2021 – Edition 3 – April 6

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.

State of the Association
2021 Annual Conference
Anti-Viral Measures
ARSA Works
2021 Economic Outlook
Legal Brief
ARSA on the Hill
Training
Membership
Resources
Industry Calendar

State of the Association

Managing Director’s Report

By Marshall S. Filler, Managing Director & General Counsel

During ARSA’s Annual Member Meeting on Friday, March 12, Managing Director & General Counsel Marshall S. Filler provided members an update on the state of the association. The following are Filler’s prepared remarks, annotated with links to relevant sources and updates.

A recording of the membership meeting, including the special presentation by FAA Associate Administrator for Aviation Safety Ali Bahrami, is available to event registrants via the Online Meeting Organizer. For information about purchasing recordings from the entire 2021 Annual Conference, visit the platform used for ARSA’s Online Training Program.

Good morning. It’s my pleasure to formally call the 2021 ARSA membership meeting to order. On behalf of ARSA’s professional team and its Board of Directors, thank you for being “here,” albeit remotely.

My name is Marshall Filler, ARSA’s Managing Director & General Counsel. In addition to recapping the association’s work since we held the last in-person aviation conference in the world in 2020, I will explain what we’re doing to ensure the association remains on a solid footing when the next generation takes over the reins in late 2023. In that regard, we’ll be sitting down with ARSA’s board in the next year or two to discuss that transition.

The Annual Conference is made possible by the hard work of many and the generous support of a few. Please take a moment to recognize our sponsors for making the event possible – and of course the participation of great members and colleagues.

2021 Annual Conference Sponsors

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For some of our attendees the annual conference began first thing Tuesday morning with our Executive-to-Executive briefings – but for the ARSA team the planning has been going on for months – will the pandemic recede enough to hold an in-person conference, could we possibly do a hybrid event and finally, we faced the stark reality that we had to do it 100 percent remotely. Talk about a steep learning curve! Ask Brett which kind of conference he prefers – in-person or remote.

By the way, we don’t particularly like the term “virtual” because we believe that all of us are actually participating in this event. Virtual would be like me donning a device so I could play in the upcoming Masters Golf Tournament.

After I conclude my remarks, I’ll introduce the FAA’s Assoc. Administrator for Aviation Safety, Ali Bahrami and after a short break our conference will conclude with the ARSA Workshop summarizing the association’s activities during the last year. It is vital to effectively communicate with each other about the work we’ve done together and what we need to continue doing.

Let me now recognize the board members who have helped guide ARSA through this most unusual and turbulent year.

The Association’s President, Gary Fortner is the vice president of engineering and quality control at Fortner Engineering & Manufacturing in Glendale, California, which is now part of The Wencor’s Group’s corporate enterprise membership. Gary and the Fortner family have been involved in ARSA since it was founded in 1984. Together, the company and the association have grown and experienced changes in the technical, regulatory, political and cultural world.

We’ve all surely seen, reacted to and headed off our fair share of change in this industry. ARSA, not yet in its 40^th year, has been a constant companion, successfully blunting many proposals that could have greatly damaged the maintenance industry. Despite it all, the core dedication to good government principles including sensible enforcement of the plain language of the regulations has not changed.

Rounding out our excellent group of officers are Vice President Terrell Siegfried, assistant general counsel at the NORDAM Group, and Josh Krotec, Sr. Vice President of First Aviation Services, Treasurer.

Our members of our board are Warner Calvo, quality & safety director for Coopesa, R.L., Gary Hudnall, general manager at Jet Center Medford, Jim Perdue, president of SONICO, Inc., and Scott Jacob, director of quality for Columbia Helicopters.

Rounding out our board are its two newest members, Hugh McElroy, Global Engine Services President and COO of Signature Aviation Plc and Bob Mabe, Director of Regulatory Compliance, HAECO Americas. Although new to the Board, Hugh and Bob have been strong supporters of this association for many years.

That means we have to say goodbye to two of our longest tenured board members. Please join me in extending a special thank you and job well done to Ian Cheyne, chief regulatory and technical officer at Dallas Airmotive and Dave Latimer, senior vice president of regulatory compliance at HAECO Americas for their years of dedicated service on the ARSA Board. These are not compensated positions and the people who serve as directors do it because they want to see the association continue to succeed and thrive.

Our Board represents each sector of the maintenance community, with Directors specifically selected to speak on behalf of international business, component, propeller and engine shops, rotorcraft, general aviation facilities, and aircraft maintenance facilities. Their diversity of experience and business focus guarantees the association’s leadership covers all segments of our industry.

Thank you, gentlemen for your leadership, guidance and dedicated service to the maintenance industry.  

It’s been a busy twelve months since last year’s Conference. On the regulatory front ARSA continued its collaboration with international aviation safety regulators, but also expanded its reach outside of the aviation-specific arena.

As the association’s international point person – I worked closely with industry and government members of the Maintenance Management Team and Certification Management Team (CMT/MMT) to pursue mutual acceptance of minor alteration data, recognition of component maintenance approvals among and between the four authorities in the “quadrilateral group” – the FAA, EASA, Transport Canada and ANAC Brazil (all of whom were represented at the Conference this week) plus the UK CAA which never went away of course but now needs to staff up in those areas where EASA had primacy, such as regulations, guidance, policy making and certification. And this year, we welcomed the CAAC to our Opening Salvo panel, and we greatly appreciated their participation.

The association continues to lead a coalition of international partners to address issues with the maintenance implementation procedures between TCCA and FAA and the FAA and EASA in particular. We’ve made progress on both fronts but, as most of you know, things move even slower in a pandemic. So, patience is required.

The recent release of change 8 to the U.S.-EU maintenance annex guidance drew attention in late 2020. ARSA has for years been a key player in dealing with MAG-related issues. That work continues: Work on the next revision of ARSA’s Model EASA Supplement is almost ready to be released…as well as an update to ALL of the Association’s model manuals, forms and supplements.

The team played a leading role in fielding questions regarding the MAG’s impact on individual member supplements and the often-contradictory messaging coming from local inspectors.

Which brings me to the first “to-do” as an ARSA member – PLEASE ASK ARSA FIRST! Sarah has been known to ask a member who tells her “But the FAA said …”  “Do you ask the IRS to do your taxes?  Well, think about it … we have about 80 years of regulatory compliance knowledge on our team so why not take advantage of it?

But it’s important to recognize that ARSA is not a one-trick pony anymore and, in fact, under Christian and Brett’s leadership ARSA has expanded into areas that Sarah and I never contemplated but which will be critically important for our members in the future.

Workforce and career development issues are now an integral part of the association’s core competence. Christian and Brett continued the association’s industry-wide leadership in pursuing funding for the aviation maintenance technician grant program conceived and led by ARSA and established by the 2018 FAA reauthorization law. Thanks to their efforts and the engagement of many proactive members, Congress fully funded the program and the FAA has done its part to roll it out! The agency’s dedicated web site has links to important announcements including Notices of Funding Opportunity published in late January for grants in support of programs to enhance career opportunities for maintenance technicians and pilots (NOTE: The first round of grant funding applications closed on March 29; if you applied, please share your experience with ARSA). While the pandemic has temporarily delayed the crisis, make no mistake that reality will be upon us again very soon as the recovery gathers steam.

ARSA’s work has also become more visible on Capitol Hill. The association remains an integral part of the aviation industry coalition that lobbied Members of Congress to ensure that the maintenance industry was eligible for the various financial aid programs enacted as a result of the pandemic. Several hundred million dollars have already been received by repair stations through the Payroll Protection Program and the Payroll Support Program.

In the last Congress, we saw a new and significant threat to the maintenance industry emerge on Capitol Hill. Peter DeFazio – the Oregon congressman who chairs the House Transportation & Infrastructure Committee – introduced the Safe Aircraft Maintenance Standards Act (H.R. 5119).

The bill would cause significant disruptions for the global aviation maintenance industry, U.S. air carriers, passengers and cargo shippers, general aviation operators and aerospace manufacturers.

If it had become law, more than 1,500 U.S. repair stations with foreign approvals and their employees would almost certainly be targets of retaliation by foreign authorities. Foreign repair stations would be subject to new and unnecessary requirements that do nothing to further safety. U.S. air carriers and their maintenance vendors would be subject to burdensome new recordkeeping requirements.

While the bill passed the House of Representatives it did not gain traction in the Senate before the 116th Congress ended on Jan. 3, 2021. We expect another fight this year.

Make no mistake: ARSA has never been more effective and visible on Capitol Hill, but the team isn’t large enough to do it all. Your engagement is critical to achieving positive results and preventing bad things from happening.

We’re very grateful for our members’ support during this excruciatingly difficult year. Our membership income held steady which, when you think about it, is pretty remarkable, given what has happened to our industry.

But we did lose some members which you can help bring back and you can help us look for new members. Ask your business partners, suppliers and customers where they get regulatory compliance, legislative and workforce development information affecting the maintenance industry…if it is from the FAA, point them to ARSA. Bringing in a new member expands our collective voice and brings you the benefit of reduced dues. While our team reaches out to everyone in the end, you can be the voice that brings them along at the beginning.

Please make sure you’re taking advantage of your memberships! Getting newsletters and supporting ARSA’s work is a first step, but you should also be utilizing the tools/documents made available only to members, learning from our regulatory minds and getting assistance engaging with the government (from inspectors to elected officials).

One of the most important things that maximizes your value and supports ARSA is the association’s online training program. There are more than 80 hours of on-demand sessions currently available, covering topics from part 21 to 39 to 43 to 65 to 145 and a lot in between. You can help new sessions get created (if you have specific needs) and the association offers different models to incorporate this resource into your existing training program.

There are already members using ARSA’s human factors training series for compliance with the FAA-EASA MAG’s training requirements. As the training team continues to build sessions, they will focus on keeping you compliant AND improving your business:

Before closing I’d like to highlight the work of ARSA’s outstanding team, including Kimberly Dimmick, the association’s membership manager and, of course, the omnipresent Brett Levanto, our VP – Operations who amazes us all with his intellect and wit, positivity, vision and capacity for hard work.

And, as Christian said during this conference, he doesn’t get as much exercise these days as he used to walking around Capitol Hill. But, his contributions to ensuring that the maintenance industry was included in the various pandemic relief bills should be recognized by every ARSA member who received and/or will receive that relief in the future, not to mention his work in beating back the DeFazio bill during the last Congress.

Finally, let me not forget to mention ARSA’s founder and Executive Director, Sarah MacLeod who is also my wife and law partner. In case you didn’t know, SMS stands for Sarah Management System. She sees things that most others don’t and, as Crystal Maguire once said to her when Crystal worked for us, “you just keep thinking up those brilliant ideas and we’ll execute them!”

Since the association’s founding 37 years ago, ARSA has known only one Executive Director but, at some point, Sarah will no longer hold that position. Many of you know that last fall Sarah was presented with the Lifetime Achievement Award by Aviation Week Magazine, which she likes to call her “Now you can go retire award.” But, as I know all too well, she’s not the retiring kind and in the not-too-distant future she’ll focus her energies on another important endeavor, that of turning our 96 acres of central Virginia farmland into a model for restorative agriculture and agribusiness. So, that’s why we’re focused on expanding ARSA’s core competencies that will allow Christian, Brett and our eventual successors to continue providing the services and value that our members rely upon.

Thank you all for being here, for your membership in ARSA and everything you do to help make aviation the safest form of transportation. In that regard, it is now my great pleasure to introduce Ali Bahrami.

NOTE: A recording of Bahrami’s speech is available to event registrants via the Online Meeting Organizer. It is available for purchase via the online training program utilized by the association.

I hereby adjourn the 2021 annual membership meeting.

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2021 Annual Conference

On the Record

Event Information | Sponsors

March 9-12, 2021
Washington, D.C., Arlington, Virginia & Online

Recording Availability

The 2021 Annual Conference is complete. ARSA is grateful to the sponsors, speakers, participants, production team and support that made the association’s first entirely-online event.

Now that the livestream is off line, the team has posted recordings of all sessions, which are available for attendees through the Conference Platform’s Online Meeting Organizer. and for purchase by non-attendees via the online training platform utilized by the association. Through these resources, attendees may:

(1) Access recordings. Select a session from the agenda and click “View Recording.”
(2) Download materials. Use the agenda or click “Resources” to find presentations, reports and documents.
(3) Rate sessions. Click “Rate Session and Speakers” within each agenda item you’ve viewed.
(4) Celebrate sponsors. Click “Resources” to see the videos played during the Conference’s “commercial breaks.”

ARSA will continue to develop new resources based on content recorded during the Conference, making them available in a variety of ways.

If you have questions are any time, contact the association.

See You Next Year: March 8-11, 2022

Sponsor Salute

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Anti-Viral Measures

New Pandemic Relief for Repair Stations

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

As ARSA members engaged Congress on March 10, lawmakers finalized the most recent pandemic relief bill.

President Biden signed the American Rescue Plan Act (ARPA) into law on March 11. The law extended the existing Payroll Support Program (PSP) with $14 billion for airlines and $1 billion for contractors. It also created a new “Aviation Manufacturing Jobs Protection” PSP specifically for repair stations, aviation manufacturers and their suppliers.

ARSA and its allies at the General Aviation Manufacturers Association and Aerospace Industries Association, along with leading companies, have been working in coalition since the summer to enact the new PSP into law. It allows an eligible company to designate up to a quarter of its workforce (“eligible employee group”) as at risk of being laid off because of pandemic-related economic disruptions. The federal government will contribute half of these employees’ compensation if the employer keeps them on payroll.

To be eligible, an applicant must either be either U.S.-based or have “significant operations” and a majority of their production/maintenance employees in the United States. The company must also meet one of the following criteria:

• Actively manufacture an aircraft, aircraft engine, propeller, or a component, part, or systems of an aircraft or aircraft engine under an FAA production approval.
• Hold an FAA repair station certificate.
• Operate a process certified to SAE AS9100 related to the design, development, or provision of an aviation product or service, including a part, component, or assembly.

Additionally, the company must:

• Have involuntarily furloughed or laid off at least 10 percent of its workforce in 2020 or experienced a 15 percent decline in 2020 revenues vs. 2019.
• Not have not used the employee retention credit created by Sec. 2301 of the CARES Act in the preceding calendar quarter.
• Not have received support through the air carrier PSP.
• Not be expending Paycheck Protection Program money as of the date the application for the new program is submitted.

The “eligible employee group” for which payroll support may be sought may not exceed

25 percent of the employer’s total U.S. workforce as of April 1, 2020, cannot include employees with a total compensation level of more than $200,000 per year and must be actively engaged in aviation manufacturing activities and services, or maintenance, repair, and overhaul activities and services. Payroll support can be granted to eligible companies for up to six months.

There are additional considerations and qualifications. To read the full legislation (Secs. 7201 and 7202 of the new relief bill), click here.

Unlike the air carrier PSP, which is administered by the Department of Treasury, the new program will be administered by the Department of Transportation. On March 25, the CEOs of ARSA, AIA and GAMA sent a letter to Transportation Secretary Pete Buttigieg urging the program be implemented as quickly as possible. ARSA and its allies ask Buttigieg to make the program “the highest possible priority to stimulate faster recovery of the aviation sector and avoid more extensive damage from the pandemic.”

The relief provided by the federal government in the past year through the CARES Act and subsequent legislation has been essential to U.S. maintenance industry’s survival. Treasury Department records indicate approximately $500 million was provided to repair stations through the airline PSP and ARSA analysis suggests that half its membership was able to take advantage of the Paycheck Protection Program. However, some maintenance companies fell through cracks because they didn’t perform functions at an airport (a requirement for the airline PSP) or were too large for PPP. For those companies in particular, the new PSP may be an attractive option.

To jump to the relevant sections of the ARPA, click here.

To read ARSA, AIA and GAMA’s letter to Secretary Buttigieg, click here.

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ARSA Works

ARSA Remembers Weston By Honoring Mickler

For more information about the Annual Conference, including access to recordings and other resources produced during the event, visit arsa.org/conference.

On March 11, ARSA recognized Thomas Mickler as the 2021 recipient of the Leo Weston Award for Excellence in Service to Aviation Safety.

The award was established in 2005 and first given to Weston himself. As an FAA official, he advocated for the creation of an organization to represent the interests of maintenance providers and was pivotal in ARSA’s founding. He was a lifelong aviator and educator whose passion was kindled at a Philadelphia high school and continued through military, civil, government and volunteer service that ceased only with his passing in November 2020.

“[Leo’s] dedication was matched with exceptional insight,” ARSA Executive Director Sarah MacLeod pronounced, remembering his unfailing support of the association’s creation. “He was as willing to learn as he was to educate; he embodied the ‘critical thinking’ sought but so rarely found in government or industry.”

The presentation of the 2021 Weston Award took place during ARSA’s Annual Conference. Managing Director and General Counsel Marshall S. Filler paused the day’s global regulatory discussion to remember Weston and recognize Mickler, who has worked closely with ARSA and its international aviation allies since taking office as Washington, D.C. representative of the European Union Aviation Safety Agency (EASA) in August 2014.

“This award recognizes [Thomas] for his contributions, for his accessibility, his willingness to share information, his candor and his friendship,” Filler said in delivering the award, describing Mickler’s role as an intermediary between EASA and the FAA as one of “the most challenging in aviation safety.”

Accepting the award, Mickler expressed gratitude at knowing his service was helpful to the industry. That helpfulness is Weston’s legacy and has defined Mickler’s decades long career, which will continue beyond his soon-to-be-complete stint in Washington.

To learn more about Weston, celebrate his legacy and share your own memories of his impact visit arsa.org/weston-award.

Presentation of the 2021 Weston Award

During ARSA’s 2021 Annual Conference, Managing Director & General Counsel Marshall Filler paused the March 11 global regulatory discussion to present the Leo Weston Award for Excellence in Service to Aviation Safety to EASA Washington Representative Thomas Micker. See Filler’s presentation and Mickler’s response, recorded during the livestreamed event:

Youth Task Force Meeting Resources

On March 31, the FAA held the second public meeting of the Youth Access to American Jobs in Aviation Task Force. ARSA specifically represents repair stations on the body – while also pressing the interests of designers, manufacturers, operators and the broader maintenance community – and encourages members to follow up on the meeting recording (a skill recently bolstered by ARSA’s Annual Conference):

After an address from FAA Deputy Administrator A. Bradley Mims, the four Task Force subcommittees provided updates on their work along with preliminary recommendations and next steps. After lunch, task representatives welcomed special guest speakers who covered aviation media, underserved populations and emerging technologies.

Meeting Materials: To download the presentations and reference documents used during the meeting, click here.
Recording: The entire meeting recording is available via the FAA’s YouTube channel.
Federal Register Notice: www.federalregister.gov/documents/2021/03/11/2021-05054/youth-access-to-american-jobs-in-aviation-task-force-notice-of-public-meeting

For information about the meeting or the task force in general, review the content at arsa.org/youthtaskforce or visit the committee page on the FAA website. ARSA encourages industry members to support the effort by sharing workforce development thoughts, questions, needs or lessons learned to arsa.org/contact.

ARAC Recruiting Repairman Working Group

Learning from Workforce Grant Submissions

The application period for the first round of FAA Workforce Grants closed on March 29 and ARSA seeks input from applicants regarding the experience.

According to FAA executives coordinating industry workforce initiatives, this first round of grants – initial notices of funding opportunity for both pilot and technician programs were released in January – will disburse funds appropriated for 2020, which had been authorized by Congress but not expended. Since the programs were again fully funded for FY 2021 (as part of the year-end omnibus), there will be another solicitation later in the year to utilize the 2021 funds. 

The agency plans to list recipients of the first round of grants in September on its central grant program website. No specific schedule has been set for the next solicitation to disburse the 2021 appropriation, but industry must get active in collecting lessons learned and preparing for new applications.

If you submitted a grant application, contact ARSA with the following information:

(1) A general description of the program for which you applied for funding, including the total grant amount sought.
(2) The names of your industry/academic/government partners in the application.
(3) A description of the application process, including notes related to any issues or challenges in working with the government or utilizing grants.gov or other resources.
(4) Useful or surprising experiences in collaborating with industry partners.

ARSA will not publish any identifiable information provided and will coordinate with any submitters regarding further analysis or use of lessons learned. Submit specific questions or notes to ARSA Vice President of Operations Brett Levanto.

For more information about the grant programs, visit the FAA’s program website or review the content at arsa.org/grant-program.

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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2021 Economic Outlook

Cautious Optimism for 2021 and Beyond

For more information about the Annual Conference, including access to recordings and other resources produced during the event, visit arsa.org/conference.

The annual rollout of the Oliver Wyman/ARSA MRO market forecast in conjunction with the ARSA Conference is a must-attend event for industry leaders, reporters and policymakers interested in the aviation maintenance economic outlook. However, the release of this year’s report took on new importance as repair stations to recover from the most challenging business conditions in the industry’s history.

Oliver Wyman Vice President Tom Cooper presented the report during 2021 ARSA Conference’s Legislative Day on March 10. His general assessment was that, while it will take some time to recover to pre-pandemic business activity levels, 2021 will be a much better year for the maintenance industry than 2020.

It could hardly be worse.

According to Oliver Wyman, global demand for maintenance services fell from $82.9 billion in 2019 to an estimated $50.3 billion in 2020, a 40 percent drop. Cooper said that at the height of the disruptions in the spring of 2020, global air travel demand and aircraft utilization were off by 80 percent and 75 percent respectively from prior years. 2020 was also the first time in modern commercial aviation history that the industry experienced a year-over-year decline in the active global commercial fleet size with 57 percent fewer new aircraft deliveries and twice as many aircraft retirements than in recent years.

According to Cooper, the worst is behind us and, if current positive trends continue, global demand for the active aircraft fleet is expected to fully recover by the first half of 2022 and maintenance demand will reach pre-COVID levels by second half of 2022.

However, there is still considerable uncertainty in the forecast, particularly when it comes to air carrier maintenance activity. Cooper discussed the four factors that will drive airline recovery: epidemiological timeline(whether and how the pandemic is constrained), traveler sentiment (whether people feel safe getting on aircraft), government restrictions (whether visitors will be freely welcomed from other countries) and macroeconomic conditions (whether the direction of the global economy will support a rebound in leisure and business travel).

Under Oliver Wyman’s most optimistic scenario, the global maintenance industry could grow to $117.6 billion per year by 2031. That assumes continued progress with vaccine distribution and a return to pre-COVID passenger demand levels by the end of 2022. If there are problems with vaccine distribution and/or efficacy or if the global economy fails to rebound, demand for maintenance services could be $15 billion lower than anticipated by the end of the decade.

The economic downturn took a significant toll on the industry’s workforce. An ARSA report released in mid-2020 determined repair stations had lost of quarter of their workforce to layoffs and furloughs in the first half of last year. However, with recovery taking hold, the industry workforce has rebounded slightly and is still an important driver of the U.S. economy. Oliver Wyman estimates that there are 273,000 Americans currently working in the maintenance sector (down from 296,000 pre-pandemic). Of those, two-thirds work at repair stations, 22 percent work for aircraft parts manufacturers and distributors and 11 percent are employed as airline mechanics.

“After an incredibly difficult year, ARSA members we’ve spoken to are generally optimistic about the future,” ARSA Executive Vice President Christian A. Klein said.  “But as demand for maintenance services picks up, repair stations are once again facing a technical talent shortage, which we expect to be even more acute than it was pre-pandemic. After a year of just trying to survive, companies are having to pivot quickly back to recruitment and workforce development. It’s definitely causing some whiplash.”

The 2021 report’s executive summary and Oliver Wyman’s Interactive Forecast Dashboard are accessible at arsa.org/news-media/economic-data. The full report is available exclusively to ARSA members free on request. A recording of Cooper’s presentation is available to conference registrants via the event’s Online Meeting Organizer.

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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.

Go and See

By Brett Levanto, Vice President of Operations

Each month, the hotline’s “Legal Brief” analyzes key compliance and government oversight issues that matter to repair stations. The expertise demonstrated in each brief is ARSA’s core value to its members. At the 2021 Annual Conference, that expertise was on display in every way, but is the centerpiece of the “Opening Salvo” session hosted on the morning of March 11. The discussions moderated by ARSA regulatory experts span an entire morning and provide a roadmap to the complex international system of regulations and bilateral agreements.

Those who participated in the Annual Conference got used to hearing me reference “four continents of engagement.” The 2021 Opening Salvo included presentations from the U.S. FAA, UK CAA, EASA, ANAC Brazil, Transport Canada and the Chinese CAAC. While ARSA has always enjoyed strong global participation, thanks to technology it reached unprecedented levels at in 2021.

So, this month’s “Legal Brief” is contained in that global discussion. See the names behind each of those agencies below, then go to the Online Meeting Organizer (if you registered for the Conference) or the online training platform (if you didn’t) to get access to the recording.

Opening Salvo—Conversations with the Regulators

Rick Domingo, Executive Director, Flight Standards Service, FAA
Dan Elgas, Manager, Strategic Policy Branch, FAA
Thomas Mickler, Washington Representative, EASA
Karl Specht, Principal Coordinator, Organisation Approvals, EASA
David Malins, Head of Airworthiness, UK CAA
Neil Williams, Safety Policy Manager, Operations, UK CAA
Jeff Phipps, Chief, Operational Airworthiness, Standards Branch, Transport Canada Civil Aviation
João Souza Dias Garcia, Manager, Operations Regulations and Support, ANAC Brazil
Li Heping, Continuous Airworthiness & Maintenance Division, Flight Standards Department, CAAC
Xue Shijun, Deputy Director General, Flight Standards Department, CAAC

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ARSA on the Hill

Economic Relief, Infrastructure and More

By Christian A. Klein, Executive Vice President

It’s been a busy month a Capitol Hill. Having enacted a new COVID relief law, the Biden administration has quickly pivoted to promoting a massive economic policy and infrastructure bill with important implications for the aviation industry.

New Relief Bill Creates PSP for Repair Stations, Aviation Manufacturers

President Biden signed the $1.9 trillion American Rescue Plan Act (ARPA) into law on March 11. The third major COVID relief law in a year extended the existing Payroll Support Program (PSP) with $14 billion for airlines and $1 billion for contractors. It also created a new “Aviation Manufacturing Jobs Protection” PSP specifically for repair stations, aviation manufacturers and their suppliers.

ARSA and its allies at the General Aviation Manufacturers Association and Aerospace Industries Association, along with leading companies, worked in coalition since last summer to enact the new PSP into law. It allows an eligible company to designate up to a quarter of its workforce as at risk of being laid off because of pandemic-related economic disruptions. The federal government will contribute half of these employees’ compensation if the employer keeps them on payroll.

The new program will be particularly valuable for repair stations that haven’t been able to tap into the airline PSP because they don’t perform services at an airport or the Paycheck Protection Program (PPP) because they have too many employees.  More details can be found in the “ARSA Works” section of this edition.

ARSA and our allies have weighed in with Transportation Secretary Pete Buttigieg to encourage rapid implementation, but there’s no word yet on when the program will be up and running.  Keep checking ARSA for details.

In other relief-related news, on March 30, President Biden signed legislation extending the PPP. The bill extends the deadline to apply for a PPP loan from March 31 to May 31 and extends the authorization period for the program until June 30.  Click here for more information about PPP loans.

ARSA estimates that the maintenance industry has obtained approximately $500 million through the airline PSP and more than half of ARSA’s members have received forgivable PPP loans.

Infrastructure Package Opportunities and Risks

The White House unveiled its $2 trillion American Jobs Plan March 31.  While characterized by the Biden Administration as an infrastructure package, it’s actually a massive economic policy proposal with implications well beyond highways, bridges, runways and sewers. The list of objectives (as revealed by section headings of the plan summary) is daunting:

• Fix highways, rebuild bridges, airports and transit systems.
• Deliver clean drinking water, a renewed electric grid and high-speed broadband to all Americans.
• Build, preserve and retrofit more than two million homes and commercial buildings, modernize our nation’s schools and childcare facilities, and upgrade veterans’ hospitals and federal buildings.
• Solidify the infrastructure of our care economy by creating jobs and raising wages and benefits for essential home workers.
• Revitalize manufacturing, secure U.S. supply chains, invest in R&D., and train Americans for the jobs of the future.
• Create good-quality jobs that pay prevailing wages in safe and healthy workplaces while ensuring workers have a free and fair choice to organize, join a union, and bargain collectively with their employers.

For ARSA members, Biden’s initiative presents opportunities and risks.  America’s infrastructure is in desperate need of additional investment. The American Society of Civil Engineers recently gave the nation’s airports a D+ grade and said that under pre-COVID projections the aviation system was facing a 10-year, $111 billion investment shortfall.  Improving airports will increase system efficiency and capacity, which will in turn lead to more maintenance activity. 

However, for the MRO sector some infrastructure needs are more direct. ARSA has heard from members concerned that a lack of new maintenance hangar capacity will constrain industry growth. A properly crafted infrastructure bill could address these challenges through grants, innovative financing tools, etc. More broadly, the plan could improve all transportation modes, enhancing overall economic efficiency and reducing logistics costs. Looking towards the future, the infrastructure package – with its heavy focus on sustainability and innovation – could also lay the foundation for increased electric aircraft activity. 

While the business community generally strongly supports infrastructure investment, parts of the Biden plan have quickly drawn criticism.  Atop the list of concerns is the administration’s proposal to pay for the package in part by rolling back the corporate tax cut enacted during the Trump administration and increasing rates from 21 to 28 percent.  Doing so would yield an estimated $700 billion.  Tax issues aside, the White House is pursuing a host of long-standing Democratic priorities – environmental, labor, etc – under the guise of infrastructure.

Democratic congressional leaders have said they want the infrastructure package done this summer, but the release of the administration’s plan is just the opening salvo in what’s expected to be a protracted debate.  It’s unlikely that the president’s plan would win the support of all Democrats in its current form, let alone gain bipartisan traction.  The road forward for infrastructure in the 117^th Congress is highly uncertain.

ARSA, AAR’s Holmes Laud Duckworth

For more information about the Annual Conference, including access to recordings and other resources produced during the event, visit arsa.org/conference.

Senator Tammy Duckworth (D-Ill.) received ARSA’s Legislative Leadership Award on March 10, 2021 in recognition of her efforts protect aviation maintenance jobs during the pandemic and improve technician training. Photo courtesy Office of U.S. Sen. Tammy Duckworth.

ARSA presented its 2021 Legislative Leadership Award to Sen. Tammy Duckworth (D-Ill.) as part of the association’s Legislative Day on March 10. The honor is given annually to a member of Congress who has demonstrated outstanding commitment to the aviation maintenance community.

AAR President & CEO John Holmes, who presented this year’s award on behalf of ARSA, lauded Duckworth as, “a true champion for the aviation maintenance industry and our workers” and highlighted her work to ensure the CARES Act included economic relief for repair stations. The association estimates repair stations received approximately $500 million through the Payroll Support Program and more than half of ARSA’s members received forgivable Paycheck Protection Program loans in 2020.

Duckworth has also been a vital ally in other recent maintenance-sector legislative victories, including establishing and funding the new workforce grant program and the enactment last year of a bill to force FAA to update 14 CFR part 147 and bring aviation technician training rules out of the dark ages.

As part of the award presentation, Holmes highlighted Duckworth’s “amazing backstory.” Born in Thailand, her mother was Thai and her father was an American Army and Marine Corps Veteran who worked on refugee and development issues. After graduating from the University of Hawaii and the George Washington University, Duckworth joined the Illinois Army National Guard. In 2004, she deployed to Iraq as a Blackhawk helicopter pilot, one of the first handful of Army women to fly combat missions during Operation Iraqi Freedom. On Nov. 12, 2004, her helicopter was hit by an RPG and she lost her legs and partial use of her right arm.

Following her recovery, Duckworth became director of the Illinois Department of Veterans’ Affairs and, in 2009, President Obama appointed her assistant secretary of veteran’s affairs. She was elected to the U.S. House of Representatives in 2012 and the Senate in 2016. During all that, she was holding down other important jobs: She didn’t retire from the Illinois National Guard – as a lieutenant colonel – until 2014 and is also a working mother of two daughters who in 2018 became the first U.S. senator to give birth while in office.

During her time in Congress, Duckworth has staked out a reputation as an effective lawmaker who can work across the aisle.  She serves on several committees that impact the maintenance industry, including Armed Services, Environment & Public Works, Small Business and Commerce, Science, & Transportation and that committee’s aviation subcommittee.

“We’re extremely pleased that Senator Duckworth was able to join us to receive the award and just as pleased that John [Holmes] agreed to present it,” ARSA Executive Vice President Christian A. Klein said. “John’s leadership and personal involvement in the legislative process have been critical to our collective success. He sets the standard for an engaged CEO and has helped advanced policies that benefit not just AAR, but our entire industry and the hundreds of thousands of Americans we employ.”

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Training

Make ARSA Training Work for 2021

ARSA’s online training program represents its most-valuable benefit to the aviation industry: knowledge gained through training and experience. The association’s team has turned its decades of work on behalf of aviation maintenance into more than 80 hours of on-demand content.

While sessions are available for registration at any time – ARSA member discounts available – companies can also incorporate the association’s training into their regular programs:

(1) Subscription. Make up-front, bulk purchases of training hours. The details of each subscription can be customized, including focus on specific subject areas (e.g., human factors) or options for specially-priced session access after the initial hours have been used.

(2) “Championing” a session. Guarantee a certain number of attendees for training in a particular topic that will also be made available for general registration. Variations include open registration for a live session (i.e., company personnel participate at the same time as general registrants) or a company-specific live event for which a recorded version (not including any company-specific information) is made available for on-demand registration.

(3) Tailored training. Contract ARSA’s management firm Obadal, Filler, MacLeod & Klein, P.L.C. to produce or modify training specific to your organization. The team can then re-record it (or offer it as a separate live session) for ARSA’s training program. Tailored programs are priced differently from ARSA’s hourly rate and are administered by OFM&K, which allows for a client engagement and related attorney-client privilege for all discussion.

Click here to go directly to the training platform (operated by ARSA’s management firm) and begin reviewing available sessions.

For more information about ARSA’s training program, review the menus below. If you have questions or would like to learn more about ways to integrate ARSA training into your own program, contact Vice President of Operations Brett Levanto (brett.levanto@arsa.org).

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.

Training Bundle – 3 Sessions on Part 43

Part 43 – The Mechanic’s Bible

This session provides an overview of 14 CFR part 43, Maintenance, Preventive Maintenance, Rebuilding and Alteration. It places the work performed on U.S. civil aircraft in the context of the “aviation safety regulatory chain,” explains general definitions and requirements and reviews the standards that impact these activities.

Instructor: Sarah MacLeod

Click here to register and get access for 90 days.

What is “Acceptable to the Administrator”? – The Performance Rules of § 43.13

This session provides an overview of the regulations that use the language “acceptable to” the Federal Aviation Administration and how to determine what makes something acceptable to the agency.

Instructor: Sarah MacLeod

Click here to register and get access for 90 days.

Overhauling Overhaul – Part 43’s Most Misunderstood Word

In June 2015, the FAA issued another legal interpretation on the term “overhaul” – stimulating a flurry of member questions about the term’s applicability to the everyday work of maintenance providers. This course provides the regulatory context, an overview of the term, a review of its interpretations and tools for applying it in a business context.

Instructor: Sarah MacLeod

Click here to register and get access for 90 days.

Click here to go straight to the bundle purchase for all three sessions on the Mechanics’ Bible.

Registration for an ARSA-provided training session includes:

• Unlimited access for 90 days to the recording made available after the live session is complete.
• 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.

Professional Government Relationships

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.

Instructor: Sarah MacLeod

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.

Registration for an ARSA-provided training session includes:

• Unlimited access for 90 days to the recording made available after the live session is complete.
• 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.

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Membership

ARSA Workshop

During the 2021 Annual Conference, ARSA’s executive team replaced Friday’s usual breakout sessions with a two-hour intensive session on the association’s work, its value to members and the industry and how repair stations can proactively support the team.

The “Member Day” recording is available for event registrants via the Online Meeting Organizer and for purchase via the platform used for ARSA’s Online Training Program.

To download a copy of the presentation slides – including key links and references – utilized during the workshop, click here.

2021 Member Survey – Thank You

The association is grateful for the time, effort and insight of the 126 respondents – the strongest participation level in recent memory – to this year’s member survey. ARSA’s survey team is currently working with response data in order to use in communications, regulatory and legislative policy efforts; the “snapshot” provided by survey data is vital to supporting the maintenance community.

In advance of seeing this year’s results, visit ARSA’s data and advocacy page to see how the association makes use of survey responses in conjunction with its annual economic data and other special reports.

Didn’t get a chance to respond but want to share some thoughts? Submitted a response but have thought of more to say? Click here to contact ARSA and share your thoughts.

Quick Question – Your Tech

With the great success of ARSA’s 2021 Annual Conference, the association is gathering information regarding its members’ use of technology. Help the team plan for new ways to deliver ARSA content by answering this month’s “Quick Question.”

For best viewing, open the survey in its own browser window by visiting: https://www.surveymonkey.com/r/ARSAtech.

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 March:

New Members

Sky Aircraft Maintenance, LLC, R01
PropWorks Propeller Systems, R02

Renewing Members

Accurate Accessories, LLC, R01, 2002
Advanced Composite Structures Florida LLC, R03, 2015
AERO Component Repair, LLC, R01, 2011
AeroParts Manufacturing & Repair, Inc., R04, 2016
Aerospace Precision, Inc., R02, 2011
Aery Aviation, LLC, Assoc, 2019
Airbus Americas, Inc., Assoc, 1995
Aircraft Electric Motors, Inc., R04, 1984
Alirio Aircraft Services Inc. dba 24Jets, R01, 2019
AMETEK Aircraft Parts & Accessories, Inc. , R03, 1985
Auburn Aerospace, Inc., Affil, 2001
Av8 MRO LLC, R03, 2014
Avborne Accessory Group, Inc. dba AerSale Component Solutions, R04, 2013
AvidAir Helicopter Supply, Inc., R01, 2011
Avionics Shop, Inc., R01, 2011
C&S Propeller, LLC, R01, 2016
Cadorath Aerospace Lafayette, LLC, R03, 2005
Cargo Systems, Inc., R01, 1999
Chromalloy, Corp, 1993
Davis Aviation, Inc., R01, 2009
Harman’s Repair Station, Inc., R01, 2012
INAir Aviation Services Company, R02, 2003
LORD Coiporation, R04, 2002
Precision Turbine Services LLC, R01, 2020
S3 International, LLC, R02, 2010
SAFETECH USA, INC., R02, 2002
Scott Richard Aircraft Maintenance, R02, 2010
SONICO, Inc., R03, 1995
Spirit AeroSystems, Inc., R03, 2005
TAE Aerospace, Inc., R01, 2019
Toledo Jet Center, LLC, R03, 2010
Vanguard Aerospace, LLC, R01, 2016

Make ARSA’s Voice Your Own: Advertise

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 arsa.org/advertise.

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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