2023 – Edition 8 – September 1
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
Aviation Life Calendar
Training & Career Development
Membership
Resources
Industry Calendar
The President’s Desk
From Cost to Investment
During budget planning money will no doubt be allocated for insurance policies to mitigate adverse events, although the cost may never provide a positive return. Costs that turn into investments are those that provide a return in either time or money. Membership in ARSA is insurance (against the inevitable negative civil aviation authority audit) that also provides an immediate return on investment. Access to ARSA’s expertise can be obtained before, during, or even after navigating an accusation of non-compliance; whenever used, it provides an immediate return on investment.
A fellow director of the association looks at full participation in ARSA as cost avoidance. Belonging to the association, utilizing its resources, learning from its expertise, and networking through its events proactively limited future expenditures. Unfortunately, cost avoidance strategies are not usually allocated dollar amounts during the budget planning cycle as are insurance premiums. (Answer this month’s “quick question” so the association can understand its members fiscal year cycles.)
However your company allocates dollars during the budgeting cycle, the cost of full participation in ARSA can be tracked to short- and long-term returns on investment and success.
(1) Publications for compliance – While ARSA’s Model RSQM Compilation can ensure effective regulatory compliance for members and non-members alike, members are given access to valuable publications through the free tools at org/publications. These compliance documents can provide an immediate return from the dollars spent on membership fees.
(2) Events – The Annual Conference, with its Executive-to-Executive Briefings, Legislative Day, and Annual Repair Symposium, is the international civil aviation maintenance community’s premier event for regulatory compliance and networking. In 2023, a commitment to bring new participants every year ensures current and future generations of compliance-savvy professionals. The registration cost has an immediate return on investment from the networking opportunities, the information received from regulators, and about new developments in laws and policy. Sponsoring the Conference establishes medium- and long-term benefits through company recognition and its commitment to regulatory compliance and aviation safety.
(3) Training – ARSA is expanding its training library with a new spate of live sessions. We are quickly approaching the 100-hour milestone for courses; registration includes copies of all materials and unlimited viewing for 90 days for every session. Let this program work for you in all ways—short term knowledge, long term advertising through sponsor sessions or series.
(4) Advertising & Sponsorship – No matter how you align yourself with the association’s commitment to compliance and quality it will highlight your company before customers, policy makers, and executive branch management. ARSA’s in-house advertising program provides targeted exposure and an investment in the immediate, medium, and future financial success of your company and the association.
(5) Members Getting Members – A program that ensures a member can have free renewal cycles. Every time a member gets another to join the association, the referring member receives a credit of 10% of the new member’s dues. It doesn’t take many referrals to enjoy a yearly “cost avoidance” strategy that tracks real dollars saved.
The yearly budgeting process provides an opportunity to determine which costs deliver a short-, medium-, and long-term return—the price to fully participate in ARSA provides all three. I don’t know of a better insurance policy or cost reduction strategy, which is why First Aviation Services invests in all available pillars.
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Josh Krotec 2023 ARSA president | First Aviation Services, Inc. senior vice president |
ARSA Works
Industry Requests More Time for MOSAIC Comments
On Aug. 29, ARSA joined six trade associations and one member company in requesting the FAA extend the comment period on its Modernization of Special Airworthiness Certification (MOSAIC) proposal. The group requested an additional 90 days beyond the current Oct. 23 deadline and provided a digest of issues to be carefully analyzed in assessing the notice of proposed rulemaking.
The request urged the FAA to consider:
(1) The true extend and nature of the proposal, which would amend nine parts of 14 CFR.
(2) The significant technical, administrative, and financial impact on small businesses.
(3) How the 2016 final rule revising part 23 was implemented to resolve most of the issues meant to be addressed by MOSAIC.
(4) Expanding the economic analysis to truly cover all impacted parties.
(5) How the rulemaking for powered-life aircraft operations, which is also in process, relates to, impacts, and complicates the MOSAIC proposal.
(6) How the ongoing work of the ARAC Repairman Working Group impacts the MOSAIC proposal.
As the association collaborates on high level analysis and comments on the MOSAIC proposal, ARSA encourages members to follow the rulemaking and comment (regardless of when the final comment due date falls).
To view the rulemaking docket, click here.
To review the extension request letter, which more thoroughly explains the six points above, click here.
To see ARSA’s training on engaging the government through rulemaking comments, follow the link below.
In addition to ARSA, the extension request letter was signed by the Aircraft Electronics Association, the Aviation Suppliers Association, the Aviation Technician Education Council, Helicopter Association International, the Modification and Replacement Parts Association, the National Air Transportation Association, and International Air Response, Inc.
On Demand Bundles – Effective Comments and the Fourth Branch of Government
New FAA Repairman Application (and ARSA Template)
The FAA has issued new forms supporting airman applications for both mechanic and repairman certificates under part 65:
Updated: Form FAA 8610-2 – Airman Certificate and/or Rating Application – Mechanic and Parachute Rigger
New: Form FAA 8610-3 – Airman Certificate and/or Rating Application – Repairman
ARSA has issued an updated template repairman recommendation letter available as part of the association’s RSQM Compilation. The new template is available as a free “tool for members” along with the ARSA Model Forms Manual. Members seeking access to the updated letter can click here to request a .zip file containing every “tool” (even if you’ve downloaded the documents before, receiving them all ensures you get the most-updated versions as evidenced by the date of last modification).
For more information on ARSA’s work related to repairman certificates, visit arsa.org/repairmen.
FAA Moving Towards D&A Testing Proposal
The FAA has delivered its proposed rule regarding foreign drug & alcohol testing programs to the White House Office of Information and Regulatory Affairs (OIRA). The text of the proposal will not be available until it is published in the Federal Register for public comment; there is no specific timeline this publication, but OIRA’s review is noteworthy as it represents the first substantive progress on the issue since 2014.
In that year, ARSA led a coalition of industry organizations on comments to the agency’s advanced notice of proposed rulemaking (ANPRM). The group implored the agency to respect national sovereignty by adhering to congressional language requiring any D&A testing rule be “consistent with the applicable laws” of the countries impacted. In addition to that legal limitation, the American imposition of testing requirements could damage bilateral aviation safety agreements (BASAs) and weaken the small businesses that are the industry’s backbone.
OIRA is a federal office established by Congress in the 1980 Paperwork Reduction Act. In addition to reviewing government collections of information from the public under the Paperwork Reduction Act, OIRA reviews draft proposed and final regulations under Executive Order 12866. The order requires an analysis of the costs and benefits of rules and, to the extent permitted by law, action only on the basis of a reasoned determination that the benefits justify the costs.
ARSA has scheduled a meeting with OIRA to share input regarding the issue and will remain alert for the issuance of the notice of proposed rulemaking (NPRM). Members can schedule their own meetings (click here) and are encouraged to catch up on the process so far by reviewing the regulatory information provided by the Office of Management and Budget and seeing ARSA’s updates at arsa.org/drugandalcohol.
This rulemaking would require controlled substance testing of some employees working in repair stations located outside the United States. The intended effect is to increase participation by companies outside of the United States in testing of employees who perform safety critical functions and testing standards similar to those used in the repair stations located in the United States.
Coming Soon – Aviation Digitalization Survey
ARSA is collaborating with industry partners to conduct a survey on digitalization in the aviation maintenance industry.
The survey is part of an effort by ARSA and its allies to identify regulatory and other barriers to the use of digital technology.
The survey will be sent to all ARSA member primary contacts the week of Sept. 4. Please watch your inbox and share your input on this important topic.
Aggregated results will be reported in a future issue of the hotline and shared with regulators from the United States, Europe, Canada, and Brazil during the Maintenance Management Team meeting in Cologne, Germany in November.
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.
Click here to access a PDF copy of the list.
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.
Safety vs. Consistency
By Christian A. Klein, Executive Vice President
Recent “Legal Briefs” described the Chicago Convention and the International Civil Aviation Organization (ICAO). The Convention created ICAO and provided a legal framework for global aviation regulation; ICAO develops standards that contracting states (i.e., countries that have signed the treaty) must incorporate into their aviation laws and regulations.
ICAO’s regulatory harmonization efforts have yielded significant efficiencies and helped create the robust global aviation system we know today. However, harmonization is not an end in itself; the ultimate regulatory goal is safety by the most efficient means possible. Only rarely will two systems be identical and, even if they were, there will always be differences in interpretation. Instead, when considering whether to accept other agencies’ certification decisions, regulators should focus on the data showing the different systems produce equivalent safety results. That philosophy started years ago, but a continued emphasis on states’ regulations and their differences has undermined progress.
Article 37 of the Convention commits states to “collaborate in securing the highest practicable degree of uniformity in regulations, standards, procedures, and organization in relation to aircraft, personnel, airways, and auxiliary services in all matters in which such uniformity will facilitate and improve air navigation.” It also empowers ICAO to develop international standards and recommended practices and procedures. Pursuant to Article 38, states that cannot or will not adopt an ICAO standard must notify the organization (known as filing a “difference”), which, in turn, notifies other states. Article 40 gives states discretion to prohibit the operation of aircraft from a state that has not adopted ICAO standards related to airworthiness or performance.
Focusing on regulatory harmonization instead of safety results made sense when the Convention was adopted. In much of the world, aviation and regulation were still infants. Common standards would ensure interoperability as states’ regulatory systems evolved. Aviation was also much less safe; a 2020 Massachusetts Institute of Technology study found the global airline fatality risk had fallen to one death per 7.9 million boardings between 2008 and 2017 from one death per 350,000 boardings between 1968 and 1977. Air travel was presumably even less safe in 1944 when the Convention was signed.
While global harmonization was one of its goals, the Chicago Convention permitted collaboration beyond ICAO. Article 83 allowed states “to make arrangements not inconsistent with the provisions of [the] Convention.” On that basis, states have entered into agreements in other areas, including design, production, and maintenance.
European countries have long pursued regional collaboration beyond ICAO. In 1970, the European Civil Aviation Conference established the Joint Aviation Authorities (JAA), by which European regulators cooperatively developed and implemented common standards and procedures. According to Skybrary, JAA’s original objective was to enhance efficiency in the European aviation manufacturing sector by producing common certification codes for large airplanes and engines; in 1987, JAA began addressing aircraft operations, maintenance, licensing, and design and certification standards for other types of aircraft. As with ICAO, the JAA had no regulatory authority; it was left up to individual states to implement and enforce JAA recommendations.
In 2002, the Council of the European Union and the European Parliament adopted Regulation (EC) No. 1592/2002, which created the European Union Aviation Safety Agency (EASA). It was built on JAAs achievements; it absorbed many of the JAA’s regulations, standards, and functions. EASA also had a broader mandate that extended beyond the development of common regulations to certification and enforcement within Europe. The FAA and EASA subsequently entered into a bilateral agreement to (among other things) develop “a comprehensive system of regulatory cooperation in civil aviation safety and environmental testing and approvals based on continuous communication and mutual confidence.”
The emphasis on “mutual confidence” rather than harmonization was an important departure from the philosophy underlying the Chicago Convention. Unfortunately, old habits die hard, and regulators have continued to focus on differences in rules that have no impact on safety resulting in compliance challenges for industry. For example, EASA generally requires Production Organization Approval holders to issue EASA Form 1; under U.S. rules, FAA Form 8130-3 is discretionary. This long-standing and fundamental difference in national regulatory requirements has received considerable attention. Over the past year, ARSA, and regulators on both sides of the Atlantic have devoted considerable time to resolving this issue, which has caused headaches for repair stations and customers. It would not be an issue if the agencies focused on each other’s system safety data and results rather than differences in regulatory language that have been clearly shown not to affect safety.
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 – Playing with Definitions
By Brett Levanto, Vice President of Operations
Each Fall, I spend considerable time officiating high school football games. This primary hobby has provided an interesting perspective on regulatory compliance. Officials have a rulebook, with guidance in the form of “case plays” analyzing potential on-field events against established standards. There is even an “Order 8900.1” dictating how an officiating crew operates on the field.
Across my decade of service to aviation safety, a few points about regulatory compliance have been made evident by my avocation:
(1) Open the book. ARSA training participants have heard repeatedly that compliance is not a “closed book test.” There is no required reading to participate in one of the association’s sessions, but reading is required for survival in aviation. None of us should answer a question or consider an issue without finding and referencing the relevant rules. Unfortunately, an official on the field doesn’t have the opportunity to pull out a rulebook while administering a contest; being stripped of reference materials – while being yelled at by coaches and spectators who don’t know the rules – is a stark reminder of a written document’s value.
(2) Allow what’s not prohibited. Another familiar dictum for the association. This point is routinely made in ARSA’s letters to civil aviation authorities, highlighted in editorials, and was the subject of a 2020 panel at the Annual Conference. For sports officials, the National Federation of High Schools is clearer on the point than the federal government: “A rule sometimes states what a player may do, but if there is no such statement for a given act (such as faking a kick) it is assumed that he may do what is not prohibited.” (See, NFHS Football Rule 2-37) This principle drives flexibility in compliance and reasonable oversight on the field and in aviation safety.
(3) Mind the meaning. The heftiest part of the football rulebook is Rule 2 – Definitions. While the book’s drafters gave the top spot to foundational standards for “the game, the field, the players, and equipment,” every new official begins their study in Rule 2. Over 14 pages, the book defines key terms utilized across the rules. From “targeting” a “defenseless player” to “players” being “out of bounds” to “catching” a “legal forward pass,” the standards governing play make sense only through the lens of explanation. (I carry personal pet peeves about commonly misused terms, most notably the announcers who conflate an infraction of the rules committed by a player, i.e., a “foul”, with the enforcement of lost yardage prescribed against that infraction, i.e., a “penalty.”)
This final connection with the aviation safety rules is incredibly important. Last month, this layman lawyer continued an ongoing – if interrupted – series related to ARSA’s challenge of FAA authority to issue certain airworthiness directives. First with a parachute and now a life preserver, the association has questioned how the articles in question fall under the applicability of part 39. That determination requires analyzing the definitions of aircraft, aircraft engine, propeller, and appliance. ARSA has three short training sessions on the word “appliance” – the time is coming for a fourth, using these examples to explain “why do you care?” – and the followers of this series should recognize the three-part standard well:
Appliance means any instrument, mechanism, equipment, part, apparatus, appurtenance, or accessory, including communications equipment, that is (1) used or intended to be used in operating or controlling an aircraft in flight, is (2) installed in or attached to the aircraft, and is (3) not part of an airframe, engine, or propeller. (Numbering added for emphasis.)
In the most recent letter to the FAA regarding AD authority, the ARSA team dove even further into the words within this definition. We focused on “operating” or “controlling” an aircraft. “Operate” is defined in § 1.1 as “[to] use, cause to use, or authorize to use aircraft for the purpose … of air navigation. “Control” is without regulatory definition but is described by Webster’s as a verb meaning “to exercise restraining or directing influence over” with reference to “controls” as a noun including “a device or mechanism used to regulate or guide the operation of a machine.” Though some rules, e.g., § 121.137, mandate equipage of approved life preservers for extended overwater operations, requiring an item as a perquisite for operation does not equate to utilization or direction for air navigation as described in the definitions of “Operate” and “Control”.
Attention to each word and the punctuation in a definition is necessary to understand and test existing rules and essential when considering new or altered ones. Members of ARSA’s team reviewed the FAA’s recent “powered lift” rulemaking proposal with industry allies, noting an issue in the agency’s reliance on the international definition provided by ICAO:
Powered-lift. A heavier-than-air aircraft capable of vertical take-off, vertical landing, and low-speed flight, which depends principally on engine-driven lift devices or engine thrust for the lift during these flight regimes and on non-rotating aerofoil(s) for lift during horizontal flight.
Commenters believed that relying strictly on the ICAO definition limited the proposed rule’s applicability to aircraft with some kind of fixed wing. The rulemaking preamble embraced this standard: “Powered-lift are unique in their ability to take off and land vertically like helicopters, and fly like an airplane during cruise flight.” The definition may leave a hole in the eventual special regulation that would exclude, as an example, the Volocopter VoloCity model being developed for urban air taxi service. Practically speaking, the agency should not – after considerable time and investment in developing an SFAR – leave new entrants caught in a loophole.
Plain reading of the rules, in aviation or sports officiating, requires careful deconstruction of words and sentences. Regardless of whether you’re facing a misused applicability, a too-narrowly-defined aircraft class, or an undefined football playing action, compliance is an exercise dependent on reading every word and recognizing the import of every punctuation mark.
ARSA on the Hill
The Final Countdown?
Lawmakers will be busy when they return to Capitol Hill after Labor Day. Preventing a government shutdown and extending the FAA’s operating authority are top priorities; the deadline for action on both is Sept. 30.
In July, the House passed an FAA bill that includes many provisions suggested by ARSA. Meanwhile, the Senate has yet to pass its more modest version out of committee due to disagreements pilot training rules and adding slots at Reagan National Airport.
Lobbyists expect Congress to pass a short-term FAA extension to keep the agency running while the Senate finishes work on its FAA bill and the House and Senate conference to resolve differences. An appropriations extension for the entire federal government through the end of the year is also likely.
It’s not unusual for Congress to pass a short-term FAA bill to buy itself more time during a reauthorization. However, the looming government-wide appropriations expiration adds risk. ARSA is particularly concerned the uncertainty is causing the FAA to divert scarce personnel resources to prepare for a shutdown, which will only add to the delays certificate holders are already experiencing when dealing with the agency.
Please use ARSA’s Legislative Action Center (sponsored by Aircraft Electric Motors) to send a note to your representative and senators urging them to get the FAA bill done quickly.
ARSA has also prepared the chart below to help members understand how the association’s priorities are addressed in the House-passed and draft-Senate FAA bills. The House bill is clearly preferable, and ARSA has been holding Hill meetings urging the Senate to add key items. When you use the Action Center to contact Congress, feel free to add words of support for any of the provisions below to the pre-prepared email message.
| Issue | House | Senate | Notes | ARSA Position |
| Maintenance data availability | Sec. 516 | Sec. 333 | Both bills direct the FAA Administrator to assign an instructions for continued airworthiness task to the FAA Aviation Rulemaking Advisory Committee to resolve longstanding questions about maintenance data availability. | Merge provisions and retain in conference. |
| Enforcement consistency; aligning regulations and guidance | Secs. 252 and 253 | No provision | Sec. 252 directs the U.S. Department of Transportation’s Inspector General to audit the Flight Standards and Certification Services regarding the consistency and application of guidance. Sec. 253 directs the FAA Administrator to ensure consistency in oversight through internal audits, more frequent updates to guidance and rules, and better documentation of findings and decisions | Include both provisions in Senate bill, retain in conference. |
| Aviation workforce grant programs | Sec. 301 | Sec. 501 | To address persistent shortages of aviation technical personnel, the House bill reauthorizes, triples funding, increases maximum grant from $500k to $750k, expands program eligibility to include 501(c)(3) nonprofits, and creates a similar new grant program for the aviation manufacturing workforce. Senate bill reauthorizes, doubles funding, creates new program for manufacturing, increases maximum grant to $1 million from $500k). | Merge and retain in conference with highest authorization level. |
| Major alterations vs. supplemental type certificates | Sec. 517 | No provision | To resolve uncertainty for maintainers and operators, requires the agency to issue or update guidance to clarify the conditions under which a major alteration requires a supplemental type certificate. | Add to Senate bill, retain in conference. |
| Ending open-ended investigations | Sec. 208 | No provision | Requires FAA investigations to be completed within two years of issuance of a letter of investigation. | Add to Senate bill, retain in conference. |
| Improve rulemaking transparency and responsiveness to petitions | Sec. 122 | No provision | Creates the new position of FAA Assistant Administrator for Rulemaking and Regulatory Improvement, who is charged with, among other things, improving transparency and responsiveness relating to the agency’s handling of petitions for rulemaking and exemptions. | Add to Senate bill, retain in conference. |
| International cooperation | Sec. 502 | Sec. 314 | Encourages the FAA to pursue cooperation more aggressively with other civil aviation authorities. | Merge and retain in conference. |
| National Center for the Advancement of Aerospace | Sec. 303 | No provision | Creates a new National Center for the Advancement of Aerospace to coordinate workforce development activities among industry, academia, and other stakeholders. | Add to Senate bill, retain in conference. |
| Military aviation technician transition to civilian careers | Sec. 311 | Sec. 504 | House establishes an interagency working group to improve the transition from military to aviation technician careers. Senate bill directs rulemaking to create new military mechanic test and adjust airman certification standards.
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Retain Senate language in conference. |
| Early airframe and powerplant mechanic general knowledge testing for students who have completed high school coursework | Sec. 312 | Sec. 503 | House establishes a working group to examine airman knowledge testing to create new opportunities for high school graduates in the maintenance industry; Senate directs GAO study.
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Retain House language in conference. |
| Foreign repair stations | Sec. 505 | Sec. 311 | Prescribes new and unnecessary regulatory and oversight requirements for foreign repair stations that will divert FAA resources from higher safety priorities. | Delete from Senate bill and do not include in conference. |
| Adding aviation maintenance representation to stakeholder bodies | Secs. 202(d) (Airspace Innovation Office integrated plan development stakeholders) and 502(b) (Women in Aviation Council composition). | Creates panels addressing issues impacting aviation maintenance. Representation from the maintenance industry should be added. | Add “aviation maintenance” to indicated stakeholder bodies in Senate bill, retain in conference. |
If you have questions about FAA reauthorization or want to get more involved in the association’s advocacy, Ask ARSA First!
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Want to Learn More 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. In this critical election year, ARSA PAC has never been more important. But ARSA is prohibited from sending PAC information to members who haven’t opted in to receive it. Please take a second to give us prior approval to talk to you about ARSA PAC. Doing so in no way obligates you to support PAC. It just opens the lines of communication. Click here to give ARSA your consent today. |
The Year-end Calendar
In June, ARSA President Josh Krotec reminded members the summer is time for engaging with lawmakers their home states and districts. The summer may be over and the long August recess behind us, but lawmakers still have scheduled state/district work days left in 2023. 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.
| House | Senate |
| Sept. 5-8 | Oct. 10-13 |
| Oct. 2-6 | Nov. 20-24 |
| Oct. 10-13 | Dec. 18-22 |
| Oct. 30-Nov. 3 | Dec. 26-29 |
| Nov. 6-9 | |
| Nov. 20-24 | |
| Dec. 18-22 | |
| Dec. 26-29 |
Aviation Life Calendar
September Through December
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.
| Month | Day | Event or Celebration |
| All | All | This Day in Aviation |
| September | All | This Day in Aviation History – September |
| September | 6 | Global Talent Acquisition Day |
| September | 15 | Hispanic Heritage Month |
| October | All | This Day in Aviation History – October |
| October | 4 | World Space Week |
| October | 20 | International Air Traffic Controller Day |
| November | All | This Day in Aviation History – November |
| November | All | National Native American Heritage Month |
| November | All | National Aviation History Month |
| November | 8 | National STEM/STEAM Day |
| December | All | This Day in Aviation History – December |
| December | 7 | International Civil Aviation Day |
| December | 17 | Wright Brothers Day |
Training & Career Development
Skills Group Seeks Industry Support for Digital Competency
Business Leaders United, an initiative of the National Skills Coalition, has requested maintenance industry support for its policy initiative to improve digital skills training and resources. ARSA supports the effort as part of its broader effort to bolster competency based training and improve open access to resources (with limited regulatory hand-wringing over “emerging” technologies) and encourages its members to consider signing on.
New technologies can make workplaces of any kind more efficient. Repair stations may utilize digital record storage, tablet interfaces for task cards or work orders, or computer-based management of materials storage as some examples of resources that improve administrative functions in support of work performed under the aviation safety rules. Despite these kinds of tools becoming common for technical employers, data shows most of the workforce does not have the skills or experience to use them effectively.
To improve digital training resources and awareness, BLU is seeking business sign-on to a letter to U.S. lawmakers show general support for better skills policies. The letter does not include specific policy suggestions and signing on does not equate to endorsing any legislation, but rather endorses a set of principles that would close the digital skill divide such as job-related digital skills training and improving access to broadband, hardware, and equipment.
Review the following text and consider signing your company on in support. For questions and to participate, contact BLU Manager Jeran Culina.
Principles for Closing the Digital Divide
The pandemic demonstrated the value of connected technology and that Americans must be empowered to adapt to technology’s constant evolution in the workplace.
America needs a comprehensive strategy to close the digital skill divide. As the nation implements historic investments in closing the digital divide, the supporting organizations encourage decisionmakers to consider five principles that can support Digital Equity at Work:
(1) High quality hardware in all hands. The pandemic laid bare the connection between access to notebooks, laptops, and other connected devices and access to education, training, jobs, healthcare, support services, and social networks.
(2) Every community connected. Broadband is a foundational service to which all Americans must have access.
(3) A digital skill foundation for all. Nearly 50 million people in the U.S. need to build foundational digital skills to harness the power of the Internet through connected devices. Every person should have the opportunity to develop broad-based, flexible digital problem-solving skills for current technologies and ongoing technological shifts.
(4) Upskilling for every worker in every workplace. Technology is impacting nearly every industry and occupation in different ways. We can empower workers with industry- and occupational-specific digital skills to adapt and advance in their careers.
(5) Rapid reskilling for rapid re-employment. Each industry has specific technical demands. Overnight the pandemic brought structural shifts to our labor market, reminding us that America’s workers must have access to rapid reskilling to move from one industry to another.
To see ARSA’s general activities related to workforce, career, and skill development, review the years’ worth of updates below. For questions about the association’s work in particular or support for BLU, contact Brett Levanto.
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.
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).
Government employees: Contact ARSA directly for auditing opportunities.
Registration: Registration and payment may be processed directly through the training platform/course catalog (free account creation required).
Technical questions and assistance: Click here for FAQ and technical support from training platform vendor.
Refunds: No refunds are granted for ARSA training sessions. When classes are canceled, registrants can choose from future courses of equal value. If a registrant is unable to attend a live session, their registration allows access to the on-demand, recorded version of the webinar.
IA Approval: A number of ARSA training sessions have been accepted for Inspection Authorization (IA) renewal credit. These sessions are denoted on their registration page with their FAA course acceptance number (in red).
Benefits: Registration for an ARSA-provided training session includes:
- Access to the live class session on the scheduled date (if applicable).
- Unlimited 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.
- A certificate* upon completion of the session as well as any required test material.
OFM&K Training Portal: All of ARSA's training sessions are provided through OFM&K's training portal. As the training provider of choice for ARSA and a trusted resource for the aviation community, the firm's training materials represent a vital tool for entities pursuing regulatory compliance and business success. All of the courses are administered via PotomacLaw.InreachCE.com, which is not part of ARSA's website.
Complying with Part 145 – “Soup to Nuts” (Four Hours) Instructor: Sarah MacLeod Description: Specially recorded with a hand-picked audience for interactive discussion, this session thoroughly reviews 14 CFR part 145, discusses the application of the rule and overviews some practical implications of obtaining and maintaining a repair station certificate. Pricing Note: This is a four-hour session and is $300 for members and $600 for non-members. Click here to register and get access for 90 days.
Sessions Accepted for IA Renewal Credit Eight of ARSA's on-demand training sessions have been accepted by the FAA for Inspection Authorization renewal credit under 14 CFR § 65.93. Each session is currently available for registration and immediate access:Click here to purchase all eight sessions (plus one required prerequisite) at a “bundled” discount – let ARSA take care of your IA renewal requirements this year. Click here to purchase all eight sessions (plus one required prerequisite) at a “bundled” discount.
Aircraft Parts
Audit Activism & Prophylactic Lawyering
Drug & Alcohol Testing
Human Factors
Instructions for Continued Airworthiness
Parts 21, 43, 65, 145 (and others)
Public Aircraft"Going Global" - International Regulatory Law
Grassroots Advocacy
Recordkeeping – "Finishing the Job with Proper Paperwork"
The Fourth Branch of Government (Administrative Agencies and Procedures)
Self Disclosure Programs and Practices
(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.
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 OFMK’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 Magic Form – Exploring the 8130-3
Bundle pricing available, click here to learn more.
FAA Form 8130-3 – Overview & History
Wednesday, September 27 @ 11am
This session reviews the history of the FAA Form 8130-3, Authorized Release Certificate, to its beginning as an export airworthiness approval, putting into context its evolution from an export document to its current usage.
Click here for more information and to register.
FAA Form 8130-3 – Completion Instructions & Multiple Releases
Wednesday, October 18 @ 11am
This session walks through the steps for completing the FAA Form 8130-3, Authorized Release Certificate, Airworthiness Approval Tag. The training uses instructions developed as part of ARSA’s RSQM Compilation and focuses on language used for work to be issued a release under the regulations of multiple civil aviation authorities including a “dual release” under the U.S./EU bilateral agreement.
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.
Going Global Again – European Enlightenment
International markets mean expanded business opportunities that require an expansive regulatory understanding. The upcoming live session on the history and practicalities of European regulatory oversight is a must for any professional dealing with EASA.
Upcoming Live Session
Going Global – European Enlightenment
Tuesday, September 12 @ 11am
This session provides the history behind the bilateral airworthiness agreements (BAA) and bilateral aviation safety agreements (BASAs) between the United States and European nations. Provides the background to the development of the European Union Aviation Safety Agency (EASA) through the Joint Aviation Authorities (JAA). It explains how implementation procedures for design and production are negotiated separately from implementation procedures for maintenance.
Click here for more information and to register.
Available on Demand
Going Global – Bilateral Agreements
This session focuses on the purpose and scope of bilateral agreements and describes how they are developed and structured. The presentation explains specific activities covered in a typical BASA including design approvals and post-design approvals, production and surveillance, export airworthiness approvals, technical assistance between authorities and special arrangements. It also covers bilateral maintenance agreements, their associated special conditions and the latest maintenance developments out of ICAO.
Click here to register and get access for 90 days.
Going Global – A Primer on International Regulatory Law
This session summarizes the framework for international safety regulation, introduces ICAO’s mechanisms for allocating regulatory responsibilities among member states and addresses the important role bilateral agreements play in enhancing efficiency and facilitating international commerce.
Click here to register and get access for 90 days.
Going Global – International Obligations
This session provides history and context for international aviation safety regulations. It explains the background to the Chicago Convention, the establishment and authority of the International Civil Aviation Organization (ICAO) to set the standards and responsibilities of civil aviation authorities.
Click here to register and get access for 90 days.
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.
Short Sessions On Demand – Part 43 “In Depth”
ARSA Vice President of Operations Brett Levanto (with support from Executive Director Sarah MacLeod) is building on ARSA’s existing training covering 14 CFR part 43 by running an “in depth” series exploring specific elements of the maintenance rule. The first four 15-minute “in depth” sessions are available on-demand.
Click here to see bundled pricing options for the currently available sessions covering part 43 (tiered savings up to 40% off the total registration cost for all sessions).
Part 43 In Depth: Performance Rules
On Demand
This session focuses on the performance rules of 14 CFR part 43, Maintenance, Preventive Maintenance, Rebuilding and Alteration. It reviews each paragraph of § 43.13 and describes the reading process maintenance providers should follow when meeting the minimum standards of the rule.
Click here for more information and to register for on-demand viewing.
Part 43 In Depth: Applicability
On Demand
This session focuses on the applicability of 14 CFR part 43, Maintenance, Preventive Maintenance, Rebuilding and Alteration. It reviews the meaning of § 43.1(a) and highlights the related regulations and definitions impacting its meaning.
Click here for more information and to register for on-demand viewing.
Part 43 In Depth: Non-applicability (§ 43.1(b))
On Demand
This session focuses on the applicability of 14 CFR part 43, Maintenance, Preventive Maintenance, Rebuilding and Alteration. It highlights the points of “non-applicability” explained in § 43.1(b).
Click here for more information and to register for on-demand viewing.
Part 43 In Depth: Life Limited Parts (§§ 43.1(c) & 43.10)
On Demand
This session focuses on the applicability of 14 CFR part 43, Maintenance, Preventive Maintenance, Rebuilding and Alteration. It highlights the responsibilities related to life limited parts created by § 43.1(c).
Click here for more information and to register for on-demand viewing.
ARSA will continue its series exploring elements related to part 43, including both 15 minute and hour-long sessions and varying levels of instruction. Stay tuned for additional sessions.
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 § 21.3, Service difficulty reports.
Click here to download the training sheet.
Membership
Advertising Update – Get in on the Joke
No reason this can’t be fun you know…
Since late July, ARSA’s team has been setting up jokes in its periodical advertisements. Curious readers – more than 100 in each edition of the Dispatch since the practice started – click for the punchline, which is provided on top of ARSA’s advertising page.
If you’ve fallen behind on this important reading, you can see the five published so far at arsa.org/news-media/advertising-jokes. Which do you think has been most popular with readers, as measured by click through rate?
This exercise more than a little fun, though it has been for the team. It demonstrates the visibility produced by an ARSA advertisement, the willingness of the association’s contacts to click on an interesting item, and the spirit of the organization to which any advertiser is tying their company name. With considerable good humor but even more tenacity in its commitment to quality, ARSA provides a unique venue for those serving the aviation community.
In the spirit of community, ARSA invites its members to participate in expanding our jokebook. Share your favorite joke or wisecrack via the Ask ARSA portal. The team’s favorites will be featured in association communications and the jokesters supplying them will be celebrated in a manner befitting their contribution (perhaps more periodical content, access to training sessions, or acknowledgement during the Annual Conference).
While you’re at it, spare a moment to learn about how ARSA association engages the maintenance community through advertising and sponsorship opportunities for its members and industry partners.
Learn more about the advertising program at arsa.org/advertising.
Not interested in advertising? Don’t forget to send your news releases and other media information to arsa@arsa.org.
Make Yourself New
ARSA Vice President of Membership Kimberly Dimmick (she knows if you’ve updated your member profile)
For the past year, all new ARSA members have received a series of welcome messages from the association’s team. Mirroring the two-month-long succession of emails used to keep membership renewal at or above 90 percent, each contact at a new member company gets walked through the resources and value of their membership.
All members can add value to themselves and their companies by returning to a “beginners’ mindset.” This edition of the hotline shares anew the value provided from the perspective of Vice President of Membership Kimberly Dimmick:
To maximize the company’s return on investment, I send a summary of research done on the company’s team members to ensure all executive, quality, human resource, and business development contacts receive the associations’ regular and special periodicals and updates. It is incredibly helpful when members help clean up and add to our profile of the company (it’s a process that never stops – be alert for your chance to update at your next renewal or contact me now to take care of it).
One of the most valuable benefits of membership is access to experts, so I direct known (and new) contacts from a member company a directory of team member expertise. To remind all members, these dedicated professionals stand ready to help you in many positive ways:
- Regulatory and compliance – Executive Director Sarah MacLeod
- Legislative and economic research – Executive Vice President Christian Klein
- Workforce, training, model manuals, and communications – Vice President of Operations Brett Levanto
- Membership – Vice President of Membership Kimberly Dimmick
- Finance and billing – Finance Manager (arsa.finance@arsa.org)
I warn the new member (and now you) to place the following addresses on the company’s or computer’s “safe list”:
- @arsa.org (direct emails/alerts)
- @potomac-law.com (training session confirmations/updates)
Finally I assure them and you that we look forward to many years of mutually rewarding opportunities for personal and professional growth.
Quick Question – Your Fiscal Year
ARSA helps its members produce value through their investment in the cost avoidance resulting from regulatory understanding and tools for compliance. Maximizing that investment results from ensuring careful budgeting for success.
Help ARSA understand your budget process better by answering a simple “quick question” about when your fiscal year begins.
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 to submit your response.
If the embedded survey does not appear/load, open the survey independently by visiting: https://www.surveymonkey.com/r/ARSA-fiscalyearID
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 August:
New Members
AMETEK Aircraft Parts & Accessories, Inc., R03
Crew Aviation LLC, R01
Diversified Aero Repair, LLC, R01
Jeronimo Gracian, Affil
Illuminair Support, Corp., R03
Summit Aerospace, Inc., R05
Renewed Members
Aero Instruments & Avionics, Inc., R04, 1991
Aero-Mark MRO, LLC-dba Certified Aviation Services, R02, 2015
Aerospace Welding Minneapolis, Inc. , R01, 2020
Aeronautical Technology, Inc. dba Precision Aero Technology, R03, 1993
Aircraft Lighting International, Inc., R01, 2018
Airframe Components by Williams, Inc., R02, 2003
Arkwin Industries, Inc., R02, 1994
Aviation Repair Solutions, Inc., R02, 2006
Construction Helicopters, Inc. dba CHI Aviation, R02, 2022
Cross-Check Aviation, R02, 2003
Curtiss-Wright Actuation Systems, R03, 2003
Gyro Specialist, Inc., R01, 2011
HEICO Aerospace Corporation, Corp, 1992
Hot Section Technologies, Inc. , R02, 2017
IBM Flight Operations, Assoc, 1997
International Turbine Industries, LLC, R02, 2010
Miami Aircraft Structures, Inc., R02, 2003
Millennium International, L.L.C., R02, 2013
NFF Avionics Services, Inc. dba NFF Aviation Services, R02, 2010
Palm Beach Aircraft Propellers, Inc., R02, 2001
Pearl River Community College, EDU, 2020
PT. Wira Jasa Angkasa , R03, 2021
REB Technologies Inc., dba REBTECH, R02, 2003
Regional Avionics Repair, LLC, R03, 2006
Rotorcraft Repair & Manufacturing, LLC, R01, 2019
Signature Engines, Inc., R02, 2017
STS Aviation Group, Corp, 2020
Vanguard Aerospace, LLC, R01, 2022
A Member Asked…
Q: Where is the authority for a repair station to perform maintenance on a Public Use (military) aircraft?
A: We are assuming the company has a contract with the DoD to perform maintenance on aircraft that do not have certificates of airworthiness from the FAA.
If that is the case, the correct question is: What is the scope of the FAA’s authority over maintenance? The specific interest here for that general question is: How does this scope include or exclude work performed on military owned and operated “so-called public” aircraft? The answer is the aviation safety agency only has jurisdiction over aircraft with U.S. airworthiness certificates (see, § 43.(1)(a)).
If the aircraft is owned and operated by the U.S. DoD and operated exclusively as a public aircraft, it will usually not have an airworthiness certificate. Commercial derivatives of military aircraft are type certificated by the FAA and may be eligible for an FAA airworthiness certificate, but will not possess one when operated exclusively by and for the military. If by off-chance a military owned and operated aircraft does have an U.S. airworthiness certificate, the FAA would have jurisdiction over the maintenance performed on that aircraft.
In summary, if you are dealing with aircraft that have an FAA airworthiness certificate, § 43.1 sets forth the agency’s authority over that work. In the absence of an FAA airworthiness certificate, the company’s performance would be subject to its contract with the DoD. If the contract provides, for example, that maintenance is to be accomplished by an FAA-certificated repair station, that is a commercial requirement. The DoD contract does create jurisdiction for the FAA over the maintenance; the safety agency’s authority is triggered by the issuance of the U.S. airworthiness certificate.
This 2010 FAA legal interpretation explains the agency’s jurisdiction over maintenance under the applicability section 43.1. Although its focus is on maintenance performed on foreign-registered aircraft and components installed on such aircraft, the same legal principles apply to maintenance performed on military aircraft, i.e., the FAA lacks jurisdiction because the aircraft do not hold U.S. airworthiness certificates. Also, you may wish to look at the on demand “in-depth” training series ARSA is running on section 43.1 by visiting arsa.org/part-43-training.
Have questions about aviation regulatory compliance or legislative policy? Ask ARSA first!
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).
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
| Conference | Dates | Location |
| MRO Asia-Pacific | 9/26-28/2023 | Singapore |
| Dubai Airshow | 11/12-16/2023 | DWC, Dubai Airshow Site |
| MRO Southeast Asia | Spring 2023 | TBD |
| ARSA Annual Conference | 3/12-15/2024 | Arlington, Virginia |
| AEA International Convention & Trade Show | 3/19-22/2024 | Dallas, Texas |
| NBAA Maintenance Conference | 4/30/-5/2/2024 | Portland, Oregon |
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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