The U.S. civil aviation maintenance industry employs more than 275,000 people and generates more than $50 billion in annual economic activity. (To see the industry’s impact in each state. go to arsa.org/news-media/economic-data.)
ARSA is the eyes, ears, and voice of the aviation maintenance industry in the halls of Congress. The association’s legislative efforts complement its regulatory expertise as our team tirelessly fights for repair station interests on Capitol Hill.
Our top priority is ensuring that aviation policy is based on facts, not fear. New laws and regulations should genuinely improve safety, not micromanage or undermine industry competitiveness. We do this by:
- Engaging lawmakers in our nation’s capital and their home states.
- Encouraging grassroots action and involvement by ARSA members.
- Raising the legislative and regulatory profile of the aviation maintenance industry.
- Offering technical and legal expertise to analyze and respond to government actions.
- Promoting the industry’s benefits and safety record among key audiences.
Legislative Priorities: 116th Congress, Second Session
Updated March 3, 2020
Prevent Enactment of the Safe Aircraft Maintenance Standards Act (H.R. 5119):
H.R. 5119, which was approved by the House Transportation & Infrastructure Committee in November 2019, would impose new and unnecessary burdens on aviation maintenance companies, airlines, general aviation operators and manufacturers while doing nothing to improve safety. If the bill becomes law, the more than 1,500 U.S. repair stations with foreign approvals and their employees would be targets of retaliation by foreign authorities. U.S. air carriers and their maintenance vendors would be subject to burdensome new recordkeeping requirements. U.S. commercial and general aviation operations outside the country would be disrupted because of a shortage – or complete lack of – FAA-certificated maintenance facilities in destination countries. And U.S. manufacturers seeking to provide product support in growing foreign markets would be prevented from obtaining FAA certification at those overseas facilities. ARSA calls on Congress to reject H.R. 5119.
Fully-Fund New Aviation Workforce Development Programs:
The aircraft maintenance technician shortage threatens to undermine the efficiency and competitiveness of the entire industry. To address the problem, as part of the 2018 Federal Aviation Administration (FAA) reauthorization law Congress created a new workforce development grant programs supported by more than 40 national, state and local aviation organizations and labor organizations. Sec. 625 of the FAA law authorizes $5 million per year for five years to support initiatives to recruit and train the next generation of aviation maintenance technicians and $5 million per year to improve pilot education and address the pilot shortage. Congress fully funded the maintenance workforce program and related one for pilot education through the 2020 appropriations process. ARSA urges Congress to once again fully fund the workforce development grant program and use its oversight authority to ensure that the Department of Transportation rapidly initiates the programs to maximize their impact.
Consistently Enforce FAA Maintenance Manual Rules
The FAA aggressively enforces the requirement that repair stations possess “current” versions of maintenance manuals (14 CFR § 145.109(d)) while the agency fails to enforce the regulation requiring design approval holders to create and make that same maintenance data available (14 CFR § 21.50(b)). As a result, many repair station small businesses face unnecessary administrative and financial burdens and loss of business opportunities. Congress should encourage FAA to either enforce the rules consistently and fairly or update them to relieve undue burdens on industry.
Improve Competition for Department of Defense (DoD) Maintenance Contracts:
DoD can save hundreds of millions – if not billions – of dollars by more widely adopting commercial best practices. Congress should – through the annual National Defense Authorization Act, appropriations process or general oversight – encourage DoD to improve competition for maintenance on DoD’s fleet of civilian derivative aircraft by more-readily accepting FAA approvals (e.g., Parts Manufacturer Approval (PMA) parts and Designated Engineering Representative (DER) repairs). Doing so will reduce maintenance costs, improve readiness, reduce bureaucratic duplication, and expand government contracting opportunities for small and medium aviation maintenance businesses.
Improving FAA Rulemaking and Enforcement Accountability and Due Process.
The Promoting the Launch of Aviation’s Next Era (PLANE) Act (S. 2198) contains several provisions proposed by ARSA to address problems at the FAA. Sec. 104 would mandate specific factors to be used by the FAA when deciding whether to act on a petition for rulemaking, require the agency to designate an employee to manage each petition filed, and direct the FAA to report annually on petition filings and dispositions. To end FAA’s practice of open-ended investigations, Sec. 105 would require the FAA to complete them within two years. Sec. 601 directs the FAA to reinstate the voluntary surrender of repair station certificates, thereby restoring due process and predictability for companies looking to adjust or shut down operations. The legislation contains several other provisions important to other industry stakeholders and supported by ARSA.
Updating Aviation Technician School Curriculum Standards
Curriculum standards for schools that train aviation technicians are set by regulation (14 CFR part 147) and haven’t been updated since the 1970s. As a result, what students are taught is well out of step with industry needs. Although the 2018 FAA bill directed improvements, the FAA has been slow to act. The Promoting Aviation Regulations for Technical Training (PARTT) 147 Act (S. 3043/H.R. 5427) would require the FAA to more rapidly update the rule and provide schools with more flexibility about what, how and where they teach to better prepare students for careers in the 21st century aviation maintenance industry.
Implement and Fund FAA Reauthorization Mandates:
In 2018, Congress enacted a new, long-term FAA authorization law to provide near-term certainty for the agency’s budget and enhance the quality of oversight. The legislation included several provisions to improve FAA operations and employee training. ARSA urges Congress to appropriate the funds necessary for FAA to conduct efficient oversight of the industry. Congress must also fulfill its oversight responsibility and ensure that FAA implements the new law in a timely manner.
Refrain from Imposing Unnecessary Regulatory Mandates:
One of biggest long-term threats to the aviation maintenance sector is government intrusion through overregulation. The basic nature of the aviation industry demands that, for a company to be successful, safety and security must be the paramount concerns. Operators and airlines will not do business with companies that put passengers and valuable business assets (i.e., aircraft) at risk. Put simply: safety is good business. Congress and the FAA must understand that government and the industry share the same safety goals and should refrain from micromanaging through unnecessary agency action.
Invest in Airport Infrastructure:
The American Society of Civil Engineers has given the nation’s airport infrastructure a grade of “D”. The Airports Council International has estimated that airports will require almost $100 billion for capital improvements over the next half decade. Congress must look for fiscally responsible ways to expand America’s airport capacity to improve passenger mobility, enhance efficiency, and ensure the continued growth, safety and health of our aviation system.
Insulate the FAA and the Aviation Industry from Future Government Shutdowns:
Because of the strict regulatory oversight regime for the maintenance industry, our members’ work is intrinsically intertwined with that of the FAA. More than three quarters (77 percent) of respondents to a 2019 ARSA survey indicated their operations were negatively affected by suspension of the FAA’s activities during the 2019 federal government shutdown. Delays in processing certificate applications, renewals and other approvals left repair stations, employees and customers in limbo. Congress should enact legislation to protect the nation’s aviation system and the agencies that regulate it from the consequences any future appropriations lapse.
To learn more about the aviation maintenance industry and its economic impact in your state, go to avmro.arsa.org or contact ARSA Executive Vice President Christian Klein at 703.739.9543 or firstname.lastname@example.org.