2022 – Edition 11 – December 2

Table of Contents

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

The President’s Desk
2023 Annual Conference
ARSA Works
Creating Careers
Legal Briefs
ARSA on the Hill
Aviation Life Calendar
Training
Membership
Resources
Industry Calendar

The President’s Desk

Taking the Time

I didn’t expect an aviation career would mean spending so much time in Washington, D.C., but quickly saw that government decisions impact my company on a daily basis, and that our success would depend upon influencing laws and policy. Fortunately, First Aviation’s CEO understood this too and empowered me to go forth and advocate.

My government engagement began around access to maintenance data, particularly in the context of Department of Defense (DOD) contracts. This led to myriad meetings at FAA, DOD, the Federal Trade Commission, the Small Business Administration, the Department of Commerce, and other agencies. The time was not limited to the executive branch; it was also spent building relationships with congressional staff and using the courts to try to compel equitable enforcement of FAA rules.

Even with a background in engineering and business (not law or government), I’ve learned that with the right knowledge, resources, allies, and a lot of patience and perseverance, you can make a difference. Here are some lessons from my experience:

Don’t be intimidated. The government isn’t a single-minded entity; it’s a bunch of people trying to do their jobs. They don’t know what they don’t know and don’t understand the unintended consequences of their decisions. Each of us ARSA members has unique insight about how government policy affects the day-to-day operations of our businesses. As I’ve requested meetings with senior officials, I’ve been pleasantly surprised by how accessible many are and their willingness to listen. 

Take advantage of the resources you already have. I appreciate all the support I’ve received from ARSA over the years, particularly in identifying the most important officials with whom to connect and in shaping my messages. ARSA Executive Director Sarah MacLeod was an excellent resource in preparing for our company’s recent meeting with FAA leadership. It was also through my participation in ARSA’s annual Executive-to-Executive meetings that I developed relationships at the Department of Commerce that led to an important personal opportunity: my appointment to the International Trade Advisory Committee for Aerospace Equipment (ITAC 1). Whether you’re trying to engage with the FAA, some other agency, or Congress, ARSA can help.

Make common cause. It’s a given that during ARSA’s Legislative Day, Executive Vice President Christian Klein will remind us that the policy process is like a big machine with lots of cogs and gears; if moved in the right direction, the machine works.  Having allies can help you move more cogs and gears.  It’s particularly compelling when competitors put differences aside to resolve a policy problem. Christian proved that concept during the last FAA reauthorization when leading the diverse coalition of more than 40 organizations (including labor organizations) to create the new Sec. 625 maintenance technician grant program. Working with allies (including other trade associations and companies) to shape and share a common objective expands the scope and impact. In this respect you can also help ARSA be more effective by urging other associations in which your company participates to support ARSA’s work.

Don’t make it all about you. You may encounter issues that are truly unique to your company, but generally you’re more effective when you show the solution has broader impact. I can explain in detail how our company is affected by FAA’s inconsistent enforcement of maintenance data rules, but it makes my case more compelling when I can cite ARSA survey results, economic data, and industry employment numbers to illustrate the industry-wide impact.

Buy-in from senior leaders matters. Effective engagement requires time and money (e.g., for travel for meetings with government officials and industry allies). Success is dependent upon your company’s senior leaders understanding of how profitability is directly affected by government action, and how government can be directly impacted by your involvement.  ARSA’s team is available to meet with member companies to brief on government affairs priorities and best practices for engagement with regulators.

One part of the government can impact others. Don’t think about the relationships you develop in a vacuum. Always consider how the various parts of the government fit together and their roles vis-à-vis one another. For example, relationships you build on Capitol Hill can influence FAA through congressional oversight, meetings with White House officials can prompt action in all parts of the executive branch, and relationships you develop with local government officials can be leveraged to influence congressional offices.

Engagement benefits you, your company, and your industry. With myriad regulatory challenges facing the industry and FAA reauthorization looming, there’s never been a better or more important time to take the time for advocacy.

Josh Krotec 2023 ARSA president | First Aviation Services, Inc. senior vice president

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2023 Annual Conference

Registration Open

	Event Information Registration
March 14-17, 2023 Arlington, Virginia and Washington, D.C. with Livestream Options for Online Participants

Experience the maintenance community’s premier event. Join ARSA members and invited guests from around the world to engage governments, network with peers and improve the state of the aviation world. In-person attendees may select a “Conference Ambassador” to receive free livestream access back at the fixed location.

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ARSA Works

OIRA Building Next Open Government Action Plan

On Nov. 17, ARSA Vice President of Operations Brett Levanto joined an engagement session hosted by the U.S. Office of Information and Regulatory Affairs (OIRA) soliciting input on improving participation in the regulatory process.

This session is part of the American federal government’s ongoing initiative to “open” government to better public engagement and participation. OIRA gathered input as part of its drafting a new Open Government National Action Plan, which the Biden administration intends to focus on building a more equitable, transparent, and accountable government. The plan will be the sixth since the program was first established in 2009 – each plan covers a two-year period, the current one ends in 2024 – and will include commitments related to public engagement in the work of government.

Speaking participants covered a broad range of regulated entities, including stakeholders from healthcare and small business interests as well as thinktanks and nonprofits focused on improving government openness or training the public in regulatory comprehension. General feedback considered regulatory engagement strategy, particularly encouraging agency to find new ways to connect with the segments of the public most likely to be impacted by a rulemaking action and do so as early in the process as possible. Specific notes included instruction on the use of resources like regulations.gov to find rulemaking documents and submit comments.

Two participants made points familiar to ARSA members dealing with the FAA:

(1) Rulemaking matters, but so does enforcement…perhaps more so. It does not matter what the Code of Federal Regulations says if the government doesn’t reasonably execute on its plain language.

(2) Agencies don’t regularly seem interested in collecting public comment but see it as a “necessary evil.” The procedures or mechanics of collecting feedback and input depend on the regulator’s capacity for action.

The discussion was held under the Chatham House Rule, which protects open exchange by preventing direct quotation or identification of speakers but allows participants to share general themes or points shared by participants. Interestingly, one speaker questioned the practice by calling it ironic to host a “closed meeting” in pursuit of open government.

ARSA members interested in learning more about the effort can go to open.usa.gov and should contact Levanto with questions or ideas.

UK Approval Applications Open in January

On Nov. 15, the FAA hosted a webinar on the Maintenance Implementation Procedures (MIP) and Maintenance Agreement Guidance (MAG) established between the United Kingdom (UK) and United States (US). The agency will begin accepting applications for UK approval of US-based repair stations on Jan. 1, 2023; approval must be held to perform work subject to British rules by the beginning of 2025.

During the webinar, FAA MIP Coordinator Paul Cloutier quickly reviewed the status of the new MIP and MAG. Cloutier explained the Special Conditions outlined in the MAG are “very similar” to those between the United States and European Union, with some “improvements” based on experience between the regulators. Once the new agreements take effect on Jan. 1, 2023, FSDOs will oversee applications by and surveillance of repair stations wishing to obtain UK certification. The MIP allows for a two-year transition period to provide the FAA time to process the expected influx of applications.

Repair stations holding EASA approval under the U.S.-EU bilateral agreement may continue performing work on UK aircraft and articles until Dec. 31, 2024. A UK Maintenance Organisation Approval will be required after New Year’s 2025.

After the overview, Cloutier was joined for Q&A by UK Head of Airworthiness Policy and Rulemaking Neil Williams (a regular participant in ARSA’s Annual Conference). The pair handled questions regarding certification, quality system integration, manual supplements, and maintenance releases. Of particular interest to ARSA members – and topics likely to recur in the association’s advocacy:

(1) The agencies have directed that repair stations cannot issue a so-called “triple release” on an FAA Form 8130-3 simultaneously showing compliance with FAA, EASA, and UK rules. When certificate/approval holders wish to authorize work for return to service under all three systems, they must issue separate dual releases: one under the UK-FAA bilateral and one under the EASA-US requirements. While an enterprising questioner confirmed these could be one document (e.g., printed on the front and back of a single piece of paper), the regulators insist upon duplicative paperwork.

(2) The Repair Station Manual Supplement required for UK approval must be separate from an EASA supplement. ARSA has long pushed to integrate manual content as closely as possible. Not only does such integration support regulatory compliance, it is a practical means to prevent human factors errors by technicians required to jump among and between various documents to find relevant procedures. Stay tuned for updates from the ARSA publications department.

(3) Applications must include a demonstration of need. Williams demurred when asked for specifics, citing interest against being overly proscriptive, but noted a customer letter or listing of orders would be sufficient.

(4) Sub-contractors need not hold CAA approval; they can be managed under existing repair station rules for contract maintenance in § 145.217.

(5) Similar to EASA requirements, the repair station must incorporate both product and procedural audits into its quality system. These audits can be performed together but must be clearly documented according to which elements are tested.

(6) Repair stations with upcoming renewals of their EASA approvals under the U.S.-EU bilateral should proceed on schedule with their European application to continue using that approval for work on UK aircraft and articles.

Repair stations seeking British approval may submit application to their local FSDOs using UK Form SRG 1783*. The fee associated with initial application is £900.

Reference Materials

To watch a recording of the Nov. 15 webinar, click here.

To download the PowerPoint presentation (with speaker notes), click here.

To download the MIP directly from ARSA’s servers, click here.

To download the FAA’s InFO directly from ARSA’s server, click here.

For updated access to documents from the agencies, visit the FAA’s Dynamic Regulatory System (drs.faa.gov), select “Other Documents” and then “International Publications” from the left-hand menu. The UK CAA also publishes documents on its bilateral agreements page.

Submit questions about the MIP/MAG to 9-awa-afs-intl-coordinator@faa.gov or call 858-999-7671.

*Appropriately, the independence of the United States was codified when the Treaty of Paris was signed in September 1783.

Klein Chronicles Workforce Initiatives for Purdue Symposium

On Nov. 8, ARSA Executive Vice President Christian Klein spoke at Purdue University’s inaugural National Aviation Symposium. Klein headlined a panel on national industry workforce demand, presenting on trends in technician employment in the United States.

The Symposium was hosted by Purdue’s School of Aviation and Transportation Technology to consider pilot and technician shortages. Invited participants represented stakeholders from across the aviation regulatory chain, including airlines, manufacturers, maintenance providers, and government agencies as well as trade associations, unions, and the media.

Klein’s presentation described the challenges facing the maintenance industry in terms of attracting talent. Not only is the industry high-regulated, but its professionals also take on a relatively high level of personal risk in performance of duties while experiencing little positive exposure. As a result of cultural and educational changes, the typical entrant to the overall workforce has less technical acumen and faces considerable training lead time before being a productive member of the workforce. As a result, current employers can only rely on existing personnel, who are aging towards retirement and tend to be less diverse than the larger society.

To build the talent pipeline, Klein underscored the importance of engaging the next generation. He called out the report of the Youth Access to American Jobs in Aviation Task Force and the upstart nonprofit Choose Aerospace. Sticking to the usual ARSA playbook, Klein also described methods to remove regulatory barriers while coordinating industry and academia involvement to open new opportunities for trainees.

Klein closed by explaining these opportunities can be marketed through broader industry visibility and emphasis on career pathways. These pathways should build off of stackable training credentials – so specialists can enter careers and grow into more-highly certificated personnel – and target previously unreached groups by removing structural burdens within the hiring process.

References

For more information on specific elements of Klein’s presentation, use the following links:

Aviation Workforce Grant Programs (Pilot/Technician)

Choose Aerospace

National Center for the Advancement of Aviation

Repairman Portability

The “new” 14 CFR part 147

The Youth Access to American Jobs in Aviation Task Force

To learn more about the Symposium, click here.

Final Documents/Your Two Cents

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

To view the list, click here.

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Creating Careers

Scaffolding for Career Building

By Brett Levanto, Vice President of Operations

The association often reports on its efforts to bolster aviation careers rather than the workforce. It’s intentional.

Of course, the “w word” does appear – purely for the sake of good diction some variety is needed – but the team focuses on what employment means for the people working in aerospace. Working in our industry is not a job, it’s a career. When both employers and individuals think in those terms, we are better positioned to understand how professionals enter the industry and evolve. Not only can a first job in aerospace take you anywhere, but the candidates for those positions can and should be found all over. In ARSA’s push to foster aviation careers, the association has been clear and consistent in two key messages to its members:

(1) Aviation employers must think expansively about the broader ecosystem of technical talent. From old-school repair shops to advanced manufacturing facilities, the demand for what we used to call “blue collar” technical employees is broader and more colorful than ever before. Aviation doesn’t pretend to be special; it is. That knowledge must be used to embrace the industry’s place in the larger world.

(2) Maintenance providers must be ready to learn from good examples across all these industries. Like the automotive training program showcased at the 2022 Annual Conference, there is something instructive in every attempt at building skills.

ARSA’s colleagues at the Aircraft Electronics Association provide such an example. The AEA Apprenticeship Program, launched in 2019, is a U.S. Department of Labor approved Competency-Based Occupational Framework (CBOF) for Registered Apprenticeship programs. The AEA website explains: “CBOFs are designed by industry subject matter experts and define the purpose of an occupation, the job functions that are carried out to fulfill that purpose, the competencies that enable the apprentice to execute those job functions well, and the performance criteria that define the specific knowledge, skills, and personal attributes associated with high performance in the workplace.”

AEA President Mike Adamson, who helped lead the program’s development, explained it was produced based on the standards in part 145 after reviewing guidance in ACs 145-9 and 145-10. The technical aspects of the program were designed with input from maintenance providers and manufacturers and are meant to offer a shell for each company to build out with specific procedures. When tailored to the procedures of a facility, it provides foundational knowledge and specific competencies for technicians and is a pathway to individual certification. (The FAA acknowledged that completion of the entire program would satisfy the “formal training” requirement for repairman eligibility in
§ 65.101(a)(5)(ii).)

“[The framework] could be many things,” Adamson said. “A small shop picks it up and picks things out of it to build qualifications for their employees. A larger shop could pick it up soup to nuts and install the whole program. It’s got … a lot of potential for different things depending on how you want to use it.”

That potential is ARSA’s point of focus for its members, both for organization-wide development and individual aspiration. For the business, the 13 job functions identified by AEA create a “scaffolding” on which a tailored personnel development program can be built, defining required knowledge and experience (§ 145.151), outlining training to ensure capability to perform tasks (§ 145.163), and organizing qualifications on employment summaries (§ 145.161(a)(4)). For individual technicians, frameworks like AEA’s can be roadmaps for personal growth and development; after meeting “level 1” qualifications, ambitious professionals can progress to more-advanced study.

With these kinds of structures – and the thinking that goes behind them – we build careers.

ARSA encourages its members to review programs like AEA’s, which can be found at aea.net/apprentice, and to share other examples of apprenticeship, career development, and personnel advancement programs with the association via arsa.org/contact.

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Legal Briefs

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

Layman Lawyer – Getting with the Programs

By Brett Levanto, Vice President of Operations

The never-really-complete Layman Lawyer series on the FAA’s Compliance Program leads to an important lesson in aviation: Safety and good business are built on professional relationships with the government.

ARSA provides both training and free member tools to help build that relationship. It requires continual and well-documented engagement and boils down to two points:

(1) Don’t limit your communications with the FAA to only when there is a problem.

(2) Put everything in writing!

All members should utilize the association’s resources for planning and logging regular communications with federal, state, and local government personnel.

It’s also necessary to recognize the programs made available by the agency to address disagreements when regular communication is insufficient. As part of a repair station’s larger mechanism for managing regulatory relationships, these avenues for dispute resolution are important options.

The first is the Consistency and Standardization Initiative (CSI). It’s noble in spirit. Formerly known as the too-businesslike “Customer Service Initiative,” the purpose of the CSI is to provide certificate holders a method to systemically address disagreements with local inspectors. For an agency that depends heavily on often-independent-minded individuals working in district and regional offices, the mechanism is an opportunity to enforce the reasonable expectation of clarity in decision-making.

It’s simple in principle. If a “stakeholder” disagrees with a decision from an FAA representative, the program provides a series of steps for the affected party to take the issue ”up the chain”. Along the way, the government promises the petitioner will get direct meetings and negotiation; one-on-one engagement between regulator and regulated to find common ground.

Equally simple (in theory) is the FAA’s Regulatory Consistency Communication Board (RCCB). Created on recommendation of the Consistency in Regulatory Interpretation Aviation Rulemaking Committee (CRI ARC), the RCCB provides “an avenue for internal and external stakeholders to raise issues of policy or regulatory inconsistency.” According to the timeframe described in Order 8000.70, the board will provide initial feedback – including an estimated time for resolution, if it is not already reached – within 45 days of submission.

These programs are not simple. They are painstaking. Those “stakeholders” can spend years waiting, responding, following up, waiting some more, clarifying confusion, and overcoming procedural hurdles. An ARSA member once spent six years pushing through the CSI program to solve a dispute over engineering approvals. ARSA’s 2017 RCCB submission regarding “100 percent replacement” during maintenance didn’t get a response until summer 2019…and the FAA’s letter basically said, “Good question!”

The imperfections of these programs do not equate to reasons for avoiding them. When confident in showing compliance, any person in aviation (a “stakeholder” in the magical parlance of the government) should utilize every avenue for taking that truth to the agency. Getting the right answer takes time, perseverance, and the will to reject all the wrong ones.

Size Matters

By Christian A. Klein, Executive Vice President

The “Legal Brief” series on FAA’s enforcement process continues this month. Recent columns have explored certificate actions, the process leading up to and following issuance of a Letter of Investigation (LOI), and self-advocacy in FAA investigations. This month’s column explores how the FAA assesses and adjudicates civil penalties administratively, the most common enforcement action.

When you are the target of a civil penalty action many things are at stake. Your company’s reputation and future business opportunities are certainly implicated (civil penalty actions stay on your FAA record for five years) and your money is on the line.

FAA’s statutory authority to assess and administratively adjudicate civil penalties is granted by Congress in 49 U.S.C. sec. 46301. The agency’s civil penalty rules are contained in 14 CFR §§ 13.16 and 13.18. The latter applies to an individual acting as a pilot, flight engineer, mechanic or repairman; the former applies to other “persons” (including businesses).

49 U.S.C. sec. 46301 establishes maximum per violation civil penalties based on whether the alleged violator is an individual, small business or other person (corporate entities). According to the FAA’s enforcement web site, the current maximums are generally $1,100 for individuals and small businesses and $27,500 for other persons. These amounts are periodically adjusted (i.e., increased) based on the cost of living.

49 U.S.C. sec. 46301(d)(8) sets forth the limits of the FAA’s statutory authority to assess and administratively adjudicate aggregate penalties (i.e., those involving multiple violations):

• $400,000 if committed by a person other than an individual or small business concern; or
• $50,000 if committed by an individual or small business concern.

The FAA can seek aggregate penalties above these amounts; however, it has no authority to adjudicate them administratively. For this reason, they are subject to a different (i.e., judicial) appeals process which will be covered in our next Legal Brief.

Per FAA Order 2150.3C, Chap. 9, in determining whether an entity is a small business, the agency uses the definition from the Small Business Act (15 U.S.C. Sec. 632) as interpreted by the Small Business Administration (SBA). A small business is a business entity:

(1) Organized for profit, with a place of business located in the United States, and which operates primarily within the United States, or which makes a significant contribution to the U.S. economy through payment of taxes or use of American products, materials or labor,
(2) That is independently owned and operated and is not dominant in its field of operation, and
(3) That meets the size standards specified by the SBA.

SBA establishes small business size standards based on the number of employees or average annual receipts and a company’s North American Industry Classification System (NAICS) category. When calculating employees or average annual receipts, SBA includes subsidiary and affiliated companies. In other words, even though your shop may look like a small business, if you are part of a family of companies or have a private equity investor that owns other companies, those affiliated entities will be included in your small business calculation.

Most aviation maintenance companies fall into one of the following four NAICS codes:

• 336411 – Aircraft Manufacturing, including “overhaul”
• 336412 – Aircraft Engine and Parts Manufacturing, including “overhaul”
• 336413 – Other Aircraft Parts and Auxiliary Equipment Manufacturing
• 488190 – Other Support Activities for Air Transportation

Companies classified as 336411 and 33641 are considered small businesses if they have fewer than 1,500 employees. The standard for 336413 is fewer than 1,250 employees. The standard for 488190 – the category into which most repair stations fall – is less than $35 million in annual revenues. Based on ARSA estimates that one employee, on average, is associated with each $125,000 in repair station revenues, a company with $35 million in revenues would have about 280 employees, considerably fewer than those companies considered small businesses in the other three categories (which are based on the number of employees and not revenue). In the past, ARSA has proposed raising the threshold for category 488190; unfortunately, the idea has not gotten any traction to date.

The FAA further divides small businesses into three additional categories for purposes of determining sanctions. Generally, the larger the company the higher the proposed penalty for the same or similar violations because the ability to pay must be considered as set forth in the statute.  Order 2150.3C identifies the categories as follows:

In calculating penalties, the FAA also looks at the severity of the violation. Order 2150.3C contains sanction guidance tables with common violations specific to various types of aviation businesses, including repair stations. For example, making an improper or incomplete entry in a maintenance record and failure to sign or complete a maintenance release are “Severity 1” (i.e., least severe). Performing maintenance improperly or having unauthorized personnel approve the work for return to service are more serious violations and are classified as “Severity 3”.

Now that you understand the monetary penalties potentially at stake in a civil penalty action, you will probably want to learn more about the appellate processes which will be covered in our next Legal Brief.

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ARSA on the Hill

Transpo Committee Leadership Changes

By Christian A. Klein, Executive Vice President

The 2022 congressional election dust is still settling with Democrats maintaining a narrow control of the Senate and Republicans winning a slim majority in the House of Representatives. While neither party will be able to advance more extreme agendas in the divided Congress, expect lots of “messaging votes” on controversial bills in both chambers. Democrats and Republicans will both be seeking to define themselves (and their opponents) in the lead-up to the 2024 elections.

If you’re an optimist, the divided Congress creates opportunities for collaboration in traditionally bipartisan policy areas, particularly aviation. In the House, Rep. Sam Graves (R-Mo.) will take the gavel of the House Transportation & Infrastructure (T&I) Committee and Rep. Garret Graves (R-La.) (no relation to Sam) is on track to become chairman of T&I’s aviation subcommittee.

With the retirement of current committee chairman Peter DeFazio (D-Ore.) at the end of the year, the race for the top Democrat slot on T&I will heat up in the weeks ahead. The two candidates are Rep. Rick Larsen (D-Wash.), the current aviation subcommittee chairman and Del. Eleanor Holmes Norton (D-D.C.), who heads the highways subcommittee.

In ARSA’s mind, Larsen is the clear choice. The current FAA authorization law (multi-year budget and policy blueprint) will expire at the end of next September and reauthorization is at the top of the T&I Committee’s 2023 agenda. Larsen has chaired the aviation subcommittee for several years and has deep knowledge about aviation policy. He has a record of working across the aisle and has been a leader on aviation workforce policy issues. He also represents an aviation-heavy district in Washington, so he has first-hand knowledge about how aviation impacts the local economy.

If Larsen’s bid is successful, there will be a new ranking member on the aviation subcommittee. Reps. Steve Cohen (D-Tenn.), Andre Carson (D-In.) and Sharice Davids (D-Kan.) are next in subcommittee seniority.

On the Senate side of Capitol Hill, while there may be some changes on the committee with jurisdiction over aviation, the faces will stay the same. Sen. Maria Cantwell (D-Wash.) will retain her chairmanship of the Senate Commerce, Science & Transportation (“Commerce”) Committee and Sen. Kyrsten Sinema (D-Ariz.) will keep the aviation subcommittee gavel. Sen. Ted Cruz (R-Texas) is set to take the full committee ranking member spot. Sen. Roger Wicker (R-Miss.), the current Commerce ranking member, is expected to take the top GOP spot on the Senate Armed Services Committee and may take over from Cruz as ranking member on the aviation subcommittee.

Once the leadership decisions are resolved and staffing decisions are made, the committees will roll up their sleeves and get to work on FAA reauthorization. ARSA is hopeful that given the experience of committee leaders the process will proceed apace and be complete by the Sept. 30 deadline. We’re looking forward to working with Congress, our members and ARSA allies to get the ball over the goal line.

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Aviation Life Calendar

Something exciting happens every day in an aviation career.

If you want to keep aviation in the forefront of career choices, celebrate success every day with these resources. Every one provides a positive view of the industry’s ability to make the impossible an everyday event by individuals from every walk of life, socio-economic level, race, creed, color, religion, orientation, and physical capability.

Check back regularly for updates.

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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.

To review sample syllabi of training session options from the firm – many of which have similar sessions available generically through ARSA training – click here to download a combined PDF. The syllabi include “Regulatory Comprehension for Maintenance,” “Public Aircraft,” “AD Compliance” and more. 

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.

Public Aircraft Series

ARSA’s three-part series on the regulations and guidance for public aircraft operation is ready for on-demand purchase. Purchase now and get 90 days access – unlimited viewing – to all three sessions. After completing the substantive presentation on the law and regulations and a review of FAA guidance pertaining to PAO, challenge your staff with 11 case studies designed to test comprehension and apply the rules and guidance to “ripped from the headlines” examples.

Description: This three-part series on the regulations and guidance for public aircraft operation will provide in-depth analysis and case-study review of various requirements. Sessions must be purchased together and viewed in order, completion of each pre-requisite – either via a live session or on-demand recording – is required for access to subsequent classes.
Instructor: Marshall S. Filler

Session 1 – The Law and Regulations
Session 2 – FAA Guidance
Session 3 – Case Study 

Entire Series On Demand – Available Anytime. Click here for package information.

Note: Public aircraft sessions must be viewed in order. Completion of each pre-requisite is required for access to subsequent classes.

Registration for an ARSA-provided training session includes:

• Access to the on-demand, recorded version of the webinar to be made available after the live session is complete (or at time of purchase, for on-demand classes).
• A copy of the presentation and all reference material with links to relevant resources and citations.
• Upon completion of the class as well as any test material, a completion certificate.

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

Regulatory Compliance Training

Test your knowledge of 14 CFR § 11.83, exemptions outside the United States.

Click here to download the training sheet.

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Membership

Change is Here…and Coming!

You are reading the first hotline delivered directly from arsa@arsa.org. Since Nov. 9, ARSA has been in full control of its periodical distribution. All members should check their inboxes for weekly Dispatch newsletters delivered on Nov. 9, 16, 23, and 30.

This delivery marks completion of a full monthly periodical cycle, which has already improved ARSA’s member contact list and simplified internal procedures. The team is finalizing details for new advertising sales and getting ready to expand its periodical offerings.

(1) Be alert to the delivery (or absence) of the two current ARSA newsletters:

ARSA first sent the Dispatch newsletter on Nov. 9 and has followed with a new edition every Wednesday.

the hotline will continue on the the first Friday of each month.

If you stop receiving these periodicals, contact ARSA immediately. The team is planning to add a new Daily Intelligence email produced by the association’s management firm to provide news, calendar, and regulatory updates every morning – stay tuned.

(2) Ensure your email systems have “marked safe” the @arsa.org email domain.

(3) Add arsa@arsa.org to your media or communications distribution list to ensure company’s news and updates are sent to the association.

(4) Check your budget and current advertising practices to make space for your company in ARSA’s newsletters or website (and encourage your suppliers to do so).

New Periodical Coming! Beginning in December, ARSA’s management firm is making its Daily Intelligence available to all primary member Contacts. The DI provides a news and regulatory snapshot that is perfect for quickly scanning, checking sources on important updates, and distributing to team members and colleagues. Stay tuned for more.

Quick Question – Conference Planning

	Event Information Registration
March 14-17, 2023 Arlington, Virginia and Washington, D.C. with Livestream Options for Online Participants

The repair station community’s premier substantive event returns; help ARSA’s team plan for the 2023 Annual Conference.

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

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

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 November:

New Members
Aircraft Accessories of Oklahoma, Inc., R03
Tunica Air Group, LLC dba FTair LLC, R02

Renewed Members
Aero Products Component Services, Inc., R03, 2019
Air Shunt Instruments, Inc., R02, 1999
Airborne Maintenance and Engineering Services, Inc., R06, 2010
Ammark Aerospace Group, LLC, R01, 2020
Austin Aerotech Repair Services Inc., R01, 2012
Bridger Aviation Repair LLC dba Bridger Aerospace, R03, 2019
Michael Daniel, EDU, 2020
Federal Aerospace Institute LLC, EDU, 2021
Fieldtech Avionics & Instruments, Inc., R04, 2016
Fire-Tec Aero Systems, LLC, R01, 2013
Gulf Aerospace, Inc., R02, 2005
Helicopter Accessory Service East Inc., R02, 2018
Helicopter Services, Inc., R01, 2019
JETTECH, L.L.C., R02, 2021
Linear Motion LLC, R02, 2017
MHIRJ Aviation ULC , R05, 2021
Miami Aircraft Structures, Inc., R02, 2003
Midwest Turbine Service, LLC, R01, 2015
Quality Aircraft Accessories, Inc., R01, 2021
Repairtech International, Inc., R03, 1992
Safran Nacelles Services Americas, LLC, R02, 2017
Southwind Aviation Supply, LLC, R02, 2008
VSE Aviation Services, Inc., R03, 2006

A Member Asked…

Q: My question is related to the release of component maintenance manual updates. Is there a grace period for a part 145 repair station to implement the change to an update of the maintenance manual, e.g., 30, 60, 90 days, or does the change become mandatory upon release?

A CMM update released this month requires an additional test for which we’d either need to purchase a particular tool or develop a tooling equivalency. We are not having any luck in finding anyone to make the tool and anticipate a 3-to-4-month lead time. What can we do?

A: What a great question. Some years ago, the FAA developed guidance for its inspectors on this issue, which all-in-all is pretty good. The guidance used by the agency during surveillance of a repair station’s is contained in 8900.1, Vol. 6, Ch. 14, Sec. 1, paragraph 6-2960 PROCEDURES.

Information on incorporating changes to maintenance instructions from the manufacturer starts on page 5 at paragraph A)3), which assumes the repair station has an agreement with the manufacturer to obtain current technical data, but no matter how the data is obtained, the important language is:

“When performing surveillance on a part 145 certificate holder, verify that the repair station has a procedure under § 145.211(c)(1)(v) for determining that the data required by §§ 43.13(a) and 145.109(d) is current, accurate, and complete. If the repair station has a contract with a provider for the documents listed in § 145.109(d), it should have instituted a system for ensuring currency and ability to conduct proper work with the new information.

1. The document/data should be reviewed for any necessary changes to:

• Housing,
• Facilities,
• Tools/tooling,
• Equipment (including test equipment),
• Materials,
• Technical training, and
• Routers/travelers.

2. If no changes are necessary, the new data should be implemented as soon as practicable.
3. If changes need to be implemented, they should be completed within a reasonable timeframe (e.g., 90 days after the receipt of the updated document or data). The implementation timeframe will depend on the complexity of the revision with respect to variables such as procurement of special test equipment, tooling, etc.”

Note that the repair station needs to reference the version of the CMM it is using until the new version could be complied with by accomplishing the new test with the new equipment, so be careful of contracts that require the “latest version” of the CMM.

I hope this answers your question without raising too many more!

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.

About ARSA PAC

ARSA’s Political Action Committee helps elect congressional candidates who share ARSA’s commitment to better regulation and a strong aviation maintenance sector.  But ARSA is prohibited from sending PAC information to members who haven’t opted in to receive it.

Careers in Aviation Maintenance

How do you share the industry’s story with the people who could be its future? Teach them about the great work done every day to keep the world in flight. (Even if we can’t recruit somebody, we sure can make them thankful for our work.) 

U.S./EU Maintenance Annex Guidance

See all of the association’s public updates since 2012 on the Maintenance Annex Guidance between the United States and European Union. The page focuses in particular on matters related to parts documentation issues arising since MAG Change 5 was issued in 2015.

The FAA Enforcement Process

There are several reasons the agency may open an enforcement investigative report (EIR). Complaints from former or current employees, routine surveillance of your operations or a problem from a customer are all examples of how an “investigation” starts.

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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