just the applicant, mandating collaboration will also act as a check to ensure government resources are spent effectively and that applications reflect a true consensus about local industry and community needs.”

Additionally, the law directs the FAA to engage with stakeholders in the program’s implementation. The notice, however, states that it and the related comment period satisfy the engagement requirement. ARSA and its allies called for more expansive involvement by industry and academia through the creation of formal stakeholder body to help guide FAA’s activities in this area.

Finally, the industry comments urged the FAA to raise the amount of the grant allowable for administrative expenses from five to 10 percent. This is in line with the standard amount allowable for these expenses in other grant programs.

ARSA was joined in its comments by the Aircraft Mechanics Fraternal Association, the Aircraft Owners and Pilots Association, the Aviation Technician Education Council, the Cargo Airline Association, the General Aviation Manufacturers Association, the Experimental Aircraft Association, Helicopter Association International and the International Council of Air Shows. To read the complete submission, click here.

As the agency considers comments, aviation businesses should use the Sept. 8 notice to begin preparing to respond to the NOFO in November. Though changes can still be made, the agency has provided its road map for successful grant applications. Utilizing the request for comment, entities planning to apply for grants can first in the door when applications are officially open.

To review the notice, click here. The FAA has created a public webpage covering its new grant programs for both technician and pilot career development (the request for comments on the pilot grant program was also posted in the Federal Register), which can be found at www.faa.gov/about/office_org/headquarters_offices/ang/grants/awd.

FAA Running Scared from Repairman Case Intervention

On Sept. 11, the FAA delivered to the NTSB the aviation agency’s “response in opposition” to ARSA’s effort – through pro bono assistance of the law firm of Obadal, Filler, MacLeod & Klein, P.L.C. – to intervene in two cases concerning repairman certificate denials.

In legal proceedings there are motions, oppositions to motions, cross-motions and appeals; the repairmen appeal matters ARSA entered are no different. On Aug. 27, the association filed a motion for leave to intervene, which means ARSA asked to become a party in the appeal of two repairmen whose certificates were denied by the FAA. Since repair stations are directly impacted by the refusal of the agency to issue the airmen certificates, and the individuals were (at that time) not being represented by counsel, the association felt the request was reasonable.

The FAA refused to do the right thing in the first place: follow the regulations that allow repair stations to support repairmen applications for supervisors and positions that will be authorized to approve work for return to service. Therefore, it is no surprise that the agency’s motion in opposition basically accuses ARSA of wishing to grandstand (and slow the proceedings by filing unnecessary motions). The agency’s document also highhandedly states the pro se litigants could “always” hire their own counsel.

The FAA’s motion graciously stated that in lieu of making the association a party, ARSA could be allowed to submit an amicus curiae (friend of the court) brief. Thank you very much, but under the Board’s Rules of Practice, those briefs are allowed only after the NTSB administrative law judge’s (ALJ’s) initial decision (or appealable order) and require either the consent of all parties or leave from the NTSB General Counsel.

The association can understand the agency would not want to face experienced counsel in these cases. It is much easier to handle pro se litigants with a desire to have their day in court but with neither knowledge in legal proceedings nor the money or desire to hire their own counsel. In these cases, the FAA certainly does not want counsel that will provide a solid legal case based on the plain language of the regulations and relevant evidence, not outdated and contradictory guidance material. The agency’s lawyers would much rather keep their righteous head-in-the-air attitude than be faced with evidence that FAA has correctly issued repairmen certificates without any ratings since the “job” is dictated by the employer’s needs and the individual’s qualifications. (You know, evidence that the agency has issued the kind of certificate requested contrary to its answer, which claimed issuance would be contrary to the regulation and guidance.)

The agency may end up getting its way in these matters; friend of the court briefs, if allowed, are poor substitutes for becoming a party. If that happens and the individual repairmen do not obtain their own counsel, NTSB ALJ may determine that the agency is correct. It might happen merely because the individuals do not understand the timing and requirements of the legal proceedings. That could result in the agency winning by default or on a technicality without ever having to defend its misaligned guidance against the facts and the plain language of applicable regulations.

In the end, the denial of the airmen certificates to qualified individuals presented another avenue to pursue in ARSA’s quest to have guidance associated with repairmen reflect the regulation and reality. Like the last stanza of Roy Orbison’s haunting ballad, the agency is standing there, so sure of itself, its head in the air; while the airmen’s hearts may be broken by an ALJ’s choice—before it is over, justice will turn around and walk away with the industry, because ARSA does not quit when the law is on its side.

To read the complete motion to intervene, click here.

To read the FAA’s complete response, click here.

For more information on ARSA’s work related to repairman certificates, visit arsa.org/repairmen.

Final Documents/Your Two Cents

This list includes Federal Register publications, such as final rules, Advisory Circulars and policy statements, as well as proposed rules and policies of interest to ARSA members.

To view the list, click here.

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Legal Brief

Editor’s note: This material is provided as a service to association members for educational and informational purposes only. It does not constitute legal or professional advice and is not privileged or confidential.

Lawyers Ruin Everything

By Sarah MacLeod, Executive Director

My first hero was Perry Mason; not only was the character a strong advocate, but he ensured justice always prevailed. Even the prosecutors supported the defense’s requests to bring the guilty party forward. The belief that the legal system brought justice drove me to volunteer at a public defender’s office. There I learned very valuable lessons about lawyers and the “practice” of law.

First, not all clients are innocent. There are some really bad folks out there and a defense attorney must put aside any thoughts of justice – the legal system is about the law and the accused party has a right to be represented no matter how reprehensible.

Second, everyone involved in the legal system are human beings that will make horrible mistakes, will stand by those errors and will not serve justice when silence is available. The saga of Richard Jewel illustrates that point.

Those lessons drove me to law school, where I learned even more about my chosen profession.

First, most individuals in law school are there not because they believe in the law or in justice, but because it seems like a good idea. I was fortunate to go to night school where the average age was above forty, the day students were “kids” with very little depth or breadth and zero experience.

Second, law school does not teach the practice of or how to practice law; it teaches how to research the law.

Combining those legal system lessons drove me to create the association while supporting the efforts of the law firm. Through the trade association, prophylactic lawyering is accomplished. That entity ensures its positions are supported by both law and fact, so its members have the right tools to make the best decisions.

When those measures fail or are taking an extraordinary length of time, and an opportunity to use the legal system in another way presents itself, ARSA will attempt to ensure justice has a chance of success. Unfortunately, the legal system does not give justice much of a chance.

ARSA’s efforts to intervene in two cases concerning repairman certificate denials provide a perfect example. Through the pro bono efforts of its management firm, Obadal, Filler, MacLeod & Klein, P.L.C., the association filed a “motion for leave to intervene” seeking to be allowed to become a party in the appeals before the NTSB. Among other lawyerly things, that action required ARSA to show a direct interest in the case.

Rather than acknowledge that repair stations will be directly impacted, the FAA “responded in opposition” to the motion. The agency accused the association of wishing to grandstand and slow the proceedings but graciously noted that an amicus curia (friend of the court brief) would be a better avenue for the association’s involvement. You can read the particulars of the FAA’s response as well as ARSA’s unvarnished analysis of the situation in the “ARSA Works” section.

Unfortunately, it is a perfect example of why lawyers ruin everything: If the agency lawyers were interested in justice, they would have taken steps to stop the quasi-judicial actions. They would have looked at the regulations (not the guidance) and asked the policy division if the guidance was accurate. The agency has the power to withdraw its appeal, issue the certificates and get the guidance straightened out at any time. Unfortunately, the most disheartening lesson from the public defender’s office continues to hold true: Humans make mistakes and will stand by those errors.

In the meanwhile, the value of “prophylactic lawyering” will continue because ARSA’s executive director has learned the most valuable lesson from the businessman’s point of view is to avoid the need for litigation in the first place.

What does this mean? ARSA has been trying to address the inconsistencies in FAA guidance related to repairmen for almost 20 years, the information provided to members and the agency deliver the tools for members and intelligent government employees to stand up with the plain language of the rules. Members have reported that “their FSDO” issues repairman certificates without any “ratings.” Those repairmen certificates point to the repair station certificate number and roster as the place to confirm the job requiring the certificate. That means prophylactic information can prevent an ugly baby from showing up in court where a lawyer (or judge) can ruin everything.

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ARSA on the Hill

Hurry Up and Wait (and Vote!)

By Christian A. Klein, Executive Vice President

Not surprisingly, being a congressional lobbyist can sometimes be frustrating. You can do all the right things –gather data to explain a problem, develop credible solutions, engage aggressively to sell your proposal…and still not get the result you’re after. With Congress set to leave town until after the elections without providing additional economic relief for the aviation industry, this is apparently one of those frustrating times.

In recent months, ARSA and its allies have been actively promoting various legislative proposals to prevent further job losses in our sector, including extending the paycheck protection program (PPP), renewing the payroll support program (PSP) for airlines and their contractors and creating a new public-private partnership cost sharing program (CSP) to help aviation manufacturers and repair stations avoid layoffs.

The needs are clear. Based on ARSA’s recent member survey, the maintenance industry has lost as many as 50,000 workers since March and 40 percent of respondents are considering additional layoffs and furloughs. With business activity for the maintenance industry anticipated to be down close to 50 percent in 2020 versus 2019, the situation is dire. Several airlines have also announced big layoffs if the PSP isn’t renewed and unions representing airline employees have been particularly active in calling for congressional action to protect their jobs.

Our pleas haven’t fallen on deaf ears. Senate Commerce Committee Chairman Roger Wicker (R-Miss.) introduced PSP legislation this month. The House Democrats’ revised HEROES Act extends the PPP and includes tens of billions of dollars for the aviation sector. And the aerospace jobs bills (H.R. 8002, S. 3705) promoted by ARSA, the General Aviation Manufacturers Association, the Aerospace Industries Association and others have picked up a handful of additional cosponsors.

But as the election draws closer, Capitol Hill has become ever more partisan and the environment even less conducive to legislating. The recent death of Supreme Court Justice Ruth Bader Ginsberg and the fight over her successor have further broadened the divide and added yet another urgent item to Congress’s to-do list. We don’t doubt that many congressional leaders and members of both parties want to pass another relief bill, but collectively they haven’t had the will to put jobs before politics.

Even so, we’re not giving up hope. The House and Senate leaders were able to set aside their differences long enough to pass a continuing resolution to fund the government through mid-December, avoiding (for now) another shutdown. Treasury Secretary Steven Mnuchin, the Trump administration’s lead negotiator on COVID relief, is working with House Speaker Nancy Pelosi (D-Calif.) to negotiate a package that satisfies Republicans’ demands for liability protections for businesses and schools and Democrats’ desire to provide more aid to cash-strapped state and local governments. The price tag remains a major sticking point.

In a largely symbolic effort to show they’re doing something and clarify their negotiating position, House Democrats passed an updated version of the HEROES Act on Oct. 1 with no Republican support (18 Democrats also voted no). Whether or not the House move adds momentum to the process or makes it even more partisan and fractious remains to be seen.

Our efforts on the relief front will continue and we stand ready to assist any ARSA member who wants to make their voice heard on the Hill.

House Committee Approves Certification Reform Bill

Congress made progress last month towards reforming FAA’s aircraft certification process to address issues raised by the Boeing 737 MAX accidents.  The Senate Commerce Committee planned to markup a bipartisan bill on Sept. 16 but pulled it from consideration after the House Transportation & Infrastructure (T&I) Committee, shortly before the Senate markup, released its Boeing 737 MAX investigation report. The T&I Committee then seized the initiative, marking up and passing it’s own certification reform bill on Sept. 30.

The bills would generally require companies that hold both a type and a production certificate to implement safety management systems, require the FAA to approve members of organization designation authorization (ODA) units, more carefully consider human factors issues related to pilot and aircraft interfaces, emphasize ODA best practices and create avenues to report safety concerns.

A summary of the House bill (H.R. 8408) is here. The bill text is here.

A summary of the Senate bill (S. 4565) is here. The bill text is here.

While the House T&I and Senate Commerce Committees have worked extremely hard to develop legislation to address apparent gaps in FAA certification process, the big question is where those bills are headed. Nothing will happen before the November elections, but it’s possible that House and Senate negotiators could spend the time brokering a compromise between the two versions of the bill both chambers could pass during the lame duck session in November. Keep watching ARSA for updates.

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Training

Effective Comments and the Fourth Branch of Government

Certificate holders must be adept at dealing with the government. Maintenance providers need to understand the administrative agencies overseeing the industry and recognize how and when to engage in the process in order to better the system. The four sessions in the “fourth branch of government” training series are now available on demand. Purchasers can bundle all four together or focus in on either the administrative agencies themselves (two sessions) or the rulemaking process (two sessions).

The Rulemaking Process – Overview
This session provides an overview of how federal agencies make regulations that have the force and effect of law. Specifically, it reviews the agencies that must follow the Administrative Procedure Act, the procedures governed by the Act as well as other methods by which an agency can obtain recommendations from the public on its rulemaking activities and mandates.
Click here to register and get access for 90 days (multiple bundles available).

The Rulemaking Process – Effective Comments
This session provides methods for submitting effective comments on FAA rulemaking proposals and on other documents that are posted for feedback from stakeholders.
Click here to register and get access for 90 days (multiple bundles available).

Administrative Agencies & Their Powers
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.
Click here to register and get access for 90 days (multiple bundles available).

Administrative Agencies – The FAA & NTSB This session reviews 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).
Click here to register and get access for 90 days (multiple bundles available).

Registration for an ARSA-provided training session includes:

• Unlimited access for 90 days to the recording.
• A copy of the presentation and all reference material with links to relevant resources and citations.
• A certificate upon completion of the class, as well as any test material.

The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit potomaclaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.

What training do you need? Contact ARSA to let the association know and help get it developed.

Building a Professional Government Relationship

This session provides a roadmap for building a useful relationship with civil aviation authorities. It begins by describing the rules that should always be considered when engaging with aviation safety regulators, then provides instruction on how to introduce your company and maintain consistent contact – not just when there’s a problem. It concludes by providing strategies for maintaining a professional relationship with regulators.

Editor’s Note: When it was recorded the session was titled as offering instruction for a “positive” relationship with the government. Since that recording, the association’s thinking has evolved to recognize that seeking “positivity” is nowhere near as productive or realistic as seeking professionalism.

Click here to register and get access for 90 days.

As a repair station, dealing with the government, particularly the Federal Aviation Administration (FAA) is inevitable. Building a good relationship with government officials in good times will help keep the bad times at bay. ARSA works to provide its members with the tools to make the most out of every interaction with a regulator. In addition to this training session, members should review the resources available from the association, at arsa.org/regulatory/faa/dealingwiththegovernment.

Registration for an ARSA-provided training session includes:

• Unlimited access for 90 days to the recording (registrants may contact ARSA directly with questions or comments).
• A copy of the presentation and all reference material with links to relevant resources and citations.
• Upon completion of the class as well as any test material, a completion certificate.

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.

About the Government, From the Government

The United States

USAGov’s mission is to make it easier for everyone to find and understand the U.S. government services and information they need—anytime, anywhere, any way they want.

USA.gov is an interagency product administered by USAGov (formerly the Federal Citizen Information Center), a division of the U.S. General Services Administration’s Technology Transformation Service. It got its start when Internet entrepreneur Eric Brewer, whose early research was funded by the Department of Defense, offered to donate a powerful search engine to government. That gift helped accelerate the government’s earlier work to create a government-wide portal.

Click here to enter that portal and review the topics available for citizen searches.

The European Union

The Publications Office of the European Union, based in Luxembourg, is an interinstitutional office whose task is to publish the publications of the institutions of the European Union (Decision 2009/496/EC, Euratom). Its core activities include production and dissemination of legal and general publications in a variety of paper and electronic formats, managing a range of websites providing EU citizens, governments and businesses with digital access to official information and data from the EU, including EUR-Lex, the EU Open Data Portal, EU Publications, TED (Tenders Electronic Daily), CORDIS and ensuring long-term preservation of content produced by EU institutions and bodies.

Click here to explore the Publications Office’s resources.

Canada

The Canadian government’s website includes a section explaining the priorities, laws, finances, transparency, digital government and policies. In addition to providing guidance for connecting and doing business with the government, the site provides an introductory overview as to how Canada works.

Click here to see what it says.

Regulatory Compliance Training

Test your knowledge of 14 CFR §§ 11.1, 11.3, 11.5 & 11.7, General Rulemaking Requirements. 

Click here to download the training sheet.

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Membership

ARSA Remembers – Mark Rosenker (1946-2020)

Mark Rosenker, photo courtesy NTSB

On Sept. 26, former NTSB Chairman Mark Rosenker died at a hospice center in Alexandria, Virginia after an intense battle with brain cancer. He was 73.

A retired Air Force Reserve Major General, Rosenker was appointed to the NTSB by President George W. Bush and served from 2005 to 2009. During his career in civilian Federal service Mr. Rosenker received eight Presidential appointments, three of which required Senate confirmation. He held posts in the Department of the Interior, the Federal Trade Commission, and the Commodity Futures Trading Commission, and the U.S. Department of Transportation.

In addition to his military and federal government service, Rosenker headed numerous transportation and policy related efforts across his career and gave voice to industry issues as a CBS television and radio spokesman. In addition to serving on multiple boards and industry bodies, he ran a specialized consulting firm until his health deteriorated.

An ARSA ally and engaged participant in association events during his years on the Sequa Corporation Board of Directors (Sequa is the parent company of ARSA corporate member Chromalloy), Rosenker contributed his expertise to and appeared in ARSA’s public television documentary about the maintenance industry “You Can’t Fly Without Us”.  Throughout his work with the maintenance community, he demonstrated the same commitment to safety and responsible business practices for which he was known in every part of his professional life.

“Mark lit up the room wherever he went,” ARSA Executive Vice President Christian A. Klein said. “He brought innate intelligence, a sense of humor and a wealth of experience and insight to every situation he encountered. It was an honor to work with him, learn from him and know him. He was a true mensch and ARSA will miss him.”

In 2018, Mark and his wife Heather founded the Rosenker Center for Political Communication and Civic Leadership at The University of Maryland. The Center is committed to the advancement of a diverse and productive democracy through the study of human communication.

There are many tributes available to Rosenker’s life and career. To view his obituary, share a memory and get service information, click here.

In lieu of flowers, memorial contributions can be made to the tunnel2towers.org or www.taps.org.

To see who else ARSA continues to remember, visit arsa.org/arsa-remembers.

Quick Question – Your Election Opportunity

In the August 2020 edition of ARSA’s hotline newsletter, Executive Vice President Christian A. Klein attributed the association’s increasing clout on Capitol Hill with its strong network of legislative allies.

“But long-term success depends on expanding the number of lawmakers who understand our industry’s importance,” Klein said. “There’s no better time to do that than during an election year.”

To support the point, he then listed a number of areas where every ARSA member should take action leading up to Nov. 3…and continuing beyond it. His direction had nothing to do with specific candidates or voting choices, the association does not make endorsements and is committed to working with all elected officials for the good of the maintenance community.

Making a checklist out of Christian’s advice, how are you doing? Let us know in this month’s “quick question” (and report back on your progress):

Note: The question is displayed in its own, embedded window. If the “Submit” button is not visible on the screen, you must scroll within the survey window in order to submit your response.

If the embedded survey does not appear/load, open the survey independently by visiting: https://www.surveymonkey.com/r/arsa-elections

For more information on ARSA’s legislative program and how it can help you become an active grassroots advocate for the maintenance industry, click here.

Click here to see what questions have been asked and answered…and keep a lookout for more.

For more information about this or any other question, contact Brett Levanto (brett.levanto@arsa.org).

Welcome & Welcome Back – New & Renewing Members

ARSA’s members give the association life – its work on behalf of the maintenance community depends on the commitment of these organizations. Here’s to the companies that joined or renewed in September:

New Members

Aerospace Welding Minneapolis, Inc., R01
GE Aviation, Corp

Renewing Members

AE & C Services. LLC, R02, 2017
Aero Design Services, Inc., Affil, 2000
Aero Instruments & Avionics, Inc., R04, 1991
AerSale, Inc. dba AerSale Component Solutions, R03, 2009
AerSale, Inc.-Goodyear, R04, 2015
Air Cargo Equipment, Inc., R01, 2010
Air Technology Engines, Inc., R02, 2006
Aircraft Ducting Repair, Inc., R03, 2002
Alticor, Inc., R02, 2018
Ametek Ameron, LLC dba Ameron Global Product Support, R01, 1989
Arkwin Industries, Inc., R02, 1994
AAR Corp, Corp, 1985
Bridger Aviation Repair LLC, R01, 2019
Commercial Jet, Inc., R04, 1999
Cross-Check Aviation, R03, 2003
Curtiss Wright Controls, Inc., R03, 2003
Dan Brauhn-Indian Hills Community College, EDU, 2015
Federal Express Corporation, Assoc, 2000
Fieldtech Avionics & Instruments, Inc., R04, 2016
Florida Jet Center, Inc., R02, 2013
Hot Section Technologies, Inc. , R01, 2017
International Turbine Industries, LLC, R02, 2010
JET Aircraft Maintenance, Inc., R04, 2010
Miami Aircraft Structures, Inc., R01, 2003
Nampa Valley Helicopters, Inc., R02, 1993
Palm Beach Aircraft Propellers, Inc., R02, 2001
Safran Nacelles Services Americas, R02, 2017
SAI Flight Support Company, R01, 2016
Schaeffler Aerospace USA Corporation, R02, 2012
SIA Engineering Company, Ltd., R06, 1997
Thomas Global Systems, LLC, R01, 2012
TMx Aero, LLC, R01, 2018
Turbine Weld Industries, LLC, R03, 2004
Unical 145, Inc., R04, 2012
Zee Company, Inc., R02, 2019

A Member Asked…

Q: I would like to get your opinion on a matter regarding “triple releases” after maintenance. I know this term was removed from change 7 to the FAA-EASA MAG but it is still allowed under the TCCA-EASA MAG. Is this correct?

Considering the change to the FAA-EASA MAG, are used components issued from a country within the EU, e.g., Ireland, on an EASA Form 1 with certifications to EASA, the FAA and TCCA requirements (and with certificate numbers) still acceptable?

A: The “triple release” was removed in change 7 of the U.S.-EU MAG not because it is no longer allowed, but because the MAG’s language was focused on the bilateral relationship between the rules of the FAA and EASA. Approval under any other country’s/countries’ rules isn’t a concern of the MAG but demonstrating compliance with those rules is not prohibited.

Sarah’s Legal Brief in the February 2020 edition of the hotline (click here to open it) addresses the triple release issue, providing a series of questions to ask when ensuring compliance with multiple national aviation authorities. You’ve already started considering those questions regarding the Form 1. If the work was accomplished in a country with an appropriate bilateral relationships and the form demonstrates compliance with the standards of all three CAAs, then the component can be used for work performed on an aircraft registered in a state under one of those jurisdictions.

Member questions should be submitted directly to the association’s team via arsa.org/contact.

Make ARSA’s Voice Your Own: Advertise

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Stand Up for ARSA

In order to provide world-class resources for its members, the association depends on the commitment of the aviation community. By sponsoring events and activities, supporters can help ARSA’s work on behalf of repair stations to endure.

Need a place to start? For information about opportunities, contact Vice President of Operations Brett Levanto (brett.levanto@arsa.org).

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Resources

ARSA strives to provide resources to educate the general public about the work of the association’s member organizations; should you need to provide a quick reference or introductory overview to the global MRO industry, please utilize AVMRO.ARSA.org.

Anti-Viral Measures

For the use of its members and the larger aviation community, ARSA is maintaining this page as a resource for pandemic-related updates on policy initiatives and business needs. It is the association’s central point of communication on the topic

H.R. 5119 – Contract Maintenance Under Attack

Help combat a bill introduced in the U.S. Congress that would disrupt the global aviation industry.

Industry News Roundup

ARSA monitors media coverage on aviation maintenance to spread the word about the valuable role repair stations play globally by providing jobs and economic opportunities and in civic engagement. These are some of this month’s top stories highlighting the industry’s contributions. You can explore these stories through ARSA’s Dispatch news portal.

Industry Calendar

the hotline is the monthly publication of the Aeronautical Repair Station Association (ARSA), the not-for-profit international trade association for certificated repair stations. It is for the exclusive use of ARSA members and federal employees on the ARSA mailing list. For a membership application, please call 703.739.9543 or visit arsa.org/membership/join. For information about previous editions, submit a request through arsa.org/contact. This material is provided for educational and informational purposes only. It does not constitute legal, consulting, tax or any other type of professional advice. Law, regulations, guidance and government policies change frequently. While ARSA updates this material, we do not guarantee its accuracy. In addition, the application of this material to a particular situation is always dependent on the facts and circumstances involved. The use of this material is therefore at your own risk. All content in the hotline, except where indicated otherwise, is the property of ARSA. This content may not be reproduced, distributed or displayed, nor may derivatives or presentations be created from it in whole or in part, in any manner without the prior written consent of ARSA. ARSA grants its members a non-exclusive license to reproduce the content of the hotline. Employees of member organizations are the only parties authorized to receive a duplicate of the hotline. ARSA reserves all remaining rights and will use any means necessary to protect its intellectual property.

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