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2018 – Edition 5 – June 8

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.

Hotline Feature
ARSA Works
Legal Brief
ARSA on the Hill
Getting FacetimeTraining
Membership
Resources
Industry Calendar


Hotline Feature – How ARSA Works

Turning the Gears

By Christian A. Klein, Executive Vice President

More than 20 years ago, one of the first members of Congress I met as a somewhat younger lobbyist told me something I’ve never forgotten: Congress is like a big machine with hundreds of gears; when you get enough of those gears turning in the same direction, you can actually get something done.

ARSA’s job on Capitol Hill is get gears turning in the right direction for the aviation maintenance industry (or to jam a wrench in works if they’re turning the wrong way!).

The task is daunting for one person or organization: There are 535 representatives and senators, scores of committee and subcommittee offices and thousands of congressional staffers. The secret to turning multiple gears is coalition building – joining with others to accomplish mutual objectives.

The industry-wide effort to create a new grant program to address the technician shortage is a case in point. The idea was born from ARSA’s interactions with Senate offices interested in getting a maintenance workforce development language included in the FAA reauthorization process. The result of ARSA’s coalition building was the introduction of a standalone bill in the Senate on March 7 (S. 2506) supported by 20 major aviation organizations. The House version (H.R. 5701) was introduced on May 8. The gears on the Hill are moving along with support from all segments of the industry, including airlines, manufacturers, business and general aviation and labor.

The coalition is notable for two reasons:

First, the FAA reauthorization process is usually acrimonious; this time it is pitting airlines against business and general aviation over the recently-abandoned (for now) issue of privatizing air traffic control. On the Senate side, efforts to reduce the hour requirements for air transport pilot training have raised the ire of passenger rights groups. Therefore, getting 20 aviation organizations on the same page on anything is a minor miracle; it underscores the widespread concern about the maintenance skills gap.

The other miracle is that it’s the first time ARSA has collaborated with labor organizations on a legislative issue. It’s no secret that unions representing airline mechanics have long opposed contract maintenance (and are continuing to paint repair stations – particularly those outside the United States – in a negative light).

In fact, as the hotline went to press, Sen. Claire McCaskill (D-Mo.), Rep. John Garamendi (D-Calif.) and Dan Donovan (R-N.Y.) introduced union-supported bills in the Senate and House targeting contract maintenance. The legislation would require airlines to publicize – via their websites, ticket confirmation and boarding passes – the cities and countries in which their aircraft undergo heavy maintenance. The intent of the legislation is clear: to turn public opinion against “outsourcing.”

CONTENT BREAK FOR A CALL TO ACTION

Make sure the maintenance community’s voice is heard and help ARSA stop the McCaskill-Garamendi-Donovan bill:

(1) Identify your representative and senators by going to https://www.govtrack.us/congress/members

(2) Click here to download ARSA’s Excel file with staffer contact information in each congressional office; find contacts working for your elected officials.

(3) Send them an email urging them opposition to the McCaskill-Garamendi-Donovan Bill using these facts:

(a) Maintenance performed on the U.S. fleet is under the complete control of the Federal Aviation Administration—all is performed to the same safety standards.
(b) Government scrutiny of all repair stations is exactly the same; the fact that bilateral agreements allow the governments to share information and collaborate in safety audits does not lower the American standards.
(c) Requiring air carriers to inform the public of where maintenance is performed does nothing to further aviation safety.
(d) Any non-safety enhancing mandates increase expenses to every business in the United States and will unnecessarily raise ticket prices.

These tactics won’t stop the collaboration to attract and retain the next generation of AMTs. In fact, lobbyists for the Aircraft Mechanics Fraternal Association (AMFA) are the most consistent participants in the dozens of House and Senate meetings ARSA has organized to build support for the workforce bill. Working together, we’ve convinced 17 senators from across the political spectrum to cosponsor it.

It’s an important lesson about politics: You don’t have enemies; you have issue-specific opponents. The organization whose message you’re picking apart in the media one day will be your strongest ally the next.

Make no mistake: ARSA will continue to zealously advocate for repair stations and crow about all the ways members have made the industry safer and more efficient. It’ll continue to protect the industry from unnecessary regulatory mandates—including the recent foray against airline customers.

The partnership built with AMFA and other organizations is a bridge to future cooperation where interests and objectives align. Together more gears will turn in the right direction, achieving much more for the entire aviation industry.

 


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ARSA Works

ARSA Calls Out “Abdication” of ICA Authority in EASA Proposal

On May 29, ARSA submitted comments in response to EASA’s Notice of Proposed Amendment (NPA) 2018-01 pertaining to Instructions for Continued Airworthiness (ICA). The association praised the agency’s effort, then critiqued the proposal against decades of industry frustration with regulatory treatment of maintenance data.

“Although NPA 2018-01 includes positive measures, it falls significantly short of what is needed to ensure continued airworthiness and address the longstanding disconnect between the design and maintenance rules,” ARSA said. “The NPA leaves continuing airworthiness management organizations and component maintenance providers in a regulatory “no man’s land.” These organizations are required to possess and follow manufacturer manuals but have no regulatory support to obtain them.”

Online Training – Full ICA Series Available On Demand

The NPA’s approach to standardizing ICA practices provides specific avenues in which maintenance instructions would be considered ICA. Outside of these situations, “remove and replace” remains the only method for continued airworthiness of a product.

Overall, EASA’s proposal demonstrated a continued “abdication” of regulatory authority to the design approval holder. It also fails to address the number of ways in which designers and producers can make ICA “constructively unavailable” to maintainers.

“Considering that the European Commission’s anti-competitiveness investigation appears stalled, there’s no imminent solution to the government-sponsored monopoly on component maintenance data bestowed on suppliers to the type certificate holders,” ARSA said.

The NPA is the result of an effort begun in 2009 (Rulemaking Task 0252, MDM 056) to review the European Commission’s (EC) ICA regulations and determine whether changes are needed. After evaluation of the comments received concerning the NPA, EASA will develop an opinion containing the proposed amendments to Part-21 and submit it to the EC as the technical basis to prepare an EU regulation. Following adoption of the rule by the EC, EASA would issue a Decision publishing the Acceptable Means of Compliance (AMC) and Guidance Material (GM).

ARSA’s comments, along with others from the industry, will impact the rest of this process. The association will remain engaged on the ICA issue on both sides of the Atlantic.

To read the complete comments, click here.

 


ARSA, AEA Request FAA Cleanse Guidance of “Letter of Compliance”

On May 29, ARSA and the Aircraft Electronics Association (AEA) asked the FAA to withdraw all references from its guidance material requiring applicants for repair station certificates to submit a “letter of compliance.”

The submission of a “letter of compliance” was specifically rejected – a 2006 notice of proposed rulemaking (NPRM) including such a requirement was withdrawn in 2009 – but its submission is “required” by the preapplication and formal application instructions in the Flight Standards Information Management System (FSIMS).

“Considering (1) the rulemaking procedure specifically declined to impose the requirement for an applicant to submit a letter of compliance and (2) the introduction of the data collection tools of the safety assurance system eliminates the need for such a document, we request the agency withdraw all references to a letter of compliance in its guidance material as soon as possible,” ARSA and AEA said.

To read the full letter from ARSA and AEA to Flight Standards Executive Director John Duncan, click here.

 


ARSA Renews “Serious” Effort on SDRs

In May 2017, an ARSA-led coalition of aviation industry associations and private businesses sent a letter to the FAA seeking an objective standard for service difficulty reports (SDRs) under § 145.221.

In its July 26, 2017 response, the FAA agreed the term “serious” in context of failures, malfunctions or defects detected in articles during maintenance was “not well defined or interpreted consistently.” The agency, unfortunately, failed to see the industry’s logic regarding mitigation by corrective action or airworthiness directive.

To rectify the situation, ARSA has been working with the FAA regarding development of clear SDR guidance for repair stations. At the agency’s urging the association and its allies are developing a draft advisory circular that will align the SDR requirements for repair stations with those of design and production approval holders as well as owners and operators. The association is currently finalizing its draft and coordinating review with its association and business partners.

In the meantime, keep ARSA in the loop: Click here to contact the association regarding issues of inspector interpretation or application of § 145.221.

To read the coalition’s May 23, 2017 letter, click here.

To read the FAA’s response, click here.

To review the entire “serious” issue, which was created by the FAA’s 2014 updates to part 145, visit: arsa.org/serious

 


Industry Sets Remote Connectivity Baseline for FAA

n May 7, ARSA and 15 of its aviation industry allies jointly submitted a draft advisory circular to the FAA providing “guidance for using remote connectivity technology and tools.”

The guidance document was developed after consultation with agency personnel regarding the existing draft policy “Remote Witnessing Using Video,” which was open for comment in early 2018. The AC would provide a baseline for the agency, its applicants and certificate holders to comply with 14 CFR while taking advantage of advances in connectivity technology and related video, live-stream and other visual and audio tools.

To facilitate the use of the best available technology, the draft AC establishes general requirements for set up and use of tools and equipment. The elements outlined in the document assist users in ensuring “the same level of acumen and capability [through remote connection] as if the oversight, inspection, test or training task or activity was conducted on-premises.”

The draft AC was delivered to Dorenda Baker, executive director of the Aircraft Certification Service and John Duncan, executive director of the Flight Standards Service. In addition to ARSA, its submission was supported by:

Aerospace Industries Association
Aircraft Owners and Pilots Association
Airlines for America
Aviation Suppliers Association
Aviation Technician Education Council
Cargo Airline Association
General Aviation Manufacturers Association
Modification and Replacement Parts Association
National Air Carrier Association
National Air Transportation Association
Professional Aviation Maintenance Association
Regional Airline Association
The Boeing Company
Gulfstream Aerospace Corporation
MOOG Aircraft Group

To view the complete submission, click here.

 


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 Brief

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.

Preparing for the Worst from Brexit

By Sarah MacLeod, Executive Director

As the deadline for Brexit approaches, many multi-country design, production and maintenance certificate holders are concerned about the impact on civil aviation relationships in the event of a “hard” Brexit. The association would like to remind certificate holders that there are ways to ensure continued operations under the various regulations of the affected countries, such as—

  • Maintenance providers may use companies located in the United Kingdom (UK) as non-certificated The originating repair station (or air carrier) may also perform final inspections and issue approvals for return to service under a “working away from the fixed location” scenario.
  • Design approval holders may continue relationships through delegated authorities or movement of the primary location to a country that will continue to participate in the European Union.
  • Production approval holders can bring UK-located manufacturing locations under the “parent” production approval authority and delegate final airworthiness inspection capabilities to that location.

While these possibilities are neither convenient nor easy, they are a stop-gap measures for continuing a relationship until bilaterals can be resurrected or negotiated. For more information on this subject:

(1) Review the resources presented on ARSA’s Brexit reference page.

(2) Answer this month’s “quick question” regarding your relationships to businesses in the UK.

(3) Members may send specific queries through arsa@arsa.org.

 


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ARSA on the Hill

A Busy and Successful Month for Repair Stations on Capitol Hill

By Christian A. Klein, Executive Vice President

ARSA is wearing out shoe leather advocating for the maintenance industry in the halls of Congress. It’s clear that messages about aviation workforce, smarter regulation and improving government efficiency are resonating and we’ve made considerable progress over the past month.

Here’s a quick look at everything we’re trying to accomplish on our members’ behalf and the status of the priority issues:

Front and Center–FAA Reauthorization

The “big game” at the moment FAA reauthorization, which Congress enacts every few years to establish the agency’s budget and set policy priorities.

Concerned that the Trump administration’s hostility to free trade and outsourcing could make repair stations a political target, ARSA mounted an aggressive campaign to educate key committee lawmakers about the industry’s employment and economic impact in every state and all the ways repair stations – domestic and foreign – contribute to aviation safety and efficiency. Those efforts paid off and, to date, no negative maintenance-related language has been included in either the House or Senate bills (though, as the association expected, efforts are under way – see this edition’s Hotline Feature to learn how to take action).

ARSA then shifted from a defensive to offensive posture and started working to include provisions beneficial to the industry. We succeeded in including language to:

  • Direct the Government Accountability Office (GAO) to examine the aviation technician shortage (House bill).
  • Add maintenance to the stakeholders included on the agency’s new Safety Oversight and Certification Advisory Committee (House and Senate bills).
  • Direct the FAA’s Aviation Rulemaking Advisory Committee to examine ways to improve repairman certificates (Senate bill).
  • Restore the right to voluntarily surrender repair station certificates (Senate bill).

As FAA reauthorization moves through the legislative process ARSA will continue to urge lawmakers to include all those provisions in the final law.

Want to Learn More About ARSA PAC?

ARSA’s Political Action Committee helps elect congressional candidates who share ARSA’s commitment to better regulation and a strong aviation maintenance sector.   In this critical election year, ARSA PAC has never been more important.  But ARSA is prohibited from sending PAC information to members who haven’t opted in to receive it.

Please take a second to give us prior approval to talk to you about ARSA PAC.  Doing so in no way obligates you to support PAC.  It just opens the lines of communication.

Click here to give ARSA your consent today.

Top Priority—Workforce Development

ARSA’s 2018 member survey highlighted all the ways repair stations are being affected by the technician shortage, adding urgency to enactment of aviation workforce development legislation. We found a strong ally on the Hill in Sen. Jim Inhofe (R), whose home state of Oklahoma has more people employed in aviation maintenance as a portion of its total population than any other.

In March, Inhofe joined with three senators from other states with big aviation maintenance sectors – Connecticut, Kansas and Washington – to introduce a bill (S. 2506) that would create a new program to provide grants of up to $500,000 to businesses (or labor organizations), schools and governmental entities that collaborate to attract and retain the next generation of aviation technicians.

ARSA is leading the lobbying coalition to build support for the bill, which in addition to Inhofe now has 16 co-sponsors from both parties. The goal is to get it added to the FAA reauthorization bill as an amendment when the Senate considers the legislation (possibly as early as June).

On May 9, Reps. Sam Graves (R-Mo.), Dan Lipinski (D-Ill.), Markwayne Mullin (R-Okla.) and Brenda Lawrence (D-Mich.) introduced a parallel House bill (H.R. 5701). The legislation currently has eight (co)sponsors. Although the House has already passed its version of the FAA reauthorization in April, having as many cosponsors as possible on H.R. 5701 will strengthen our allies’ hands during eventual conference negotiations to reconcile the House and Senate bills.  Click here to learn what you can do to support these vital efforts.)

And Now a Word for Our Sponsors …

The members of Congress listed below have all officially signed onto legislation to create a new grant program to support maintenance workforce development.  If your representative and senators are on the list, click here to send them a note to say thanks.  If they aren’t on the list, click here for instructions on how to contact them and get them on board.

Senators Cosponsoring S. 2506

Sen. Richard Blumenthal (D-Conn.)
Sen. Maria Cantwell (D-Wash.)
Sen. Shelley Moore Capito (R-W.V.)
Sen. Tammy Duckworth (D-Ill.)
Sen. Maggie Hassan (D-N.H.)
Sen. Orrin Hatch (R-Utah)
Sen. John Hoeven (R-N.D.)
Sen. Jim Inhofe (R-Okla.)
Sen. Amy Klobuchar (D-Minn.)
Sen. Catherine Cortez Masto (D-Nev.)
Sen. Claire McCaskill (D-Mo.)
Sen. Jerry Moran (R-Kan.)
Sen. Gary Peters (D-Mich.)
Sen. Pat Roberts (R-Kan.)
Sen. Dan Sullivan (R-Alaska)
Sen. Tom Udall (D-N.M.)
Sen. Roger Wicker (R-Miss.)

Representatives Cosponsoring H.R. 5701

Rep. Ted Budd (R-N.C.)
Rep. Cheri Bustos (D-Ill.)
Rep. Julia Brownley (D-Calif.)
Rep. Sam Graves (R-Mo.)
Rep. Brenda Lawrence (D-Mich.)
Rep. Daniel Lipinski (D-Ill.)
Rep. Markwayne Mullin (R-Okla.)
Rep. Richard Nolan (D-Minn.)

Improving DOD Commercial Derivative Aircraft Maintenance

ARSA is also urging lawmakers to explore ways to enhance the efficiency of Department of Defense (DOD) procurement practices associated with the maintenance of commercial derivative aircraft (CDA). ARSA believes broader DOD acceptance of FAA approvals (e.g., for “DER-repairs” and parts manufacturer approvals) would reduce redundant reviews, enhance military readiness and save taxpayers’ money.

We’ve found a lot of sympathetic ears on Capitol Hill and a willingness to include language in the National Defense Authorization Act (NDAA) to explore opportunities to promote more consistent DOD acceptance of FAA approvals.

The version of the NDAA passed by the House on May 24 (H.R. 5515) includes report language directing DOD to brief members of Congress on aviation parts availability and supply issues and reads as follows:

Supply of Aviation Parts and Spares
The committee is concerned by the rate of non-mission capable aircraft due to issues with supply of parts and spares. The committee is aware of numerous examples of aircraft that have been non-mission capable for several months waiting for the arrival of a part. Therefore, the committee directs the Under Secretary of Defense for Acquisition and Sustainment to provide a briefing to the House Committee on Armed Services not later than September 30, 2018, on the Department’s efforts to address issues associated with the availability and supply of aviation parts and spares. At minimum, the briefing should provide an update on the rate of non-mission capable aircraft due to supply, specific actions the Department is taking to decrease this rate, and commercial and industry best practices for maintenance and supply that may be adopted as part of an overall strategy to improve aircraft mission capability rates.

Related language is also included in the report for the Senate’s NDAA bill (see page 239). The Senate provision is more direct and urges DOD to prioritize the use of non-developmental and commercially available items with existing FAA certifications when maintaining CDA as long as the use of those products does not compromise safety or security requirements established by DOD. The Senate is expected to take up the NDAA bill in June.

It’s important to note that provisions in the House and Senate bills are report language, not legislative mandates. They therefore do not have the force of law and should be instead considered informal statements of congressional opinion on the FAA approval issue.

ARSA supports improved access to government contracting opportunities for all its members. That said, as the debate over DOD acceptance of FAA approvals has played out, DOD has raised questions that must be addressed. We believe the House and Senate language furthers the goal of meaningful dialogue between industry and DOD through which ARSA and its members will obtain more information about the Department’s current policies and concerns. At the same time, these actions will provide DOD with better awareness about the benefits of more consistent acceptance of FAA approvals along with information about, and access to, contracting opportunities.

Get Active

Members interested in learning more about ARSA’s legislative activities should reach out to ARSA Executive Vice President Christian Klein. ARSA is standing by to help members organize facility visits for lawmakers. Hosting a member of Congress or other government official is a great way to raise your company’s–and the industry’s–visibility and improve awareness about how repair stations are impacted by decisions made on Capitol Hill.

 


Tell Congress to Support Maintenance Workforce Bill

Members of the aviation maintenance community need to join ARSA’s aggressive effort to include the association’s workforce development legislation in the FAA reauthorization process. The bill would create a new grant program to develop skills demanded by repair stations. So far, 20 national interest groups and labor unions have joined the effort and momentum is building on Capitol Hill (see below for updates on the House and Senate versions of the bill).

Aviation businesses can (and should) help add more cosponsors in the House and Senate and help demonstrate support for the proposal to congressional leadership. The association webpage linked below makes it easy to send notes to elected officials encouraging them to cosponsor the bill (or to thank them if they already have).

Make your voice heard and engage lawmakers in the work of closing the aviation maintenance workforce skills gap:

Get Involved – Tell Your Elected Officials to Support the Aviation Maintenance Workforce Grant Program

ARSA Workforce Legislation Action Center

 

 


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Getting Facetime

Open Door Policy – How ARSA Engages the Government

Many bosses have “open door policies.” Employees are always welcome into their manager’s office or workspace to discuss issues, air grievances or share feedback. The practice has become a familiar strategy to ensure openness and transparency in the workplace.

It’s also a completely misguided waste of time, if taken only at face value.

Having an “open door” means nothing if nobody comes through it. The best way for a leader to understand what’s going on around them is to go out and see for themselves.

The same is true for organizations, particularly those charged with advocating on behalf of others. The policy world won’t come to you, no matter how “open” you are, unless you make it happen. ARSA’s letters, petitions and other official requests to aviation regulators are well publicized. However, those deliveries come at the end of a long process of negotiation and discussion.

ARSA members will recognize this conviction in the association and should model their own behavior on the association’s engagement:

(1) Going to Them–Get Out That Door. ARSA’s team painstakingly manages a schedule of regular meetings with government officials. At these updates, the association reviews issues it is working, reports on what matters to the industry and solicits feedback on plans for regulatory action. This means regular visits to the FAA, of course, but also other offices impacting aviation businesses in the Departments of Transportation, State and others.

Putting this into practice requires a careful review of the parts of government that directly impact your work. Create a list of those officials and/or offices and establish priorities, making the most time and meeting with the highest frequency those at the top. Some basic research will reveal organizational profiles and basic contact information for relevant offices. Reach out and tell them you’d like to come visit.

It also means becoming familiar with the schedule of public conferences, stakeholder meetings and other gatherings sponsored by the government. ARSA’s team regularly attends and actively engages the government through these events. It encourages industry to get involved and often works directly with organizers to shape content and plan discussion. Not only does this help ensure a useful, productive event, it cultivates personal relationship with the individuals working on relevant matters.

Of course, physically getting there can be difficult. ARSA’s location convenient to Washington, D.C. makes visits to many parts of the American government simple, but the association represents a world of aircraft maintenance providers (not to mention various regions, districts and offices supporting centralized agencies).

To manage distance, make choices about when and how to invest. When physical presence is impossible, find other means. Now that regulators are using remote connectivity for inspections and training, surely technology can support some collegial face time.

(2) Bringing Them to You–This is the way that an “open door” actually works: When you make others come through it. Just as it regularly goes out to others, ARSA has a routine schedule of hosting visitors. In a three-week span this May, the association’s team sat down, with representatives from fellow trade associations, EASA, the U.S. Small Business Administration and the Department of Commerce. Attendees at these meetings talk about their priorities, ask questions about specific issues, share resources and learn how different pieces fit together.

Hosting someone from the government takes the exact same planning as going to them. It depends on geography, of course, but even contacts who typically work elsewhere have other reasons to land close to you (as a prime example, ARSA once took advantage of the 2016 FAA-EASA International Safety Conference to get time with EASA Executive Director Patrick Ky, who had come to D.C. for the event).

No matter how it engages with the government–both in-person and through other correspondence–ARSA is always professional and goal-oriented. By making a plan, carefully documenting resources, communicating follow up actions and always having a purpose when interacting with the government, the association builds useful relations and is a valuable resource to others.

Everyone can. All it takes is a plan and time. Don’t just call your contacts when there’s a problem (as attendees to ARSA’s training session on “building a positive relationship with the government” are reminded).

It’s great to have an open door, but only if you know how to use it.

 


ARSA’s Filler to Lead Panel at FAA-EASA Conference

Marshall S. Filler, ARSA managing director and general counsel, will moderate a panel on “aviation maintenance in the digital era” during the 2018 FAA-EASA International Safety Conference in Washington, D.C. Registration is open for the event, which will run from June 19-21.

ARSA members are encouraged to attend, click here to register.

Filler’s panel will be held on Wednesday, June 20 at 10:45 a.m. as one of two sessions focused on “Global Collaboration.” The general topic was identified by event organizers – with input from ARSA and its allies – as a strategic focus area for the aviation community. Filler will lead panelists through discussion outlined in the abstract:

A range of new approaches to maintenance is under development or already in commercial use such as electronic logbooks/maintenance records; aircraft inspections using drones; remote inspections using video; and big-data driven maintenance decision-making.  In this panel session, industry will present innovative maintenance solutions, discuss potential issues with paperless maintenance records (including input from leasing companies), and propose possible regulatory approaches to related issues, such as addressing duplicative MRO oversight.

Through the annual event, the agencies and the aviation community share information and work toward harmonized safety standards, policy and procedures. That purpose – though noble – only becomes reality through active participation by the industry, and maintenance must be well represented for there to be a true “systems approach” to international regulatory oversight.

To see the agenda, click here.

To register, click here.

To learn how to make the most of the event and its setting in the nation’s capital, visit arsa.org/faa-easa-conference and read “2018 FAA-EASA Conference – Attend, Assist, Advocate.”

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Showing Global Leadership

On May 1, the FAA hosted its Annual Global Leadership Meeting in Washington, D.C. ARSA Executive Director Sarah MacLeod participated in a panel discussion of western hemisphere priorities. The panel was moderated by Christopher Barks, director of the agency’s western hemisphere region under the Office of International Affairs, and included participants from Honeywell, JetBlue Airways and the International Air Transport Association.

The conference brings together the various FAA offices involved in international activities. Through a day-long series of moderated sessions, the agency engages industry stakeholders to review key issues, collect lessons learned and to formulate yearly strategic goals for the Global Leadership Initiative. Agency personnel then reconvene for an additional day of working sessions on specific action areas–this year including global engagement, innovation technology and cyber security.

Industry input is critical for the FAA in making gains in aviation safety, air traffic management and regulatory harmonization across international borders. By supporting this kind of event, ARSA ensures an experienced voice represents maintenance interests.

In doing so, MacLeod didn’t confine herself to Canada, Latin America and the Caribbean. She reviewed broader issues with regulatory harmonization that matter globally–the state of registry’s control of maintenance and the troubles of current bilateral relationships. The panel’s western hemisphere focus allowed her to highlight the U.S.-Canada relationship as the only truly bilateral aviation safety agreement–neither country issues an approved maintenance organization or repair station certificate to entities already holding the other’s approval–as part of a larger point as to how far there is to work towards true reciprocal acceptance.

To review MacLeod’s presentation slides, click here.

Even the region-specific discussion of the panel provides a perspective on broader international needs. Harmonization efforts led through ICAO’s regional technical cooperation projects and involving regional safety oversight organizations seek to promote greater acceptance of organizations and approvals across borders. As ARSA has long advocated, pursuing real bilateral agreements that actually address maintenance matters is vital to aviation safety everywhere.

As MacLeod wrote in the April 2015 edition of the hotline, the end goal of aviation world unity is WAR: world aviation regulations:

“Without a single world-wide regulatory regime, civil aviation authorities utilize national laws and [bilateral agreements] to collaborate and to create avenues for mutual recognition … Regrettably, the many [bilaterals] bearing American signatures do little for the maintenance community. Overarching agreement is great for the appearance of cooperation, but without robust maintenance implementation procedures, there is little of value to repair stations seeking to manage international responsibilities.”

The FAA’s representatives and other panelists were sympathetic to the need for good technical procedures to support bilateral agreements, but added that official international aviation cooperation is always a step in the right direction.

Industry’s responsibility is to remind the FAA and its partner agencies of their responsibility to aviation stakeholders and businesses. Events like the annual leadership meeting are key avenues to perform this duty and press toward better, more-sensible regulatory oversight in the United States and around the world.

Resources and Bodies Involved in Aviation Regulation of the Western Hemisphere

FAA Office of International Affairs
ICAO South American Office
Regional Safety Oversight Cooperation System
Central American Corporation of Navigation Services Area (COCESNA)
Central American Agency for Aviation Safety (ACSA)
Caribbean Aviation Safety and Security Oversight System (CASSOS)
U.S.-Brazil Aviation Cooperation Program

 


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Training

Travel Well with “Going Global” Regulatory Training

International markets mean expanded business opportunities that require an expansive regulatory understanding. Working on your global knowledge with two on-demand training sessions from ARSA Managing Director & General Counsel Marshall S. Filler.

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

Going Global – Bilateral Agreements

This session focuses on the purpose and scope of bilateral agreements and describes how they are developed and 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.

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.

Registration for an ARSA-provided training session includes:

  • Unlimited access for 90 days to the recording made available after the live session is complete.
  • 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 PotomacLaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.

 



Recordkeeping from Three Angles

roper maintenance demands proper documentation. Review the association’s recordkeeping sessions – led by Sarah MacLeod and Marshall S. Filler – and learn how to “finish the job with proper paperwork.”

Recordkeeping for Mechanics

Instructor: Sarah MacLeod
This session defines the regulatory responsibilities of the operator versus the maintenance provider in creating and maintaining maintenance records, including how obligations can be shifted by contract, but not under aviation safety regulations. It also covers maintenance recordkeeping regulations; the documents essential to making airworthiness determinations.

Click here to register and get access for 90 days.

Recordkeeping for Repair Stations

Instructor: Sarah MacLeod
This session delineates the differences between operator maintenance records and those required to be created, maintained and provided by repair stations.

Click here to register and get access for 90 days.

Recordkeeping for Airlines

Instructor: Marshall S. Filler
Air carriers have unique recordkeeping requirements under parts 121 and 135 that do not match the requirements for transferring an aircraft under part 91 or obtaining maintenance records from individual mechanics or repair stations under part 43. This session differentiates among and between the varying requirements so regulatory and contractual obligations can be clearly delineated.

Click here to register and get access for 90 days.

Registration for an ARSA-provided training session includes:

  • Unlimited access for 90 days to the recording made available after the live session is complete.
  • 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 PotomacLaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.

 


From the FAA – The Aviation Maintenance Awards

The FAA’s “Maintenance Hangar” on faasafety.gov contains information and resources the agency has produced or compiled to support safety in maintenance operations. Members of the maintenance community working on U.S.-registered aircraft should become familiar with these resources; at the very least they help highlight the areas considered most important by the agency.

To provide a taste of the content available in the “maintenance hangar,” this edition of the hotline highlights the FAA’s aviation maintenance awards program:

In October 1991, [the] Flight Standards Service determined a need for an incentive program to encourage AMT employees and employers to participate aggressively in available and recurrent maintenance training. Through the William (Bill) O’Brien Awards Program, the FAA recognizes eligible technicians and employers by issuing awards to those who receive or promote and foster initial and recurrent training.

Learn more about the program by reviewing the tutorial document, which guides individuals through registration, enrollment, participation and finally the claiming of the award:

Click here to access the tutorial document.

 



Regulatory Compliance Training

Test your knowledge of 14 CFR §§ 65.75 & 79 – Knowledge and skill requirements.

Click here to download the training sheet.

 


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ARSA-onlinetraining


Membership

The New AMS is Coming – Get Ready

This is your first warning (a good one):

ARSA is transitioning to a new membership engagement tool. The “association management system” (AMS) will integrate with www.arsa.org through an online portal providing direct access for members to information, benefits and resources.

Once the new AMS is unveiled, members will be able to manage the contacts included under their organization, navigate a contact directory, access/purchase publications, register for events, pay invoices and communicate with ARSA’s team and each other.

The ARSA team has spent the first half of the year learning the new system, tailoring it to member’s specific needs and updating procedures to accommodate its various features. The final review of current membership data is underway; it will be uploaded into the AMS shortly.

You will receive a “launch” notice via email when your membership information has been loaded into the new system. The message will include basic instructions for setting up your member portal account and begin exploring.

Stay tuned…

 


2018 NextGen Awards – Celebrate Young Talent

ARSA’s commitment to building the aviation maintenance workforce of the future means celebrating the excellence of the men and women who already keep the world safely in flight. The association encourages its members to celebrate outstanding young personnel through Aircraft Maintenance Technology Magazine’s Next Gen Awards. The 2018 schedule for the awards has been shifted earlier from previous years, so act now while memories of last year’s winners are fresh.

Criteria for selection include job commitment, industry involvement and contribution, professional achievement and innovation. Anyone working in any aviation maintenance field who will be 39 years old or younger on June 30, 2018 is eligible for nomination. Winners will be featured in the magazine’s August/September issue and celebrated on AviationPros.com.

Click here to learn more and nominate someone today. The deadline for submissions is June 15, 2018.

Anyone submitting a nomination is encouraged to contact ARSA’s Vice President of Communications Brett Levanto, so the association can join AMT Magazine in celebrating the best of this community’s young talent. Through its experience with the awards program in 2015, ARSA saw first-hand the vital importance of celebrating the maintenance industry’s most valuable resource: its people.

 


AMT Day 2018 – Celebrating Charlie

Charles Taylor, the Wright Brothers’ mechanic and father of aviation maintenance, was born on May 24, 1868. Now — 150 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 AMT and all those who support them; this is Taylor’s legacy and our shared responsibility.

Airborne Maintenance & Engineering Services – an ARSA member in Wilmington, Ohio – uses Taylor’s birthday to demonstrate appreciation for technicians in a way that lasts more than a single day. The company shares a message about his legacy and provides personnel with a custom-designed sticker (new each year) that can be displayed on work stations or toolboxes.

The entire company looked forward to this year’s design, officially delivered on May 24:


“Taking the time to say ‘Thank You’ for what our technicians do day in and day out is just a small way to show they are appreciated,” said Airborne’s Kym Cooper Parks, describing the value of celebrating AMT Day as part of the company’s continual effort to recognize and engage its people. “Every person that is part of the Airborne team is responsible for our growth and providing world class MRO service to our customers, so each person needs to feel like they are an important part of the team who makes an impact.”  

Hopefully all ARSA members did something to celebrate Charlie. If you hadcelebrations or activities of any kind, please share them with ARSA (contact Brett Levanto at brett.levanto@arsa.org). Regardless of what happened this year, here are some ways to celebrate AMTs on any day:

(1) Talk with 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 celebrate 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.

 


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 May:

New Members (Member Category)

Aeroworx, R01
Avsource, R01
Hancock Enterprises Inc., R01
Restored Aircraft Sales & Service, LLC, R01

Renewing Members (Member Category, Member Since)

ACSS Repair & Overhaul, R02, 2002
AeroKool Aviation Corporation, R04, 2017
Aircraft Tooling, Inc., R02, 2004
Aviation Safety Products, Inc., R01, 2013
Cargo Systems, Inc., R01, 1999
Harman’s Repair Station, Inc., R01, 2012
IAR Technical Services LLC, R03, 2017
L.J. Walch Company, Inc., R04, 1985
Pacific Aero Tech, LLC, R03, 1994
Stein Seal Company, R02, 2017
T&W Electric Service Inc., R01, 2014
The Pennsylvania State University, R01, 2016
Timberline Helicopters, Inc., Associate, 2013
Triumph Airborne Structures, Corporate, 2003

 


Quick Question – Brexit Impact

The prospect of the UK’s departure from the European Union has cast a cloud of uncertainty over transatlantic aviation regulatory issues.

Brexit means that on March 30, 2019 all EU laws will cease to apply in or to the UK, including those related to civil aviation safety. Because it’s no longer a part of the EU, the UK will also cease to be a party to the bilateral aviation safety agreement (BASA) between the United States and the EU.

Although negotiators from the UK, United States and EU are considering options to mitigate the impact, some disruption is inevitable and the lack of certainty alone is causing headaches for companies with customers, suppliers, subsidiaries or parent companies in the UK.

ARSA is monitoring those discussions and working to identify ways to lessen the impact on repair stations. Help the association by answering this month’s “Quick Question” to let us know whether your company will be impacted by Brexit and what steps you’re taking to prepare:

Note: The question is displayed in its own, embedded window. If the “Done” button is not visible on the screen, you must scroll within the survey window in order to submit your response.

 

For more information about this or any other question, contact Brett Levanto (brett.levanto@arsa.org).

Click here to see what questions have been asked and answered…and keep a lookout for more.


A Member Asked…

Q: We are an approved maintenance organization located in Spain and certificated by EASA, the FAA and TCCA to perform component work.

This question concerns data approved by a designated engineering representative (DER): Is it accepted by EASA?

More specifically, as you know, according to the bilateral agreement between FAA and EASA (Technical Implementation Procedures (TIP), Section III), the FAA accepts EASA-approved design data produced under EASA Part 21 by a Design Organization Approval holder, except for major repair design data for critical components when produced by other than TC/STC Holder.

But does EASA accept FAA-approved design data, for non-critical components, in support of major repairs, if the FAA repair design data approval is substantiated via an FAA Form 8110-3 (DER)?

A: The current versions of the TIP and the Maintenance Annex Guide (MAG) address the mutual recognition of approved data supporting major repairs. Please see pages 96-98 of MAG 6 and pages 29-30 of the TIP 6; both contain language on this subject. Both have a “NOTE” for EASA-based repair stations regarding the use of FAA approved data on EU-registered aircraft, which states:

NOTE: An EU company must use EASA Part 21 for the approval of repair data for use on an EU-registered aircraft. Unless the minor repair data has been previously used on an N-registered aircraft, an EU company cannot determine any data to be acceptable data under 14 CFR Part 43 for use on an EU-registered aircraft.

So, as you can see, the FAA approved data is good for an EASA AMO to use on a U.S.-registered aircraft, but unless it has been approved under the European system, it cannot be used on an EU-registered aircraft, aircraft engine, propeller or component. I am sure the reasoning is that the AMO in Europe has to follow European rules for the approval of data used on aircraft (and installed products and components) registered by that “State.”

 


Make ARSA’s Voice Your Own: Advertise

ARSA has a menu of advertising opportunities for arsa.org, the hotline and the ARSA Dispatch.

Take advantage of these great opportunities today to showcase your company, a new product or event. For more information go to arsa.org/advertise.
 


Stand Up for ARSA by Sponsoring in 2018

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, contact Vice President of Communications Brett Levanto (brett.levanto@arsa.org).

 


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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

RAA Summer Seminars – New Orleans, Louisiana – June 10-12
NATA Annual Meeting & Aviation Business Conference – Washington, D.C. – June 12-14
2018 FAA-EASA International Safety Conference – Washington, D.C. – June 19-21
Farnborough International Airshow – Farnborough, England – July 21-22
LABACE – Sao Paulo, Brazil – August 14-16
Aero-Engines Europe – Hamburg, Germany – September 12-13
ATEC Annual Fly-In – Washington, D.C. – September 12-14
MRO Europe – Amsterdam – October 16-17


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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 arsa.org/membership/join. For information about previous editions, submit a request through arsa.org/contact. 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.

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