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2018 – Edition 6 – July 6

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.

Association Management System Transition
ARSA Works
Legal Brief
ARSA on the Hill
Regulatory Update
Getting Facetime
Training
Membership
Resources
Industry Calendar


AMS Transition

Connecting with ARSA

By Sarah MacLeod, Executive Director & Brett Levanto, Vice President of Communications

ARSA is in the final throes of its transition to a new membership management and industry engagement tool. To ensure all our members can maximize its features, we are taking this opportunity to explain the sequence of events and anticipated outcome.

Phase One: Data Transfer – “Non-Corporate” Members and Contacts

Contact information for affiliate, associate, regular, educational, military or individual members has been uploaded into the new system and is undergoing a quality check. Once that is complete, primary and registered contacts for members in good standing within the listed categories will receive a “launch” message with instructions for accessing the online portal.

The secure access information allows members and registered contacts to immediately manage organizational and personal contact information along with member benefits, communications with the association as well as industry colleagues, pay membership dues and registration for events.

Benefits

With the launch, access to model manuals, supplements, forms and other resources will become more readily available. Purchases of model manuals will begin through arsa.org/publications; that “public” link will direct users into the new system’s “store” where purchasers can process credit card transactions and download the relevant files after payment is complete.

Similarly, ARSA members will be able to immediately download versions of members-only resources like the association’s Form E100 and the Working Away Advisory.

Queries

Members know – or should know – to “ask ARSA first” when confronted with business or regulatory challenges. Member queries will be managed through the online portal “dashboard” – exchanges will be tracked so that answers and references can readily be found for later review.

New Applications

Thinking of referring a potential member to ARSA? Similar to publications, the application process will begin at arsa.org/join; once the information provided has been validated by the membership team, portal access will be granted.

Phase Two: Corporate Members and Other Contacts

As the non-corporate members begin using the system, ARSA will monitor functions and gather feedback. Now and during the phase one launch, the remaining contacts – corporate members, allied organizations and the government – will be uploaded into the system in preparation for their “launch” under phase two.

For corporate members – entities that registered multiple constituent parts, divisions or wholly-owned subsidiaries under a single membership – phase one will be used to validate the system’s company profile structure. The validation will ensure that the phase two on-boarding of the more complicated profiles goes smoothly.

Phase Three and Beyond

ARSA chose the new system to enhance its relationship with members and the aviation industry. After completion of phase one and two, additional features will be introduced –the membership directory, training module and job board, to name just a few.

In the meantime, after you receive a launch message, please utilize the system’s available features and send comments, share your experience, ask questions – thus turning the lessons you learn into a smoother transition process for everyone.

 


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ARSA Works

FAA Takes ARSA Suggestions in Rulemaking Procedures Update

On June 20, the Federal Register published the FAA’s final rule “Updates to Rulemaking and Waiver Procedures and Expansion of the Equivalent Level of Safety Option.” The agency accepted the two suggestions made by ARSA in comments to the 2016 notice of proposed rulemaking (NPRM).

In general, the rule focuses on 14 CFR 404’s rules for commercial space transportation – reorganizing and clarifying its “regulations and licensing requirements” into “petition and rulemaking procedures.” The agency updated language to reflect “current practice” and expanded the equivalent level of safety options available to commercial space applicants and certificate holders.

ARSA’s NPRM comments focused on minor edits to the general rulemaking procedures in part 11. The association encouraged the FAA to avoid overly specific references to online resources – the evolution of the internet could send CFR readers to broken web addresses – and unnecessarily exhaustive lists of standing committees.

“ARSA believes that regulatory text should be clear, concise and free of explanatory information that is more appropriately included in guidance documents,” ARSA said in its comments. “The association applauds the agency’s attempt to streamline and clarify existing regulations; however, the … revisions [proposed by the agency] fail to achieve that objective.”

In response, the FAA’s final rule simplified an edit including the agency’s website in § 11.63 and left § 11.27 unaltered.

To read the final rule, which becomes effective on Aug. 20, click here.

To read ARSA’s complete comments to the 2016 NPRM, click here.

 


Report Shows Aviation Maintenance Connects U.S. Workers to Global Economy

Global trade in aviation maintenance creates jobs and business opportunities in every corner of the United States, a new analysis by ARSA shows. Florida, California and Texas top the list of states with the most maintenance companies serving European customers, ARSA found. Arizona, Connecticut, Kansas, New York, Washington, Georgia and Oklahoma round out the top ten.

ARSA analyzed the list of FAA-certificated repair stations in the United States by EASA to work on European-registered aircraft and components. The association then correlated the data with industry employment figures developed by Oliver Wyman’s CAVOK Division. ARSA conducted a similar analysis of EASA approval holders in 2017.

The association determined there are 1,437 repair stations with EASA approval across 47 of the 50 states. Overall, roughly one out of every three U.S. repair stations holds European certification. There are five states – including Connecticut, Florida, Kansas and Delaware – in which 50 percent or more of maintenance facilities can perform work on European-registered aircraft or components. West Virginia, the fifth state, has a smaller aircraft maintenance industry but the highest percentage (73 percent) of EASA approval holders.

Nationwide, repair stations employ more than 184,000 workers. When those numbers are added to the roughly 27,000 mechanics working for airlines and the 66,000 employed in aviation parts manufacturing and distribution, the maintenance industry’s total workforce is approximately 279,000. More than 110,000 Americans are employed at maintenance companies in the top 10 states for EASA approvals.

“Just as the aviation industry connects the world, the maintenance sector connects companies and workers throughout the United States to the global economy,” ARSA Executive Vice President Christian Klein said. “This analysis demonstrates the interconnectedness between American aviation business and European air operations. It shows us one of the many ways U.S. industry is well positioned to benefit from the expected growth in demand for maintenance. At the same time, the impact of any trade disruptions – for example, due to retaliation by foreign governments because of new U.S. laws or regulations targeting foreign repair stations – would be felt in all corners of the country.”

To review the ARSA-generated data, click here. The table below contains the top 25 states for EASA certificate holders:

EASA-Approved Repair Stations – By State (Top 25)
Rank State EASA-Approved Repair Stations (#) Percentage of Repair Stations w/ EASA approval (%) Total Repair Station Employment in State
1 Florida 293 52 17,879
2 California 196 33 24,944
3 Texas 128 34 15,909
4 Arizona 67 48 6,147
5 (tie) Connecticut 51 50 4,710
5 (tie) Kansas 51 53 5,408
7 New York 49 43 5,176
8 Washington 47 44 9,174
9 Georgia 42 38 16,774
10 Oklahoma 45 33 11,455
11 Ohio 42 32 6,686
12 Illinois 37 35 3,871
13 Michigan 31 35 4,208
14 North Carolina 26 37 3,655
15 Alabama 25 44 4,271
16 (tie) New Jersey 22 38 3,854
16 (tie) Missouri 22 38 1,446
18 (tie) Wisconsin 19 40 2,342
18 (tie) Tennessee 19 37 2,273
20 (tie) Pennsylvania 18 33 2,706
20 (tie) Indiana 18 19 2,572
22 (tie) Massachusetts 17 31 2,105
22 (tie) Kentucky 17 43 823
24 Colorado 16 21 1,421
25 Nevada 13 39 664

 


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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 – Part II

Importing from the UK

By Marshall S. Filler, Managing Director & General Counsel

This is the second in a series of Legal Briefs on the potential fall-out from the United Kingdom’s (UK) withdrawal from the European Union (EU), commonly known as Brexit.

The old saying “prepare for the worst; hope for the best” certainly applies in this situation. A recent ARSA survey revealed that the vast majority of respondents had not done any risk mitigation planning for Brexit. The most often cited reason was “we can’t plan because we don’t know what we’re planning for” and this is certainly understandable…up to a point.

Previously, ARSA advised its members of a memo released by the European Commission on April 13 describing what would happen on March 30, 2019 if no deal was reached. This “worst-case” scenario is sobering for many aviation companies both inside and outside the EU – and that’s putting it mildly.

This article addresses Brexit from the perspective of a U.S. company (e.g., an operator, maintenance provider or distributor) that currently imports new articles manufactured by a UK POA holder certificated under EASA Part-21, Subpart G. Future Legal Briefs will cover other Brexit scenarios.

Given the unpredictable nature of the negotiations, any U.S. purchaser of new articles manufactured by a UK POA holder should inquire about that company’s risk mitigation strategy. No one has a greater incentive to minimize or eliminate the potential disruptions from Brexit than approval holders located in the UK. The available options include relocating the POA or becoming a supplier to a POA holder in an EASA member state (that is not exiting the EU). These strategies can be successful in certain situations but they take time to implement.

You can also try to take control of your own destiny. For example, you can request the UK POA holder to increase the supply of replacement parts prior to the March 30, 2019 Brexit date. An EASA Form 1 issued by a UK POA holder prior to that date will remain valid even after Brexit. Of course, whether the UK concern is prepared to accelerate production is beyond your control but you won’t know if you don’t ask.

There are several potential outcomes from Brexit that would minimize or eliminate the disruptions for the U.S. importer. Similarly, they are not under your control. For example, the UK and the EU could negotiate an extension to the March 30, 2019 Brexit date, thus buying more time to work out a deal. Alternatively, the UK could become an associate Member State of EASA, similar to Norway, Iceland, Switzerland and Lichtenstein. Neither of these scenarios are considered likely by those close to the negotiations but they remain possibilities.

For its part, the FAA has a strong incentive (and no apparent disincentive) to recognize the continued validity of UK production approvals after March 29, 2019. The FAA could accomplish this by reinstating the previous Bilateral Airworthiness Safety Agreement (BASA) with the UK or negotiate an interim agreement that would minimize or eliminate the fallout.

What happens to articles released by a UK POA holder on and after March 30, 2019, even if the FAA agrees to accept them under part 21, subpart N? Would a U.S. repair station be able to execute a dual release if it installed them during maintenance subject to the FAA-EASA Maintenance Annex Guidance (MAG)? It depends. In the absence of a negotiated settlement, new articles released from the UK POA holder’s quality system after March 29, 2019 would no longer be accompanied by an EASA Form 1. However, the EU could direct EASA to negotiate a bilateral agreement with the UK just as it has with the U.S., Canada, Brazil and other countries. That shouldn’t be a heavy lift, especially if the UK CAA retained EASA rules, acceptable means of compliance and guidance material, at least in the near term. At least harmonization wouldn’t be an issue but timing is everything and March 30, 2019 will be here soon enough.

One of my favorite quotes comes from the movie, The Best Exotic Marigold Hotel. Dev Patel’s character Sonny says optimistically, “Everything will be all right in the end. If it’s not all right, it is not yet the end.” Admittedly, it’s nearly impossible to plan for every Brexit contingency but hoping for the best without some advance planning strikes us as a risky strategy.

 


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ARSA on the Hill

Legislation Backlog Builds as Senate Cancels August Recess

By Christian A. Klein, Executive Vice President

Washington, D.C. has a reputation for being a sleepy city during the summer. It’s hot, it’s humid, and, in most years, Congress is in recess for several weeks, which brings legislative activity to a standstill. That’s particularly true in election years, when lawmakers are anxious to spend as much time campaigning in their home states and districts.

However, 2018 promises to be a little different. While the House of Representatives is still scheduled to be in recess the entire month of August, Senate Majority Leader Mitch McConnell (R-Ky.) announced in early June that he was effectively cancelling the Senate’s August recess. Under the revised schedule, the Senate will be in session the entire month of August except the week of Aug. 6.

Although McConnell blamed the calendar change on Democratic obstructionism and the desire to complete work on appropriations bills and judicial nominations, the 24 Senate Democrats up for reelection this year grumbled that the real purpose was to keep them in D.C. while their Republican challengers campaign. Politics aside, given all the important uncompleted legislation awaiting Senate action, most Americans would likely agree lawmakers should be in the nation’s capital working through the backlog.

Supreme Court Fight Added to Already Packed Senate Agenda

Justice Anthony Kennedy’s announcement that he’s retiring from the Supreme Court has only added to the workload and charged partisan atmosphere on Capitol Hill.

President Trump is expected to quickly announce his pick to replace Kennedy, which will set off a nomination fight par excellence. Kennedy has long been regarded as the high court’s swing vote and his departure could shift the balance squarely to conservatives. Given the narrow margins in the Senate and the fact that Sen. John McCain (R-Ariz.) is out battling brain cancer, it would take only one Republican defection to block a Trump nominee. The Supreme Court drama is sure to suck up most of the political oxygen on the Hill this summer.

Keeping Aviation Workforce Front and Center

For ARSA’s part, we’re focusing on the FAA and defense authorization bills. The FAA legislation, which will establish a multi-year budget blueprint for the agency, includes several provisions sought by ARSA. The Senate version (which passed the Commerce Committee last year but has yet to receive a floor vote) would direct the FAA to restore the voluntary surrender of repair station certificates and explore ways to improve the value of repairman certificates.

ARSA is also working to add language to the Senate FAA bill to create a new aviation maintenance workforce development program. The provision, which would authorize $25 million over five years to worker recruitment and training, has been introduced as stand-alone legislation in the House (H.R. 5701) and the Senate (S. 2506). ARSA has been leading coalition activities in support of the bill, which has garnered 21 bipartisan sponsors in the Senate and 13 in the House. Our goal is to add it to the FAA bill when its considered by the full Senate. Floor action could come at any time as the bill is currently being “hotlined” – a final step to determine whether senators have any objections to the legislation.

Take action and tell your senators to support the aviation workforce. Visit arsa.org/grant-program to get involved.

As ARSA gears up for Senate action on FAA, we’re also on the lookout for hostile amendments, particularly anything that could impose new costs on repair stations without any safety benefit. A case in point is legislation introduced in May by Sen. Claire McCaskill (D-Mo.) and Reps. John Garamendi (D-Calif.) and Dan Donovan (R-N.Y.) targeting contract maintenance. The union-backed bills (S. 3026 and H.R. 6028) 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”. Although the legislation has garnered little support (the McCaskill bill has no cosponsors, while only member of Congress has joined the Garamendi-Donovan bill), ARSA isn’t taking any chances and is stepping up Hill activity on international aviation maintenance issues.

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.

New ARSA Study Illustrates Broad Economic Benefits of International Aviation Maintenance

As part of our ongoing effort to beat back threats to contract maintenance and build understanding about our industry, ARSA released new economic data in June highlighting how international trade in aviation maintenance creates jobs and business opportunities in every corner of the United States. The ARSA analysis found that Florida, California and Texas top the list of states with the most maintenance companies serving European customers, ARSA found. Arizona, Connecticut, Kansas, New York, Washington, Georgia and Oklahoma round out the top ten.

ARSA analyzed the list of FAA-certificated repair stations in the United States approved by EASA to work on European-registered aircraft and components. The association then correlated the data with industry employment figures developed by Oliver Wyman’s CAVOK Division. ARSA conducted a similar analysis of EASA approval holders in 2017.

The association determined there are 1,437 repair stations with EASA approval across 47 of the 50 states. Overall, roughly one out of every three U.S. repair stations holds European certification. There are five states – including West Virginia, Connecticut, Florida, Kansas and Delaware – in which 50 percent or more of maintenance facilities can perform work on European-registered aircraft or components.

ARSA has shared the report with House and Senate offices to remind them about our industry’s impact. The message is clear: Anything Congress does to potentially disrupt global trade in aviation maintenance will hurt U.S. companies and workers.

Defense Bill Urges DOD to Consider Wider Use of FAA Approvals

ARSA is also tracking the National Defense Authorization Act for 2019. The Senate version (S. 2987), which was approved by the Senate Armed Services Committee on May 24, includes report language urging the Department of Defense (DOD) to make use of FAA-approvals (e.g., Parts Manufacturer Approval (PMA) parts) to reduce costs and improve readiness). Specifically, the Senate bill says that DOD,

“has long operated products that are identical to those in civil use, including aircraft, aircraft engines, and propellers. These commercial derivative products have been certified by the Federal Aviation Administration (FAA), which has an effective system for approving parts, repairs, and alterations. The FAA’s existing certification process allows the DOD to maintain its commercial derivative fleet without duplicative review or approval. The committee believes leveraging existing FAA certifications can provide the DOD cost and schedule efficiencies that should be pursued to the greatest extent practicable.”

It urges DOD, “to prioritize the use of non-developmental and commercially available items with existing FAA certifications as long as the use of those products do not compromise safety or security requirements established by the Department of Defense.”

The Senate NDAA bill is yet another of the important pieces of legislation awaiting Senate action this summer.

Help ARSA Move the Ball Forward

Although the Senate’s August recess has been cancelled, senators will still be back and forth between the Capitol and their home states all summer and House members will be home the entire month of August. That means this is a great time to host members of Congress at your facility, attend town hall meetings, and attend campaign events for candidates you agree with.

ARSA Executive Vice President Christian Klein is standing by to provide all the support you need to build your company’s and industry’s visibility. To get the ball rolling, send an email to christian.klein@arsa.org.

 


AeroTEC Opens Doors and Congressman’s Eyes

U.S. Rep. Dan Newhouse poses between AeroTEC President Lee Human (Left) and Flight Test Center Site Manager Matt Davis.

One of the best ways to educate elected officials about your company and the maintenance industry is to host them at your facility. Visits give lawmakers the opportunity to hear from company executives, meet with employees, see their work first-hand and learn how repair stations are affected by government policy.

Associate member AeroTEC Inc. has embraced that philosophy and is doing its part to raise the maintenance community’s collective visibility. The company, which hosted local elected officials earlier this year (covered in the May 4 edition of the hotline), recently received a visit from Rep. Dan Newhouse (R-Wash.) at its Moses Lake, Washington flight test center.

Newhouse is a member of the powerful House Appropriations Committee, which controls federal purse-strings. As a member of the House Rules Committee he also serves as one of the gatekeepers who helps decide what legislation reaches the House floor and what amendments can be offered to bills.

During the visit on May 31, AeroTEC President Lee Human and Site Manager Matt Davis gave the congressman a company tour and discussed issues impacting the maintenance industry. The aviation workforce skills gap was a top issue discussed. The visit provided an opportunity to encourage Rep. Newhouse’s support for legislation pending in the House and Senate (H.R. 5701 and S. 2506) to create a new grant program to address the technician shortage and help underscore the local impact of maintenance jobs.

ARSA Workforce Legislation Action Center

ARSA is standing by to help its members coordinate visits from elected officials and candidates this summer and fall. The association can help establish contact with schedulers, suggest an agenda for the meeting and provide briefing materials. To get the process started, send an email to ARSA Executive Vice President Christian Klein (christian.klein@arsa.org).

If you already have a visit on the calendar, let ARSA know (and be sure to take lots of pictures!).

U.S. Rep. Dan Newhouse (Center Right) walks through AeroTEC’s Moses Lake Flight Test Center as his district representative Vicki Holleman-Perez looks on.

U.S. Rep. Dan Newhouse (Left) walks through AeroTEC’s Moses Lake Flight Test Center.

U.S. Rep. Dan Newhouse (Right) walks through AeroTEC’s Moses Lake Flight Test Center.

Aerospace Testing Engineering & Certification LLC AeroTEC develops, tests and certifies new aircraft products using innovative and scalable development, test and certification techniques to help large and small aerospace companies everywhere bring their products to market quickly, easily and efficiently. To learn more, visit www.aerotec.com.

 


ARSA Joins Broad Coalition Urging Skills Education Reform

Legislation to improve federal career technical education (CTE) programs took an important step forward on June 26 with the Senate Health, Education, Labor & Pensions (HELP) Committee’s unanimous approval of its Carl Perkins Act reauthorization bill. Senate committee action has been a long time coming: The House passed its version of a Perkins bill (H.R. 2353) by voice vote on June 23, 2017.

Maintenance providers have expressed growing concern about increasing difficulty finding workers with the technical skills necessary to work in aviation. As part of its ongoing efforts to address this shortage, ARSA joined a letter coordinated by the National Association of Manufacturers urging HELP Committee leadership to move quickly to enact a Perkins bill into law (see arsa.org/technical-workforce-development for a series of updates on Perkins reauthorization).

Among other things, the HELP Committee’s bill would give states more flexibility in designing career technical education programs, while establishing tighter timelines and performance indicators to measure the success of state efforts. Other broad objectives of the legislation are to enhance coordination between schools, businesses and government to ensure students graduate with skills local businesses actually need, increasing student participation in work-based learning opportunities and promoting the use of industry-recognized credentials.

Focusing on local collaboration has become a cornerstone of modern CTE policy. The association leveraged this interest in developing its independent legislation to pilot an AMT workforce grant program. For updates on the industry-wide effort to get that bill passed into law as part of the FAA reauthorization process, stay tuned to arsa.org/grant-program.

Given that workforce legislation has languished in the Senate for more than a year, the move by the HELP Committee is welcome news. Although the Senate’s agenda for the summer is jam packed, hopefully the growing need for more technical workers in many sectors, bipartisan and broad industry support for the bill and the Trump administration’s desire to get Perkins done this year will combine to help get the legislation over the finish line before the elections.

 


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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.)


Regulatory Update

Trump’s Government Reorg Plan Would Shift ATC from FAA

In June, the Trump administration unveiled an ambitious and unlikely plan to reorganize and reform the federal government. While some of the biggest changes would come to social services programs, few parts of the federal government would be left unchanged.

The plan is based around three principles:

(1) Mission: Ensuring that government activities are rooted in the missions the American people require.
(2) Service: Creating a customer experience for those dealing with the federal government that compares to or exceeds that provided by the private sector.
(3) Stewardship: Channeling taxpayer dollars to effective programs that produce results efficiently.

Among many other things, the president’s proposal would:

(a) Spin off air traffic control services and the Saint Lawrence Seaway from the government and integrate into the Department of Transportation certain Department of Homeland Security programs related to surface transportation security, including transit security grants.
(b) Merge the Departments of Education and Labor into a single Cabinet agency (the Department of Education and the Workforce), charged with education, skill development, workplace protection and retirement security.
(c) Move the Army Corps of Engineers Civil Works programs (navigation, flood control and water resource management) out of the Department of Defense and to the Departments of Transportation and Interior.
(d) Move the Department of Agriculture non-commodity assistance programs current managed by the Food and Nutrition Service into the Department of Health and Human Services, which would be renamed the Department of Health and Public Welfare.

To see the White House’s full publication regarding the plan, click here.

While government streamlining advocates will find much to like in the president’s plan, most of it is unlikely to ever be implemented. Many of the changes would require Congress’ approval, not to mention coordination and consolidation of responsibilities of various congressional committees; public benefit program advocates fear consolidation would lead to cuts; and lawmakers representing districts and states with large number of federal employees are likely to balk at the job cuts that would result.

 


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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Getting Facetime

FAA-EASA Conference Recap – Pursuing the “Systems Approach”

The FAA and EASA held their annual safety conference from June-19-21 in Washington, D.C. While the agencies are the primary drivers of this event, other regulators including Transport Canada and ANAC of Brazil were also present as were other civil aviation authorities from Asia, Europe and South America. The conference covered a variety of safety topics and, after a year’s absence (see 7/19/17 update at arsa.org/faa-easa-conference), maintenance was back on the agenda.

As usual, the plenary sessions focused on high-level relationships and agreements among regulatory agencies. They highlighted continued progress made by the authorities toward accepting each other’s design, production and maintenance approvals to the extent allowed by law. Attendees discussed the need to establish and maintain confidence in each other’s regulatory systems and sustain trust in order to keep cross-border relationships robust.

Historically, aviation agreements have been bilateral and transactional. In other words, between two countries or regions and addressing specific kinds of approval. The key question is always whether all or some aspects of an exporting country’s approval can be accepted by the importing country.

A good example is repair data. EASA and the FAA have significantly different systems for determining which repair data requires approval, how the data should be classified (i.e., major or minor) and the methods of approval. During the last 15 years, the agencies transitioned from the point where all repair data had to be approved in accordance with the importing authority’s requirements to requiring it only for critical repairs to recently deciding to accept all repair data approved under the other’s system. Positive experience generated confidence in the agencies that the agreement could be expanded to full reciprocal acceptance.

During the conference, the leaders of both agencies spoke about transitioning to a systems approach for evaluating each other’s technical competence. While this will happen incrementally and therefore slowly, it shows that the regulators recognize industry spends far too much on obtaining redundant regulatory approvals that provide little, if any, safety value. There is no doubt this practice diverts scarce resources away from more important safety initiatives. While almost everyone recognizes the legal and nationalistic realities, there is widespread agreement that the 75-year old international regulatory structure overseen by ICAO creates some undesirable outcomes.

Bilateral agreements are still the main vehicle for achieving international safety objectives; however, the authorities have recognized the value in working multilaterally. The Certification Management Team (CMT) and Maintenance Management Team (MMT) consist of representatives from the FAA, EASA, TCCA and ANAC. The bodies meet twice each year – at least once in person. During the latter event, which lasts most of the week, industry is given an opportunity to discuss issues of particular interest. The next CMT meeting is in September in Washington, D.C. followed by the MMT in Brasilia in November.

Marshall S. Filler, ARSA’s managing director & general counsel, moderated an industry-regulator maintenance panel entitled “Maintenance in the Digital Era.” Panelists included Tim Shaver (FAA), Ralf Erckmann (EASA), David Van den Langenbergh (Luxaviation), Gilles Garrouste (Dassault Aviation) and Marc Olson (FedEx).

Many of the activities discussed during Filler’s panel have been in use for some time, including electronic records, manuals and signatures. However, some of the more recent technological advances such as remote connectivity (i.e., performing inspections remotely using live video streaming or similar methods) and aircraft health monitoring systems generated a lot of interest. There was consensus that technology could provide useful tools and information to operators and maintenance providers as long as robust processes were in place to control it. ARSA expects the regulators will issue guidance on these topics in the not-too-distant future.

Another topic worth noting was the session on New Parts Documentation moderated by Jason Dickstein of the Modification and Replacement Parts Association (MARPA). There are several outstanding issues remaining from Changes 5 and 6 to the FAA-EASA Maintenance Annex Guidance which required an Authorized Release Certificate to accompany all new parts installed during maintenance subject to a dual release. Some pesky issues remain including the fact that commercial-off-the-shelf parts are confined to a “no man’s land” since those that have an Authorized Release Certificate (or are even eligible for one) are few and far between.

EASA continues its rulemaking efforts to create a 4-tier new part criticality classification system for maintenance with only a small number of parts requiring a Form 1. ARSA remains skeptical that the EU design approval holders will voluntarily do this on their own in which case nothing will change. As ARSA has stated previously, this issue would benefit greatly from a systems approach where each authority would agree to accept the other’s parts documentation system since they produce equivalent safety outcomes.

Unfortunately, the international aviation community has a long way to go before the systems approach is universally applied.

 


SOC-ARC Moving Beyond “Transactional” Certification

Following the FAA-EASA Annual Safety Conference, the Safety Oversight and Certification Aviation Rulemaking Committee (SOC-ARC) held its second meeting in Washington, D.C. on June 21-22. The first half day was attended by industry only followed by another half day meeting with industry and FAA representatives.

The SOC-ARC is the next step in the FAA’s AIR Transformation Initiative designed to update certification policies and procedures to reflect the agency’s greater emphasis on risk-based oversight. Among the key initiatives is recognition that “mature” (a term yet to be defined) applicants for design approvals do not require the same level of oversight as those with less experience in the certification process. The same philosophy can be seen in today’ Organizational Designation Authorizations (ODAs). 

Rather than continuing to focus on transactional approaches to certification and overseeing each required compliance finding to the applicable airworthiness standards, the agency will recognize robust compliance assurance systems where they exist (and audit to those systems). For such applicants, the FAA will focus its resources on new and novel design features, new technology and higher-risk certification issues. Less mature applicants requiring a more traditional approach to certification will also be accommodated.

The SOC-ARC previously appointed three sub-task groups to address Flight Standards Integration, Performance Measures and an applicant’s Compliance Assurance System. Each of the groups reported out at the June meeting and identified the scope of their review. Each group requested the appointment of subject matter experts to support the next phase of their work, which will be ongoing. The next meeting will be held in the Dallas-Ft. Worth area in September. The SOC-ARC must report its recommendations to the FAA by the end of 2018.

Trade association members of the ARC include (in addition to ARSA):

Aerospace Industries Association
General Aviation Manufacturers Association
Modification and Replacement Parts Association
Aircraft Electronics Association
Aerospace and Defence Industries Association of Europe

Industry members of the ARC include:

Boeing
Gulfstream
GE
Bell
Garmin
Textron Aviation
UTC-Pratt & Whitney
Rockwell Collins
Duncan Aviation
Astronautics
Wipaire

Government employee unions are also involved:

Professional Aviation Safety Specialists
National Air Traffic Controllers Association
American Federation of State, County and Municipal Employees

 


Summer* Briefing on EASA Technical Matters

On June 5, Marshall S. Filler, ARSA managing director & general counsel, represented the association at the bi-annual meeting of EASA’s Engineering and Maintenance Technical Committee (EM.TEC) in Cologne, Germany. The committee reports to the EASA Stakeholders’ Advisory Body (SAB) established for industry to actively participate in the agency’s activities.

After returning from Germany, Filler provided the following updates for the maintenance community regarding topics addressed by the committee:

Parts Documentation

EASA staff briefed the EM.TEC on the status of the agency’s rulemaking activities affecting continuing airworthiness. Of particular note is Rulemaking Task (RMT) 00-18 relating to the documentation of new parts to be installed during maintenance. Earlier this year the association filed comments to Notice of Proposed Amendment (NPA) 2017-19, which would authorize (but not require) design approval holders to determine the criticality level of each part in their approved designs. Only those parts with higher criticality levels would have to be accompanied by an EASA Form 1.

The outcome of this rulemaking is potentially important for U.S. and European industry as changes to EASA rules may impact the parts documentation requirements in the U.S.-EU Maintenance Annex Guidance (MAG). Currently, the MAG requires that an Authorized Release Certificate accompany all new parts to be installed during maintenance subject to the MAG, except for standard parts and parts fabricated during maintenance.

Industry comments are currently being reviewed and EASA hopes to publish an opinion during the last quarter of 2018, after which the document will be considered by the European Commission (EC). Because the NPA would change the current Implementing Rules, or “hard law,” the agency does not have the legal authority to issue the amendment as this is the exclusive province of the EC. While the briefing indicated that the EC’s review of the opinion should be completed by the last quarter of 2019, there are several EASA opinions still awaiting action by the EC, which is obviously pre-occupied with Brexit.

SMS Requirements

Another important rulemaking project discussed at the meeting is RMT.0251 relating to SMS requirements for EASA Part-145 organizations. An NPA is expected in the third quarter of 2018 with an EASA opinion expected next year. Although this rulemaking will not apply directly to U.S. repair stations holding an EASA Part-145 approval, it could very well become a special condition (similar to mandatory quality assurance) unless the FAA implements SMS for repair stations. (For now, the FAA is encouraging voluntary SMS programs for design, production and maintenance organizations.)

During the EM.TEC meeting EASA representatives sought the committee’s feedback on the desirability of implementing voluntary SMS programs in advance of rulemaking. Both ARSA and the Aircraft Electronics Association (AEA) expressed reservations that voluntary SMS programs are being designed for large aerospace companies and will be unduly burdensome for small to medium enterprises (SME) to scale down to fit their more limited operations. Both associations advocated a slimmer voluntary SMS program more suited to the SMEs which represent a significant majority of aerospace companies, while encouraging the larger companies to scale up as appropriate.

Working Outside

Another topic of interest for holders of EASA Part-145 certificates in the EU and those countries not covered by a bilateral agreement is whether an organization with an aircraft base maintenance rating (A1) may perform work outside its hangar in circumstances that would not impact the airworthiness of the work performed. This is currently allowed under FAA rules; however, EASA and several EU Competent Authorities have issued interpretations that require all base maintenance activities to be performed in a hangar.

The EM.TEC committee approved a draft Frequently Asked Question (FAQ) for posting on EASA’s web site clarifying that certain base maintenance tasks may be performed outside a hangar. EASA will evaluate the draft and advise the committee following its review. ARSA encouraged EASA staff to distinguish between the requirements for obtaining an aircraft base maintenance rating vs. whether certain tasks may be safely performed outside a hangar in accordance with procedures set forth in the organization’s Exposition.

Standardization

The committee also received a briefing from the General Aviation Manufacturers’ Association (GAMA) on the ongoing standardization challenges faced by industry in their dealings with the EU’s Competent. Standardization has always been one of EASA’s primary focus areas; however, as U.S. readers will readily appreciate, regulatory compliance decisions are often made based on factors other than the regulations and guidance, such as inspector opinions, past practices, personality and the like. Standardization is a big enough challenge for the FAA; imagine what it’s like under the EU system!

Brexit

Finally, the EM.TEC received a briefing on Brexit from EM.TEC Vice Chair Erik Moyson (Airlines International Representation in Europe) based on the EC’s Notice to Stakeholders dated April 13, 2018. While the terms of Brexit are in the hands of the politicians, industry must develop contingency plans if a “hard Brexit” occurs as currently scheduled on March 30, 2019. ARSA has previously informed members of several options for mitigating the risks of Brexit and will continue to do so in the months ahead – stay tuned to member newsletters as well as the association’s Brexit resource page (arsa.org/regulatory/easa/brexit). EASA also has a web page devoted to this issue.

Stay tuned for more updates on EASA technical and regulatory issues.

*The meeting occurred prior to the summer solstice (Thursday, June 21), so it technically was a spring event. However the issues covered in this piece will play out during summer 2018 and beyond, so the editor of this piece chose a title that looked ahead.

 


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Training

Bundle – 3 Sessions on Part 43

Bundle pricing is now available for three of ARSA’s training sessions focusing on 14 CFR part 43. Each 0n-demand recording is available for 90 days of unlimited viewing – purchase together and save.

Click here to go straight to the bundle purchase.

Part 43 – The Mechanic’s Bible

This session provides an overview of 14 CFR part 43, Maintenance, Preventive Maintenance, Rebuilding and Alteration. It places the work performed on U.S. civil aircraft in the context of the “aviation safety regulatory chain,” explains general definitions and requirements and reviews the standards that impact these activities.

Instructor: Sarah MacLeod

Click here to register and get access for 90 days.

What is “Acceptable to the Administrator”? – The Performance Rules of § 43.13

This session provides an overview of the regulations that use the language “acceptable to” the Federal Aviation Administration and how to determine what makes something acceptable to the agency.

Instructor: Sarah MacLeod

Click here to register and get access for 90 days.

Overhauling Overhaul – Part 43’s Most Misunderstood Word

In June 2015, the FAA issued another legal interpretation on the term “overhaul” – stimulating a flurry of member questions about the term’s applicability to the everyday work of maintenance providers. This course provides the regulatory context, an overview of the term, a review of its interpretations and tools for applying it in a business context.

Instructor: Sarah MacLeod

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.

 



“The Fourth Branch of Government”

Maintenance providers deal with numerous administrative agencies of the U.S. government. Not only must certificate holders understand “the fourth branch of government,” they need to know how to engage with the fundamental systems related to the rules. 

Interested in a full understanding of “the fourth branch of government?” Click here to purchase multiple sessions together and save.

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.

Instructor: Sarah MacLeod

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 Federal Aviation Administration (FAA) and the National Transportation Safety Board (NTSB).

Instructor: Sarah MacLeod

Click here to register and get access for 90 days (multiple bundles available).

Investigation & Enforcement Under Part 13

This session reviews 14 CFR part 13, which defines the FAA’s powers of investigation and enforcement. It walks through the rule in order to explain its organization and define the procedures and authority contained within each of the nine subparts. To support this general overview, the session highlights key sections and phrases within each subpart.

Instructors: Sarah MacLeod & Brett Levanto

Click here to register and get access for 90 days.

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.

Instructor: Sarah MacLeod

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.

Instructor: Sarah MacLeod

Click here to register and get access for 90 days (multiple bundles available).

Dealing with the Government – Building a Positive Relationship

This session provides a roadmap for building a positive relationship with civil aviation authorities. It begins by describing the rules that should always be considered when engaging with aviation safety regulators, then provides instruction on how to introduce your company and maintain consistent contact – not just when there’s a problem. It concludes by providing strategies for maintaining a professional relationship with regulators.

Instructor: Sarah MacLeod

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 – Risk Management

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 this content; at the very least they help highlight the areas considered most important by the regulators.

To provide a taste of the content available in the “maintenance hangar,” this edition of the hotline highlights an online presentation on risk management:

To launch the presentation in your browser, click here.

 



Regulatory Compliance Training

Test your knowledge of 14 CFR §§ 65.77 & 80 – Experience requirements and AMTS students.

Click here to download the training sheet.

 


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ARSA-onlinetraining


Membership

Member Spotlight – Gulfstream

The first Gulfstream aircraft, the Gulfstream I, debuted in 1958. It had been conceived at the end of World War II, when Roy Grumman proposed the development of an aircraft specifically designed for fast, efficient and comfortable business travel.

The Grumman Aircraft Engineering Corporation had deep experience building warplanes and the company’s co-founder was in search of new business horizons as the world turned to peace. After years of developing an aircraft to fit the necessities of business, Grumman introduced the Gulfstream I.

Since then, Gulfstream Aerospace Corp. has celebrated countless milestones. In 1968, the company’s GII became the first business jet to cross the Atlantic Ocean nonstop. In 1983, the GIII was the first business aircraft to fly over both poles in a single flight. The GV won the prestigious Robert J. Collier Trophy in 1997. The G650 held the title of the world’s fastest business jet from December 2012 to June 2014 and has since flown around the world in 41 hours, 7 minutes. The G650 won the Collier Trophy in 2014, while the G550 won it in 2003.

The Gulfstream I (1981).

Today, the company continues to build on its long history as a leader in business aviation. “Gulfstream engineers, manufactures and services the world’s finest business aircraft,” the company’s website proclaims. “Headquartered in Savannah, Georgia…Gulfstream operates facilities on five continents and employs more than 17,000 people worldwide.”

There are a number of different pieces that go into making such a great company. Gulfstream’s focus on engineering and research allows its manufacturing and maintenance facilities to support and expand its record-breaking fleet of aircraft. Customers can personalize their aircraft – customizing and stylizing cabin elements and amenities – so that each delivery is unique.

Gulfstream offers the largest factory-owned service network in the business aviation industry. Through its well-trained customer support organization and the product expertise that is part of this original equipment manufacturer’s DNA, the company helps its owners solve issues ranging from simple checks to engine replacement and complete overhauls. Gulfstream relies on ARSA to be its voice in Washington, D.C., for the company’s 13 service centers worldwide. The association’s experience and knowledge of the FAA and other civil aviation agencies allow Gulfstream to focus on leading and innovating.

For some “inside insight” into the company’s commitment to growth, the future of the industry and the value of collective industry action through organizations like ARSA, the association’s team went to Heidi Fedak, the company’s director of Corporate Communications and Media Relations:

ARSA: Gulfstream has the Field and Airborne Support Teams (FAST), which provide mobile support. How has that enhanced the company’s ability to serve its customers?

Fedak: Plane-side service and support is a necessity in business aviation. Often, your customers can’t come to you, so you need to be able to get to them as quickly as possible. Our Field and Airborne Support Teams (FAST) are designed to ensure swift, well-coordinated support for operators in aircraft-on-ground situations, particularly in areas where we do not have a maintenance facility. Gulfstream FAST provides 24/7 customer support and includes specially equipped vehicles in the U.S. and Europe, more than 125 dedicated technicians worldwide and two dedicated aircraft based in the U.S. The aircraft can deliver parts and/or technicians to operators in North America, Central America and the Caribbean.

ARSA: What does the future of business jets look like?

Fedak: Gulfstream is primarily focused on its next two aircraft to enter service, the G500 and G600, but we continuously evaluate the products and services we offer to customers. This kind of exploration could not be accomplished without a robust research and development program, which involves the work of approximately 1,500 engineers.

Click to learn more about the G500.

ARSA: What was the process of opening up the first service facility in mainland China like?

Fedak: Gulfstream Beijing, the first original equipment manufacturer-owned business jet service center in China, was borne out of tremendous growth in the Chinese market, which was – and still is – led by Gulfstream. Gulfstream’s fleet in China grew from 84 aircraft in 2013 to more than 124 since; it is approximately 200 in Greater China (China, Hong Kong, Taiwan, Macau).

The process to establish a service center in China began in approximately 2010, when Gulfstream started negotiations with two subsidiaries of Hainan Airlines Group (HNA), including charter operator Deer Jet, which first added a Gulfstream aircraft to its fleet in 2004 and had more than 20 by 2010. Chinese law dictates that foreign companies who wish to do business within the country must enter into a partnership with a Chinese company.

Gulfstream announced its joint venture with HNA in February 2012, and operations began at Gulfstream Beijing in November 2012 after the site was approved as a Part 145 maintenance facility by the Civil Aviation Administration of China. Gulfstream Beijing earned U.S. Federal Aviation Administration Part 145 approval in April 2015.

ARSA: What separates Gulfstream from its competitors?

Fedak: Gulfstream sets itself apart through a combination of factors. First, we have an unwavering commitment to delivering on our promises, providing aircraft that meet or exceed our customers’ expectations. The G650, for example, had 1,000 nautical miles more range than we promised (6,000 nautical miles vs. 5,000). With the Gulfstream G550, we delivered the PlaneView flight deck with enhanced vision, a first for the industry. With the G280, we delivered 200 nautical miles more range. With our G500 and G600, which will enter service in 2018 and 2019, respectively, we announced in 2017 that they will deliver range beyond our initial projections.

Another factor that distinguishes Gulfstream is our willingness to listen to our customers, whether we’re working with them to develop their customized interior or garnering their input on future designs. In terms of designing our aircraft, we have two customer-based groups we leverage, a Customer Advisory Board (CAB) and an Advanced Technology Customer Advisory Team (ATCAT). Together, these groups provide a tremendous level of feedback in terms of existing and future products, and we truly value the insight they provide.

We’re also set apart by our long history of designing and building industry-leading products. We’re the only business aviation company that has won the prestigious Robert J. Collier trophy three times for three different aircraft: the GV, the G550 and the G650. The trophy recognizes the greatest achievement in astronautics or aeronautics in North America.

Another differentiator for us is our customer support network, which is the largest in business aviation, with more than 4,700 professionals worldwide. No other business jet manufacturer offers a wider range of service, enhancements, spares, support functions and technical publications than Gulfstream.

ARSA: Considering the record-breaking history of Gulfstream’s aircraft, how does the company continue to push itself forward?

Fedak: We have a continuous improvement culture at Gulfstream. Throughout the company, from the hangar floor to the engineering department, we always look for ways to improve our processes and become more efficient. By continually getting better at what we do and subscribing to a team philosophy, we can meet or exceed customers’ expectations.

ARSA: How important is it to have the collective support of industry groups like ARSA? What value does this representation bring to Gulfstream?

Fedak: It is very important. ARSA is the only industry group devoted to the needs of the civil aviation maintenance industry worldwide. Gulfstream’s maintenance organization, Customer Support, is a major element of the company, with nearly 30 percent of its 17,000-plus employees devoted to the business unit. Through constant communication with legislators, federal regulatory bodies and the media, ARSA helps member companies such as Gulfstream operate more efficiently and effectively, while continuing to ensure the safety of its worldwide fleet.

Gulfstream has been an ARSA member since 1999. To learn more about the company, visit www.gulfstream.com/company.

 


Have You Seen this Person? – Tim Shaver, FAA

Tim Shaver, Photo Courtesy FAA.

Tim Shaver is the acting director of the FAA Office of Safety Standards. The office has eight divisions focusing on industry areas including airmen, air carrier operations, maintenance and alteration, aircraft suitability and technology, international agreements and the certification and oversight for foreign entities. 

Tim began his career as an Air Force avionics mechanic before transitioning to civilian airline maintenance, where he served in various capacities. He supported the FAA Aircraft Certification in the Avionics Systems Branch (AIR-130) before joining Flight Standards in 2009.

ARSA works regularly with Tim and his team, helping to determine industry needs and coordinating efforts between regulators and the association’s allies. In June, he participated on Marshall S. Filler’s panel “Maintenance in the Digital Era” at the FAA-EASA Annual Safety Conference.

The Office of Safety Standards is one of four offices that incorporate the Flight Standards Service. Accompanying the Office of Safety Standards is he Office of Air Carrier Safety Assurance, Office of General Aviation Safety Assurance and the Office of Foundational Business.

To learn more about the office, click here.

 


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 June:

New Members (Member Category)

Nitetrain Aviation, R01

Renewing Members (Member Category, Member Since)

Asko Processing, Inc., R04, 1996
Pac West Helicopter, Inc., R02, 2009
Piedmont Propulsion Systems, LLC, R03, 2011
RUAG Schweiz AG / RUAG Aviation, R05, 2013

 


Quick Question – Tariffs and Trade Disputes

Candidate Donald Trump made no secret of his misgivings about U.S. trade policy.  Like or not, as president he’s made good on his campaign promises, withdrawing from Trans-Pacific Partnership negotiations, challenging the North American Free Trade Agreement, threatening to withdraw the United States from the World Trade Organization and slapping new tariffs on a wide variety of imported of manufactured goods and materials (including a ten percent tariff on aluminum).

The president’s actions have drawn the ire of America’s closest allies and trading partners and let to retaliatory tariffs on U.S. exports. 

Given the globally-integrated nature of the aviation maintenance and manufacturing sector, ARSA wants to know how you think the new wave of protectionism, tariffs and trade disputes will affect your company.

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 purchase used parts (and run them through our shop for maintenance and give them an 8130-3 if they did not come with an appropriate record) and used parts with appropriate maintenance records (FAA Form 8130-3/EASA Form-1).

We also occasionally send parts out for a specific service that are returned with an FAA Form 8130-3 for the work the certificated entity performed (NDT, rewinding of coils, refinishing of surface treatments, etc.).

I have always known that any subassembly part we send out for servicing and then reinstall it in the same the next higher assembly it came from as part of an overall repair is contract maintenance, whether it came back with an airworthiness certificate or not.

The “updated” AC 145-9A seems to say something different.

A: Contract maintenance has always been a thorn in the side of the agency and the industry. Without understanding the history of section 145.217, it is hard to fathom and is often misinterpreted. While I have not reviewed the “new” AC, I can tell you that the agency isn’t responsible for establishing compliance and as a recent legal interpretation made clear, ACs can be wrong.

Let’s start with the application for a repair station certificate – FAA Form 8310-3Block 4. List of Maintenance Functions to be Contracted to Outside Agencies. The applicant will indicate the functions included in the ratings applied for that will be performed by outside agencies but for which the applicant will be responsible.

In other words, what maintenance functions (step or steps in the process) will have to be performed by an “outside” person? Those would be the functions that the repair station does not have the housing, facilities, equipment, tools and such to perform. Whenever a repair station contracts any steps (up to and including an overhaul of a subassembly) that will be incorporated into the assembly that will be approved for return to service, the “installer” has to take responsibility for that “replacement.” (Refer to the definition of maintenance in section 1.1, which includes inspections, repairs and the replacement of parts.)

While that question has always been part of the application process, when the rule changed in early 2000s, the agency removed Appendix A, which listed the equipment and tooling that a repair station had to have on premises and under its control in order to be issued certain ratings. That appendix (which was never up-to-date and therefore a thorn in the side of the agency and industry) was replaced by the requirement to have maintenance functions approved under section 145.217(a)(1).

The approval process was supposed to prevent “virtual repair stations” (ones that merely disassembled, assembled and tested). Unfortunately, instead of preventing virtual repair stations it has created confusion and consternation for repair stations that are just trying to get the best work done for their customers, some of which has to be contracted since very few repair stations can do everything to every article received for maintenance.

In addition to the maintenance functions that have to be performed by outside “persons”; a repair station is smart to include in the maintenance functions submitted to the FAA for approval, those “functions” that it may want to contract or will have to contract if equipment breaks down.

Once the maintenance function list is approved, the repair station has to keep a list of its contractors by name and the function performed; if the outside provider is a repair station or other certificated entity, the certificate held by the contractor is also required to be on the list. The list needs to be provided to the agency upon request (or however the repair station says it will be provided in its repair station and quality manual).

Now, back to your question – contract maintenance is any step or steps in the overall work scope that is done by an “contractor,” i.e., someone other than the originating repair station. If that work is “incorporated” into the next higher assembly during a work scope, it should be considered contract maintenance. First, it was not done by the originating repair station and second, the “installer” is responsible for ensuring the work performed by the “other person” was done correctly (look at the back of any FAA Form 8130-3 or EASA Form 1).

Conversely, when you buy parts, that is not contract maintenance. When you perform maintenance on your own or a customer’s article under the part 145 repair station without help from an outside source, that is not contract maintenance.

Finally, calibration labs are not performing maintenance functions. They are validating the calibration status or recalibrating a tool or piece of equipment that will be used during the performance of a maintenance function. The reason I am adding this side note is because I have noticed that calibration labs are being allowed to “register” anti-drug and alcohol programs—something ARSA believes is squarely prohibited by the regulations since calibration is definitely not a safety-sensitive (e.g., maintenance or preventive maintenance) function!

 

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

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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