Registration is officially open for ARSA’s 2018 Executive to Executive Briefings, Legislative Day and Annual Repair Symposium.

Click here to reserve your spot now.

This year, ARSA’s team is planning a series of executive branch meetings on Tuesday, March 13 for senior industry executives. Modeled on the association’s successful Strategic Leadership Conference, the “Executive to Executive” (E2E) briefings will further raise visibility among policymakers and expand the scope of the repair station community’s premier event. (Priority registration for this additional day is available to event sponsors at the Platinum and Gold levels.)

To see what’s planned — an expanded, four-day schedule of meetings, presentations and interaction — and to register, click here.

A block of rooms has been reserved at the preferred federal government rate for event participants at the Ritz-Carlton Pentagon City in Arlington, Virginia (where conference sessions will take place on Wednesday, Thursday and Friday). While the booking information was not available when the initial registration alert was distributed, readers of the hotline get first crack at the block of rooms: click here to reserve your room.

Don’t waste a click…submit your registration right here…

2018 Registration & Sponsorship Form

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Unified Agenda Provides Insight into 2018 Rulemaking Priorities

On Dec. 18, the Trump Administration unveiled its Unified Agenda of Regulatory and Deregulatory Actions for 2018. The document provides insights about the priorities and planned actions of executive branch departments and agencies for the coming year. 

According the Department of Transportation’s preamble, the FAA will focus its resources on four major strategic initiatives in 2018:

• Risk-based Decision Making. Building on safety management principles to proactively address emerging risk by using consistent, data-informed approaches to make smarter, system-level, risk-based decisions.
• National Air Space Systen (NAS) Initiative. Laying the foundation for the NAS of the future by achieving prioritized NextGen benefits to enable the safe and efficient integration of new entrants (including unmanned aerial systems, supersonic aircraft and commercial space flights) and delivering more efficient, streamlined air traffic management services.
• Global Leadership. Improving safety, air traffic efficiency and environmental sustainability across the globe through an integrated, data-driven approach that shapes global standards, enhances collaboration and harmonization, and better targets FAA resources and efforts.
• Workforce of the Future. Preparing FAA’s human capital for the future by identifying, recruiting, and training a workforce with the leadership, technical and functional skills to ensure the United States has the world’s safest and most productive aviation sector.

The preamble indicates the FAA plans to publish two notices of proposed rulemaking addressing UAS and commercial space technologies (Small Unmanned Aircraft Over People, 2120-AK85 and Orbital Debris Mitigation Methods for Launch Vehicle Upper Stages, 2120-AK81), in addition to addressing the previously published Interim Final Rule on Registration and Marking Requirements for Small Unmanned Aircraft (2120-AK82) and publishing an advance notice of proposed rulemaking seeking comment on UAS security-related issues (Safe and Secure Operations of Small Unmanned Aircraft Systems, (2120-AL26).

The FAA’s top deregulatory actions will involve issuing two final rules. The first, Transport Airplane Fuel Tank and System Lightning Protection, (2120-AK24), would amend certain airworthiness regulations regarding lightning protection of fuel tanks and systems. The Rotorcraft Pilot Compartment View (2120-AK91) rulemaking will the testing requirements for pilot compartment view to alleviate the cost of the flight test and reduce administrative burdens on affected applicants.

Finally, the FAA will focus on two rules related to airline safety and pilot training improvements. The first will establish an electronic pilot record database that air carriers would use for pre-employment checks on pilots (Pilot Records Database, 2120-AK31). The second will implement improvements to pilot training and professional development programs to address mentoring, leadership, and professional development of flight crewmembers (Professional Development, (2120-AJ87).

The agenda also provides a snapshot of the status of all rules currently under consideration by FAA (see table below).  The pre-rule stage indicates FAA is determining whether or how to initiate rulemaking. The proposed rule stage indicates that FAA plans to publish or has published a Notice of Proposed Rulemaking. Rules indicated as being in the final stage are actions for which FAA plans to issue a final or interim rule. Long-term actions are those which the FAA is considering but not expecting to action on in the coming year.

When reviewing the table below, it’s important to keep in mind that the fact that the item isn’t included doesn’t necessarily mean the FAA will act on it in the coming year – just like the inclusion of an issue here does not guarantee government action. A review of last year’s Unified Agenda indicates that many items have been carried over and their status has not changed.

FAA Internal Training on Repair Station Certification Open to Industry

From Jan. 8-12, 2018, the FAA is hosting the year’s first installment of its week-long training session “Certification and Surveillance of Part 145 Repair Stations.” It will be administered in person at the FAA Academy in Oklahoma City and is open to industry enrollment.

The course is designed to provide aviation safety inspectors with knowledge and skills necessary to participate as certification project team members for repair stations. Attending a session like this is the perfect opportunity for an industry professional to go directly to the source and see what the FAA is teaching its own personnel; it helps a lot to understand the perspective of an ASI if you know what they’ve been told about the rules…and it provides an opportunity to help the agency make the whole process better.

The course includes:

(1) Information on the differences between certification of repair stations located inside and outside the United States.
(2) Overview of international agreements for maintenance.
(3) Instruction on application of risk-based certification management.
(4) Review of what ASIs should look for during continuing surveillance.

Click here to view course information on the FAA Academy website.

A limited number of seats are available. Anyone interested in attending can initiate a request by emailing Carl Hayes at carl.hayes@faa.gov. The following information should be included in the initial message:

• Requesting organization.
• Contact name.
• Email address.
• Phone number.
• Number of students from requesting organization.
• Name and email address of each student.
• Number and name of the requested course: 21058 Certification and Surveillance of Part 145 Repair Stations.
• Training date: Jan. 8-12, 2018.
• Tuition cost per student per class: $622.56.

Once students are enrolled, they will receive a welcome letter from the course manager providing specific instructions for access to the facility. For more information on logistics, individuals can reach out to the FAA Academy Student Services Section. Information regarding lodging options is also available through the FAA Academy Housing List. 

Beginning with the session in January, the course is currently scheduled to be held ten times in 2018. While seat availability cannot yet be determined for future sessions, consider contacting the FAA about getting your people into the classroom.

In case you can’t make it to Oklahoma…

ARSA Online Training Resources

The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit PotomacLaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.

Featured Course (Click title for more information)

Part 145 – From Soup to Nuts

Live FAA Training Session on China IPA

Click the image to register for the training session.

On Jan. 17 at 1:00 p.m. EST, ARSA will host an online training session led by FAA personnel on the Implementation Procedures for Airworthiness (IPA) established under the Bilateral Aviation Safety Agreement between the United States and China. This session mirrors the presentation delivered to FAA staff in November 2017, focusing on the use of the IPA when the FAA is acting as the certifying authority.  It is intended to provide industry with the background and major concepts of the agreement, and highlight specific areas relevant to CAAC validation of U.S. products.

Presenters

Tom Groves is a Supervisory Aerospace Engineer in the FAA’s Aircraft Certification Service Transport Standards Branch.  He is currently working on temporary assignment with the International Division, providing technical expertise to support development of high-priority bilateral agreements such as the EASA TIP and the IPAs with both China and Brazil.

Daniel Commins is a Foreign Affairs Specialist in the FAA’s Aircraft Certification Service International Division.  As the focal point for AIR’s international engagement with China, he manages the bilateral relationship and manages projects such as IPA development and other bilateral activity.

Agenda

(1) FAA – CAAC IPA Status and Background
(2) FAA – CAAC IPA Change Management Plan
(3) Q&A
(4) FAA – CAAC IPA Key Validation Concepts
(5) Validation Process Overview – FAA as the Certifying Authority
(6) Summary
(7) Q&A

Target Audience

Aviation industry professionals and stakeholders with interest in the FAA’s administration of international aviation agreements.

Registration

Special Session Price: $30 (ARSA Members and Non-Members)

Click here to register.

Registration for this ARSA-provided training session includes:

• Unlimited access to the recording for 90 days after the live session is complete.
• A copy of the presentation and all reference material with links to relevant resources and citations.

The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit PotomacLaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.

Welcome & Welcome Back – New & Renewing Members

ARSA’s members give the association life – its work on behalf of the maintenance community depends on the commitment of these organizations. Here’s to the companies that joined or renewed in December.

New Members

Safran Nacelles Services Americas
Turbines, Inc.

Renewing Members (Member Since)

KLM  Royal  Dutch  Airlines-Engineering (2010)
Midwest Turbine Service, LLC (2015)
N1, LLC (2015)
Peter Stonefield (2010)
Rapco Fleet Support, Inc. (2008)
SIA Engineering Company, Ltd. (1997)
Southwind Aviation Supply, LLC (2008)
Spirit AeroSystems, Inc. (2005)

Final Documents/Your Two Cents

This list includes Federal Register publications, such as final rules, Advisory Circulars and policy statements, as well as proposed rules and policies of interest to ARSA members.

To view the list, click here.

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2017 in Review

Each story will take you to the hotline in which it appeared. Peruse those editions and see what 2017 really meant for the men and women who keep the world safely in flight every day.

Leading Off

May 5: You Showed Us
The 80 respondents who provided insight through this year’s survey described a thriving industry facing strategic challenges. See what they shared (in aggregate) as ARSA incorporates the data into its work on behalf of the maintenance community.

June 9: You Can’t Be a Little Bit Pregnant
Executive Director Sarah MacLeod shares a basic principle of both life and lawmaking.

Aug. 4: Courts or Congress – The Devil and the Deep Blue Sea
The official avenues for challenging executive branch actions are limited, which makes it essential to work with the government in a productive way. Using examples from ARSA’s “voluntary surrender” efforts, Executive Director Sarah MacLeod explains how the association resolves issues based on facts and data…not feelings and fears.

Oct. 6: Laissez-Faire? We Wish
Executive Director Sarah MacLeod uses a recent “exposé” on lax FAA oversight to illustrate how the general media can counterfeit an aviation safety crisis in order to “sell” a story. MacLeod makes the point to underscore why ARSA will always respond to negative publicity.

ARSA Events

April 7: Symposium 2017 – See What Happened
Thanks to all the participants, speakers, sponsors and allies who made ARSA’s 2017 Legislative Day & Annual Repair Symposium possible.  See what happened when the maintenance community descended on the nation’s capital and scroll this edition of the hotline to see how the symposium crosses every area of the association’s service.

Nov. 3: MRO Leaders “Engage for Effect” at 2017 ARSA SLC
Engagement was the theme of ARSA’s 2017 Strategic Leadership Conference, which was held in Washington, D.C. on Oct. 18 and 19. Dozens of senior executives representing ARSA member companies from around the world converged on the city to make the industry’s voice heard.

ARSA Works

June 9: FAA Confirms Receiving Tasks Not Maintenance, No D&A Testing Requirement
On May 30, the FAA issued a legal interpretation clarifying that repair station employees receiving items for stock are not performing safety sensitive functions under 14 CFR part 120 and need not be included in a drug and alcohol testing pool.

July 7: ARSA, Industry Partners Help FAA Reconstruct Recordkeeping Guidance
On June 12, an ARSA-led coalition of ten industry partners submitted a complete rewrite of the agency’s proposed Advisory Circular 43-ARTS, “Use of FAA Form 8130-3 for Approval to Return to Service Under Part 43.”

Sept. 5: Industry Gives FAA a Commercial Parts Solution
On Aug. 8, ARSA and its allies provided a method to address international issues created by the regulatory definition of “commercial parts.” Led by the association, a coalition of aviation groups and private businesses submitted a draft notice dealing with commercial and commercial-off-the-shelf parts in the context of change 6 to the U.S.-EU Maintenance Annex Guidance.

Oct.6: ARSA Form for New Article Inspections Remains Valid After FAA Extends Notice 8900.380
At the time of its release, Form E100’s instructions referenced FAA Notice 8900.380, which was scheduled for cancellation this year, before ARSA and a coalition of industry groups requested and received an extension.

Nov.3: New ARSA Guidance Clarifies Duty-Free Aviation Parts Importation Rules
ARSA has released new guidance aimed at helping the aviation maintenance industry import parts for repair in order to more efficiently do business internationally.

Legal Briefs

Aug.4: Being Held “Accountable”
A deeper review of the issues at play in U.S. v. Weygandt and how prosecutors made regulatory responsibility tantamount to criminal culpability – a dangerous precedent that, if allowed to stand, should make everyone with the title “accountable manager” a little nervous.

Sept. 5: Importing Aircraft Parts into the United States Duty-Free
In addition to having to pay duties, maintenance providers have devoted considerable resources for navigating Customs rules and dealing with conflicting views from exporters, importers and government agents. One major question has been whether the imported part must be airworthy to qualify for duty-free treatment.

Nov. 3: Compliance Over a Dead Body – Lessons on a Long-Fought-For Exemption
When dealing with a regulator, being “right” only gets you half way. You have to be accurate in your interpretation of the rules, armed with the technical capabilities and data to reinforce your position and then willing to see it through until the end.

ARSA on the Hill 

March 3: ARSA Joins Multi-Industry Letter Urging Congressional Regulatory Reform
On Feb. 6, a broad coalition of industry groups led by the U.S. Chamber of Commerce delivered a letter to Senate leadership urging passage of the Regulatory Accountability Act of 2017. ARSA joined the effort supporting the legislation to improve the federal rulemaking process.

June 9: Staking Out – Positions on ATC Reform
Now that President Trump has released his administration’s philosophy for reforming the U.S. air traffic control system, the aviation community must understand the issues at play, how they might impact businesses and where key stakeholders stand.

July 7: ARSA, Allies Take Voluntary Surrender Fight to Congress
On June 18, an ARSA-led coalition of aviation interests asked Congress to direct the FAA to reinstate the right of a repair station to voluntarily surrender its certificate.

Oct. 6: Congress Avoids FAA Shutdown, Kicks Reauthorization Down the Road … Again
There was some drama as things came down to the wire, but Congress ultimately did what everyone expected and voted Sept. 28 to keep the FAA running for another six months.

Regulatory Outlook 

March 3: White House Order Brings Some Form to Regulatory Reform
On Feb. 24, President Donald Trump issued an executive order providing general instruction for staffing and procedure to execute his policies for controlling regulatory burden. ARSA is well-positioned to offer counsel as the FAA follows instruction to “seek input and other assistance.”

June 9: ARSA, A4A Collaborate on Regulatory Reform Suggestions
On May 19, ARSA joined Airlines for America in submitting to the Aviation Rulemaking Advisory Committee a list of rules the associations would like to see repealed, modified or replaced.

Oct. 6: Advisory Committees Merely Advise
Executive Director Sarah MacLeod describes the statutory authority behind the FAA’s Aviation Rulemaking Advisory Committee and highlights how the general media sensationalizes away its “advisory” nature – particularly in response to the body’s recommendations under the White House’s regulatory reform initiative.

Quality Time

April 7: What Determines LTL Freight Rates? 9 Things You Should Know
Freight costs can be reduced by intelligently managing pricing factors. Working with a freight broker like PartnerShip through the ARSA Shipping Program will help you ship smarter and stay competitive by helping you to get the best rates possible.

May 5: Additive Manufacturing – Does it Fit into the Regulations?
For some, additive manufacturing is a “shiny new thing” that requires new production rules. Aviation lawyer Jason Dickstein explains the industry’s growing experience with so-called 3-D printing and how the practice can fit within the current regulations.

Aug. 4: SAS Part 2 – How Did We All Get SAS?
Carol Giles, president of The Giles Group and longtime ally of ARSA, continues her exploration of the FAA’s Safety Assurance System. In this installment, Giles details the various agency programs that have attempted to make good on its “safety system philosophy.”

Dec. 8: Breaking Silence – More “Lessons on a Long-Fought-For Exemption”
A previous edition of the hotline described the years’ worth of effort by Advanced Composite Structures Florida (and ARSA’s management firm) to successfully receive an FAA exemption from § 21.9(c). To help readers continue their education on the matter, ARSA followed up to see how that exemption has been put to work.

Membership

Feb. 3: Don’t Let Technology Keep You from ARSA
If you’re reading this, you’re good; but thanks to spam filters, firewalls and quarantines, it can sometimes be difficult for organizations like ARSA to get messages into your inbox. Make sure your friends and colleagues aren’t cut off from the voice of the maintenance community.

May 5: ARSA at MRO Americas – Always Among Friends
If walking the exhibition floor is a proxy for traveling the maintenance world, then ARSA is always among friends…these organizations carry the flag on behalf of all members as the association works for them.

June 9: Skills Gap Could Cost Repair Stations Billions in Revenue, Survey Finds
On May 12, ARSA shared analysis from its 2017 member survey indicating that repair station earnings are hampered considerably by unfilled technical jobs.

Nov. 3: AerSale’s Barimo Brings Leadership, Technical Expertise to ARSA Presidency
The selection of the association’s 2018 president was made during the board’s annual meeting, which followed the 2017 Strategic Leadership Conference in Washington, D.C. As an executive for AerSale, a global leader in aftermarket aircraft, material and management services, Basil Barimo will bring both his professional perspective and technical experience to bear on ARSA’s work in 2018.

Training

Sept.5: Defining “Safety Sensitive” for D&A Testing
Marshall S. Filler returns for another installment of his popular series on drug & alcohol testing requirements. This session explores “safety sensitive functions” and describes how to properly define who is “performing” them. In Filler’s words, remember: This is not a logic exercise…it’s a regulatory one.

Sept. 5: The Mechanic’s Bible – Part 43
This session places the work performed on U.S. civil aircraft in the context of the “aviation safety regulatory chain,” explains general definitions and requirements and reviews the standards that impact these activities.

Oct.6: Eight ARSA Training Sessions Accepted for IA Renewal Credit
On Sept. 12, ARSA announced that eight of its on-demand training sessions have been accepted by the FAA for Inspection Authorization renewal credit under 14 CFR § 65.93. Each session is currently available for registration and immediate access.

Nov. 3: Importing Aircraft Parts for Maintenance – Establishing Duty Free Rates
The session reviews the World Trade Organization’s exemption of civil aviation products and parts from import duties and describes the U.S. implementation of rules and guidance to support duty-free importation. It then walks through the association’s resources for ensuring that eligible imports are made free of Customs tariffs.

Quick Questions

June 9: Time to Onboard a New Technician
ARSA asked and 35 members answered: How long does it take to turn new hires into productive technicians?

Sept. 5: Technician Workforce by Certification
As ARSA works to help close the skills gap and get aircraft technicians/mechanics/engineers to work, it asked the repair station community for insights into the certifications held in their shops. ARSA asked and 28 respondents – representing employment of more than 1,000 technicians – answered.

A Member Asked

May 5: Foreign Drug Testing
My company has part 145 repair station certificates in Europe. Last summer’s FAA bill contained provisions mandating the agency require drug and alcohol testing for foreign repair stations within one year. It’s almost been a year; do I need to start a drug and alcohol program?

Aug 4: Defining “Accident”
Section 145.211(c)(iii) states that you must perform a hidden damage inspection on all articles that have been involved in an accident. In this instance, how is an accident defined? If an aircraft hits a tree while being transported on a trailer, is this an accident in the view of the regulations?

Sept. 5: Rely on the FAA?
I read with interest the amicus brief the association filed in U.S. v. Wygandt. However, I believe a sentence in that document contradicts what [Executive Director] Sarah MacLeod has been telling us for years.

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AVMRO Resources

ARSA strives to provide resources to educate the general public about the work of the association’s member organizations; should you need to provide a quick reference or introductory overview to the global MRO industry, please utilize AVMRO.ARSA.org.

AVMRO Industry Roundup

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.

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Industry Calendar

Aerospace & Defence MRO South Asia Summit – New Delhi – Jan. 18-19
Airline Engineering & Maintenance: Middle East – Dubai – Jan. 22
MRO Middle East – Dubai – Jan. 23-24
Aero-Engines Americas – Fort Lauderdale, Florida– Jan. 31-Feb. 1
MRO Latin America – Panama City, Panama – Feb. 14-15
HAI HELI-EXPO – Las Vegas – Feb. 27-March 1
MRO East Asia – Hanoi, Vietnam – March 7-8
ARSA E2E Briefings, Legislative Day & Annual Repair Symposium – Arlington, Virginia – March 13-16
ATEC Annual Conference – Falls Church, Virginia – March 17-20
MRO Americas – Orlando, Florida – April 10-12

Previous Editions

the hotline is the monthly publication of the Aeronautical Repair Station Association (ARSA), the not-for-profit international trade association for certificated repair stations. It is for the exclusive use of ARSA members and federal employees on the ARSA mailing list. For a membership application, please call 703.739.9543 or visit http://arsa.org/membership/join/. This material is provided for educational and informational purposes only. It does not constitute legal, consulting, tax or any other type of professional advice. Law, regulations, guidance and government policies change frequently. While ARSA updates this material, we do not guarantee its accuracy. In addition, the application of this material to a particular situation is always dependent on the facts and circumstances involved. The use of this material is therefore at your own risk. All content in the hotline, except where indicated otherwise, is the property of ARSA. This content may not be reproduced, distributed or displayed, nor may derivatives or presentations be created from it in whole or in part, in any manner without the prior written consent of ARSA. ARSA grants its members a non-exclusive license to reproduce the content of the hotline. Employees of member organizations are the only parties authorized to receive a duplicate of the hotline. ARSA reserves all remaining rights and will use any means necessary to protect its intellectual property.

© 2018 Aeronautical Repair Station Association

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