2017 – Edition 5 – June 9, 2017

the hotline 1984

Table of Contents

Note: The order of material varies in hotline emails, but is always presented the same on this landing page. Readers scrolling through content on or printing this page will find it organized consistent with the table of contents.

Sarah Says
SLC 2017
ARSA Works
Legal Briefs
ARSA on the Hill
Quick Questions
Quality Time
Industry Calendar

Sarah Says

You Can’t Be a Little Bit Pregnant

By Sarah MacLeod, Executive Director

No, this is not about abstinence. It’s about the impossibility of getting rid of bad laws and the facts associated with unintended consequences.

Once legislators have enacted a law, it is almost impossible to reverse the process – you have to deal with the results. The “baby” is coming and the industry (or general public) will have to raise it regardless of its true parentage.

Case in point: In 2003, Congress passed a law forbidding the FAA from certificating foreign repair stations until the Transportation Safety Administration (TSA) issued new security rules. The TSA didn’t want to control repair stations, because they were such a low security risk in a time where the agency had plenty to keep it busy. The repair station community certainly didn’t want security regulations since many aren’t even on airports – where’s the threat? – and most are small businesses that can’t absorb the costs of unnecessary requirements. The FAA didn’t want to stop certificating foreign repair stations since they are required for operators of U.S.-registered aircraft operating overseas.

Neither the facts (the lack of an actual threat to aviation security) nor the unintended consequences (no actual stakeholder sought the congressionally-mandated outcome) stopped the law from being passed; the only thing that stops or starts the legislative process are the taxpayers and voters. Sure, politics is disheartening. So is direct involvement in the process. But without activism, we all end up having to comply with the unintended consequences of unwanted laws.

Activism is essential to a democracy. It is our one prophylactic measure against a lifetime of unwanted regulatory responsibility. Now is the time to exercise that protection: Lawmakers have gotten busy reauthorizing the FAA, flirting with regulatory and tax reform and courting the technical workers of the future. The association needs your support as it works for you on the Hill.

Regardless of what you do this summer, you should join us this fall. At October’s Strategic Leadership Conference, ARSA will focus on activism. Come to Washington and tell our story, face to face, with law and policymakers. They say abstinence is 100 percent safe, but it’s in aviation that good safety is good business – come show off the goods.


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SLC 2017

Register Now to “Engage for Impact”


Registration is officially open for the aircraft maintenance industry’s 2017 Strategic Leadership Conference, hosted by ARSA in Washington, D.C. on Oct. 18-19. The SLC provides industry leaders from around the world an informal setting to discuss important issues facing aviation maintenance. 

This year’s focus is industry advocacy in Washington’s new political environment; the SLC will be a platform to engage policymakers, build relationships and produce lasting impact. Given the risks and opportunities repair stations are facing, it’s imperative that maintenance providers elevate the sector’s visibility and bring the power of a vital global industry to bear on the process. 

The need for action is not limited to American citizens or businesses. Changes in the political winds in Washington will blow across the aviation world, so every corner of it should be represented in October.

Top level industry participation is critical to success. The association encourages interested participants to consider who else might be valuable for the event — regardless of membership status or professional role — and extend this invitation to them.

Space is extremely limited in order to maintain the high-level focus of the SLC. Register today to ensure you have a place at the table:

Click here to visit the main event page (then bookmark it).

Don't need more information? Register now...

2017 Registration & Sponsorship Form

2017 SLC Registration & Sponsorship Form

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ARSA Works

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.

The interpretation was provided in response to a Feb. 15 request from 16 different aviation industry organizations, led by ARSA and representing both trade associations and private companies. The group had asked FAA Assistant Chief Counsel Lorelei Peter to confirm that tasks associated solely with receiving functions did not meet the regulatory definition of maintenance and therefore were not safety sensitive. The group’s submission had been stimulated by learning some auditors in the agency’s Drug Abatement Division had indicated the contrary to certificate holders.

The interpretation concurred with the request’s reasoning. After citing the pertinent regulations for defining maintenance and preventive maintenance as well as outlining recordkeeping requirements under part 43, Peter’s response described the general responsibilities of individuals performing receiving tasks. 

“These [receiving] tasks are not maintenance or preventative maintenance activities,” the response stated. “Therefore, employees receiving items for stock are not safety sensitive employees under part 120 and should not be included in the pool of employees subject to drug and alcohol testing.”

If you have employees in your random pool who perform only receiving functions, they should be removed immediately. No other actions (e.g., voluntary disclosures) should be necessary in light of the contrary positions previously taken by some FAA auditors.

To read the complete interpretation, click here.

To read the coalition’s request, click here

Upcoming Training: Stay tuned for an online session on safety sensitive functions.


ARSA Leads Industry Effort for “Serious” Standardization

On May 23, a coalition of aviation industry associations and private businesses sent a letter to the FAA seeking an objective standard for service difficulty reports under § 145.221.

The letter had 13 signatories and was prompted by reports from ARSA members of inconsistent enforcement of SDR reporting requirements. The group sought clarity regarding the application of the word “serious” for determining when a report must be filed.

“The fact is most articles sent for maintenance or alteration actions have ‘serious’ issues; it is why they are being sent for restoration or alteration,” the letter said, noting that defects caused by design or production deficiencies are easily spotted. “On the other hand, the ‘serious’ failures and malfunctions that are known, anticipated, recognized as correctable or have corrective action instituted are the bread and butter of the maintenance industry. It seems incongruous that the agency would need [an SDR] on any and all items received for processing by a repair station that have known and correctable ‘serious’ failures, malfunctions or defects.”

The agency can alleviate enforcement inconsistencies by focusing on issues without appropriate corrective actions. When maintenance providers have the data or practices to support a fix, there is no “serious” issue.

To help make that determination, the group suggested a process for evaluating articles: Whenever an “unknown or unusual discrepancy” is determined to have caused a failure, the issue should be further investigated to determine if it would require a report from a design approval holder (§ 21.3) or an operator (§§ 91.1415, 121.703 or 135.415). If so, an SDR should be submitted.

In 2014, ARSA lead an industry-wide campaign to prevent the new repair station rule from becoming effective without the word “serious” in § 145.221. As it was written when published to the Federal Register that August, the rule would have imposed the onerous burden of requiring an SDR on every failure, malfunction or defect. Returning to the “serious” issue, the association and its allies now seek an objective standard for aviation safety inspectors to use while ensuring compliance with reporting requirements.

To read the full letter, click here.

See all of ARSA’s “serious” work by visiting:

The following organizations joined ARSA in signing the letter:

Aerospace Industries Association
Aircraft Owners and Pilots Association
Airlines for America
Aviation Suppliers Association
Cargo Airline Association
General Aviation Manufacturers Association
Modification and Replacement Parts Association
National Air Carrier Association
National Air Transportation Association


ARSA, A4A Collaborate on Regulatory Reform Suggestions

On May 19, ARSA joined Airlines for America (A4A) in submitting to the Aviation Rulemaking Advisory Committee (ARAC) a list of rules the associations would like to see repealed, modified or replaced.

The submission was part of an ARAC task to support aviation regulatory reform. The committee must provide the FAA “recommendations on existing regulations that are good candidates” for some kind of alteration or elimination. Active ARAC participants were asked to assist this effort by submitting specific suggestions.

To perform this work, ARSA solicited input from its members (see below), utilized experience with rules and guidance that complicate members’ compliance efforts and collaborated with A4A on issues of consequence to air carriers. The combined submission highlights a wide range of areas where the existing rules impact job creation, impose unnecessary costs, create inconsistencies or are otherwise outdated, unnecessary or ineffective.

The committee will incorporate all submissions into a unified document and prepare it to for FAA leadership as the “phase 1” report of the agency’s regulatory reform activity. The committee’s task supports the larger effort to satisfy the Trump administration’s government-wide effort to “enforce the regulatory reform agenda.” A Feb. 24 executive order called for establishment of agency-level task forces. As ARSA foresaw, the FAA is using the ARAC for this purpose.

As the process continues, stay tuned for more information and insight into the ARAC’s process.


Skills Gap Could Cost Repair Stations Billions in Revenue, Survey Finds

ARSA members could miss out on close to $200 million in foregone revenues this year as a result of unfilled technical jobs at their companies, the association announced on May 12.

Fifty-five percent of respondents to ARSA’s recent member survey reported having unfilled positions. Based on the average number of vacancies at the responding organizations, the association estimates its members have 1,045 open technical jobs. The total economic loss figure – $185 million – was derived by multiplying the number of open positions by the $177,000 in average annual revenue per employee reported by respondents.  

Projected across the entire population of FAA-certificated repair stations in the United States, the number of open positions may be close to 11,000.  If those positions go unfilled, the industry could stand to miss out on as much as $1.95 billion in economic activity in 2017.

“These numbers are a snapshot of how just one industry is being affected by the technical worker shortage plaguing the U.S. economy,” ARSA Executive Vice President Christian Klein said.  “Well-paying jobs in the high-tech aviation maintenance sector are going unfilled because workers aren’t available or candidates lack basics skills.

“We hope lawmakers working career technical education policy on Capitol Hill – including the recently-introduced Perkins reauthorization bill – will keep the aviation industry in mind when crafting solutions,” Klein said.  “But Washington can’t solve this problem alone.  Expanding the base of eligible job candidates and better aligning school curricula with repair station needs will require greater industry engagement at the local, state, and federal levels,” Klein said. 

The worker shortage has become a major concern for maintenance providers. When asked to indicate the most-pressing risks to company business outlook, “difficulty finding and retaining technical talent” tied with “regulatory costs/burdens” among survey respondents. Availability of maintenance information, international regulatory inconsistencies and restrictions on trade rounded out the top five respondent concerns.

Despite these challenges, the survey found ARSA’s membership generally optimistic about the future. More than 90 percent of member companies expect their markets to expand or remain stable this year and more than half plan to add positions. The survey also underscored the significant impact that international business has on repair stations: almost one-third (31 percent) of revenues for the average U.S.-headquartered respondent came from customers outside North America.

ARSA Member Survey Respondent Overview

  • Eighty ARSA member companies from around the world provided input for the survey, which was conducted during the first quarter of the calendar year.
  • Respondents reported total 2016 gross annual revenues of $1.791 billion.
  • Eighty-eight percent of respondents were headquartered in the United States.
  • Respondents reported operating facilities in 29 of the 50 U.S. states.
  • The best represented U.S. states were Florida (17 percent of respondents reported having facilities), California (17 percent), Texas (16 percent), Georgia (10 percent) and Ohio (10 percent).

If you have questions about the survey or the results, click here to contact ARSA.

To see more and learn about the international maintenance industry, visit the association’s Data & Advocacy page.


ARSA’s Filler at EASA STeB: Rulemaking, Personnel Moves and “Hard Law”

On May 9, Marshall S. Filler, ARSA’s managing director & general counsel, attended the EASA Engineering & Maintenance Stakeholder Technical Body (E&M STeB) in Cologne, Germany.

The meeting was chaired by Juan Anton, maintenance regulations section manager of the Flight Standards Directorate with the assistance of several of his colleagues. They covered a lot of ground, including the status of several EASA Opinions that were now subject to review by the European Commission (EC) because they involve changes to “hard law,” meaning amendments to the Basic Regulation or Implementing Rules under the EC’s jurisdiction. These included:

(1) Control of maintenance suppliers.
(2) Changes to Part-66 B2L and L licenses.
(3) Basic examinations by Part-147 schools.
(4) Part-ML and Part-CAO.
(5) SMS for CAMOs.
(6) Technical records.
(7) Maintenance check flights.

EASA staff also presented a compilation of the survey responses submitted regarding the proposed changes to Parts-147 and 66. ARSA and the Aviation Technician Education Council (ATEC) had submitted a joint response to the survey in February of this year (click here to read the associations’ response).

Of particular note is that EASA has prepared draft Terms of Reference (ToR) for a new SMS rulemaking affecting Part-145 maintenance organizations and Part-21 design and production organizations. The pertinent STeB members are reviewing that document as part of their consultative responsibilities. The ToR precedes the issuance of a Notice of Proposed Amendment (NPA) which is similar to an FAA Notice of Proposed Rulemaking (NPRM).

A copy of the complete May 9 STeB agenda may be found here.

Mr. Anton announced that, effective July 1, he will move to a Cybersecurity position in EASA’s Strategy and Safety Management Directorate. He will be replaced by Ms. Eugenia Díaz Alcázar, senior regulations officer for continuing airworthiness. Mr. Anton will retain his position as chair of the ICAO Airworthiness Panel which is improving Annex 8 (Airworthiness) and related guidance to support a greater degree of mutual acceptance of certification and surveillance findings by civil aviation authorities regarding approved maintenance organizations.


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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Legal Briefs

Editor’s note: This material is provided as a service to association members for educational and informational purposes only. It does not constitute legal or professional advice and is not privileged or confidential.

Regulatory Reform: Campaign Speeches to Committee Rooms

By Ryan M. Poteet, Regulatory Affairs Director

Every new administration is forced to reconcile promises made on the campaign trail to overhaul the administrative state with its own regulatory agenda. Politicians demonize administrative agencies as the cause of the nation’s woes; the proverbial red tape created by out-of-touch Washington bureaucrats is said to be killing jobs and preventing American businesses from being competitive in the global marketplace. Elected officials then have to manage their rhetorical (and administrative) messes once in office.

Just 10 days after Inauguration Day, the Trump Administration issued an executive order that, among other things, directs each federal agency to repeal two regulations for every new rule it promulgates. Through sheer weight of numbers, the executive order aims to control regulatory costs by reducing the overall size of the rulebook. This approach, however, is problematic for safety-focused agencies because it attacks the very premise of each regulation currently on the books.

The FAA has expansive statutory authority to promulgate rules necessary for safety in air commerce. In principle that means each regulation in 14 CFR should increase aviation safety. If that’s the case, then is it really practical to meet a forced promulgation/repeal ratio? There are numerous reasons a rule might be ripe for repeal, replacement or modification. Plenty are outdated – superseded by market forces – while others may simply be duplicative. It’s great to have discretion to actually consider the impact of existing rules, but it must be done based on their legitimate impact on certificate holders and service to aviation safety.

Outdated regulations can be annoying; even after passing into irrelevance they leave behind compliance-related vestiges that can trip certificate holders. The most vexing, not to mention costly, are duplicative rules. Duplication in the CFR brings us back to the original question: If a rule is truly repetitive how does it enhance aviation safety? It can’t.

The FAA is already grappling with how to comply with President Trump’s executive order. Thankfully, the agency has enlisted industry: In April, it requested the Aviation Rulemaking Advisory Committee (ARAC) recommend regulations that are good candidates for repeal, modification or replacement (a subsequent executive order directed creation of task forces to review existing rules and ARSA rightfully prophesied that ARAC could serve this purpose).

Last month ARSA and Airlines for America (A4A) – both ARAC members – jointly submitted a list of rules to the full committee that the associations would like to see eliminated or modified. The combined submission highlights a wide range of areas where existing rules impact job creation, impose unnecessary costs, create inconsistencies or are otherwise unnecessary or ineffective. ARAC will submit a preliminary report to the FAA later this month. A final report will be submitted later this summer for agency acceptance during the September ARAC meeting.

It is not yet clear how the actual mechanics of the executive order will work. Nevertheless, the FAA will have some soul-searching to do this summer. The premise of every rule will be subject to greater scrutiny and industry will be better positioned to combat rulemaking actions through notice and comment. Unlike past administrations, President Trump appears to view regulatory reform as more than an aspirational goal. Indeed, the two-for-one executive order has the potential to hold regulators accountable for imprudent or downright lazy rulemaking practices. As always, the devil is in the details and so we’ll have to wait and see whether the executive order can live up to its promise.


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ARSA on the Hill

The Clock is Ticking – It’s Time to Engage!

By Christian A. Klein, Executive Vice President

It’s been a busy spring for ARSA on Capitol Hill as the House and Senate get to work on the FAA reauthorization bill. The latest word on the Hill is the bill may be on the House floor before the August recess (the Senate timeline is still up in the air).

As Congress rolls up its sleeves to write the legislation, now is the time for maintenance industry leaders across the country (and the world) to get engaged. And one of the best ways to do that is by hosting a member of Congress or congressional staffer at your company. Even if you’re not located in the United States, we’ve got some ideas about other ways you can impact the process.

What’s at Stake for You?

Repair stations have an enormous stake in the FAA debate. It’s an opportunity to shape the agency’s budget and priorities, improve enforcement consistency and make oversight more efficient. FAA reauthorization is also an opportunity to pursue MRO-specific objectives, like restoring voluntary surrender for repair station certificates and shining a spotlight on the technician shortage.

There are also threats: We’ve heard rumblings about a renewed effort to impose a ban on new repair station certificates (potentially both foreign and domestic) because the FAA hasn’t completed rulemakings on employee background investigations and foreign drug and alcohol testing. We are also concerned that growing hostility to free trade could lead to policy outcomes that jeopardize bilaterals and hurt our global industry. In recent weeks, ARSA has sent clear message to lawmakers: Don’t punish the maintenance the industry because of FAA rulemaking delays (click on the link to see our letter to Congress).

Wearing Out the Shoe Leather

ARSA isn’t taking the threats laying down nor letting the opportunities go to waste. Over the past several months, we’ve conducted more than 50 meetings on Capitol Hill, focusing on House and Senate aviation subcommittee committee staff and member personal offices. It’s no exaggeration to say that ARSA is more visible in the halls of Congress than ever before, but our meetings have revealed how little policymakers know about our industry.

A recent meeting with a House staffer who’s worked with Florida members for more six years is a case in point: he had no idea the maintenance industry existed, let alone that it employs more than 20,000 people in his state! The bad news is that’s not uncommon; the good news is that as elected officials learn more about industry and economic impact, they become very receptive to the message of this high-tech, highly-specialized, small business-dominated, global industry.

ARSA is wearing out the shoe leather making sure your interests are represented on the Hill. But 535 members of the House and Senate and countless committee and leadership offices, ARSA’s small legislative team can’t by itself guarantee victory. For that, your participation is the key.

The Best Way to Make a Difference

One of the best ways to show members of Congress and staff what you do and how you impact the local economy is to host them at your facility. Congressional visits aren’t a heavy lift. ARSA will help you identify the best person to invite, extend the invitation and provide materials to help guide your conversation. The visit usually takes about an hour. The usual sequence of events is to hold a brief sit-down meeting with your execs to provide an overview of the company and discuss hot policy issues, do a walking tour through your facility to shake some hands and provide first hand perspective, and take a few photos. It’s really that simple.

At the moment, our top targets for facility visits are members of the House Transportation & Infrastructure and Senate Commerce Committees with a particular emphasis on their aviation subcommittee members.

Please review the lists and look to see if your state is represented on the committees and subcommittees. Even if your own representative isn’t on the list, keep in mind that House members are usually willing to visit facilities in districts near their own, particularly if there’s a likelihood that some of your employees are constituents.

Also, just because you don’t see one of your representatives or senators on the above lists doesn’t mean you shouldn’t host a visit. ARSA is lobbying a lot of other issues on the Hill: workforce, taxes, and regulatory reform, just to name a few. It’s a good bet that there are other members of Congress on key committees from your state who’d be interested in learning more about your company. To identify your representatives and see what committees they’re on, go to

The next step is to send me an email at and let me know which member(s) of Congress you’d be willing to host. We’ll get the ball rolling by identifying the scheduler, making the request and working with both sides to coordinate a visit date.

But hosting a facility visit isn’t the only way to help. Some other things you can do are:

  • Sending a note to your representative and senators’ transportation legislative assistants introducing yourself and our industry. We can provide names and email addresses. We’ve found congressional offices to be much more receptive if there’s a strong constituent connection back home.
  • Signing up for Twitter and following @ARSAworks, @caaklein, and @levantoair. We tweet regularly about our activities and developments on the Hill. The hotline and Dispatch are great tools, but Twitter can provide up-to-the-minute information.
  • If you haven’t already, give us prior approval to communicate with you about ARSA PAC. You can do it online here: org/legislative/about-arsa-pac/

Not in United States? Not to Worry

Even if you’re located outside the states, if you have an FAA repair station certificate you have a big stake in the debate and can have an impact. It’s a good bet you have suppliers and customers in the United States who can be important allies. Reach out to them and encourage them to join ARSA and become involved in our industry’s efforts on Capitol Hill. ARSA can also connect you with the economic or transportation attaché at your embassy in Washington, D.C. to make sure they’re aware of your interest in the FAA debate and looped into ARSA’s advocacy network. Embassy involvement can be particularly important as international issues emerge.

And, finally, mark your calendar for the 2017 ARSA Strategic Leadership Conference on Oct. 18 and 19 in Washington, D.C. The meeting will be an excellent opportunity for senior MRO sector execs from around the world to engage with executive and legislative branch officials to promote our industry’s policy agenda.

ARSA is working for you, but we need your help. Thanks for your support.


Don’t Punish Industry for FAA Delays, ARSA Tells Congress

As Congress begins the process of reauthorizing the FAA, ARSA is urging lawmakers not to punish the aviation maintenance industry because the agency has not yet finalized new rules for repair stations.

Recent FAA authorization laws have directed the agency to undertake rulemakings to extend drug and alcohol (D&A) testing to foreign repair stations and require pre-employment background investigations for all repair station employees performing safety-sensitive functions on air carrier aircraft.   For various reasons, including the complexity of the issues and potential impact on thousands of small businesses, the FAA has yet to finalize the rules.

In a letter sent to the leaders of the House Transportation & Infrastructure and Senate Commerce, Science & Transportation Committees on May 15, ARSA urged lawmakers to give the FAA adequate time to complete the rulemakings.  In 2008, Congress banned the FAA from issuing new foreign repair station certificates if the Transportation Security Administration (TSA) failed to issue repair station security rules.  The subsequent ban lasted until the rules were issued in 2013, causing significant economic disruptions for airlines and maintenance companies – including many from the United States – wishing to open facilities abroad.

ARSA said that instituting a new ban on repair station certificates – foreign or domestic – would make it difficult for U.S. companies to tap into foreign markets, make it harder for U.S. air carriers to operate internationally, and potentially subject U.S. facilities to retaliation by foreign aviation authorities. 

“Those who do not learn the lessons of history are doomed to repeat them,” ARSA Executive Vice President Christian Klein said in the letter.  “Punishing industry would do nothing to motivate executive branch action but would instead undermine growth in a globally-competitive sector of the U.S. economy, undermine the FAA’s ability to pursue reciprocal acceptance of U.S. certifications abroad, and further jeopardize the U.S. aviation industry’s global leadership.”

The letter to House T&I Committee leaders can be viewed at:

The letter to Senate Commerce Committee leaders can be viewed at:

Bookmark this page for more updates as the reauthorization process continues. To catch up on what happened in the 114th Congress, visit:


Unanimous Committee Passage of CTE Bill is “Step in the Right Direction”

On May 17, ARSA Executive Vice President Christian A. Klein released the following statement in response to the House Education & Workforce Committee’s unanimous passage of the Strengthening Career and Technical Education for the 21st Century Act (H.R. 2353). The legislation would reauthorize federal career technical education programs with the goal of better preparing workers for high demand careers.  The association recently estimated that if open technician positions in the industry go unfilled, repair stations could miss out on as much as $1.95 billion in economic activity in 2017.

“ARSA commends Chairwoman Foxx, Ranking Member Scott and all the House Education & Workforce Committee members for working together to make career technical education a top priority. 

“The aviation maintenance industry’s technical worker shortage is undermining productivity and growth. Well-paying aviation technician jobs are going unfilled because companies can’t find workers with the necessary skills.  Of course, our industry is not alone in facing this challenge. 

“By itself, reauthorizing the Perkins Act won’t solve the problem, but it’s a significant step in the right direction. By, among other things, improving coordination between businesses, schools and government the bill will help ensure Americans are better prepared for 21st century careers in high-tech sectors like ours. 

“We look forward to continuing to work with the House Education & Workforce Committee’s leadership to steer this important legislation to enactment.”

Continue reading to see ARSA’s initial assessment of the bill, as well as the association’s previous updates on workforce development policy:

Initial Review: House Stays with What Works in New Technical Education Bill

On May 4, Reps. Glenn “GT” Thompson (R-Pa.) and Raja Krishnamoorthi (D-Ill.) introduced the “Strengthening Career and Technical Education for the 21st Century Act.” The bill, which bears the same title as legislation that passed the House in 2016 by 400 votes but saw no action in the Senate, builds on recent reforms to the K-12 education system and enhancements to federal resources for workforce development in order to enhance flexibility for states and increase engagement of technical employers.

According to the House Committee on Education and the Workforce, which is chaired by 2017 ARSA Legislative Leadership Award Winner Rep. Virginia Foxx (R-N.C.), the proposal is largely identical to the 2016 version (ARSA’s legislative team is currently performing a side-by-side comparison). Like its predecessor from the 114th Congress, this year’s legislation seeks to:

(1) Empower state and local community leaders by simplifying application requirements and maximizing flexibility.
(2) Improve alignment with in-demand jobs by building industry-sector partnerships.
(3) Increase transparency and accountability by giving a voice to students, parents and stakeholders in assessing programs.
(4) Ensure a limited federal role by minimizing the authority of the secretary of education.

Each of these pillars will surely remain popular with industry members. In July, 2016, ARSA joined more than 250 other organizations on a letter to Congress praising the same values in that attempt to rebuild the nation’s career and technical education system. The association and its allies have long argued that responsive federal workforce policy should provide states and communities with the tools necessary to stimulate the growth of skills that put students into jobs – this bill pursues that end.

In addition to the general attention on employer needs and local flexibility that has been sought by industry, the bill utilizes programmatic structures from the Every Student Succeeds Act and the Workforce Innovation and Opportunity Act. By taking advantage of the systems within these laws, both of which passed Congress in the last three years with bipartisan support, the new bill will help minimize burden on local governments, schools and employers while making efficient use of existing educational and workforce resources.

Given the priority level of technical workforce policy in this Congress, the bill will likely be taken up by the committee in the coming weeks. Stay tuned to ARSA for updates and ways to get involved.

To read a fact sheet on the bill, click here.

To read a detailed bill summary, click here.

To read the bill, click here.


Staking Out – Positions on ATC Reform

ARSA is letting the debate on air traffic control reform play out in Congress and with advocacy groups across the country. Though the association isn’t actively involved, its important to understand the sides of an issue that could completely overhaul the air transportation system.

Who’s For It?

Proponents of ATC reform argue the system has become bogged down in government bureaucracy. For evidence, they highlight the FAA’s glacial pace in rolling out the long-touted NextGen Air Transportation System. In order to maintain the American place as leader of the aviation world, they argue, ATC responsibilities must be removed from the executive branch and vested in a non-profit organization composed of both public and private interests and overseen by a stakeholder board.

Who Are They?

[The following list includes non-governmental organizations that have publicly supported privatization. It is not exhaustive. For more information on their positions, click the relevant link.]

Airlines for America
Air Line Pilots Association
Air Traffic Control Association
Citizens for On Time Flights
National Association of Air Traffic Controllers

Who’s Against It?

Opponents of ATC reform recognize the slow-moving nature of government, but see that progress is being made and do not want to upset the system during a time of transition. They argue that the supposed benefits of reform – cost savings, increased efficiency and flexibility – have been overblown and that the successful examples of privatization in other countries are not instructive as the airspace systems are much smaller. They also fear for limitations or eliminations of access to rural communities or non-major airports, as well as a proposed board structure they say instills too much power in major air carriers.

Who Are They?

[The following list includes non-governmental organizations that have publicly opposed privatization. It is not exhaustive. For more information on their positions, click the relevant link.]

Aircraft Electronics Association
Aircraft Owners and Pilots Association
Alliance for Aviation Across America
General Aviation Manufacturers Association
Helicopter Association International
National Air Transportation Association
National Business Aviation Association

What Other Resources Are Out There?

Congressional Budget Office – Analysis of H.R. 4441, Aviation Innovation, Reform, and Reauthorization Act of 2016
Congressional Research Service – Air Traffic Inc.: Considerations Regarding the Corporatization of Air Traffic Control
GAO Report – FEDERAL AVIATION ADMINISTRATION: Preliminary Observations of Potential Air Traffic Control Restructuring Transition Issues
White House Principles for ATC Reform


Let Us Tell You About It – ARSA PAC

In Washington, if you’re not at the table then you’re on the menu. Elected officials constantly consider policies that will directly impact the maintenance industry’s business. Many of them do so while knowing very little about aviation and even less about repair stations.

How can maintenance providers change that? ARSA’s legislative program provides a variety of resources. By working with the association, member organizations can become the kind of active constituents that make a difference. While the business of governing is completely separate from the effort of campaigning for office, it’s important to participate in the never-ending process of selecting members of Congress.

ARSA’s Political Action Committee (ARSA PAC) is a tool through which individuals in the aviation industry can amplify their political impact. ARSA PAC is a special fund that allows financial contributions to U.S. House and Senate candidates who support the legislative goals of the industry.

Only executive, management and administrative employees of ARSA member companies who have given solicitation permission can contribute. These employees must be United States citizens or lawful permanent residents (e.g., “green card” holders). ARSA PAC can only accept personal (not corporate) contributions.

To get more information about ARSA PAC, complete the solicitation consent form below. Completing the form in no way obligates you to financially support the PAC, it simply allows the association to provide more information (including how to actually give money). Providing this consent is the first step to helping provide the resources necessary to have our collective voice heard in the legislative decision-making process.

If you have questions about ARSA PAC or the legislative program in general, contact Executive Vice President Christian A. Klein (

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Quick Questions

Parts Importation

Several ARSA members have approached the association about problems importing aircraft parts into the United States for repair.  Inconsistent application of customs rules has resulted in repair stations paying import duties on parts that should be exempt under the Agreement on Trade in Civil Aircraft. In addition to having to pay the government, companies report devoting considerable personnel resources to navigating customs rules and dealing with conflicting guidance from stakeholders. 

If you are importing articles for maintenance, help ARSA work the issue by sharing a bit of your experience:

Please note that the survey appears on this page in an embedded window; you can scroll in the window to access the “Done” button and complete the questionnaire.


If you have questions or want to provide additional information, contact Brett Levanto (


Time to Onboard a New Technician [Answered]

Click the image to view the full size graphic. To download a copy to your computer, right-click and save the image.

For years, the maintenance community has faced recruitment headwinds. According to ARSA’s recently-completed member survey, the vast majority of respondents have difficulty finding technical talent – one of the two biggest perceived risks for the industry this year. It is challenging to attract qualified applicants, so it’s important to consider what happens once they’re actually in the door.

ARSA asked and 35 members answered: How long does it take for you to turn new hires into productive technicians? On average, respondents report that the average non-certificated technician needs 14 months of development to be a profitable employee and certificated technicians need nine months. While those figures were moderated by several reported quick-turnarounds for each type of technician, there were multiple respondents that indicated a full two years (24 months) were needed to produce a useful technician regardless of their certification.

The member survey data indicated each employee represents $177,000 in average annual revenue. Considering that figure, the lost productivity produced by this onboarding time lag could result in a considerable amount of lost revenue across the entire industry.

If you have questions or want to provide additional information, contact Brett Levanto ( Keep a lookout for more “quick questions” from ARSA.



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Quality Time

Editor’s note: The views and opinions expressed by contributing authors do not necessarily state or reflect those of ARSA and shall not be used for endorsement purposes.

SAS: The FAA’s New Approach to Risk-Based Safety Oversight

By Carol Giles, President, The Giles Group

Part One – How did we get here?

To understand the FAA’s Safety Assurance System (SAS), let’s look at the agency’s oversight responsibility and its prior variations and models so we can make sense of how the government arrived at today’s “risk-based” focus.

Of the FAA’s core missions, safety oversight is paramount. The Flight Standards Service (AFS), within the agency’s aviation safety organization, is responsibile for monitoring airmen, airlines, repair stations and aviation schools to ensure they are performing their privileges and limitations safely and responsibly. In the agency’s terms that means the certificate holder is performing within the regulations.

In early 2014, AFS announced the rollout of SAS. The system is a pillar of the FAA’s Safety Management System. It is a set of policies, procedures and checklists provided to Safety Inspectors to verify compliance with the regulations by validating a certificate holder’s operations. Before getting to the details and impact of SAS, let’s review the history and evolution of the AFS oversight system.

In the late 1970s, the FAA started the Aviation Safety Analysis System (ASAS), which was the first oversight system using computer technology. The Work Program Management Subsystem (WPMS) was the actual program used by inspectors; it was designed to reduce the paperwork burden and increase time in the field.

Based on multiple studies of the ASAS, the FAA created the National Program Guidelines (NPG) in the mid-1980s. These guidelines identified 41 critical types of oversight audits and requirements as well as setting minimum numbers of reviews for each certificate holder within a region. The oversight audits were not based on risk as we think of it today: Ideally, the inspector was to use the findings in the ASAS database along with the required items in the NPG to plan annual reviews. Inspectors completed Planned Inspections (P items) throughout the year based on safety data only after completing all Required Inspections (R items). While the R item program scope would change from year to year, there was no data-driven logic as to what was required to be audited or surveilled.

A GAO report published in 1987 found the FAA was not using inspector time effectively and potentially missing critical safety trends by not analyzing data and targeting inspections at the highest risk areas.  This resulted in Flight Standards developing the Safety Performance Analysis System (SPAS). SPAS was the first tool designed to provide reliable data to assist with decision-making and risk analysis. The system was to be a smarter way for inspectors to plan oversight better by identifying specific higher-risk areas and certificate holders.

While SPAS was a start on data collection and oversight work programs, it was not the best tool to find that safety-issue needle in the haystack. It suffered from development and deployment delays in addition to data quality issues. Therefore, it did not come on line until almost 2000; thus, it wasn’t officially in use until after the ValuJet accident in May 1996. Even after deployment, inspectors weren’t trained comprehensively on its use and the ability to effectively analyze data and target inspections based on risk did not fully materialize.

ValuJet was one of those significant events that forced the agency to look deeply into its philosophies, culture, hiring, training, processes and procedures.  AFS put together a 90-Day Safety Review, a short-term focus group, to examine the regulatory framework and oversight processes, find shortcomings and make recommendations that could be implemented quickly.

Considering the agency’s history, the main takeaway from the 90-Day Safety Review was improved targeting of oversight and inspector resources on the then top 10 air carriers. This all-encompassing inward study by AFS changed the way inspectors performed their oversight responsibilities; and we continue to see its impact today. Rather than basing inspection plans on uniform standards for minimum levels of oversight, the FAA implemented a system safety approach based on data analysis, risked-based decision making and processes for comprehensive surveillance plans tailored for each individual carrier.

Part two of this series will investigate how the FAA rolled out system safety philosophy in the form of the Air Transportation Oversight System (ATOS), the Repair Station Assessment Tool (RSAT) and, least but not last, SAS.

Since founding The Giles Group in 2011, Carol Giles’s industry experience, regulatory knowledge and relationships across aviation have contributed to crucial compliance solutions and resolutions for major airlines and leading MRO providers, as well as successful renewal certifications for U.S. and international maintenance facilities.


Dealing with Violations in Export and Import Transactions

By Thomas McVey, Esq., Williams Mullen

Note: This article contains general, condensed summaries of actual legal matters, statutes and opinions for information purposes. It is not meant to be and should not be construed as legal advice. For more information, please visit our website at or contact the author.

You are the general counsel or CEO of your company. Your compliance manager comes into your office and tells you that she may have discovered an export violation within the company. Or perhaps you have received a directed disclosure from the State Department requesting information, an administrative subpoena from Bureau of Industry and Security, or an informed compliance letter from Customs. You are aware that export and import violations can result in significant civil and criminal penalties, so a lot is at stake.

The following are a number of issues that you might present to your company in responding to this hypothetical situation under the Export Administration Regulations, International Traffic In Arms Regulations, U.S. sanctions laws and U.S. import laws. The details of your response, of course, will vary depending upon the company and violations involved. A lot will have to happen quickly so it is important for you to be prepared in advance for this situation.

(1) Stop the unlawful activity.
(2) Collect the relevant information.
(3) Analyze possible violations, identify criminal violations early.
(4) Consider a voluntary self-disclosure.
(5) Respond to requests for information.
(6) Review other possible issues in export and import enforcement actions.
(7) Understand personal liability for export and import violations.

To see the details of each of these steps, read McVey’s full article at:

Thomas McVey is the Chair of the International Practice Group at Williams Mullen in Washington DC where he advises clients on export control issues under ITAR, the Export Administration Regulations and the OFAC Sanctions Laws.



Effective Comments and the Fourth Branch of Government

Certificate holders must be adept at dealing with the government. Maintenance providers need to understand the administrative agencies overseeing the industry and recognize how and when to engage in the process in order to better the system. The four sessions in the “fourth branch of government” training series are now available on demand. Purchasers can bundle all four together or focus in on either the administrative agencies themselves (two sessions) or the rulemaking process (two sessions).

The Rulemaking Process – Overview
This session provides an overview of how federal agencies make regulations that have the force and effect of law. Specifically, it reviews the agencies that must follow the Administrative Procedure Act, the procedures governed by the Act as well as other methods by which an agency can obtain recommendations from the public on its rulemaking activities and mandates.
Click here to register and get access for 90 days (multiple bundles available).

The Rulemaking Process – Effective Comments
This session provides methods for submitting effective comments on FAA rulemaking proposals and on other documents that are posted for feedback from stakeholders.
Click here to register and get access for 90 days (multiple bundles available).

Administrative Agencies & Their Powers
This session reviews why federal administrative agencies are created and how they use their powers to regulate activities within their jurisdiction. The course will also cover the basic procedures agencies must follow to create or revise regulations.
Click here to register and get access for 90 days (multiple bundles available).

Administrative Agencies – The FAA & NTSB
This session reviews the creation and powers of the two agencies most prominent in civil aviation – the FAA and the National Transportation Safety Board (NTSB).
Click here to register and get access for 90 days (multiple bundles available).

Registration for an ARSA-provided training session includes:

  • Unlimited access for 90 days to the recording.
  • A copy of the presentation and all reference material with links to relevant resources and citations.
  • A certificate upon completion of the class, as well as any test material.

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 To learn more about the association’s training program and see course availability, visit


ICA – From the Basics to Your Business

View ARSA’s three-part series on instructions for continued airworthiness (ICA), led by Managing Director and General Counsel Marshall S. Filler. ICA has been a key focus of ARSA’s work on behalf of the maintenance community for decades and it continues to demand attention from aviation businesses worldwide. Turn the association’s experience into your benefit.

ICA – The Basics
This session overviews the regulatory basis for ICA, including what documents are considered ICA and the obligations of design approval holders to prepare, furnish and otherwise make them available under 14 CFR § 21.50(b). It also covers the related regulations that apply to operators and maintenance providers regarding the use and availability of ICA. Finally, it shows how the FAA has interpreted some of the more important ICA requirements in Order 8110.54.
Click here to register and get access for 90 days.

ICA – The Business Side
This session explains the importance of ICA and describes ARSA’s efforts to strike an appropriate balance between often-competing regulatory and business considerations. It also addresses various design approval holder (DAH) business practices that affect the availability and use of ICA and explains the FAA’s policy prohibiting DAHs from engaging in certain behaviors. It also explores various FAA ICA legal interpretations and some of the issues being examined in an ongoing anti-trust inquiry by the European Commission’s Competition Directorate.
Click here to register and get access for 90 days.

ICA – Case Study: Testing Your Knowledge
This session will test participants’ knowledge of ICA-related provisions in 14 CFR and FAA guidance by presenting several hypothetical case studies. Each one will focus on one or more of the significant ICA regulatory principles.
Click here to register and get access for 90 days.

Click here to purchase all three sessions together and receive a “bundle” discount.

Note: Sessions must be viewed in order. Completion of each pre-requisite – either via live session or on-demand recording – is required for access to subsequent classes.

Registration for an ARSA-provided training session includes:

  • Unlimited access for 90 days to the recording.
  • A copy of the presentation and all reference material with links to relevant resources and citations.
  • A certificate upon completion of the class, as well as any test material.

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 To learn more about the association’s training program and see course availability, visit


“Going Global” with International Regulatory Law

International markets mean expanded business opportunities that require an understanding of international regulatory requirements.

Going Global – A Primer on International Regulatory Law
This session summarizes the framework for international safety regulation, introduces ICAO’s mechanisms for allocating regulatory responsibilities among member states and addresses the important role bilateral agreements play in enhancing efficiency and facilitating international commerce.
Click here to register and get access for 90 days.

Going Global – Bilateral Agreements
This session focuses on bilateral airworthiness agreements (BAA) and bilateral aviation safety agreements (BASA). Topics include the purpose and scope of these agreements, the process required to obtain a BASA and how BASAs are structured. The presentation explains specific activities covered in a typical BASA including design approvals and post-design approvals, production and surveillance, export airworthiness approvals, technical assistance between authorities and special arrangements. It also covers bilateral maintenance agreements, their associated special conditions and the latest maintenance developments out of ICAO.
Click here to register and get access for 90 days.

Want your regulatory knowledge to travel well? Click here to purchase both “Going Global” sessions together and save.

Registration for an ARSA-provided training session includes:

  • Unlimited access for 90 days to the recording.
  • A copy of the presentation and all reference material with links to relevant resources and citations.
  • A certificate upon completion of the class, as well as any test material.

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 To learn more about the association’s training program and see course availability, visit


Part 21 – Seeking Approval

In November 2016, Marshall S. Filler wrapped up a three-part series on 14 CFR part 21, “Certification Procedures for Products and Articles.” The entire series is available for unlimited on-demand viewing.

Part 21 – Overview
This session provides an overview of the aviation safety regulations governing design and production of civil aviation products and articles as well as airworthiness certification of civil aircraft.
Click here to register and get access for 90 days.

Part 21 – Design Approvals & Design Changes
This session reviews the elements necessary to obtain design approvals for civil aviation products, including type certificates, amended type certificates and supplemental type certificates. It will explain the requirements for obtaining approval of design changes to those certificates including the changed product rule. Finally, it will describe the design requirements for obtaining a parts manufacturer approval and technical standard order authorization, and for obtaining approval of design changes to those articles.
Click here to register and get access for 90 days.

Part 21 – Production Approvals
This session explains the requirements for obtaining a production approval for civil aviation products and articles as well as the elements of an FAA-approved quality system and the method for making revisions to that system. It also addresses the privileges and responsibilities of production approval holders including the issuance of airworthiness approvals and authorized release documents for aircraft engines, propellers and articles.
Click here to register and get access for 90 days.

Want all three sessions? Click here to  purchase them together and save.

Registration for an ARSA-provided training session includes:

  • Unlimited access for 90 days to the recording.
  • A copy of the presentation and all reference material with links to relevant resources and citations.
  • A certificate upon completion of the class, as well as any test material.

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 To learn more about the association’s training program and see course availability, visit


Regulatory Compliance Training

By ARSA Training and Regulatory Teams

Test your knowledge of 14 CFR § 43.17(a)-(c) – Additional performance rules for inspections.

Click here to download the training sheet.


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Tell Us About It: How to Contact ARSA

As the voice of the global aviation maintenance industry, ARSA provides its members with world class resources including regulatory compliance assistance and professional advocacy services.

Having trouble with an inspector? Need clarification on regulations or guidance material? Want access to industry resources? Have a story to share? The association’s staff will consider all questions, comments and requests.

Individuals from member organizations have several venues to get in touch with ARSA’s experts. They may contact any team member by phone or email (click here to see the team listing), submit general email queries to or using the online contact form.

If you don’t know to whom your question or request should be sent, the contact form is the best avenue. It will help you categorize your submission, which allows the administrative team to quickly rout it to the appropriate person.

The form – as well as the office phone number and a link to the team directory – is always available at For easy reference by readers of this edition of the hotline, it is also included below.

Remember, it’s always worth it to ask ARSA first!

Try It Out...

Contact Form

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AMT Day 2017 – No Days Off


Charles Taylor

Charles Taylor, the Wright Brothers’ mechanic and father of aviation maintenance, was born on May 24, 1868. Now – 149 years later – we celebrate him with every safe arrival.

In 2008, a congressional resolution dedicated the date in honor of Taylor, establishing National Aviation Maintenance Technician Day. While the “holiday” doesn’t get anyone out of work (there are no days off from aviation safety), it’s important to celebrate the commitment, integrity and skill of every aircraft mechanic and all those who support them – this is Taylor’s legacy and our shared responsibility.

Hopefully all ARSA members did something to recognize May 24, 2017. Those had celebrations or activities of any kind are encouraged to share them with ARSA (contact Brett Levanto at

Regardless of what was planned, here are some ways to celebrate AMTs on any day:

(1) Talk with fellow technicians, colleagues and friends about how they became technicians. Ask what inspires them about the work. If you hear a great answer, send it to ARSA.
(2) Plan a visit to a local school or invite students to tour your facility. Show off for a day, maintenance work is interesting an important. Take some pictures and send them to ARSA.
(3) Hold a screening (or send around) the association’s short documentary “You Can’t Fly Without Us – The World of Aviation Maintenance.”
(4) Support industry events, particularly those that showcase the talent and skill of technicians. This year’s Aerospace Maintenance Competition just wrapped up in Orlando, check out the highlights of the event and see how you can get involved next year.

No matter how you celebrated AMT Day, it’s a small bit of well-deserved recognition. Thank you for your hard work, dedication and support.

The world can’t fly without you.


A Member Asked…

Q: When does a change in ownership trigger the involvement of the FAA in a repair station certificate?

A: The rule states that the privileges of a repair station certificate are not transferable. Specifically, section 145.57(b) states that if a person holding a “repair station certificate sells or transfers its assets and the new owner chooses to operate as a repair station, the new owner must apply for an amended or new certificate.” (Emphasis added.) The requirement to apply for a new or amended certificate is only triggered with the sale of assets.

Straightforward stock purchases on the other hand will not require any action or oversight by the FAA. Stock is transferred all the time and the FAA will not get involved because the person that holds the repair station certificate remains the same. Should the stock sale trigger a name change or if the new owners want to change the repair station’s ratings or its location, those actions must be coordinated with the FAA.  See 14 CFR § 145.57(a). The FAA’s internal guidance walks through some of the nuances of an asset sale. See Order 8900.1 CHG 504, vol. 2, ch. 11, sec. 7, para. 2-1273 (Dec. 28, 2016).

The FAA chief counsel opined in 2012 – although in different context – that the agency’s main concern when a certificated entity changes ownership “is whether any of the elements that formed the basis of the original certification have been altered as a result of the sale.” (Legal Interpretation to Gregory S. Walden (Nov. 8, 2012)) The legal opinion relies on and is consistent with the plain language of § 145.57: When there is no change in assets (e.g., housing, facilities, equipment, technical data), the certification basis remains the same. A stock purchase alone will not require any of the new owners to seek a new or amended certificate.

Have a question for ARSA? Click here to let us hear it.


Make ARSA’s Voice Your Own: Advertise

ARSA has a menu of advertising opportunities for, 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


Stand Up for ARSA by Sponsoring in 2017

In order to provide world-class resources for its members, the association depends on the commitment of the aviation community. By sponsoring events and activities, supporters can help ARSA’s work on behalf of repair stations to endure.

Need a place to start? For information about opportunities, including sponsorship of the Strategic Leadership Conference in October (click here for info), contact Vice President of Communications Brett Levanto (


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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 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

EAA Airventure – Oshkosk, Wisconsin – July 24-30
ATEC Fly-In – Washington – Sep. 6-7
Aero-Engines Europe – Madrid – Sep. 13-14
MRO Europe – London – Oct. 3-5
Airline Engineering & Maintenance: North America – Miami – Oct. 18-19
AVMRO Strategic Leadership Conference – Washington – Oct. 18-19 
MRO Asia-Pacific – Singapore – Oct.31-Nov. 2
Aerospace Manufacturing Asia-Pacific – Singapore – Nov. 1-2
Aero-Engines Asia-Pacific – Singapore – Nov. 1-2


Previous Editions

2017: Jan Feb Mar Apr May               
2016: Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec 
2015: Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec
2014: Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec
2013: Jan Feb Mar Apr May June July Aug Sept Oct Nov Dec
2012:           June July Aug Sept Oct Nov Dec

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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 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.

© 2017 Aeronautical Repair Station Association