2023 – Edition 5 – June 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
ARSA Works
Legal Briefs
ARSA on the Hill
Conference Corner
Aviation Life Calendar
Training & Career Development 
Membership
Resources
Industry Calendar

The President’s Desk

Avoiding Cliffs

All eyes were on American lawmakers as they negotiated their way out of a debt ceiling crisis of their own making. As seems to be the case with every one of these legislative “cliffs” we face in the United States, a late deal averts disaster while pleasing almost nobody.

The approaching expiration of the FAA’s authorization won’t produce the same level of crisis – at least one short term extension would not be surprising and is definitely not without precedent. Regardless of the time taken to get to a final deal, ARSA members must support the association’s efforts to include high level policies into the new law.

To do this effectively takes a little effort in organizing your local ground game. Just like we do on Capitol Hill each March on Legislative Day, our responsibility is to continually engage with members of Congress and their staffers. Building relationships in the home states will put a face on the larger industry, show its impact in each state and congressional district, and make each of us into a resource for those who set the FAA’s direction.

Summer is the perfect time. The committees in charge of the reauthorization process have already held hearings in the Capitol and lawmakers will soon be back home for a long recess. Periods of inactivity in Washington make for important engagement opportunities across the country; representatives and senators want to be particularly active and visible around their constituencies during election cycles.

Here are a few different venues to consider in your own advocacy plans:

Facility visits give members of Congress and legislative staff an opportunity to see first-hand and up close what your company does, how it fits into the economy, and the aviation industry. It’s also an opportunity for lawmakers to meet employees (whose votes they want to win) and to show their commitment to the local business community.

Town halls or other local community events are a chance to initiate meaningful dialogue with politicians and staffers. Information on events scheduled or occurring in your area are available from the staff at district offices. You may also learn of an event through your local paper, newscast, or congressional office’s newsletter or website.

If you don’t know anything about your elected officials or need to know where to find them, start at arsa.org/congress. The directory and search functions will help you identify representatives and senators and find their websites (remember to check the locations of all your facilities as well as nearby districts in which you have employees).

Building and maintaining these relationships is part of running an aviation business. While ARSA pushes key initiatives at the top, we help make sense of those issues in our communities. It should be done constantly, but certainly we can be better than waiting until we see the cliff.

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

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ARSA Works

AMT Day 2023 – Celebrating Charlie

Charles Taylor

Charles Taylor, the Wright Brothers’ mechanic and father of aviation maintenance, was born on May 24, 1868. Now – 155 years later – we celebrate him with every safe arrival and continued commitment to good work.

In 2008, a congressional resolution dedicated the date in honor of Taylor, establishing National Aviation Maintenance Technician Day. While the “holiday” doesn’t get anyone out of work (there are no days off from aviation safety), it’s important to celebrate the commitment, integrity and skill of every aircraft mechanic and all those who support them – this is Taylor’s legacy and our shared responsibility.

Hopefully all ARSA members recognize May 24, 2023 and share with ARSA (contact Brett Levanto at brett.levanto@arsa.org). The association often highlights member celebrations via its various communications and is always looking for great examples.

No matter how you celebrate AMT Day, it’s a small bit of well-deserved recognition. Thank you for your hard work, dedication and support.

The world can’t fly without you.

AMT Day – Celebrating Charlie (and Each Other)...

GAO Workforce Report Makes Limited Use of Misleading Data

Click the report image to go to the information page.

On May 17, the U.S. Government Accountability Office (GAO) released a report on the “Current and Future Availability of Airline Pilots and Aircraft Mechanics.” The GAO’s analysis reads like a travelogue of pandemic era discussions among and between aviation stakeholders about the struggle to find technical talent necessary to meet demand.

The report divides its narrative between pilots and mechanics – which it acknowledges are only “one of several types of aviation maintenance workers” – by reviewing FAA certification standards, employment data, and salary/wage trends. It then chronicles efforts to bolster hiring pipelines (like pathway programs) and resources available to support such development (like the ARSA-supported workforce grant programs established by the 2018 FAA reauthorization law).

For maintenance employers, the report highlights key factors described to the GAO as limiting career development efforts. In addition to pay and working conditions, which factor into all employment decisions, companies employing technicians face fierce competition from other industries and the cultural pressures produced by “stigma” associated with technical careers.

In 2020, the GAO reported that government data needed improvement to support efforts to promote a robust, diverse aviation workforce (see arsa.org/gao-workforce). At the time, the review found that neither the government nor the business community could accurately assess the workforce, detect trends, or prepare for future needs. Despite covering more than 50 pages and recording numerous interviews, the authors of the new report admit their analysis relies on incomplete or misleading data.

“The total pool of mechanic certificates increased [from 2017 to 2022]; however, these data provide limited information about the supply of aircraft mechanics, as the number of certificate holders who have left the industry since 2017 is unknown,” the new report said. “Additionally, available data provide limited information on the extent of demand for aircraft mechanics.”

The problems associated with these limitations are exacerbated by the fact that mechanics form only a portion of the maintenance workforce. While the GAO does little to expand on this detail beyond its basic acknowledgement, the broad range of non-certificated personnel employable by repair stations means that FAA data on certificated persons provides only a glimpse of the larger community.

Despite this overarching limitation, the government’s auditors clearly recognize the larger problem. In the short podcast episode released with the report, GAO Director of Physical Infrastructure Issues Heather Krause explained: “Aviation is a critical component of the economy, so the viability of the workforce is a federal interest.”

To support that critical component of the economy, ARSA continues to press the government to accurately describe the various pathways through maintenance careers and improve policies for training and regulatory compliance while helping certificate holders understand the flexibilities of the personnel rules in part 145, subpart D.

For more information about the GAO report, including the companion podcast, 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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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.

Bilateral Due Process?

By Christian A. Klein, Executive Vice President 

Recent “Legal Briefs” have reviewed the process a certificate holder is due in FAA enforcement actions. The rules by which fines are imposed and certificates suspended or revoked provide opportunities to be heard and appeal to a higher authority within the FAA, the National Transportation Safety Board and, ultimately, U.S. federal courts.

Unfortunately, due process is a much murkier concept – and in some cases virtually nonexistent – when it comes to European Union Aviation Safety Agency (EASA) Part-145 approvals held by U.S. repair stations pursuant to the U.S.-EU bilateral aviation safety agreement (BASA) and related Maintenance Annex Guidance (MAG).

In theory, bilateral agreements are supposed to make life easier for certificate holders in both countries because they need only comply with the home country CAA’s rules and the Special Conditions. But, as has been discussed in past Legal Briefs, the agreements do not live up to expectations, making compliance more complicated and less certain for industry.

Sec. A-2 of the U.S./EU MAG provides for Sampling Inspection System (SIS) visits that allow one agency to confirm the other is implementing the BASA and MAG in accordance with its terms. SIS visits are audits of the CAA’s oversight, not of the repair station or approved maintenance organization. However, there is still considerable risk when the FAA and EASA both come knocking. Sec. A-2.2.7.2 of the MAG states the EASA Flight Standards designated focal point,

shall take action on all EASA Visit Report AMO Level 1 findings raised following the visit … Action shall be taken directly with the affected organization. This may involve removing the organization from the EASA list of approved organizations.

As described in sec. A-2.4.6.3, a Level 1 finding is “any significant non-compliance with a 14 CFR part 145 requirement that lowers the safety standard and seriously impacts flight safety.” While a finding of this nature would also likely result in FAA enforcement action, due process protections exist. However, the determination of the Level 1 finding during an SIS visit is at the discretion of the EASA auditor and the decision to revoke EASA approval is at the discretion of the EASA designated focal point.

On its face, the MAG does provide some due process in this situation, but only after the certificate is in effect. Sec. B-6.1.1, which addresses revocation and suspension of EASA Part-145 approval, states that, “any certificate action involving suspension or revocation shall be carried out by EASA in accordance with EASA Part-145.B.35 and applicable EASA procedures.” Per sec. B-6.2.1, in such cases, EASA notifies the approval holder in writing about any suspension or revocation, including the option to appeal the decision in accordance with Article 108 of Regulation (EU) 2018/1139.

In other words, even though EASA Part-145 approval of a U.S. repair station is based on the validity of its FAA part 145 certificate, appealing a revocation of the approval requires going through the same EASA process as if the certificate was issued directly by EASA. While this is a form of due process, it means engaging in an unfamiliar appeal process on a different continent.

ARSA is also concerned about the lack of transparency in the FAA’s non-recommendation process (i.e., the way in which FAA advises EASA that a repair station is eligible to renew EASA Part-145 approval). Per sec. B-2.4.3 of the MAG, the FAA provides a non-recommendation when the agency finds significant safety issues related to failure to comply with EASA requirements or the Special Conditions or failure to use FAA-approved data for major repairs, alterations and modifications or maintain a working Quality Assurance System.

Upon receipt of a non-recommendation, EASA may elect not to renew the approval or to suspend or limit it until corrective action has been taken or a plan has been submitted to the FAA. It is not clear from the MAG whether a certificate holder facing a non-recommendation by the FAA has any due process rights at all. ARSA has seen instances of members threatened with non-recommendation by an FAA inspector for arbitrary reasons; the association also knows that non-recommendations are forwarded to EASA with no notice or information being provided to the certificate holder of the action or why it was taken.

The MAG is constantly evolving and an update to it is expected within the year. As we look to future iterations, the demand for more due process and transparency from regulators on both sides of the pond to ensure the bilateral lives up to its promise will be forthcoming.

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 – European Summer School

By Brett Levanto, Vice President of Operations

While ARSA’s president focuses on the summer plans of American legislators, the association keeps its focus global. Two key European events will return to their in-person, pre-pandemic form: the Paris Air Show will take over Le Bourget for the first time since 2019 and the FAA/EASA International Safety Conference will return to Cologne, Germany after three years of online or American iterations.

ARSA will occupy multiple spots on the FAA/EASA agenda – no plans for a chalet at Le Bourget – with Executive Vice President Christian Klein tackling both career development issues through a “flash talk” and on a technical presentation covering bilateral cooperation. Naturally, any international discussion of collaboration will center on recent upheavals between the United States and European Union.

Those upheavals are well chronicled on arsa.org/mag and throughout ARSA’s periodicals as well as in editorial placements in AviationWeek, AMT Magazine, and DOM Magazine. The situation drove this layman lawyer to ask in February whether “being bilateral” was even worth it and stands as a good education carefully reading regulatory text.

This installment continues that education by sharing some historical analysis. Since 2015, EASA’s strong preference for paperwork has driven oversight of U.S. repair stations with European approval to the detriment of the mutual recognition embodied in the bilateral. The forces behind the problem began while Europe was still overseen under the Joint Aviation Authorities (JAA). Pre-EASA changes to FAA Form 8130-3 and its guidance for completion (Order 8130.21) provide insight into the collaborative focus of the JAA era.

The initial use of the form in the U.S. was for export only; it was issued by the FAA to establish compliance with an importing country’s requirements. Under harmonization efforts spearheaded by the FAA and JAA, the form underwent considerable revision in the 1990s to harmonize it “more closely with the form used for comparable purposes in other countries.” The new tag, updated in 1991, was primarily intended to facilitate acceptance of FAA-approved products and parts in other countries and be used for conformity determinations.

The FAA also noted the expansion of the form’s use to include approving work on articles for return to service: “Many countries have indicated to the FAA that an FAA Form 8130-3 form [sic] on a used product, filled out for return to service, will be acceptable documentation rather than requiring the tag to be filled out as an export airworthiness approval.” (Emphasis added.)

The fundamental purpose of a bilateral is mutual acceptance of each other’s aviation safety systems and regulations, except as set forth in the Special Conditions. Under that premise, it is clear the only FAA Form 8130-3 required from a U.S. repair station is after the maintenance has been performed under U.S. regulations. That interpretation is consistent with previous bilateral maintenance agreements between the United States and its European allies (France and Germany) with respect to parts documentation on maintained articles.

European policymakers have pushed their American cousins into a corner over the installation of airworthy parts because documentation preferred by one is not required by the other. Thousands of parts sitting on shelves for want of paperwork serves neither safety nor the aviation industry – particularly when the form required by EASA states that it does not constitute eligibility for installation without further action by a maintenance provider.

Preparing for this European summer requires going to school on these historical and regulatory nuances. A joint working group is considering ARSA’s most-recent arguments regarding parts documentation under the bilateral – regardless of that outcome, industry’s challenge is to master these regulatory details while maintaining practical focus on airworthiness.

If you will be in Paris or Cologne, let ARSA know and bring the association with you as a “champion” (it could pay your membership dues).

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ARSA on the Hill

Debt Deal Distractions

The debt ceiling (or “statutory debt limit”) is the maximum amount of money the United States can borrow by issuing bonds. The government uses funds raised by these bond sales to pay for existing expenses. In May, the U.S. Department of Treasury had already begun “extraordinary measures” to continue covering bills without the ability to borrow more. Despite the financial tricks keeping the lights on, Secretary Janet Yellen had projected the country would begin defaulting on its obligations by June 5 without a deal to increase the $31.4 trillion limit.

The Washington Post reported that the deal struck by Biden and House Speaker Kevin McCarthy after weeks of halting negotiations despite opposition from lawmakers on the extreme ends of both parties (R-Calif.) includes:

• Suspending the debt ceiling into 2025, after the next round of national elections.
• Basically freezing, but maintaining, funding for most domestic programs.
• Potentially limiting the congressional approved expansion of the Internal Revenue Service and rescinding other unobligated funds authorized to address the pandemic.
• Increasing military and veterans affairs spending, which are exempted from inflation-adjusted cuts for other discretionary programs.
• Expanding work requirements for some recipients of federal food stamps and family welfare benefits, while making it easier for the homeless and veterans to get benefits.
• Expediting a natural gas pipeline in West Virginia.
• Resuming required payments on student debt (but not reversing the White House plan to cancel student loan debt).

These general provisions, presented in a 99-page bill (H.R. 3746, the “Fiscal Responsibility Act of 2023”), faced criticism from liberal Democrats (for unpalatable cuts) and conservative Republicans (for not further reigning in spending). Despite these objections, a bipartisan coalition ushered the legislation through the Congress and to the president’s desk.

While the debate over the debt ceiling attracted general interest over its potential impact on the American economy, the aviation community was particularly impacted by the process. Rep. Garret Graves (R-La.) was one of the chief Republican negotiators of the eventual deal. Graves is chairman of the Transportation & Infrastructure Committee’s Subcommittee on Aviation, which holds jurisdiction over issues related to FAA reauthorization. With four months left on the agency’s current congressional authorization, which passed in 2018, the intense focus on American fiscal health has prevented progress towards a new FAA bill.

With the debt ceiling removed until the next Congress, Graves and his fellow lawmakers can return to other business. As they do so, ARSA and its allies will continue to advance regulatory and career development priorities for inclusion in the FAA’s new authorization law.

Reading the Calendar

Since ARSA President Josh Krotec has reminded members the summer is time for engaging with lawmakers their home states and districts, it’s important to know how to find your member of Congress. While specifics can be gathered from official websites or by calling the district or state office (using arsa.org/congress, thanks to generous support from ARSA member Aircraft Electric Motors), businesses can plan longer term by looking at the House and Senate calendars.

These plans show when each chamber expects to be in session. While emergencies may require additional time in the capital, Americans can focus on planned recess periods for opportunities to meet their lawmaker (or host them for a facility visit). According to the calendars, these are the weeks designated for homework for the remainder of 2023:

Note: The dates below capture workdays and do not include weeks where only one or two days has been identified for district/state work. For specifics, refer to the House and Senate calendars.

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Conference Corner

Engaging for Effect

As ARSA members gear up for a busy summer engaging American lawmakers, all should look back on this 2023 Legislative Day session with some of the association’s most-engaged professionals.

Engaging for Effect

Industry colleagues share insights and lessons learned from their companies’ engagement with government. 

Josh Krotec, Senior Vice President, First Aviation & 2023 ARSA President 
Etain Connor, Director, Community Affairs, FEAM Aero 
Bob Arnett, Vice President, Earp Aviation Repairs 

See you at next year’s Conference: March 12-15, 2024

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Aviation Life Calendar

June Through September

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 & Career Development

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.

Now Available On Demand – An Overview of Part 91

On May 31, ARSA Executive Vice President Christian Klein presented an online training session overviewing 14 CFR part 91. The recording is now available for immediate on-demand viewing.

Description: This session overviews the general operating rules of 14 CFR part 91. It reviews the structure of the part and its subparts and describes their applicability to persons operating aircraft within the U.S. national airspace system.

Objectives: Upon completion of this session, participants will have the tools to understand:

• The framework for rules impacting aircraft operations in U.S. airspace.
• The interplay between part 91 and other operating rules.
• The responsibilities for maintenance and continued airworthiness under part 91.

Click here for more information and to register.

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.

Part 43 for Repair Stations

On June 14 at 11:00 a.m. EDT, ARSA Vice President of Operations Brett Levanto will lead an online training session covering 14 CFR part 43 that highlights the interplay between the maintenance rule and the standards for repair stations in part 145.

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

Objectives: Upon completion of this session, participants will have the tools to understand:

• The scope and breadth of part 43.
• The persons it impacts.
• The quality standard applicable to all work performed on civil aviation aircraft.
• The connection between the requirements of part 43 and compliance with part 145.

Click here for more information and to register.

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.

Part 91 – Compensation or Hire

On June 29, ARSA Executive Vice President Christian Klein will continue his exploration of 14 CFR part 91.

Description: This session explores the details of the general operating rules in 14 CFR part 91 impacting operations performed for compensation or hire. It highlights the elements of the rule governing such operations and identifies relevant other areas in 14 CFR.

Objectives: Upon completing this course, students will have the tools to understand:

Click here for more information and to register.

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 part 11, subpart A with this combined packet containing every training sheet produced since 2021.

Click here to download the bundle.

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Membership

Your Face Here – Advertise with ARSA

In late 2022, ARSA took control of its periodical distribution and advertising sales. As members and avid readers, you’ve benefited from cleaner distribution lists, clearer management policies, fresher design, and (for primary members) the addition of the new Daily Intelligence from the association’s management firm.

Deepen the benefit and commitment to the only association representing the international aviation maintenance industry and see that investment go directly to the people representing your interests (not a service provider).

Placement Options

ARSA.org

With nearly 5,000 monthly visitors, advertising on ARSA.org will ensure your message reaches the aviation industry.

the hotline

ARSA’s monthly members-only publication, the hotline, reaches readers in hundreds of international aviation-centric companies including certificated maintenance organizations/repair stations, manufacturers, air carriers, consultants, specialists, service providers, and suppliers. It has been a trusted source of news and analysis – and a valued member benefit – since the association’s founding in the early 1980s.

The Dispatch

The Dispatch is a subscription email resource providing comprehensive weekly news and regulatory briefings to more than 3,000 readers. Delivered to ARSA members and subscribers, the Dispatch keeps readers abreast of topics that impact the civil aviation community.

The Daily Intelligence

ARSA’s management firm delivers a news and regulatory update email each business day – excluding U.S. federal holidays and certain office closures – to every association member primary contact. The Daily Intelligence is a tool allowing these 400+ member representatives to scan key updates, catch government announcements, and distribute their own alerts.

Ready to see your company in ARSA’s communications? Visit arsa.org/news-media/advertising for more information.

Not interested in advertising? Don’t forget to send your news releases and other media information to arsa@arsa.org.

Quick Question – Untangling the Supply Chain

The “supply chain” has become a common excuse for business problems. From the absence of a chosen product from your corner store to a complete disruption of a global industry, supply chain inadequacies have replaced the pandemic from which they emerged as the primary knee-jerk explanation for any operational shortcoming.

ARSA is working on multiple projects in support of both U.S. government analysis and European aviation policy engagement. Help the association gather some data about the realities of supply chain dependability (or lack thereof) in this month’s “quick question”:

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/qq-supplychain.

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

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 May:

New Members
Farsound Aviation Limited, Assoc

Renewed Members
Aeroneuf Instruments Ltd., R02, 2022
Aerospace Turbine Rotables, Inc.-Texas, R01, 2016
Aeroworx, Inc, Ro2, 2010
AOG Reaction, Inc., R02, 1993
Aviation Instruments Repair Specialists (AIRS), Inc., R03, 2022
Aviation Safety Products, Inc., R01, 2013
Business Jet Access, R02, 2021
Coopesa, R.L., R06, 1996
Earp Aviation Repairs LLC, R02, 2019
EcoServices, LLC, R02, 2020
Fleet Support Services, Inc., R01, 2013
Ford Instruments & Accessories, LLC, R01, 2018
GA Telesis Component Repair Group Southeast, LLC, R04, 2022
Heliblade, LLC dba Heliblade International Inc., R01, 2022
Honeywell International, Inc., Corp, 1996
Houston Aircraft Instruments, Inc., R01, 2002
L. J. Walch Co., Inc., R03, 1985
Ozark Aeroworks, LLC , R02, 2015
Piedmont Propulsion Systems, LLC, R04, 2011
Pennsylvania State University, R01, 2016
Quality Aviation Instruments, Inc. dba QAI Aerospace, R03, 2012
Southwest Airlines, R06, 2005
Vibrant Corporation, R02, 2021

A Member Asked…Splitting Inspections?

Q: A customer wants to split its 24-month inspection on a large twin-turbine powered corporate jet into two sections, on different dates within two weeks of each other. The full inspection would be accomplished within the required timeframe established by the manufacturer. There would be no overflying the required due date for the second portion of the inspection. The manufacturers manuals have no statements or indications the inspection must be completed at one time.

Having never experienced a request like this, I’ve thought it through and have spoken with some colleagues. Our collective opinion is that splitting up the inspection would be unorthodox but allowable under the rules, but I can’t locate any documentation supporting this position.

What’s ARSA’s analysis?

A: Under 14 CFR Sec. 91.409(f) the registered owner or operator of a turbojet multiengine airplane operated under part 91 must select, identify in the aircraft records, and use either “a current inspection program recommended by the manufacturer” (Sec. 91.409(f)(3 or an “F3 program”) or “any other inspection program established by the registered owner or operator of that airplane or turbine-powered rotorcraft and approved by the Administrator [pursuant to 91.409(g)]” (an “F4 program”).

Your email said you “researched the manufacturers manuals and have not found any statements or indications the inspection must be completed at one time.” Based on this, we understand the owner/operator is following an F3 program.

While we found nothing in Sec. 91.409 that specifically prohibits segmenting F3 inspections when the practice is not discussed in the manual, FAA Order 8900.1, Chg. 562, Vol. 6, Chap. 1, Sec. 2 (“Inspect a Part 91 Inspection Program”) states at paragraph 6-42(B)(3) that:

The use of WINDOWS – allotted periods of time – within the inspection programs accepted under Sec. 91.409(f)(3) is allowed only if contained as part of the manufacturer’s recommended program.” (Capitalization in original.)

That does not mean segmentation is always prohibited. Indeed, Sec. 91.409(d) specifically provides for progressive inspection programs conducted in stages that result in the complete inspection of an aircraft within 12 calendar months consistent with the manufacturer’s recommendations. That same section requires an owner or operator desiring to use a progressive inspection program to “submit a written request to the responsible Flight Standards Office.” Similarly, segmentation could be incorporated into an F4 inspection program, which must also be approved by the agency.

Segmenting the inspection without approval presents practical problems for the maintenance provider because the condition of items inspected during the first phase of the inspection may change during operations prior to the second half.

Taken together, the regulations and guidance make it clear that FAA wants the inspection to occur at one time unless segmentation is approved as part of the manufacturer’s manual, a progressive inspection program, or an F4 program.

As such, if the customer wishes to conduct segmented inspections, it should seek approval of an F4 program that specifically permits doing so. More information about establishing an F4 program is contained in Advisory Circular 91-90.

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/advertising.

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.

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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