2015 – Edition 3 – April 2
Table of Contents
President’s Message – The State of ARSA
By Jim Perdue, President, Board of Directors and Vice President of SONICO, Inc.
Editor’s Note: ARSA President Jim Perdue addressed members in remarks delivered at the 2015 Annual Repair Symposium’s Membership Meeting and Breakfast. The following is the text of Mr. Perdue’s prepared remarks.
Good morning, I am Jim Perdue, ARSA’s president and vice president of SONICO, Inc. I have been involved in component maintenance repair my entire work life, starting out in inventory control, status reporting, purchasing and now sales. Sonico is a medium-sized component repair station located in the center of Washington State. Our business operates out of the former Larson Air Force base in Moses Lake, Washington about two and a half hours east of Seattle.
We work on a wide variety of components: hydraulic, structures, electrical and mechanical assemblies due to our relationship with Boeing as a warranty repair station and Boeing’s requirement for a variety of capabilities. We have evolved through our 35 years of business and, today our customers are the major domestic and international airlines.
On behalf of the board of directors I would like to welcome you and, officially call the 2015 annual membership meeting to order.
The first item of business is to introduce the board of directors. I ask each present to stand when I call your name and remain standing through the explanation of all the industry segments represented by your service.
First, ARSA vice president and general manager of Jet Center Medford, Gary Hudnall, ensures general aviation interests heard.
The association’s treasurer and Coopesa’s Quality & Safety Director Warner Calvo represents the association’s international members.
Of course, former president Gary Jordan of Jordan Propeller Service is still very much a part of ARSA’s board.
Ian Cheyne of BBA’s Dallas Airmotive represents engine maintenance providers.
Gary Fortner of Fortner Engineering and I represent component maintenance, which makes up the vast majority of ARSA membership.
Chris Erickson from Erickson AirCrane represents the rotorcraft industry.
Dave Latimer, from HAECO Americas, represents companies that work on large aircraft.
Basil Barimo of the NORDAM Repair Group ensures various corporate, business and airline maintenance issues are addressed.
Questions or concerns are heard, discussed and approached with an understanding of the various interests and perspectives of the international aviation maintenance industry because of these individuals. Thank you to the board members for donating your valuable time to the association, you may be seated.
Now it is my honor and privilege to give this year’s state of the association.
As Christian mentioned yesterday morning, association regulatory staff worked extensively with the agency and industry to refine the part 145 repair station rule issued in August 2014.
Most notably, the association and its allies pointed out the FAA needed to replace the word “serious” in the service difficulty report requirements before the implementation date. Seven other industry ally groups signed the successful petition, including Airlines for America, the Aerospace Industries Association and the General Aviation Manufacturers Association. These efforts build relationships through common ground that pay immediate and long-term dividends.
We have hit exciting strides on the workforce development front, thanks in part to the management firm’s new relationship with the Aviation Technician Education Council. In six short months the associations have submitted joint comments on two advisory circulars and procured a workforce development study that sheds new light on the challenges of finding, retaining and growing a world-class aviation maintenance workforce.
In the coming weeks ARSA will join ATEC to submit comments to the Standard Occupational Classification or “SOC” system Policy Committee asking it to consider changes to aviation maintenance personnel definitions. The SOC system is used to collect, calculate, and disseminate occupational data on which many statistical analyses rely.
Under the current framework nearly all aviation maintenance professionals are lumped together in one group; the draft comments ask that certificated mechanics and repairman and non-certificated maintenance technicians be tracked separately to produce a more accurate picture of the current labor force in order to address the looming industry-wide personnel crisis. Please see Laura if you’d like to see a draft copy of those comments.
ARSA also joined the international community as active participants in the International Civil Aviation Organization or “ICAO”’s Next Generation of Aviation Professionals Task Force. The N-GAP, as it’s called, has the mission to ensure that enough qualified and competent aviation professionals are available to operate, manage and maintain the future global air transport system. This major initiative dedicated to the international aviation workforce crisis finally has a voice for the maintenance community.
ARSA’s legislative team is focused on FAA reauthorization, the multi-year blueprint setting the agency’s priorities and policies. The current authorization law expires on September 30.
We are off to a good start educating lawmakers on our issues, particularly micro-management, and its impact aviation maintenance. At Wednesday’s Legislative Day, nearly 50 ARSA members stormed Capitol Hill, participating in over 30 meetings with lawmakers and staff. Additionally, many congressional staffers attended a luncheon briefing and Capitol Hill premiere of the aviation maintenance industry documentary. When compared to 2003 when 14 attendees participated in the annual fly-in, it’s clear the association’s legislative program has grown considerably.
The early, consistent congressional engagement yields considerable benefits. ARSA can affirmatively push industry priorities and oppose detrimental proposals. Its suggestions have resulted in proposals to expand due process protections for all FAA certificate holders, reform the FAA’s part 147 curriculum requirements and encourage more bilateral aviation safety agreements.
Individual involvement is still the key to success. The association needs an engaged membership responding to calls for action, hosting congressional facility visits and educating lawmakers about the important role repair stations have within the broader aviation industry. When Daniel asks for help, it’s imperative that we answer the call.
Perhaps one of the more exciting initiatives undertaken by the association this past year is production of the documentary you saw yesterday. The communications team spent hours upon hours on product development; now it’s up to us in the industry to take it and run:
Use it in your recruitment campaigns.
Share it with fellow repair stations, local schools and community groups.
Play it for your employees.
Send it to your friends – or future friends – in the media.
Most importantly, invite your local council members, state legislators and members of the U.S. Congress to watch it at your facility. When the credits role, take them for a walk and show them the important work being done right in their home districts.
ARSA once again joined forces with the company previously known as TeamSAI, now CAVOK, to release its annual economic report. This report illustrates a booming, global industry – a rising tide that will lift us all. The global aviation maintenance industry is projected to top $100 billion in the next decade. Committing now to nurturing this growth, which we all do through our ARSA membership, will earn us a part of that future.
Finally, ARSA staff has taken sides and are in a heated program development competition. It will be interesting to see who prevails, Team Training or Team Membership.
This year’s training schedule will cover regulatory compliance, legislative advocacy and business development topics. Through a wide range of programs and course offerings, the association will ensure that your staff remains sharp on the issues that matter most to your business’ survival and success.
Utilizing infrastructure improvements made over the last two years, most notably a new, highly-customized database that allows for online payment processing and improved member tracking, a new and improved membership campaign is scheduled for implementation in the second quarter. If you receive a call from ARSA staff asking for your assistance recruiting a neighbor or colleague, we expect an enthusiastic response. Current members are our best recruitment tool and the membership team will certainly put that tool to good use this coming year.
In closing, please ensure you check your email this afternoon for the symposium feedback survey. Your input is vital to ensure ARSA’s annual event is continually improved. Mark your calendars for March 16-18, 2016 here at the Ritz Carlton. I look forward to seeing you then.
As ARSA’s President, I pledge to ensure the association continues to push the envelope. I thank the ARSA staff for their hard work on our behalf. It is truly a special organization, one dedicated to the progress of our industry, and I am proud to play such a key role.
2015 Repair Symposium – Engagement in Action
By Ryan Poteet, Regulatory Affairs Manager
ARSA’s 2015 Annual Repair Symposium provided attendees two jam-packed days of presentations, speakers and panels covering a broad range of regulatory and industry issues.
Executive Director Sarah MacLeod and Executive Vice President Christian Klein kicked things off by highlighting some of the association’s legislative and regulatory successes over the past year. During the symposium’s “Opening Salvos,” regulators from the FAA and EASA addressed the varying procedures between the two regulatory systems, the effect that non-conformity has on the global aviation maintenance industry and the need for strong bilateral agreements.
Representatives from ARSA’s sister associations provided the resounding message that the aviation community must work together as politicians and regulators make policy decisions that will ripple through a global industry. Technological innovation and the FAA’s role in collecting maintenance data also took center stage when agency representatives introduced the newest data exchange program and solicited feedback from attendees. The first day came to a close with a message from Kevin Hiatt of the International Air Transport Association (IATA) to emphasize the importance of the ARSA-IATA relationship and the need to continue to engage internationally with trade groups and regulators.
ARSA’s President Jim Perdue began the symposium’s second day by providing his “state of the association” report to the annual member meeting. Perdue was followed by the Honorable Michael P. Huerta, FAA administrator, who gave an overview of the agency’s policy objectives and priorities for the coming year and fielded questions from attendees. After hearing from the FAA’s top official, participants broke off to attend smaller sessions focusing on discrete issues ranging from negotiations of maintenance agreements (i.e., ICAs) and workforce development, to data reporting and best practices for interacting with the FAA. These smaller sessions provided a unique opportunity to interact with panelists and bring to light problems and concerns that impact individual businesses and touch the industry as a whole.
This year’s Symposium could not have succeeded without the help of the association’s sponsors and panelists. ARSA looks forward to next year’s symposium and will continue to vigorously advocate on behalf the aviation maintenance industry.
Get ready for 2016. The Annual Repair Symposium will return to Arlington, Virginia March 16-18, 2016. Have a topic you’d like to see explored in 2016? Click here to tell us about it.
Did you attend this year? Participant materials are available for download, contact ARSA for more information.
2015 ARSA Scholarship Winner – Paul Mart, Embry Riddle Aeronautical University
By Brett Levanto, Director of Operations
On Mar. 4, the Northrop Rice Foundation announced the 2015 ARSA Scholarship had been awarded to Paul Mart of Daytona Beach, Florida. Mart is an AMT student at Embry Riddle Aeronautical University (ERAU).
Mart is pursuing a Bachelor of Science in Aviation Maintenance with a concentration in maintenance management in addition to minors in aeronautical studies and flight. Before arriving at ERAU, Mart earned credits at Green River Community College and the University of Colorado, Boulder.
Mart has a passion for advancements in industry-leading avionics and an interest in business aviation. His goal is to someday be Director of Maintenance at a corporate flight department, but Mart understands the work ahead and looks forward to it. Crediting his parents, who immigrated to the United States from Romania, with teaching him invaluable lessons about hard work and sacrifice, Mart has a clear vision of where he’s going and what it will take to get there.
“It is clear that Paul will be a leader in the industry,” noted one of his instructors in a recommendation letter. “He has all the right characteristics that will help him be a great mechanic and [give him] the desire to grow.” Those characteristics, outlined across all of Mart’s recommendations, include effective personal skills, a meticulous nature and the highest level of integrity.
In short, Mart will be a great asset to the aviation maintenance community and the flying public. It is for people like him that ARSA supports this annual scholarship through NRF; those that will grow the industry, uphold the highest ideals of its work and keep the world safe in flight for years to come.
To see all of NRF’s scholarships and winners, click here. Start getting your materials ready for next year; applications are due December 1, 2015.
ARSA Member Survey Is in the Field
By Brett Levanto, Director of Operations
The association’s annual member survey is in your primary contact’s inbox. This is your opportunity to contribute to ARSA’s work on behalf of the industry.
This year’s survey is supplemented by a separate set of recruitment questions that will fill gaps in existing data regarding the aviation maintenance workforce. This separate questionnaire is to be forwarded to the persons responsible for human resource activities.
Responses are invaluable to ARSA staff as we work with regulators and lawmakers, develop content on key issues and find solutions to the challenges most impactful to the repair station community. This information will also be provided to your company as a tool for developing plans and responding to market needs. We are capturing your snapshot of aviation maintenance – make it useful.
To review last year’s survey results, click here.
Want to ensure that your office got the survey? We can help.
You Can’t Fly Without Us – The World of Aviation Maintenance
By Brett Levanto, Director of Operations
The seven-minute documentary was developed by the ARSA as part of a series of informational public-television features and is intended to introduce the work of the men and women who keep the world safely in flight. To see more, please visit AVMRO.arsa.org.
ARSA grants a non-exclusive license to those who wish to use “You Can’t Fly Without Us” (“the work”) for the exclusive purpose of promoting the aviation maintenance industry, including the right to distribute copies of the work and to display the work publicly. ARSA reserves all remaining rights in the work.
To see all the ways that ARSA is working as the voice of the aviation maintenance industry, visit our ARSA Works page.
ARSA to Congress: You Can’t Fly Without 300,000 American Aviation Workers
By Brett Levanto, Director of Operations
On Mar. 18, ARSA hosted a dual-premiere event on Capitol Hill to provide both visual and quantitative evidence for the importance of the aviation maintenance industry to American lives and livelihoods.
At a congressional briefing in the Rayburn House Office Building, Rep. Carlos Curbelo (R-Fla.) helped the association unveil You Can’t Fly Without Us – The World of Aviation Maintenance. The seven-minute documentary was developed as part of a series of informational public-television features and is intended to provide a foundational introduction to the work of the men and women who keep the world safely in flight.
The video can be seen on AVMRO.arsa.org, the aviation maintenance industry’s information portal.
After the screening, ARSA released the 2015 Global Fleet and MRO Economic Assessment, prepared by CAVOK, a division of Oliver Wyman. David Marcontell, CAVOK’s vice president, presented an overview of the report’s findings, noting that the total worldwide market for commercial aviation maintenance activity will surpass $100 billion by 2025. On American soil, Marcontell noted that the industry employs nearly 300,000 men and women and generates more than $43 billion in economic activity, while producing more than $5 billion in federal corporate and individual income taxes.
The full report, as well as a fact sheet illustrating U.S. state-by-state employment figures, can be found in ARSA’s economic data center at arsa.org/news-media/economic-data.
“Each year, [the Global Fleet and MRO Economic Assessment] continues to paint a clear picture of a complex, but vibrant industry,” Marcontell said before the event. “People across the world are becoming more connected with each other and demanding even more from the aviation industry to carry them and their products safely and cost-effectively around the globe. As air carriers and other aviation businesses respond to this demand, the already-dynamic aviation maintenance market will march right along in step.”
“The message here is pretty simple,” said Christian A. Klein, ARSA’s executive vice president. “Every single time you land safely, or pick a loved-one up at the airport, or have a package arrive on your doorstep, there’s a maintenance provider somewhere for you to thank. These repair stations, maintenance facilities and component shops – the businesses that ARSA represents every day – are part of a complex global network of services that are vital to our national and global economy. We can tell those stories in many different ways, and this report and our documentary make key points in the overall discussion: You can’t fly without us.”
Contract Maintenance Requirements Comparisons & Timeline
By ARSA Regulatory and Legislative Staff
On March 4, the FAA unveiled a congressionally-mandated rule on air carrier contract maintenance requirements. The association has been engaged for years on Capitol Hill and with regulators to mitigate the rule’s impact on repair stations and their airline customers.
The following resources have been produced to assist industry members in interpreting the new rule and understanding its development:
- Comparison between the proposed and final rule.
- Comparison of Sec. 310, FAA Reauthorization Act (H.R. 915) and Sec. 319, FAA Modernization & Reform Act (as enacted).
- Contract Maintenance Requirements Timeline (from Dec. 1997 to Mar. 2015).
To see all of the ways ARSA is working on behalf of the aviation maintenance industry, please visit the ARSA Works page. For more reference material and compliance information, visit the association’s resource page.
Still Nothing Generic About Generic Clearance
By Laura Vlieg, Regulatory Affairs Manager
On Mar. 12, ARSA submitted its continued objections to the FAA’s request for generic clearance of information collections contained in Airworthiness Directives.
ARSA again provided the Office of Information and Regulatory Affairs (OIRA) with evidence that generic approval of information collections contained in ADs is inappropriate, and that the FAA’s supporting statement was inadequate under the Paperwork Reduction Act. ARSA gave OIRA reason to disapprove the information collection request, or at a minimum to return the request as improperly submitted due to its procedural deficiencies.
And now we wait – will OIRA do the right thing? Stay tuned.
Contract Maintenance – A Bit of History
By Laura Vlieg, Regulatory Affairs Manager
On March 4, the FAA released a final rule on air carrier contract maintenance requirements. The regulation comes after nearly two decades of fear mongering over a safe and efficient practice – contracting between air carriers and maintenance providers.
Contract maintenance came under intense scrutiny during the ValuJet accident in 1996. After which the FAA subjected repair stations performing “substantial maintenance” for air carriers to increased surveillance. “Substantial maintenance” was not addressed in regulations, but rather through paragraph D091 of the air carriers’ Operations Specifications (OpsSpecs). The term was defined by Order 8300.10 (HBAW 96-05C) as, “[a]ny activity involving a C-check or greater maintenance visit; any engine maintenance requiring case separation or tear down; and/or major alterations or major repairs performed on airframes, engines or propellers.”
A few years later, an aggressive lobbying campaign from organized labor provoked a volatile discussion among Congress, regulators and industry about contract maintenance. Beginning in 2003, the Department of Transportation Office of Inspector General (DOT-OIG) released three reports over the course of five years criticizing FAA’s oversight of air carrier contract maintenance programs.
The FAA responded to congressional maneuvering and the DOT-OIG reports by improving its guidance materials on oversight of the air carrier and maintenance provider relationship. ARSA worked with its airline colleagues and the agency on those changes to ensure they closely follow the regulations and impending language from Capitol Hill. The new iteration of OpsSpecs D091 replaced the term “substantial maintenance” with “essential maintenance.” The updated guidance material (Notices 8900.102 and 8900.103) defined “essential maintenance” as any on-wing accomplishment of any maintenance or alteration that the air carrier designates as required inspection items (RII). FAA guidance also clarified that RIIs are only applicable to on-aircraft maintenance.
The updated D091 also improved the process for identifying maintenance providers. Rather than listing maintenance providers in the OpsSpecs, the paragraph spells out the necessary categorization of maintenance providers in the air carrier’s required vendor manual. The paragraph also outlined means to identify the providers that have qualified, trained and authorized individuals to perform required inspections. The categorization coincides with the repair station ratings.
Congress still mandated specific language in the FAA Modernization & Reform Act of 2012 (Public Law 112–95) to further regulate the relationship between air carriers and maintenance providers. However, ARSA’s collective advocacy for maintenance providers to Congress mitigated the effects of the new legislation. The association successfully drafted legislative language and lobbied for its enactment to ensure the law and current guidance on D091 were aligned. The final rule is the result of that congressional activity.
ARSA submitted comments to the proposed rule, and was again successful in tempering the ultimate impact of the regulation. Section 319 of the FAA Modernization & Reform Act of 2012 required that “covered work” be carried out “under the supervision and control of the part 121 air carrier directly in charge of the covered work being performed on its aircraft.” Thus, the proposed rule included provisions defining both “directly in charge,” and “supervision and control.” The proposed definition of “supervision and control” would have required the certificate holder to personally observe covered work, or to be “available for consultation.” ARSA and other industry groups pointed out that similar terminology is used in existing regulations and the new definition of the phrase would lead to confusion. The agency ultimately scrapped the definition of “supervision and control,” conceding that the term lacked clarity, while keeping “directly in charge.” The final rule preamble makes clear that the agency considers the two terms synonymous.
Amid the politics, ARSA has provided a loud and steady voice of reason. The association advocates strongly for its members and allies on both regulatory and legislative fronts, and for the past two decades it has continuously educated the government and the public on the safety and economic benefits of contract maintenance. The result: a contract maintenance rule that causes minimal disruption to business as usual.
For a full account of the regulatory and legislative activities surrounding this congressionally mandated regulation, check out:
- Comparison between the proposed and final rule.
- Comparison of Sec. 310, FAA Reauthorization Act (H.R. 915) and Sec. 319, FAA Modernization & Reform Act (as enacted).
- Contract Maintenance Requirements Timeline (from Dec. 1997 to Mar. 2015).
Next month we will take a close look at the elements of “covered work” in the law, regulations, and guidance.
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.
ARSA Lands on Capitol Hill
On March 18, ARSA members descended on Capitol Hill to engage legislators and discuss the aviation maintenance industry’s important economic and safety contributions.
The day kicked off with a presentation by Sen. Jim Inhofe’s (R-Okla.) Legislative Director Luke Holland and a briefing by ARSA staff. After descending on Capitol Hill, attendees participated in over 30 congressional meetings to educate lawmakers about ARSA’s 2015 legislative priorities, including refraining from implementing unnecessary regulatory burdens on the aviation maintenance industry, encouraging more bilateral aviation safety agreements, and expanding due process protections for FAA certificate holders (the Pilots Bill of Rights II (H.R. 1062, S. 571).
After crisscrossing the Hill all morning, ARSA hosted a congressional briefing in the Rayburn House Office Building where Rep. Carlos Curbelo (R-Fla.) unveiled ARSA’s documentary, You Can’t Fly Without Us: The World of Aviation Maintenance. Florida Lt. Governor Carlos Lopez-Cantera also addressed the crowd and his message: Florida welcomes the MRO industry and the state is ready to do what is necessary to bring more MRO jobs to the Sunshine State.
The briefing concluded with ARSA’s release of the 2015 Global Fleet and MRO Economic Assessment, prepared by CAVOK, a division of Oliver Wyman. David Marcontell, CAVOK’s vice president, presented an overview of the report’s findings, noting that the total worldwide market for commercial aviation maintenance activity will surpass $100 billion by 2025. On American soil, Marcontell noted that the industry employs nearly 300,000 men and women and generates more than $43 billion in economic activity, while producing more than $5 billion in federal corporate and individual income taxes.
This economic data provided ARSA members with a powerful tool to impress upon congressmen and senators the importance of the MRO industry and the effect legislative and regulatory action on their constituents.
Once again Legislative Day was a success and provided members a valuable opportunity to connect with their local representatives. ARSA will continue to support its members by advocating for legislative action that is responsive the needs of the industry, and we are standing by to help you connect with your lawmakers.
If you were unable to join your fellow members on Capitol Hill, see all the ways you can get involved back at home by visiting arsa.org/legislative/get-involved. And be sure to mark your calendars for next year’s Legislative Day on March 16, 2016!
I Need a DER – Or Do I? Part V: Developing the Data Package
By Peter Lauria, Principal, JT Consulting, LLC © 2015 Peter Lauria ALL RIGHTS RESERVED
The previous articles in this series covered the basics of the repair vs. replace decision based on inspection and repair criteria (in Part I), the major/minor determination (Part II), the history and types of delegations (Part III) and selecting and contacting a DER (Part IV).
By this point, you’ve identified the repair you want to perform on the article, made at least a preliminary determination of major or minor and sought the assistance of a DER.
The Data Package
The next step is to develop a data package that will describe the repair steps in detail and provide technical and engineering support for approval of the substantiating data by the DER.
The most-applicable AC is AC 21-47: “Submittal of Data to an ACO, a DER or an ODA for a Major Repair or a Major Alteration.” This AC provides a high-level summary of required elements of development and submittal of the data package.
If is the article is from a turbine engine , Advisory Circular (AC) 33-9 provides a very detailed process for classifying the criticality of the part and developing substantiating data for a major repair.
If you need to fabricate detail parts in order to complete the restoration, AC 43-18 provides guidance to ensure an equivalent level of safety to the original parts.
(a) Descriptive data, which includes:
1. The drawings (or equivalent) and specifications necessary to define the configuration and the design features; [Note: We accept sketches, photos or pictures as descriptive data when it is appropriate, such as for certain one-time approvals.]
2. Information on dimensions, materials, and processes;
3. Airworthiness limitations, if applicable; and
4. Documents required by the airworthiness requirements such as instructions for continued airworthiness (ICA) and airplane or rotorcraft flight manuals, if applicable.
(b) Substantiating data, which can be test results, computations and other information necessary to show that the descriptive data meets the applicable requirements. You should present the data in a logical order with explanations of how the data shows compliance.
While substantiating a repair does not require a validation of the original design, it does require a complete description of the original design vis-à-vis the contemplated restoration action.
Descriptive data is generally explained in chapter 2, section 5 of the AC as:
Descriptive Data: List the descriptive data related to this submittal, such as drawings and specifications. Be sure to include the revision level or dates of the descriptive data in the listing. You may provide a reference to a document, such as a master drawing list, that provides this information. If the descriptive data is listed only as a reference for substantiation data and is not included in this submittal, indicate “not included.”
To establish compliance with regulatory and business requirements, details are essential and would need to include a description of the part, system or product, the discrepancy being corrected by type and extent (crack, wear, dent, etc.) and the extent and nature of the proposed repair. A detailed package makes it easier to for the DER or ACO to review and when substantiated it will ensure technicians know and will obtain the intended results.
Review the process described in a report by the ARAC Major/Minor Working Group, of which ARSA’s Executive Director Sarah MacLeod and I were members, along with experts from the FAA, industry (manufacturers and repair stations), the general aviation community and operators. Part of the report was a suggested AC which was not published although portions were incorporated in later guidance material. Excerpts of that suggested AC concerning descriptive data are helpful:
Product and Discrepancy Descriptions:
(A) Description of the Product Affected. This description should include but is not limited to:
1. Part number.
2. Assembly number.
3. Serial number(s), if applicable.
4. Make and model of product.
5. If known or as appropriate: hours cycles, time in service, time since new, time since last maintenance action.
(B) Description of the discrepancy or contemplated alteration. A complete description of the damage, discrepancy or alteration should include, but is not limited to:
1. Explicit location on the product.
2. Type (i.e. corrosion, limit exceeded, cracks, dents).
3. Extent and/or dimensions.
4. Remaining dimensions of the affected area(s) or part (s).
5. Associated, hidden and/or adjacent discrepancies, damage or alteration(s).
6. Previous maintenance action(s)or disposition(s) thereof, or alteration(s) at or adjacent to the affected area(s) or part(s).
7. Cause, if known (i.e. environmental, accidental, design).
Under the heading of Data Development, a clear and distinct functional description is helpful:
As appropriate to the action being considered, the functions, interactions, environment and consequence of failure of the product, as applicable, must be assessed to determine the extent of analysis and the expertise needed to develop technical and substantiating data required to comply with the airworthiness regulations.
This assessment may include, but is not limited to:
1. Functional information – how the part functions within the assembly; how the assembly functions within the system; and/or how the system functions within the product. This outlines the nature of the product being maintained or altered.
2. Operating environment of the product – the conditions an/or specification under which the product is intended to operate.
3. Interaction with other systems and consequences of failure – which of the part’s failure modes could be most influenced by the maintenance, disposition or alteration and what would be the most probable effect on its capability to perform its intended function. For parts other than those listed above as primary structural parts or critical engine parts, consider the effect on airworthiness due to part failure (e.g. secondary bearing and bearing support repairs, secondary structure forward of control surfaces).
4. Effect of the repair and/or alteration – which may ultimately change the part’s type certification, operational characteristics, or performance.”
These elements ensure a proper regulatory and business review; the more complex or essential an article or a repair, the more definitive the data needs to be in order to understand compliance and return on investment strategies.
The final component of descriptive data is the contemplated repair. In this portion, the data package should include:
1. Detailed work instructions;
2. Inspection criteria – incoming (initial), in-process and/or final inspection;
3. Description of, or reference to, processes and the instructions for their accomplishment.
a) Heat treating, surface treatment, blending, welding
b) Consideration of specialized processes on engine hardware, such as, but not limited to:
i. HPT turbine blade repair (especially single crystal alloys)
ii. LPT turbine blade repair
iii. Subjecting engines and parts thereof to specialized processes (acid stripping, ultrasonic cleaning etc.) outside of the manufacturer’s maintenance manual or instructions for continued airworthiness;
4. Continuous inspection requirements and/or future maintenance action requirements;
5. Acceptance of condition without further specific maintenance action.
Now that you have described the article being repaired, its function within the next higher assembly and the product (aircraft, engine, or propeller) and the restoration actions, including inspection criteria, repair methods, techniques and practices and fabrication requirements, you will need to substantiate the result. That is, show how the repaired article stays in compliance with the applicable regulations. The ACs referenced in this article describe substantiation data.
One key factor: Does the substantiation data actually show compliance to the regulations, or do they restate the regulation in the negative?
For example, if you want to show a repair to an aircraft meets the requirements of 14 CFR § 25.305 (strength and deformation), the DER will look for a connection between the data and, for instance, subparagraph (a) “The structure must be able to support limit loads without detrimental permanent deformation. At any load up to limit loads, the deformation may not interfere with safe operation.”
What the DER cannot sanction is a simple restatement of the rule such as, “The structure is able to support limit loads”, or the negative version, “There is no detrimental permanent deformation of the structure under limit loads”. The substantiating data should be detailed enough to demonstrate “how” and “why” the repair meets those requirements or if the particular section of the regulation is not applicable, why it is deemed so.
Once the package is complete, the final step is the subject of the next article: Coordination with the DER—Completing the Project
Peter Lauria (www.jtcengineering.com) has over 30 years’ experience with aircraft manufacturers, test equipment manufacturers, repair stations and airlines. He is the owner and principal of JT Consulting, LLC., providing engineering consulting, DER services and ODA guidance.
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.
2015 Global Fleet and MRO Market Assessment – Summary
By CAVOK, a division of Oliver Wyman
This summary details CAVOK’s 2015 assessment and ten-year outlook of the air transport maintenance, repair, and overhaul (MRO) market and a one year out look of the business aviation MRO market, starting with a review of global economic conditions, a key driver for the health of the industry. The global economy is expected to improve in the coming years, but concerns remain over the strength of the recovery. Generally, airlines operate with very thin margins with major cost drivers such as labor, maintenance, and fuel, greatly influencing financial performance. Operators are increasingly relentless in managing costs; with limited leverage over labor and fuel, airlines focus significant attention on managing maintenance expenses.
The global commercial air transport fleet stands at nearly 24,000 aircraft. Approximately one-third is domiciled in North America. Twenty percent is in Western Europe while Eastern Europe has five percent. Asia Pacific, China, and India combined have slightly more than a quarter of the world’s fleet; however, the composition will be changing over the next ten years. The North American share is expected to experience a decline of seven percent; any net growth is limited by the large operators’ significant re-fleeting efforts. The Asian markets anticipate the highest growth rates, representing opportunities for the MRO industry.
Globally, the 2015 air transport jet and turboprop MRO markets are expected to be $67.1B, piercing the $100B milestone by 2025. This represents a healthy 4.1% compound annual growth rate (CAGR). The airframe, engine, component, and line MRO market segments each have a different growth profile:
Airframe MRO 2015 forecast is $14.5B, increasing to $16.7B by 2025. This represents a 1.4% growth rate, the slowest MRO segment during the forecast period. Airlines and their affiliated maintenance providers maintain a solid hold on this market. The airframe MRO market is considered a low-margin, labor intensive segment.
Engine MRO is expected to be $27.9B in 2015; growing at 5.3% annually it will reach $46.8B by 2025. Unlike airframe MRO, the engine segment is largely contracted with the engine original equipment manufacturers (OEMs) having a large share of the market. Engine MROs, recognizing the value of the aftermarket, typically enjoy higher margin work.
Component MRO is forecast to be $12.4B in 2015, growing to $19.2B by 2025, representing a 4.4% annual growth rate. Like the engine MRO business, much of the component segment is contracted, though it varies greatly from one component type to the next. Similarly, the labor and material mix can vary.
Line MRO is pegged at $12.3B in 2015 and forecast to grow at 3.7% annually to $17.8B by 2025. The nature of line maintenance is less prone to contracting, and because the work is labor-intensive and subject to limited ground times in a scheduled operation, the opportunities to take advantage of economies of scale are limited.
An examination of the flow of maintenance work among and between regions reveals that North America contracts more airframe maintenance to the rest of the world than it provides to other regions. Engine maintenance, on the other hand, is just the opposite. North America supports other regions with more capacity and throughput than its region demands. Structural characteristics in the global economy such as labor rate differentials and complex supply chains have led to these trends; however, as the differentiators between developed and developing regions narrow, North America will be ripe to repatriate airframe maintenance currently contracted to other regions.
The business aviation fleet currently consists of nearly 31,400 aircraft requiring roughly $8.8B in MRO market activity in 2015. Nearly 67% (17,814) of the business aviation fleet is domiciled in North America.
In terms of economic activity, MRO plays a significant role. In the United States, approximately 4,023 firms with more than 218,000 employees operate in the civil MRO market (including airline employees). Small and medium-sized enterprises (SME) account for 84% of these U.S. firms and 20% of all employees. There are 141,707 technicians in the U.S. and approximately 37% are certificated.
On Mar. 18, CAVOK Vice President David Marcontell briefed the results of the 2015 Global Fleet and MRO Market Assessment at a congressional luncheon held in conjunction with ARSA’s Legislative Day. To view Mr. Marcontell’s presentation, click here.
For more information, please visit ARSA’s economic data center.
By ARSA Communications Staff
In his TED talk, career analyst Dan Pink examines the puzzle of motivation, starting with a fact that social scientists know but most managers don’t: Traditional rewards aren’t always as effective as we think. Listen for illuminating stories — and maybe, a way forward.
That should be all the motivation you need, click here to get started.
From the ARSA Symposium
Each year, ARSA’s Annual Repair Symposium provides association staff an opportunity to review for members the work done on their behalf.
On Mar. 19, Executive Director Sarah MacLeod and Executive Vice President Christian A. Klein provided this yearly update. To see their presentation and see what ARSA has done for you, click here.
By ARSA Communications Staff
Many factors contributed to the great success of ARSA’s 2015 Legislative Day and Annual Repair Symposium. From dynamic speakers and substantive discussion to a great venue and dedicated staff, many contributed to the aviation maintenance industry’s premier event.
The association is particularly grateful to the businesses who sponsored the event. Without their support, none of the panels, presentations or discussions would have been possible.
Each month, the hotline spotlights key regulatory, legislative, and business leaders making important contributions to the aviation industry. This month we look at Kevin Hiatt, senior vice president of safety and flight operations for IATA.
Kevin Hiatt is the senior vice president of safety and flight operations for the International Air Transport Association (IATA). IATA’s mission in the 70 years of its existence has been to represent, lead and serve the global air transport industry. Our members account for 84 percent of global air traffic – 250 airlines in 117 countries. Hiatt joined IATA in February, 2014.
Prior to joining IATA, he was president and CEO of the Flight Safety Foundation, an international non-profit organization whose sole purpose is to provide impartial, independent, expert safety guidance and resources for the aviation and aerospace industry.
Hiatt had a 26-year career in various positions with Delta Airlines, including chief pilot at the Hartsfield-Jackson Atlanta International Airport Pilot Crew Base from 2002 to late 2005.
Hiatt is a great friend of ARSA’s and an invaluable advocate on behalf of maintenance interests and the aviation community at large. He joined association members for dinner during the Annual Repair Symposium and addressed the group about future opportunities for international development. At the conclusion of his remarks, Hiatt shared the trailer for Aviation: The Invisible Highway.
The best form of advertising is word of mouth. Use the Members Getting Members Toolkit to recruit an ARSA member and your company will receive a discounted membership rate for your next membership term. Get more information at http://arsa.org/membership/members-getting-members/
Target Your Message: Advertise Today in ARSA’s Newsletters and Website!
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 http://arsa.org/advertise/
Exhibit, Sponsor the 2016 Repair Symposium
As the maintenance industry’s top event devoted exclusively to regulatory compliance, the ARSA Symposium attracts a highly qualified professional audience. Use this opportunity to promote your company while showing support for ARSA. Get more information at http://arsa.org/news-media/events/arsa-symposium/arsa-annual-repair-symposium-sponsorship/
Q: Did the FAA change the rule about surrendering a Part 145 repair station certificate? If so, how does a repair station surrender its certificate now?
A: Yes, the FAA did change the rule on voluntary surrender. Under the new section 145.55(a) the agency must “accept” the repair station certificate for surrender. However, the FAA has not given any guidance on how it will administer that acceptance, so the process remains unclear.
If you are surrendering your certificate because you are going out of business, it should be a simple matter of submitting a letter to the agency explaining your circumstances and enclosing the certificate (and all operations specifications). As always, be sure the letter and certificate are delivered via certified mail return receipt requested, or some other verifiable method. Also, make sure to keep a copy of the letter and its attachments.
According to the preamble of the final rule, the new requirement is meant to stop “bad actors” from resubmitting an application for a repair station certificate in the future. Thus, if you are merely closing your doors and are not under investigation as accountable individuals, the following letter format should be sufficient:
NAME OF COMPANY is submitting its 14 CFR part 145 air agency certificate for surrender. The company will no longer exist after X date.
By this delivery the agency accepts surrender of this repair station certificate under section 145.55(a).
AVMRO News Portal
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.
ARSA monitors media coverage on aviation maintenance to spread the word about the valuable role repair stations play globally by providing jobs and economic opportunities and in civic engagement. These are some of this month’s top stories highlighting the industry’s contributions. You can explore these stories through ARSA’s Dispatch news portal.
MRO Americas – Miami – April 14-16
Aerospace Maintenance Competition – Miami – April 14-16
Aircraft Interiors Expo – Hamburg, Germany – April 15
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