2021 – Edition 7 – August 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.

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

Sarah Says

The Purpose of Engagement

By Sarah MacLeod, Executive Director

ARSA has used every opportunity within its resources to focus U.S. government attention on FAA’s inconsistent enforcement of the rules requiring the provisioning and use of manufacturer’s maintenance information. President Biden’s recent competition executive order (EO) is another opportunity to bring this issue within focus for attention and potential resolution. The association providing leadership, coordination, and resources has little chance of success without member engagement.

The executive order is the president’s method of directing department and agency heads to examine competitive impact; ARSA’s July 30 letter to Transportation Secretary Pete Buttigieg and FAA Administrator Steve Dickson explained that FAA is undermining competition for maintenance services and parts. It urged FAA and DOT to resolve the maintenance manual issue as part of the EO implementation strategy.

(See the letter and catch up on ARSA’s 20-year history of engagement on Instructions for Continued Airworthiness in this month’s “ARSA Works.”)

Support of the effort is also being sought from Capitol Hill to use its Congressional oversight authority to change the FAA’s behavior. Members must join in this engagement to make it purposeful and persuasive. Your job is to communicate directly with elected officials about the ICA issue and put a face on it by hosting facility visits for representatives, senators and staff.

It does not matter if this effort will also result in little or no action; it is the purpose of the engagement that reaps benefits. To make it easy, thanks to the generous support from member Aircraft Electric Motors, ARSA created a new legislative action center. Members can send pre-written messages to congressional offices urging action and inviting members of Congress to visit. The center also allows personalized messages on any other issue of importance to your company. The purpose of the engagement is to create activist members and to ensure the association is fully engaged with member concerns. Once the message is relayed, ARSA will follow up with legislative staff to provide more context and coordinate discussions or visits by providing an agenda, talking points and more.

Visits create a forum to discuss ICA and any other issues in person; having that conversation while walking the shop floor meeting employees (i.e., voters) has never failed to have a positive return on investment even if the issues discussed are never resolved.

Engagement is a process, not a single act. ARSA has been fighting to improve the ICA and similarly disparate policies for more than three decades. In that time, the association and its members that have become purposefully engaged have realized how to apply pressure and obtain long-term gains by short-term commitments.

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Anti-Viral Measures

Aviation Jobs Protection Program Applications Open

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

On July 26, the U.S. Department of Transportation announced it would re-open applications for the Aviation Manufacturing Jobs Protection (AMJP) Program effective Aug. 4. The secondary application window will remain open for four weeks; submissions are due by Sept. 1 at 5:00 p.m. EDT.

According to the DOT announcement, the decision was made to compensate for confusion by some businesses about the relationship between the AMJP and the Employee Retention Tax Credit (ERTC) programs. Eligibility requirements remain the same and all applicants must have an active registration in the System of Award Management (SAM).

DOT will conduct a third webinar on the AMJP on Wednesday, Aug. 4 at 12:00 p.m. EDT to address the ERTC issue and highlight important information about the application process. The link will be posted on the AMJP website.

Companies that have already submitted confirmed applications do not need to resubmit.

For program information and to submit an application, click the DOT logo below or visit www.transportation.gov/AMJP

Click the DOT Logo to go to the application process webpage.

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ARSA Works

What Has ARSA Done Lately – Second Quarter 2021

Each quarter the board of directors receives reports on the association’s activities and fiscal health. Step into a board member’s shoes by reviewing the financial, operations, legislative and regulatory reports highlighting advocacy on behalf of aviation safety between April and June 2021.

Fiscal Health

The association’s balance sheet and budget performance are stronger than summer 2020 and back in-line with pre-pandemic reports.

Membership

Renewal rate for the quarter approached 90 percent, continuing improvement on already-strong retention based on team efforts to engage lapsing members.

Regulatory Advocacy

• Reported on EASA communications/resources related to “ramp up” after pandemic recovery.
• Publicized SBA event and related resources providing general industry pandemic safety guidance.
• Reviewed GAO report analyzing FAA workforce planning.
• Continued weekly meetings to draft the ARAC Part 145 Working Group report and acceptable means of compliance—will be the one of the focus areas for the remainder of the year.
• Continued weekly meetings to draft Workforce Development and Training task recommendation report for SOCAC Subcommittee—will be the other focus area for the remainder of the year.

Legislative and Lobbying

• Economic recovery
  • Engaged with U.S. Department of Transportation re: Aviation Manufacturing Jobs Protection program outreach and implementation.
  • Ongoing engagement with Government Accountability Office (GAO) regarding relief program implementation, including coordinating GAO meeting with PSP recipients.
• Workforce
  • Led industry coalition and congressional ally outreach to appropriations committees re: FY 2022 funding for Sec. 625 grant programs.
  • In partnership with Aviation Technician Education Council, Aircraft Mechanics Fraternal Association, and AAR, developed strategy and collateral to seek White House Executive Order.
  • Advocated for legislation to create National Center for Advancement of Aviation and new DOT transportation careers public service announcement program.
• Facilitated member congressional engagement
  • FAA enforcement of ICA rules.
  • Standards for FAA approval of technical data required to perform a major repair or alteration.
  • Federal funding for maintenance hangar construction.
  • Facility visits and August recess meetings.
• Participated in semimonthly Runway to Recovery and electric aircraft coalition meetings.
• Joined industry letter re: Advanced Air Mobility Planning Grants and industry statement of principles regarding sustainable aircraft fuel.
• Conducted maintenance industry briefings for new congressional staff.

Communications and Surveys

ARSA in the News – Selected Industry Coverage

SCC to expand Aviation Maintenance Technology program
June 17, 2021 | Commonwealth Journal
Somerset Community College is playing a strategic role in addressing the growing demand for skilled workers through our career and technical programs, specifically in Aviation Maintenance Technology.

Sullivan, Peters, and Cortez Masto Reintroduce Bipartisan Legislation to Strengthen Transportation Industry Workforce
May 26, 2021 | Press Release from Office of Dan Sullivan
The Promoting Service in Transportation Act would direct the U.S. Department of Transportation (DoT) to deploy public awareness campaigns highlighting job opportunities in the transportation sector to help fill existing and future workforce shortages.

Aviation Mx Industry Looks for Post-pandemic Recovery
May 5, 2021 | AINOnline
The aviation maintenance industry is showing signs of a post-pandemic recovery while concerns about a technician shortage are renewed, according to results of an Aeronautical Repair Station Association (ARSA) survey.

10 things suppliers should know about the $3B aviation manufacturing protection program
April 9, 2021 | Puget Sound Business Journal
Congress recently approved a $3 billion payroll support program to ensure workers in the aviation manufacturing industry are retained, rehired or recalled.

ARSA-placed Industry Editorials

Surveys

• Ran “quick question surveys regarding technology use (April), ARSA tools & resources (May) and emerging tech in the industry (June).

Events, Meetings and Training

Meetings

• Sarah participated in weekly meetings with the FAA Aviation Rulemaking Advisory Committee (ARAC) Part 145 working group, FAA AFS personnel and the SOCAC Workforce Development taskforce.
• Brett and Sarah convened numerous meetings related to ARSA’s repair station manual compilation.
• Brett participated in numerous meetings of the Youth Access to American Jobs in Aviation Task Force and its subcommittees.
• Christian participated in multiple meetings with congressional staff, industry allies and members related to industry economic recovery, federal support for maintenance workforce development, FAA enforcement of ICA rules, FAA approval of technical data required to perform a major repair or alteration and hanger infrastructure investment.
• Brett and Christian continued regular monthly collaboration with Oliver Wyman.
• Christian met with Dan Vukelich/Association of Medical Device Reprocessors to discuss removing federal procurement barriers for remanufactured products (Apr. 13).
• Christian and Brett met multiple times with Government Accountability Office analysts re: implementation of federal relief programs (Apr. 28, June 3) and coordinated a meeting between PSP recipients and GAO researchers (June 22).
• Christian and Brett met with Chris Braun/Embry-Riddle re: aviation maintenance safety culture doctoral research (Apr. 30).
• Marshall took part in the semi-annual EASA EM.TEC meeting (May 4).
• Brett and Christian participated in an FAA Aerospace Workforce Roundtable discussion (May 19).
• Christian attended a DOT webinar on the Aviation Manufacturing Jobs Protection (AMJP) Program (May 26).
• Christian met with Drew Jacoby Lemos/Regional Airline Association (May 28).
• Brett participated in a meeting regarding aviation education opportunities for K-12 students in Georgia schools (June 4).
• Brett met with Nancy Hocking/JetBlue to discuss Gateway Career Development Programs (June 10).
• Brett spoke at an ILS Connect Conference on the Industry Associations Panel with AFRA, ASA and MARPA (June 23).
• Sarah attended an Aerospace Industries Association meeting on developing a new AIA/NAS industry standard (June 23).
• Sarah, Christian and Brett hosted an in-person meeting with EASA Executive Director Patrick Ky and EASA Washington, D.C. representatives Thomas Mickler and Ludovic Aron (June 30).
• Sarah made remarks honoring former FAA Associate Administrator Ali Bahrami at his retirement gathering (June 30).

Board Administrative

Directors with expiring terms indicated interest to continue service.

Ending Maintenance Manual Rule Enforcement Inconsistency

On July 9, President Biden issued an Executive Order (“Promoting Competition in the American Economy”) establishing a whole-of-government policy to address overconcentration, monopolization and unfair competition in the American economy. Agency heads are directed to consider and address the impact of regulations on industries under their jurisdiction.

In a July 30 letter to FAA Administrator Steve Dickson and Transportation Secretary Pete Buttigieg, ARSA Executive Vice President Christian A. Klein urged them to end FAA’s inconsistent enforcement of its maintenance manual (i.e., instructions for continued airworthiness or ICA) rules as part of the EO implementation plan.

14 CFR § 21.50(b) and its predecessors require design approval holders (DAH) to prepare information essential to continued airworthiness and “make [it] available” to persons required to comply with the terms of those instructions. Owners are required to ensure the information is followed; certain maintenance providers are required to possess and/or perform maintenance in accordance with it.

Notwithstanding the clear language and safety intent of § 21.50(b) and predecessor requirements, some DAH’s have refused to make ICA available and the FAA fails to enforce these obligations. However, the agency has vigilantly enforced the requirement that those performing maintenance possess and follow the manufacturer’s instructions (see §§ 43.13, 145.51 and 145.109).

“By allowing DAHs to withhold regulatorily-required information from potential competitors (whether through outright denial, licensing schemes, or economically impractical prices), the FAA is complicit in extending the government-induced monopoly on required replacement parts and limiting competition in maintenance services,” Klein said.

The victims are not only repair stations (the majority of which are small and medium-size entities), but also the general and commercial operators (and their passengers and customers) who rely on repair stations and independent mechanics to keep aircraft airworthy. Given that some of the offenders are foreign DAHs, FAA’s enforcement policy also disadvantages U.S. companies seeking to compete internationally.”

ARSA has fought for decades to improve access to maintenance data (a detailed history of its work over the past 20 years is available on the ICA issue page). Given the FAA’s lack of action, the association is raising the visibility of the issue among senior administration officials and members of Congress. ARSA members wishing to become involved in these activities should contact the association.

To read ARSA’s letter, click here.

ICA Efforts

FAA to Restart Global Leadership Meeting

On July 20, the FAA announced plans to host its 8th Annual Global Leadership Meeting in Washington, D.C. on Sept. 22-23. The event will have both in-person and online attendance options and focus on “Restart and Recovery.”

Agenda and speaker information has not yet been released. Review the content below for recaps of the 2017 and 2019 meetings and click here to register for this year’s event.

To see ARSA’s coverage of pass Global Leadership Meetings, visit arsa.org/global-leadership-meeting.

Unpacking AD Authority

On July 2, ARSA requested clarification of the FAA’s authority to issue an Airworthiness Directive, questioning the April 22 posting of an AD against certain Uninsured United Parachute Technologies, LLC Parachutes. It followed up on July 23 after the agency’s initial response was unsatisfactory.

According to 14 CFR § 39.3: “FAA’s airworthiness directives are legally enforceable rules that apply to the following products: aircraft, aircraft engines, propellers, and appliances.” The association’s letter reviewed the relevant definitions in § 1.1 against this applicability, concluding a parachute could not be included under the definition of an aircraft, aircraft engine, propeller, or appliance.

“Considering the fact part 39 does not include parachutes in its applicability, please explain the FAA’s authority to issue the subject AD,” the letter requested.

To read the full letter, click here and see this month’s “Legal Brief” for reflections on the continuing effort.

Learn more about ADs…

ARSA Training: Airworthiness Directives

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.

Layman Lawyer – Unpacking the Rules

By Brett Levanto, Vice President of Operations

ARSA’s value is the expertise of its management firm, which allows members to tap into decades of legal experience reading laws, commenting on rules, creating documents that establish compliance and drafting guidance for aviation safety agencies.

Recognizing that non-lawyers are the ones that need to understand and apply those legal requirements has forced me to become a dilettante lawyer. Success in aviation safety depends on attention to detail, curiosity, and willingness to press for the right answer – areas where ARSA excels and that I must constantly enhance.

For the sake of that growth, I decided to take on the FAA directly by questioning its ability to issue an AD against a parachute. The now-ongoing exchange is not unlike what members experience with local inspectors – you may or may not obtain the right answer, so you keep asking.

Follow the exchange:

(1) Initial Inquiry to the FAA, July 2:

On April 22, the FAA issued an Airworthiness Directive (AD) for certain Uninsured United Parachute Technologies, LLC Parachutes, which became effective on May 7. This letter seeks more information regarding the agency’s authority to mandate the action required.

According to 14 CFR § 39.3, “FAA’s airworthiness directives are legally enforceable rules that apply to the following products: aircraft, aircraft engines, propellers, and appliances.”

It seems that determining applicability of 14 CFR part 39 depends upon the general definitions set forth in § 1.1 for those named items. Section 1.1 states—

Aircraft means a device that is used or intended to be used for flight in the air.

Aircraft engine means an engine that is used or intended to be used for propelling aircraft. It includes turbosuperchargers, appurtenances, and accessories necessary for its functioning, but does not include propellers.

Appliance means any instrument, mechanism, equipment, part, apparatus, appurtenance, or accessory, including communications equipment, that is used or intended to be used in operating or controlling an aircraft in flight, is installed in or attached to the aircraft, and is not part of an airframe, engine, or propeller.

Propeller means a device for propelling an aircraft that has blades on an engine-driven shaft and that, when rotated, produces by its action on the air, a thrust approximately perpendicular to its plane of rotation. It includes control components normally supplied by its manufacturer, but does not include main and auxiliary rotors or rotating airfoils of engines.

Parachute means a device used or intended to be used to retard the fall of a body or object through the air.

In addition to the definitions in § 1.1, neither § 91.307 or part 105 classify a parachute as a product to which part 39 is applicable. Though § 105.3 explains “[a]pproved parachute means a parachute manufactured under a type certificate or a Technical Standard Order,” the applicability of part 39 does not include all articles for which a TC or TSO exists, only those that fit the definition of appliance from § 1.1.

Considering the fact part 39 does not include parachutes in its applicability, please explain the FAA’s authority to issue the subject AD.

(2) Initial FAA Response, July 6:

In your letter you asked whether or not the FAA has the authority to issue an airworthiness directive (AD) for a parachute. You also correctly identified that 14 CFR Part 39 section 39.3 states that AD’s can be issued for appliances. Parachutes are defined as appliances in Title 49 United States Code (U.S.C.) section 40102, thus granting the FAA the authority to issue an AD for a parachute.

49 U.S.C. § 40102 – U.S. Code – Unannotated Title 49. Transportation § 40102. Definitions

(11) “appliance” means an instrument, equipment, apparatus, a part, an appurtenance, or an accessory used, capable of being used, or intended to be used, in operating or controlling aircraft in flight, including a parachute, communication equipment, and another mechanism installed in or attached to aircraft during flight, and not a part of an aircraft, aircraft engine, or propeller. [Emphasis added]

Please confirm that this addresses your inquiry.

(3) First follow up to FAA, July 23:

Your response to the July 2 inquiry focused on the inclusion of “parachute” as an example in the statutory definition of “appliance.” You failed to consider the applicable prerequisites in both that definition and also 14 CFR § 1.1, which require the item—

(1) Be used, capable of being used, or intended to be used in operating or controlling aircraft in flight.
(2) Be installed in or attached to aircraft during flight.
(3) Not be a part of an aircraft, aircraft engine, or propeller.

Parachutes utilized by the Cirrus Airframe Parachute System (CAPS) may meet those requirements. However, supplementary information in the Federal Register for the subject AD noted “the affected parachutes are UPT Vector 3 SE containers.” According to the UPT website, the Vector 3 is a line of “skydiving harness/container systems.”

Since the UPT Vector 3 SE parachute is not installed in or attached to an aircraft nor is it used, capable of being used or intended to be used in operating or controlling an aircraft in flight, please explain how it meets either the statutory or regulatory definition of “appliance.”

To get to this point – not the end, there’s work ahead – one must understand that regulatory “interpretation” is like a slalom course—you need to be on the right mountain and hit every gate or you will be eliminated:

(1) In the parachute case an AD was issued against an item that I knew wasn’t a “product,” and therefore an oddity. In a repair station, rules challenges can emerge from a wide range of actions including new capabilities, facility changes, or an inspector’s bad day.

(2) Before even raising the issue to Executive Director Sarah MacLeod, I read the rules. When I remained stymied, I asked for guidance, being sure to reference (and hyperlink) every section of the CFR consulted. Next time, both Sarah and I will remember that the first place you always look is the law, meaning the statute upon which the softer law, i.e., the regulations, is based.

(3) With help, the issue was cut to the most basic question (“not asking the right question” is a key failing of many laymen and lawyers alike). Drafts were worked and reworked until only the essential points remained (the entire exchange so far is shorter than a usual “Legal Brief” but took hours of concentrated effort and several exchanges with “real” lawyers who do not believe they should be paid by the word).

(4) Don’t give in or up. The first response from the agency was wrong and should not be allowed to stand. Value is obtained only by continuing until the answer is right. Let’s see if the next round brings about a better analysis.

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ARSA on the Hill

Improving FAA Transparency, Due Process

By Christian A. Klein, Executive Vice President

Sen. Jim Inhofe (R-Okla.) introduced the Promoting the Launch of Aviation’s Next Era (PLANE) Act of 2021 (S. 2453) on July 22.  It includes numerous ARSA-championed provisions to enhance legal protections for certificate holders and improve FAA transparency.

• Section 104 of the bill was proposed by ARSA in response to FAA’s inability to handle petitions for rulemaking and exemptions in an open and timely manner. FAA would be forced to consider the number of certificate holders directly impacted by the proposed rulemaking, the impact on small business, and the number of organizations requesting the rulemaking. The agency would also be required to designate a single responsible employee to manage each petition, to grant or deny the petition within 30 days and to provide a clear timeline for action. Regular reports to Congress on the status of petitions would enhance oversight of the process.
• Section 105 requires FAA to conclude investigations and decide on whether to initiate an enforcement action within two years of a complaint filing or issuance of an order of investigation. ARSA wishes to address the problem of “stale” letters of investigation (those that seem to linger forever with no action or follow-up from the FAA).
• Section 601 would address FAA’s arbitrary decision to prevent repair stations from voluntarily surrendering their certificates. In its November 2014 updates to 14 CFR part 145, the FAA took the unprecedented step of subjecting surrendered repair station certificates to “acceptance for cancellation” (see, § 145.55). In 2015, ARSA led an effort calling for the removal of the requirement, since it is unique among aviation certificates, runs counter to the interest of aviation safety and increases regulatory administrative burden without any agency explanation as to how its “acceptance” will be communicated. The initial petition was denied by the FAA and a subsequent request for reconsideration remains unaddressed more than five years after it was filed (which underscores the need for Sec. 104).
• Section 301 would protect FAA designees from civil liability when carrying out their duties, except in cases of intentional or fraudulent misconduct.

The outlook for the legislation is uncertain. Major FAA bills were enacted in each of the last two Congresses and with lawmakers focused on surface transportation and Biden administration priorities, there’s minimal bandwidth for aviation policy.  But whether or not the PLANE Act is enacted in this Congress, it’s an excellent rallying point for industry stakeholders concerned about FAA’s arbitrary conduct. The more support the PLANE Act gets now, the more likely it is to be included in the next FAA reauthorization bill, which will be debated in 2023.

Please visit ARSA’s Legislative Action Center (sponsored by Aircraft Electric Motors) to urge your senators to cosponsor and support the PLANE Act.

This month Sen. Inhofe also introduced the Hangars Accelerate National Growth And Regional Stability (HANGARS) Act (S. 2459). The bill would provide $1 billion to fund hangar construction at smaller airports and $100 million for hangars at larger, primary airports.

Advanced Air Mobility Bill Advances in House

On July 28, the House Transportation & Infrastructure Committee approved the Advanced Air Mobility Coordinating and Leadership Act (H.R. 1339), which would establish an advanced air mobility (AAM) interagency working group at the U.S. Department of Transportation comprised of federal departments and agencies, the public sector, and key stakeholders (including maintainers) to evaluate, plan, and coordinate efforts to help advance U.S. leadership in the emerging AAM industry.

Lawmakers Explore Aviation Workforce Diversity

The House Aviation Subcommittee held a hearing July 20 to discuss enhancing diversity in the aviation workforce.

The witnesses were (click a name to download their written testimony):

• Rebecca Lutte, an associate professor at the University of Nebraska at Omaha Aviation Institute
• Claudia Zapata-Cardone, executive director of community relations and outreach for the Latino Pilots Association
• Icema Gibbs, vice president of corporate social responsibility and diversity, equity and inclusion at JetBlue Airways
• Joel Webley, chairman of the Organization of Black Aerospace Professionals
• Kyle Kaiser, president of VIPER Transitions (and 2021 ARSA Annual Conference speaker)

According to Lutte, women make up less than 20 percent of the workforce in most aviation occupations. In the two types of jobs where the worker shortage is most acute – maintenance technicians and airline pilots – they represent just 2.5 percent and 4.6 percent of the workforce, statistics that have changed very little over the past 15 years. 

Lutte suggested that improving the quality of data about women and other underrepresented groups in aviation would help. “What gets measured gets done,” Lutte said. She also discussed barriers to women entering aviation jobs, including lack of outreach, low numbers of women in leadership positions, a lack of commitment to diversity and inclusion from the C-suite, costs of obtaining education, balancing family and professional responsibilities and workplace gender bias and sexual harassment. 

Gibbs discussed both gender and racial diversity in aerospace. While Black Americas make up 13.4 percent of the U.S. population, she said only 3.4 percent of all airline pilots are African American. The data she cited suggest the maintenance sector is doing a better job than other parts of the industry in recruiting minorities. According to Gibbs, 10.8 percent of technicians are Black and 23 percent are Hispanic or Latinx.

Addressing the diversity gap requires a two-pronged strategy, Gibbs said: increasing representation and building awareness of aviation careers. She discussed JetBlue’s diversity strategy, which includes improving diversity in leadership positions by helping frontline crewmembers transition from operational to corporate services roles and to help internal crewmembers interested in transition to maintenance careers.

Webley’s testimony described OBAP’s efforts to expose young people to aerospace careers as early as possible through school visits and student mentoring, with a particular emphasis on career tracks to help illustrate pathways to success. OBAP’s Aerospace Career Education (ACE) Academy provides middle and high school youth with exposure to opportunities in aerospace through week-long summer academies.

Kaiser told the subcommittee that improving veteran career transition would address multiple societal problems at once.  In addition to increasing the available talent pool for the aerospace sector, helping veterans find civilian jobs improves their perceptions of self-worth, which in turn reduces the risk that they will engage in harmful behaviors such as drug and alcohol abuse or suicide (according to Kaiser, 16 to 22 veterans die by their own hand each day).

Witness testimony and video of the hearing, which includes statement by and questions from members of the subcommittee is available here.

As ARSA continues to address the maintenance workforce crisis, the team is anxious to hear from members about initiatives they are pursuing to improve diversity in their companies. Let ARSA know what your organization is doing.

Recording of the hearing live stream…

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Training

Make ARSA Training Work

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.

The Symposium

The full day of content recorded during the third day of ARSA’s 2021 Annual Conference. Each item below on the day’s agenda can be found at the points noted in the recording:

8:30 a.m. | Welcome & Introductory Remarks (Recording at 0:02:00)

ARSA is the voice of the global aviation maintenance industry. Find out how the association is advocating for your interests with legislators, regulators and the media and how you can help advance the industry’s collective interests.
Sarah MacLeod, Executive Director, ARSA
Christian A. Klein, Executive Vice President, ARSA

8:30 a.m. | Keynote Address (Recording at 0:14:00)

A. Bradly Mims, Deputy Administrator, FAA

9:15 a.m. | Opening Salvo—Conversations with the Regulators (Recording at 0:49:30)

International agencies will provide updates on the regulations, policies and procedures governing the maintenance industry.
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

2:00 p.m. | Careers in Crisis (Recording at 6:29:30)

While some believe the international business impacts of the pandemic – including furloughs and other workforce reductions – staved off a long-brewing human capital crisis, the opposite is true. Learn about how businesses can continue to focus on their people regardless of forces beyond their control.
Kyle Kaiser, President, Veteran Internships Providing Employment Readiness (VIPER)
April Keister, Quality Engineer, Barnes Aerospace

4:00 p.m. | What Have We Learned? (Recording at 5:28:32)

Regardless of our best hopes, there will be no “return to normal” from the pandemic. That isn’t necessarily a bad thing, if we make good on the lessons learned from a year of ongoing disruption.
P.J. Anson, CEO, STS Aviation Group
David Kelly, Vice President of Strategy & Marketing, HAECO Americas
William Morris, General Counsel & Executive Vice President, Wencor Group
Brian Prentice, Partner, Oliver Wyman

Click here to access the symposium on-demand.

Click here to review all content available from the Conference.

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.

Parts Documentation Under the U.S.-EU MAG

To see all of ARSA’s work on the MAG, visit arsa.org/mag.

For years, ARSA lead an industry wide effort to “smooth” implementation of parts documentation issues in the U.S.-EU Maintenance Annex Guidance. Take advantage of that experience and learn to utilize the association’s Form E100 as a method of compliance.

Recorded: November 2017
Description: This session provides an overview of the documentation requirements that United States repair stations with European Union Aviation Safety Agency part 145 approvals must follow when performing maintenance on EU-registered aircraft and components to be installed thereon—that is, when a “dual release” is issued for the work performed. The session was developed in response to parts documentation issues that emerged in change 5 to the MAG, which was released in September 2015. The issues persist in subsequent updates.
Instructors: Marshall S. Filler & Sarah MacLeod

Click here to register and get unlimited access for 90 days.

NOTE: Registration for this session is open to any interested participant. However, ARSA Form E100 is available only to association member organizations or as part of the RSQM Compilation.

Registration for an ARSA-provided training includes:

• Access to the on-demand, recording for unlimited viewing over 90 days.
• 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.

Aircraft Parts – Purchase, Receiving and Sale

Get immediate access to Executive Director Sarah MacLeod’s three-session series on the regulations and other requirements affecting the purchase, stocking and sale of aircraft parts.

Regulations Impacting the Purchase of Aircraft Parts
The course reviews the civil aviation regulations in 14 CFR that impact the purchase of civil aviation parts, as well as other requirements that should be considered when making such purchases.
Click here to register and get 90-days of access to the recording.

Regulations Impacting the Receiving, Inspection and Stocking of Aircraft Parts
The course reviews the civil aviation regulations in 14 CFR that impact the receiving, inspecting and stocking of civil aviation articles for maintenance purposes, as well as other requirements that should be considered.
Click here to register and get 90-days of access to the recording.

Regulations Impacting the Sale of Aircraft Parts
The course reviews the civil aviation regulations in 14 CFR that impact the sale of civil aviation articles, as well as other requirements that should be considered when selling parts.
Click here to register and get 90-days of access to the recording.

Interested in all three? Click here to purchase them together and save.

Registration for an ARSA-provided training includes:

• Access to the on-demand, recording for unlimited viewing over 90 days.
• 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.

Regulatory Compliance Training

Test your knowledge of 14 CFR §§ 11.33, tracking rulemaking activities.

Click here to download the training sheet.

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Membership

How’s Marshall?

On July 8, ARSA Managing Director & General Counsel Marshall S. Filler underwent successful heart surgery. His ongoing recovery has included the usual challenges associated with major surgery. As he explained to members in the June 2021 hotline newsletter, the operation is an opportunity to transition more completely into retirement while still maintaining connection to ARSA’s work.

The surgery included installation of a “bovine replacement” for Filler’s aortic valve, which was replaced by a mechanic valve in a subsequent procedure. During his recuperation, Executive Director Sarah MacLeod has been keeping well wishers updated and has begun a healthy debate about how the maintenance community should define his procedure.

ARSA’s members and some other colleagues have already begun to weigh in. See their analysis of maintenance vs. alteration (and good wishes) in the de-identified responses below and add your own by completing the survey at the bottom of this page:

What do you think?

To share your good wishes and regulatory analysis, visit: www.surveymonkey.com/r/heart-maintenance.

Quick Question – Recovery?

Industry data and aviation trends indicate business is recovering from the global pandemic. Answer this month’s “quick question” to provide ARSA insight into the factors impacting your business’ ability to keep pace.

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

Note: The survey below is in an embedded window and you may need to scroll down within the window to see/click the “Submit” button.

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 July:

New Members

FJ Turbine Power, Inc., R03
Great American Barnstormers, Inc. dba Mapoles Aviation, R01

Renewing Members

AAR Corp., Corp, 1985
Aero Design Services, Inc., Affil, 2000
Aerotron AirPower, Inc. dba Fokker Aerotron, R04, 1990
AllFlight Corporation, R03, 2011
Bemidji Aviation Services, Inc., R03, 2017
Cross-Check Aviation, R02, 2003
DART Aerospace, R02, 2019
E.U.A. Air Support, Inc., R01, 2003
Empire Airlines, Inc. d/b/a Empire Aerospace, R03, 2002
Eagle Creek Aviation Services, R04, 2016
EXTEX Engineered Products-A Kaman Company, Assoc, 2002
Fleet Support Services, Inc., R01, 2013
Helicopter Services of Nevada LLC, R02, 2005
Hot Section Technologies, Inc. , R01, 2017
MT Texas, LLC, R03, 1990
Nampa Valley Helicopters, Inc., R02, 1993
Ozark Aeroworks, LLC , R02, 2015
Rotorcraft Repair & Manufacturing, LLC, R01, 2019
Sunshine Aero Industries, Inc., R01, 2003
Texas Air Services, Inc., R02, 2003
Turbine Weld Industries, LLc, R03, 2004
Unipak Aviation, LLC, R02, 2003

A Member Asked…

ARSA received two similar questions this month about the U.S. and U.K.’s evolving bilateral relationship and whether U.S. repair stations will be required to obtain a separate certificate post-2022 to work on products and articles under the U.K. CAA’s regulatory control.

Q: According to the maintenance annex guidance (MAG) and the maintenance implementation procedures (MIP) between the U.S. and the U.K., the U.K. CAA shall not issue its own (U.K.) approval for U.S. based maintenance organizations. Section A, 1.4 of the MAG has a deadline of January 1, 2023 through which the CAA shall rely on EASA certificates for U.S. based 145’s. So, after the deadline, is the first statement no longer valid and we would need to apply for a U.K. certification?

A: While ARSA doesn’t have a crystal ball, the answer is that during ARSA’s 2021 Conference (available on demand), U.K. CAA representatives suggested the bilateral would continue “as is” since it more than less reflects prior agreements and, the U.K. CAA, like Canada, does not have the resources to perform its own audits of “foreign” repair stations. Since it is adopting the EASA regulatory model, accepting an EASA part 145 certificate from a U.S. facility would be an extremely smart strategy that provides quality assurance and – in the next three to seven years – SMS, without the U.K. CAA having to do anything but verify paperwork.

ARSA will, of course, attempt to ensure there is no disruption of “approvals” and if the U.K. CAA does determine it must issue its own certificates, the process is implemented in a timely and cohesive manner.

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

Resources for Dealing with the Government

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.

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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