2015 – Edition 1 – February 5
Table of Contents
ARSA on the Hill
AVMRO News Portal
Sarah Says – Eye Exam
By Sarah MacLeod, Executive Director
Hindsight is 20/20, but successful trade associations must see forward with the same clarity. ARSA works by looking ahead and getting its members on course for destinations not yet mapped.
ARSA 20/20, the association’s strategic plan, is the central tool in this work. Strategic planning is a regular process for determining (and changing) priorities, establishing goals and plotting strategies for improving services to our members. A good strategic plan tells us where the organization is going and how it gets there.
Still, there’s a more important component: Why? The goals and objectives we outline means little if we fail to capture the underlying purpose being served. The answer to this all-consuming question is the vision.
ARSA’s vision is to ensure its members can perfectly manage the intersection of business and government. The association seeks to find the exact boundary between professional responsibility and government oversight. We know good safety is good business; we seek the point of good government, too.
In this pursuit, we’ve updated our strategic plan – a “living document” needs constant attention to stay valid. The new ARSA 20/20 will continue to bolster the association in four key areas:
- Advocacy and compliance assistance to manage an increasingly complex regulatory environment.
- Lobbying and media relations to affect the uncertain—and in many cases, hostile—legislative environment.
- Business programs to reduce costs and improve competitiveness in an erratic global economy.
- Workforce development to attract and train the next generation of skilled workers to the aviation maintenance industry.
In short, every day we’re building an efficient, effective organization with a broad reach and international impact. It has many goals, but one purpose: to serve a vision for you.
In aviation, clear vision is a beautiful sight.
ARSA on the Road: Landing at COOPESA in San Jose, Costa Rica
By ARSA Communications Staff
Every year, countless tourists from all over the world descend upon Costa Rica searching for “Pura Vida” (the pure life), the beautiful weather and the country’s natural beauty. Upon arrival, most visitors to Juan Santamaria International Airport won’t notice that less than an American football field away from the main terminal sits one of the preeminent aviation maintenance companies in the world— Cooperativa Autogestionaria de Servicios Aeroindustriales (COOPESA).
While undetected by the untrained eye, the citizens of Costa Rica and the aviation maintenance community are keenly aware of the company’s well-deserved reputation. Established in 1963, COOPESA employs 750 highly-skilled workers and has FAA and EASA certifications, among others. On Jan. 20, ARSA’s Vice President of Legislative Affairs Daniel B. Fisher visited the company’s headquarters and was treated to a tour by ARSA Board Member and COOPESA Quality and Safety Director Warner Calvo.
“It’s an invaluable experience for ARSA staff to visit member companies,” said Fisher upon returning to Washington, D.C. (though not as tan as we hoped). “While foreign repair stations have a unique set of challenges, interestingly many of the issues are very similar to U.S. MRO companies, such as managing relationships with local inspectors and customers, finding and retaining skilled workers and navigating an overly burdensome regulatory climate. And just as in the United States, there are no shortcuts—safety is the absolute top priority.”
While some in Washington, D.C., and in the media demonize contract maintenance, in particular foreign repair stations, Fisher invites them to visit companies like COOPESA. “Security was top notch. The shop floor is clean and the employees are courteous, dedicated professionals. Customers oversee repairs and maintenance directly. As with every repair station I’ve visited, a culture of safety and security was pervasive throughout the company,” Fisher commented.
A highlight from the visit was a briefing by Calvo and his team on COOPESA’s planned expansion. Ground will be broken soon on a new facility, not far from the current location, that will allow it to service more customers with increased efficiency. “The excitement exuded by Warner and his colleagues was evident when discussing the new facility. COOPESA is growing and the employees are eager to be a part of the company during expansion,” said Fisher.
“It’s important for ARSA staff to get out and visit aviation maintenance companies,” said ARSA Board Member Calvo. “I know Daniel learned a great deal about COOPESA while in Costa Rica, but it was an educational experience for us too. Calvo added, “Despite vacationing, Daniel took the time to visit COOPESA and meet with our staff. A hands-on approach is one of the many reasons that ARSA is so valuable and further evidence that the association’s work on our behalf never rests.”
Thank you to Warner Calvo and the COOPESA team for opening their doors to ARSA. Do you want an ARSA staff member to visit your facility? Please let us know at arsa@ARSA.org.
Have You Met OFMK? ARSA’s Management Firm, Your Contingency Plan
By Brett Levanto, Director of Operations
You know that ARSA works for you, your business and the aviation maintenance industry every day. Who’s working for ARSA?
Obadal, Filler, MacLeod and Klein, PLC, (OFM&K) an Alexandria, Virginia based law firm, manages the association’s business affairs, member services, and regulatory and legislative engagement. If you see an ARSA logo on it, there are OFM&K minds behind it.
The firm’s regulatory team has worked for airlines and repair stations, providing a unique perspective on the interplay between business and regulation. When disputes with regulators arise, OFM&K is a zealous advocate and works to resolve the matter so repair stations can focus on serving customers.
What does this mean for you? In addition to providing you world-class service every day, ARSA’s managers are your insurance policy against the unexpected. Members receive discounted rates on legal fees, so when trouble comes your way there’s always someone in your corner.
How can OFM&K help you? Let’s talk about it.
ARSA to Congress: Overregulation Hinders Growth, Competitiveness
By ARSA Legislative Staff
On Jan. 15, ARSA Vice President of Legislative Affairs Daniel B. Fisher laid out the association’s legislative agenda in a letter to congressional leadership. Fisher focused on economic growth, operational freedom and safety on behalf of the aviation maintenance industry.
As Congress enters another FAA reauthorization cycle, ARSA’s top priority is ensuring lawmakers understand government and aviation maintenance companies share the same safety goals and that Washington must refrain from micromanaging industry with unnecessary, burdensome mandates. “The basic nature of the aviation industry demands that safety and security are paramount,” the letter states. “Operators and airlines will not do business with companies that put passengers and valuable business assets (i.e., aircraft) at risk. Put simply: good safety is good business.”
“The new Congress has a unique opportunity to start with a clean slate for aviation maintenance,” said Fisher. “Past FAA reauthorizations have been fraught with battles over proposals that would detrimentally impact repair stations by imposing duplicative and unnecessary government mandates that would hurt international competitiveness and increase administrative costs for this small business-dominated industry. Lawmakers must focus on addressing real threats to the U.S. aviation sector’s effectiveness and flight safety, not manufactured economic and safety assertions.”
Additionally, the association pressed the 114th Congress to adopt regulatory reform and due process protections for regulated entities, encourage bilateral aviation safety agreements, provide necessary resources for the FAA, restore tax certainty and simplification and address one of the industry’s greatest challenges: the dearth of skilled, technical workers.
For more information about ARSA’s legislative program, please visit: http://arsa.org/legislative.
ARSA Submits Statement to T&I Committee Hearing
By Legislative Staff
On Jan. 21, the House Transportation & Infrastructure Committee held a hearing on “Reforming and Streamlining the FAA’s Regulatory Certification Processes.”
The association submitted a statement to the record. In that submission, Vice President of Legislative Affairs Daniel Fisher noted: “ARSA members are routinely plagued by the FAA’s inconsistent application of its regulations; the lack of consistency threatens aviation safety, economic growth and job creation. The lack of regulatory standardization particularly impairs small businesses, which are predominant in the civil aviation industry.”
Watch the full hearing:
- Mr. Ray Conner, President and CEO, Boeing Commercial Airplanes, The Boeing Company
- Mr. Aaron Hilkemann, President and CEO, Duncan Aviation
- The Honorable Chris Hart, Acting Chairman, National Transportation Safety Board
- Ms. Dorenda Baker, Director, Aircraft Certification Service, Federal Aviation Administration
- Dr. Gerald Dillingham, Director of Civil Aviation Issues, Government Accountability Office
President Unveils Free Community College Plan
By Brett Levanto, Director of Operations
On Jan. 9, the White House unveiled a proposal to make two years of community college free for many students. At the same time, President Obama announced a new American Technical Training Fund to prepare Americans for better-paying jobs by connecting skills development to the needs of employers.
Building on a model that has been used by Tennessee and Chicago, the president’s America’s College Promise proposal would allow students to attend community college with two-years of tuition paid for by federal and state governments.
Given the federal budget situation and the ongoing debate about the proper role of the federal government, there are considerable questions about whether making community college a new entitlement is the right course of action. But ARSA commends the administration for highlighting the country’s skilled, technical worker shortage and looks forward to working with Congress and the president on this important issue. Simply put, the aviation maintenance industry depends on trained technicians and there are important opportunities for the federal government to help get more workers into the pipeline.
Stay tuned for more updates as the association continues its advocacy on workforce policy issues in the months ahead. For more information on the president’s proposal, please visit: http://www.whitehouse.gov/the-press-office/2015/01/09/fact-sheet-white-house-unveils-america-s-college-promise-proposal-tuitio
ARSA on President’s Budget: Politics Aside, Good Safety is Good Business
Daniel Fisher, vice president of legislative affairs for the Aeronautical Repair Station Association (ARSA), issued the following statement in response to President Obama’s Federal Aviation Administration (FAA) fiscal year 2016 budget proposal. The administration has requested $15.8 billion, including $9.915 billion for agency operations, a slight increase over current funding levels. However, the White House also proposes once again to alter business aircraft depreciation schedules.
“ARSA commends the administration for requesting Congress provide the FAA more resources to do its job. For repair stations, good safety is good business and the maintenance sector is dedicated to continuing its impeccable safety record regardless of government oversight. However, since aviation maintenance companies rely on the FAA for congressionally-mandated certifications and inspections, any shortfall results in administrative delays and ultimately undermines American competitiveness.
“Unfortunately, the administration’s call to reduce the depreciation schedule for general aviation aircraft is an unnecessary political gambit. It will impact the entire aviation industry – a sector that lifts the American economy, creating jobs for millions of people in communities across the country – from parts suppliers to repair stations. ARSA encourages lawmakers to reject measures that would hurt the hardworking men and women who keep the nation safely in flight.”
To see all the ways that ARSA is working as the voice of the aviation maintenance industry, visit our ARSA Works page.
Industry to FAA: Repair Stations Know When to Fold ‘Em
By Brett Levanto, Director of Operations
On Jan. 9, a coalition of aviation trade associations petitioned the FAA to restore the right to voluntarily surrender a repair station certificate.
In its new repair station rule, which became effective in November 2014, the FAA took the unprecedented step of subjecting surrendered certificates to “acceptance for cancellation.” The coalition called for the removal of this requirement, which is unique among aviation certificates, runs counter to the interest of aviation safety and increases regulatory administrative burden without any agency explanation as to how the new discretion will be utilized.
“It is critical for any aviation business to be able to voluntarily surrender its certificate,” said Laura Vlieg, ARSA’s regulatory affairs manager . “The FAA has set a dangerous precedent by treating maintenance providers differently from any other certificate holder. The aviation community quickly realized the implications and has asked the agency to put repair stations back on equal footing.”
The group points out that the FAA’s ability to investigate individuals is unaffected by the surrender of the entity’s certificate. Therefore, denying a repair station’s right to voluntarily surrender its certificate bears no rational connection to the aim of ensuring safety through the investigation and banishment of “bad actors.”
“We do not support individuals that use any certificate irresponsibly or in a manner that jeopardizes safety,” said Sarah MacLeod, ARSA’s executive director. “We do however have to deal in the real world; business demands make it too problematic for surrendered certificates to depend on the administrative whims of the FAA.”
In addition to ARSA, the group included the Aerospace Industries Association, the Aircraft Electronics Association, the Aviation Suppliers Association, the General Aviation Manufacturers Association, Helicopter Association International, the Modification and Replacement Parts Association, the National Air Carrier Association, the National Air Transportation Association and the Regional Airline Association.
ARSA to FAA: “Or New” Unacceptable
By Laura Vlieg, Regulatory Affairs Manager
On Jan. 29, ARSA asked the FAA to clarify when the new owner of a repair station can apply for an amended versus a new certificate.
The change to the repair station rule, which became effective Nov.10, 2014, revised Title 14 Code of Federal Regulations (CFR) section 145.57(b). That section states the new owner of repair station assets “…must apply for an amended or new certificate in accordance with § 145.51.” (Emphasis added).
The addition of the words “or new” was not even mentioned in the notice of proposed rulemaking, but the FAA reasoning is that “[t]he revision clarifies that a new owner will need to apply for a new certificate only if the new owner chooses to operate as a repair station.”
The change was totally unnecessary, and creates confusion rather than clarity. While ARSA appreciates that a repair station certificate cannot be transferred, amending one takes fewer resources for both industry and agency. Considering the current waiting time for a new certificate can be up to two-years, any uncertainty regarding the application is unacceptable.
“It should be very clear by now how much trouble can be caused by a misplaced or unnecessary word in the regulations,” said Sarah MacLeod, ARSA’s executive director. “I say that because ARSA has been making exactly that point for months: Since the new repair station rule was announced last year this association has been working to scrap every one of these ‘broken parts,’ since they offer no safety benefit to the flying public and represent immeasurable administrative burden for repair stations.”
Along with its letter, ARSA submitted suggested changes to guidance material. The association asked the agency make clear an application for a new certificate is only required where the new owner opts for a new certificate number. And even then, the processing interval should depend upon the changes the new owner makes to the location, housing, facilities, equipment and personnel.
ARSA to FAA: Nothing Generic About AD Info Collection
By Laura Vlieg, Regulatory Affairs Manager
On Jan. 29, ARSA objected to the generic clearance of information collections contained in Airworthiness Directives (ADs). Although the practice has been going on for years, the recent request for renewal of the generic collection prompted the association to take action.
The Paperwork Reduction Act (PRA) mandates that federal agencies obtain the Office of Management and Budget’s (OMB) authorization to collect information from the public. Each request must be evaluated according to criteria including the requirement for “a specific, objectively supported estimate of burden.”
Generic information collection approvals are not specified in the PRA; rather they are allowed by an OMB memorandum that sanctions them for activities that are “usually voluntary, low-burden, and uncontroversial.” Where the OMB provides generic approval, the requesting agency outlines a plan providing an estimate of the average burden imposed on respondents, but does not need to seek public comment on each specific collection.
ARSA provided evidence that generic clearance is ill-suited for ADs where each information collection is unique and requires the individualized approval mandated by law. Additionally, the association pointed out that the FAA’s estimate of a five minute burden per response was inaccurate and misleading.
ARSA, ATEC Capitalize on Update to O’Brien Awards
By Brett Levanto, Director of Operations
On Jan. 21, ARSA and the Aviation Technician Education Council (ATEC) submitted joint comments on FAA Draft Advisory Circular (AC) 65-25F, “William (Bill) O’Brien Aviation Maintenance Technician Awards Program.”
The O’Brien Awards
Through the William (Bill) O’Brien Awards Program, the FAA recognizes eligible technicians who receive and businesses that promote professional development. The program was founded in 1991 to create an incentive for AMT employees and employers to participate aggressively in maintenance training courses.
Updating AC 65-25
The agency’s purpose for updating the AC was to provide a general overview of the program and direct potential participants online for further information. To ARSA and ATEC, the update represents an opportunity to improve the document in other ways. Most notably:
- Adding part 147 Aviation Maintenance Technical Schools (AMTSs) to the list of acceptable instruction or course providers. Individuals should be encouraged to take refresher courses from these FAA-controlled institutions. For their part, the schools should have an incentive to provide classes (and many do as IA renewal seminars) that do not meet the definition of “college level course” in the AC.
- Removing the three-employee requirement from eligible companies. Any company that engages in aviation services should be supported by this program, no matter the size.
To view the entire submission, including a suggested version of the AC with red-lined changes, please click here.
Government Can’t Work in ISO-lation – ARSA Submits FOIA Request
By Zach F. Bruckenstein, Advocacy Manager
ARSA works to ensure consistent application and enforcement by holding the FAA accountable to its policies and procedures. To do this, the association and its members need access to the most current documents, guidance and resources used by the government.
In 2006, FAA Aviation Safety (AVS) implemented an International Organization for Standardization (ISO) 9001:2000 compliant Quality Management System (QMS). The agency is certified under the updated 9001:2008 accreditation, but has failed to make its QMS documents available so the public can understand the way government is currently conducting business.
So what do all of these numbers and acronyms mean? The QMS helps an organization provide consistent and effective service to its customers. In the FAA’s case, the public (including certificate holders) is the customer and every regulation, guidance or enforcement action is the service. While the agency’s website has an older version of its QMS guidance, the latest is not available nor are the policies and procedures used to show compliance to the standard. So, on Thursday, Jan. 22 ARSA submitted a Freedom of Information Act Request (FOIA) seeking the records and manuals pertaining to the AVS QMS.
Once ARSA receives these materials, it will conduct a thorough review to ensure it understands how the AVS QMS is supposed to be working. Understanding how the government has promised to conduct its business will allow customers to provide meaningful feedback.
The Right Stuff: Working for a Better 145
By Laura Vlieg, Regulatory Affairs Manager
The latest changes to the repair station rule became effective in November 2014. ARSA is still working to make the regulation better. In September, a coalition of aviation trade groups successfully petitioned the FAA to reinsert the word “serious” into the service difficulty reporting requirement (14 CFR § 145.221). While a major victory saving incalculable cost, there is more being done.
ARSA is spearheading efforts to reinstate a repair station’s ability to voluntarily surrender its certificate. Since implementation of the repair station rule, surrendered certificates are subject to FAA “acceptance for cancellation.” The agency has yet to give guidance on how or when it will use its newly minted discretionary authority to accept or reject surrendered certificates. This administrative uncertainty creates confusion and additional expenses when selling assets and winding up a business – the normal reasons for surrendering a certificate.
On Jan. 9, a coalition of trade groups submitted a petition for rulemaking asking the FAA to reinstate a repair station’s ability to voluntarily surrender its certificate and put those certificates back on equal footing with other certificate holders. That coalition includes the Aerospace Industries Association, Aircraft Electronics Association, Aviation Suppliers Association, General Aviation Manufacturers Association, Helicopter Association International, Modification and Replacement Parts Association, National Air Carrier Association, National Air Transportation Association and Regional Airline Association.
In the final rule, the FAA claimed that requiring its acceptance of a voluntarily surrendered certificate “will prevent a repair station under investigation from attempting to circumvent a possible enforcement action.” That reasoning confuses individual bad actors with the repair station. The FAA already has the authority to deny a repair station certificate where key positions will be filled by individuals who materially contributed to the revocation of a certificate or the initiation of revocation proceedings for a current certificate holder. Thus requiring agency acceptance of a voluntarily surrendered certificate is without reason and imposes an unnecessary administrative burden on industry and the agency. After the repair station surrenders its certificate, the agency can still investigate and take action against individual bad actors and deny repair station certificates with bad actors in key positions.
Ultimately, the requirement for affirmative agency acceptance of a repair station certificate runs counter to interests in aviation safety. When individual bad actors are using a repair station certificate, the agency’s primary concern is the immediate cessation of work that could potentially jeopardize safety. That concern is evident in the context of air carriers and other certificates where no agency acceptance of surrender is required. By requiring an “acceptance for cancellation” of a voluntarily surrendered certificate, work (or operations) may continue, potentially jeopardizing safety.
These and other concerns are articulated in the submitted petition, which ARSA members should support. The ultimate aim of the agency is to set standards for and oversee aviation safety; it need not expend resources on unnecessary actions. The petition merely requests that repair stations retain the same ability all other certificate holders enjoy, to voluntarily surrender a certificate.
To submit comments in support of the petition, go to the docket and click the “comment now” button.
Click here to download a customized comment template.
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 on the Hill
We Need You! Plan Ahead to Attend Legislative Day
As bitter cold descends upon Washington, D.C., and much of the United States, it’s hard to believe spring is right around the corner. The season of chirping birds, blooming flowers, and ARSA’s Legislative Day (Mar. 18) is almost here.
A March tradition, Legislative Day is a rite of passage for ARSA members. It’s the aviation maintenance industry’s premier public policy event and allows participants to become lobbyists for the day (without the negative connotations reserved for the most hated profession in America). You’ll be briefed and well-prepared to discuss the association’s legislative priorities with lawmakers and staff, including urging Congress to:
- Refrain from implementing unnecessary regulatory mandates.
- Reform the regulatory process.
- Encourage bilateral aviation safety agreements (BASAs).
- Give the FAA the resources to do its job.
- Ensure a skilled and dynamic aviation workforce.
- Restore tax code certainty and simplification.
Congress hears from ARSA’s legislative team throughout the year; however, representatives need to receive the message directly from you—the voter.
This year’s Legislative Day will also feature a congressional briefing luncheon where ARSA will unveil its 2015 MRO economic data and the Capitol Hill premiere of the aviation maintenance industry documentary. With the FAA reauthorization process right around the corner, it’s never been more important for the aviation maintenance sector to advocate for the industry’s priorities on Capitol Hill.
We hope you’ll mark your calendars and plan to be with us on Mar. 18. ARSA’s legislative team is standing by to make Legislative Day easy and enjoyable.
Need help scheduling Capitol Hill meetings? Clarification on legislative priorities? More reasons to attend Legislative Day? Contact me directly and we’ll see you soon!
What We Do – FAA’s Continued Operational Safety Policy Section
By Keith Lardie, Aerospace Engineer, FAA Operational Oversight Policy Branch (AIR-140)
How do I make it so it doesn’t sound so bureaucratic? Never mind, too late.
Since you haven’t skipped ahead to the next article and decided to read on, I’d like to introduce you to the roles and responsibilities of my office ahead of our presentation and discussion at the 2015 Annual Repair Symposium.
Within the Aviation Safety’s Aircraft Certification headquarters’ division, the office for our Continued Operational Safety Policy Section is located in Oklahoma City. We are responsible for standardizing policies FAA offices use when:
- Developing airworthiness directives (including the supporting regulations).
- Engineering acceptance data for repairs and alterations.
- Assessing potential risk to a product’s design.
We also maintain the Regulatory and Guidance Library (http://rgl.faa.gov) where you can find information on FAA regulations (Title 14 Code of Federal Regulations), design approvals, advisory circulars and other policy documents.
Over the last few years, we have implemented policies that move away from using individual qualitative information, often called “engineering judgment,” to a more structured and consistent data-driven approach to assessing risk. This risk-based decision making approach is dependent on the availability of good data. In that capacity, we are a part of the internal FAA team that has been reaching out to many aviation industry organizations to help shape our concept for the service that will upgrade and absorb our current safety defect reporting systems, including our Service Difficulty Reporting System.
Our approach is basic: we need to make it faster and easier to communicate potential safety information, both submitting information about possible safety problems as well as providing the necessary fleet-wide information to those responsible for maintaining safe and airworthy aircraft.
Join Mr. Lardie and his team at this year’s Annual Repair Symposium in Alexandria, Virginia. Register now.
Final Documents/Your Two Cents
This list includes Federal Register publications, such as final rules, Advisory Circulars, and policy statements, as well as proposed rules and policies of interest to ARSA members. To view the list, click here.
Many Signs of New Life – For Industry, ARSA and Its Partners
By Brett Levanto, Director of Operations
In March, ARSA will release its annual Global MRO Market Assessment. This year’s release marks a special milestone for the consulting firm formerly known as TeamSAI, the association’s partners in providing analysis and insight into the growing aviation maintenance market.
On Feb. 2, Atlanta-based TeamSAI was acquired by Oliver Wyman to be integrated into CAVOK, the firm’s aviation technical services and consulting practice. The combined entity creates a deep source of expertise with over 130 dedicated, full-time specialists who assist airlines, MRO providers, lessors and other aviation and aerospace stakeholders with mission-critical issues surrounding certification, safety and performance and execution support for technical operations.
CAVOK will be at this year’s Legislative Day and Symposium, be sure to see them.
“The expanded content from this change of ownership should be a great advantage in providing even wider content and resources to ARSA and its members,” said Chris Doan, friend of the association and new vice president of CAVOK.
Read the full release from Oliver Wyman.
To celebrate this union, and to look forward to the 2015 Global MRO Economic Assessment, this month’s Quality Time highlight highlights Signs of New Life, the report of Oliver Wyman’s MRO Survey 2014. Going on its second decade, the annual survey is an industry standard for information about changing trends in aviation maintenance.
MRO Survey 2014: Signs of New Life – New Partnerships, Fresh Hiring, 3D Printing
Authors: Chris Spafford, Partner and Darryl Rose, Principal
Original equipment manufacturers won the market for high-value, aftermarket aviation services, leaving independent maintenance, repair and overhaul providers scouting for paths to evolve and grow.
The survey found engine and component MROs are preparing to fortify their remaining footholds through strategic partnering and by accelerating development of unique services. Airframe MROs, meanwhile, seek to capitalize on shifts caused by rising labor costs in emerging economies.
- M&A in the sector to heat up.
- S. MROs to step up hiring.
- 3-D printing to be used to make expendable parts, but not proprietary materials.
Have you read the full report? Download it now at: http://www.oliverwyman.com/insights/publications/2014/apr/mro-survey-2014.html.
Personal Development – Managing Your Time
By ARSA Communications Staff
Time management tips that help everyone from busy executives to new employees get more out of their work day. Learn how to think differently about time management, embrace the 80% rule, find your “Einstein” window, protect that window, and broadcast your availability to ensure others know when you’ll be available.
Click here to get started. (Don’t worry, it’s short.)
School’s In Session – Regulatory Training at Heli Expo
By Brett Levanto, Director of Operations
Going to HAI HELI-EXPO 2015 in Orlando, Florida? ARSA’s great regulatory minds will be there, and a front-row seat is waiting for you.
Marshall S. Filler and Sarah MacLeod, the association’s foremost experts in regulatory compliance (and managing members of the firm of Obadal, Filler, MacLeod and Klein, PLC) will be leading professional education courses at HAI HELI-EXPO. Register now to make the most of your time in Florida and get to the head of class.
Regulations 101 – Law for the Aviation Professional
Mar. 1, 8:00am to 5:00pm
Marshall S. Filler and Sarah MacLeod
This one-day course will cover the basic FAA requirements associated with making day-to-day decisions on purchasing, designing, manufacturing, operating, maintaining, or selling civil aviation products and parts.
Dealing with the Government
Mar. 2, 8:00am to Noon
As a certificated entity, dealing with the government, particularly the FAA, is inevitable. Building a good relationship with government officials in good times will help keep the bad times at bay. The course will also review best practices for handling FAA audits and investigations.
Mar. 2, 1:00pm to 5:00pm
Marshall S. Filler
This course covers the basic requirements for an aircraft to be operated as a public aircraft on behalf of federal, state, and local governments, including the difference between government-owned and government-leased aircraft, what constitutes an eligible governmental function, and the practical implications of using the same aircraft to conduct both civil and public operations.
Regulatory Compliance Training
Test your knowledge on § 145.205 – Maintenance, preventive maintenance, and alterations performed for certificate holders under parts 121, 125, and 135, and for foreign air carriers or foreign persons operating a U.S.-registered aircraft in common carriage under part 129.
Member Spotlight: Aviation Institute of Maintenance – Nationwide
By Kelsi Oliver, Communications Coordinator
Aviation Institute of Maintenance (AIM) is an FAA part 147-certificated Aviation Maintenance Training School (AMTS) with locations across the United States. Offering training to become maintenance technical engineers, maintenance technicians and avionics technicians, AIM features accreditations, association memberships and strong graduation rates.
In addition to its ARSA membership, the Institute is a central part of the Aviation Technician Education Council, a valuable partner in the work of providing repair stations with a world class technical workforce. To include educational members like AIM under the association’s broad base of support means resources and insight into the needs of the institutions that supply the aviation maintenance industry with the human capital it needs to thrive.
For more information concerning the Aviation Institute of Maintenance, please visit http://www.aviation.edu.
Are you an ARSA member who would like to be in the “Member Spotlight?” If so, please contact Kelsi Oliver at Kelsi.Oliver@arsa.org.
Each month, the hotline spotlights key regulatory, legislative, and business leaders making important contributions to the aviation industry. This month we look at U.S. Frank A. Lobiondo (R-N.J.).
Congressman Lobiondo serves as chairman for the U.S. House of Representatives Subcommittee on Aviation. Built inside the Transportation and Infrastructure Committee (T & I), the subcommittee counts the FAA as one of the few agencies within its jurisdiction. In addition to these agencies, the group also oversees all aspects of civil aviation, including labor, safety, infrastructure, commerce and international aviation issues, as well as unmanned aircraft systems.
Lobiondo displayed his interest in FAA reauthorization during the Jan. 21 hearing of the Full Committee on Transportation and Infrastructure: “FAA Reauthorization: Reforming and Streamlining the FAA’s Regulatory Certification Process.” Thanking T&I Committee Chairman Bill Shuster for “elevating the issue to the full committee level because of its critical importance,” Lobiondo made use of the witnesses before him. His main concern seemed to be the FAA’s certification process’s effect on the represented businesses (Boeing and Duncan), questioning the impact it has on aviation companies’ ability to compete and innovate. He also demonstrated his alertness to other countries’ regulatory processes, asking whether or not the agency’s methods are hindering their advancement with “global competition that is dealing with some different standards.”
Lobiondo grew up in southern New Jersey and has served the region on the county, state and federal levels ever since. He takes great pride in his role on the Subcommittee of Aviation given its critical importance to his district and home.
Take Advantage of ARSA’s Members Getting Members Program, Get 10% Off on Membership Dues
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 recently updated its 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 2015 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: If a part 121 operator requests a maintenance activity be performed on its equipment through the use of an engineering order (EO), for which the parts and processes are not described in the applicable component maintenance manual (CMM) or approved by the design approval holder (DAH), can an 8130 still be issued by simply referencing the work was done in accordance with the Operators EO in block 12, and not the CMM?
A: The performance standard requires that maintenance, preventive maintenance and alterations performed on articles that will be installed on aircraft with U.S. certificates of airworthiness (see section 43.1) be performed in accordance with methods, techniques and practices acceptable to the FAA (see section 43.13). Those methods, techniques and practices (“how-to instructions”) are usually contained in aircraft, engine and component maintenance and overhaul manuals.
However, sections 43.13(c) and 145.205 (see thehotline’s Regulatory Compliance Training for this month) set forth the requirements for performing maintenance for or on a particular air carrier aircraft. Those sections make clear the “how-to instructions” developed by the air carrier is acceptable to the FAA (section 43.13(c)) and must be followed by the repair station (section 145.205).
As a repair station, you must follow the air carrier’s section 43.13(c) developed methods, techniques and practices, which, in this case, is the EO.
AVMRO News Portal
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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.
The FAA is very concerned about counterfeit aircraft parts. They call them Suspected Unapproved Parts (SUP). Having any in your inventory could be a legal disaster!!
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