2019 – Edition 12 – Year in Review
Table of Contents
Maintaining Momentum in 2020
By Brett Levanto, Vice President of Operations
Executive Director Sarah MacLeod once wrote “anything worth doing is worth doing again.” In that spirit, we remind ourselves every year that whatever we do next, it must be rooted in our past. By building on success and learning from shortcomings, we get better every time around.
As we begin 2020, ARSA invites you to see just what it did over the past year. Below, after a few updates from December – we need to stay current, after all – you’ll see the pieces that best capture the issues that mattered in 2019. Each illustrates an important moment for the industry and underscores how this association works on behalf of the maintenance community.
Each story will take you to the hotline in which it appeared. Peruse those editions and see what 2019 really meant for the men and women who keep the world safely in flight every day. Just don’t get caught looking back, the world can’t fly with us stuck in the past.
Annual Conference 2020 – See the Agenda
Registration is open for ARSA’s 2020 Annual Conference, which will be held in and around the nation’s capital from March 10-13, 2020. The agenda, which covers four days of briefings, panels, discussion sessions, networking and personal engagement, is available for review on the event webpage.
ARSA Gifts FAA a Petition to Remove “Current” Maintenance Data Requirement
On Dec. 23, while the U.S. North American Aerospace Defense Command (NORAD) prepared to track Santa Claus’ Christmas Eve trek around the world, ARSA delivered a holiday present to another branch of the American government: a petition to eliminate language from 14 CFR § 145.109(d) requiring certain documents and data be “current and accessible when the relevant work is being done.”
In 2018, the association stimulated submission of a number of industry requests for exemption from § 145.109(d)’s “current” maintenance data requirements. By submitting those petitions, FAA-certificated repair stations set the stage for ARSA’s rulemaking request by applying pressure on the agency to uniformly apply both design and maintenance requirements in addition to aligning parts 145 and 43. As those maintenance providers are aware, the FAA does not require design approval holders (i.e., manufacturers) to make maintenance data available as they are required to by § 21.50(b). However, the agency aggressively enforces the requirement for repair stations to possess the most current version of those documents. (For background on the “toolkit” produced by ARSA to support exemption requests, visit arsa.org/145-109.)
“The last sentence of section 145.109(d), applies only to repair stations, the vast majority of which are small-to-medium-sized enterprises,” ARSA’s petition said. “The requirement to maintain current and accessible documents and data irrelevant to the work performed provides no safety benefit. The costs cannot be justified and the unnecessary sentence causes substantial confusion and expense for the agency. The requested amendment of section 145.109(d) will eliminate needless and discriminatory burdens.”
To read the full petition, click here.
Review ARSA’s Assessment of MAG Change 7
On Nov. 18, EASA published change 7 to the Maintenance Annex Guidance (MAG 7) associated with the bilateral aviation safety agreement (BASA) between the United States and the European Union (U.S.-EU). Repair stations have 90 days to implement changes, which means no later than Feb. 17, 2020, and ARSA seeks industry input to support upcoming interaction with both the FAA and EASA.
As it does with any significant regulatory update, ARSA has been reviewing the plain language of MAG 7 alongside relevant regulations and guidance from the agencies, considering its impact on the association’s publications and coordinating with both member contacts and government personnel to understand how the change has been received across the industry.
ARSA is currently preparing for meetings with agency personnel from both sides of the Atlantic and is specifically working for clarification related to (1) work performed on articles without U.S. design approval and (2) the alignment between MAG 7 and the current FAA-EASA Technical Implementation Procedures. To assist this work, the association is seeking industry input on its complete assessment of the significant changes to the MAG.
That assessment is contained in a draft document is arranged in a table displaying impacted sections from MAG 6, which was signed in June 2016, the updated text (or notation of its removal) as it appears in MAG 7 and ARSA’s assessment of impact on the EASA supplements used by FAA-certificated repair stations performing work under the MAG.
To assist ARSA in its review:
(1) Click here to access a PDF version of the draft document (save/download the file as necessary to facilitate your review).
(2) Review the content of the document, comparing it to your own reading of MAG 7, information provided by inspectors and industry colleagues and documentation used by your facility.
(3) Contact Brett Levanto (firstname.lastname@example.org) with questions, comments or observations.
The information provided via this review will help ARSA update its own Model RSQM EASA Supplement and should assist members using the current supplement revision in determining what updates should be made to their own documentation.
For more information on all of ARSA’s publications, including the RSQM itself as well as a number of resources available for free to members, visit arsa.org/publications.
EASA Issues Opinion on ICA and Parts Documentation
On Dec. 19, EASA issued Opinion 07/2019 – along with two comment response documents (CRD) – in answer to consultation provided to the agency’s notices of proposed amendment (NPA) pertaining to instructions for continued airworthiness (NPA 2018-01) and “installation of parts and appliances that are released without an EASA Form 1 or equivalent” (NPA 2017-19).
Note: The link to the Opinion also references draft documents that EASA is providing to the EC which show the specific amendments that would be made to Parts-21, M and 145.
In 2018, ARSA submitted comments in response to each NPA. After praising the agency for its efforts in both cases, the association critiqued each proposal against decades of industry frustration with regulatory treatment of maintenance data, calling out unnecessary complication and suggesting a simpler, internationally harmonized approach for assessing part criticality.
For background on the NPA and the association’s comments, review the content below.
For NPA 2018-01, “Instructions for continued airworthiness”
To review ARSA’s May 2018 comments, click here.
To access the CRD, related Opinion and other documents related to the rulemaking process via EASA’s website, click here.
NPA 2017-19, “Installation of parts and appliances that are released without an EASA Form 1 or equivalent”
To review ARSA’s March 2018 comments, click here.
To access the CRD, related Opinion and other documents related to the rulemaking process via EASA’s website, click here.
Stay tuned for further updates as the association’s team reviews the matter.
EASA Seeks Input for Impact Assessment Methodology
On Dec. 17, EASA contacted ARSA – as part of the association’s participation on the agency’s Engineering & Maintenance Technical Committee (EM.TEC) – seeking assistance with an online survey supporting its methodology for assessing economic impact on maintenance organizations. Members should review the survey’s details, seek further information as necessary and respond if appropriate.
EASA provided the following description along with the survey announcement:
This survey is intended to collect relevant data for the assessment of economic and financial size of targeted stakeholders, in support of the impact assessment methodology used in the decision-making process put in place by EASA to justify opinions, decisions, acceptable means of compliance and guidance material for the application of the Basic Regulation and its implementing rules.
The following specific aviation stakeholders are covered by the survey:
(1) Helicopter operators and training organisations: operators holding a valid Air Operator Certificate (AOC) in the fields of Commercial Air Transport, General Aviation, Special Operations and State aircraft operations as well as Approved Training Organisations (ATO).
(2) Maintenance organisations: further detail and granularity, including Continuing Airworthiness Management Organisations (CAMO) approved under Part-M Subpart-G, Approved Maintenance Organisations (AMO) approved under Part-145 and AMO approved under Part-M Subpart-F, and Maintenance Training Organisations (MTO) approved under Part-147.
(3) Aerodromes: in particular by improving the granularity in terms of specific economic data for single aerodromes.
An active contribution from the affected stakeholders is critical to the success of this survey. The answers will be aggregated and de-identified to ensure confidentiality.
Please ensure that the survey is answered only once per company/organisation.
The survey will close on January 31, 2020.
To access it, visit: https://ec.europa.eu/eusurvey/runner/FIN-EST-H-CAW-ADR.
If you have questions, comments or difficulty, contact email@example.com.
To see more of ARSA’s own “Data and Advocacy” resources, visit arsa.org/news-media/economic-data.
Congress Fully Funds New Workforce Grant Program
In a major victory for the aviation maintenance industry, the FY 2020 appropriations deal unveiled by House and Senate negotiators Dec. 16 includes full funding for a new aviation technician workforce development program.
Section 625 of last year’s FAA reauthorization bill authorized $5 million annually for five years to support the education and recruitment of aviation maintenance technical workers and the development of the industry’s workforce. It also created a parallel program, authorized at the same level, to support pilot education.
Congress created the programs to address the workforce crisis confronting the U.S. aviation sector. An analysis by Boeing suggests that airlines in North America will need 189,000 new technicians and 206,000 new pilots over the next two decades. The consulting firm Oliver Wyman has forecast that demand for aviation maintenance technicians will outstrip supply by 2022. More than two-thirds of U.S. companies responding to ARSA’s 2019 member survey reported vacant technician positions.
ARSA led the coalition that created the maintenance grant program and lobbied for its funding. More than 40 national, state and local organizations representing all segemnts of the aviation industry supported the effort. The original sponsors of the bills that created the technician grants (see March and May 2018 updates below) were Sens. James Inhofe (R-Okla.), Jerry Moran (R-Kan.), Maria Cantwell (D-Wash.) and Richard Blumenthal (D-Conn.) and Reps. Sam Graves (D-Mo.), Dan Lipinski (D-Ill.), Brenda Lawrence (D-Mich.) and MarkWayne Mullen (R-Okla.).
“We’re proud of what we’ve accomplish with our coalition partners and pleased that Congress has acted in a truly bipartisan way to tackle a problem with significant consequences for both the aerospace community and the broader U.S. economy,” ARSA Executive Vice President Christian A. Klein said. “The new program will encourage local partnerships and innovative thinking about how recruit and train the maintenance professionals the aviation industry needs to thrive in 21st century.”
The technician program supports a wide variety of aviation maintenance workforce development recruitment and training activities. Grants of up to $500,000 may be used to:
- Establish new educational programs that teach technical skills used in aviation maintenance, including purchasing equipment, or to improve existing such programs.
- Establish scholarships or apprenticeships for individuals pursuing employment in the aviation maintenance industry.
- Support outreach about careers in the aviation maintenance industry to primary, secondary, and post-secondary school students or to communities underrepresented in the industry.
- Support educational opportunities related to aviation maintenance in economically disadvantaged geographic areas.
- Support transition to careers in aviation maintenance, including for members of the Armed Forces.
- Otherwise enhance aviation maintenance technical education or the aviation maintenance industry workforce.
The maintenance grant program was designed to facilitate public-private collaboration and innovation. In order to be eligible, a grant application must be supported by an aviation business or union, a school and a governmental entity.
The ball is now in the FAA’s court to get the grant programs up and running and release funds for worthy projects. While the agency has not indicated when it will start accepting applications, in a sign that the agency is moving in the right direction, the Nov. 26 Federal Register included a notice and request for comment required by the Paperwork Reduction Act regarding the collection by the FAA to select and oversee grant recipients.
More information about the coalition effort and aviation maintenance skills gap is at http://arsa.org/legislative/grant-program-action-center.
ARSA’s Filler Reports on Global Issues at EASA EM.TEC
On Dec. 5, ARSA Managing Director & General Counsel Marshall Filler represented the association at the EASA Engineering & Maintenance Technical Committee (EM.TEC) meeting in Cologne, Germany. The EM.TEC is one of several EASA stakeholder advisory bodies (similar to the FAA’s Aviation Rulemaking Advisory Committee) that meets twice yearly to discuss current issues primarily affecting the European maintenance industry, but also touching on international issues.
Along with EASA’s Thaddee Sulocki, Filler briefed the EM.TEC on the October 2019 Maintenance Management Team (MMT) meetings among EASA, the FAA, Transport Canada and ANAC of Brazil (see the Nov. 1 “hotline highlight” by visiting arsa.org/hotline-highlight and scrolling down the page to the previous highlights). and the recently published EASA-FAA Maintenance Annex Guidance Change 7 (MAG 7; see arsa.org/mag for the most recent updates from ARSA).
Not surprisingly, there was considerable interest among EM.TEC members on the so-called Safe Aircraft Maintenance Standards Act (H.R. 5119) introduced by Rep. Peter DeFazio and reported last month to the full House of Representatives. Filler gave a short overview of what the legislation would do, focusing on the potential impact on the EU-U.S. bilateral aviation safety agreement, prompting one attendee at the EM.TEC meeting to say “we might as well tear up Annex 2” [which contains the maintenance provisions of the agreement] if the DeFazio bill becomes law. (See arsa.org/hr5119 to follow ARSA’s lead in opposing the bill.)
Of particular interest to ARSA members is the status of the EASA parts’ documentation and ICA rulemaking projects (NPAs 2017-19 and 2018-01). Look for an EASA Opinion to be issued before the end of the year after which it will be sent to the European Commission for review.
At the EM.TEC meeting, the AeroSpace and Defence Industries Association of Europe (ASD) presented a position paper on the requirements for component certifying staff in the EU. Under current regulations, that authority is left up to the individual EU Civil Aviation Authorities to decide, resulting in an unlevel playing field for industry since several authorities have adopted their own licensing requirements for component certifying staff while others leave this to the discretion of their approved maintenance organizations (AMO). The objective of the ADS paper is to provide an option for AMOs to either follow their respective national authority licensing rules or their own internal procedures for inclusion in the AMO’s Exposition. The EM.TEC supports this proposal and it has been presented to EASA for review.
ARSA Highlights Threats from Anti-Repair Station Bill
On Dec. 5, ARSA hosted a webinar to encourage industry action in opposition to an anti-contract maintenance bill rushed through the U.S. House of Representatives Transportation & Infrastructure (T&I) Committee on Nov. 20.
To stream a recording of the webinar, click here.
To download a PDF copy of the presentation, click here.
The bill could be considered by the full House before the end of the year, demanding immediate attention from the repair station community as well as suppliers, customers and business partners.
Among other things, the Safe Aircraft Maintenance Standards Act (H.R. 5119) would:
- Impose burdensome new maintenance-related reporting requirements on air carriers.
- Ban the FAA from issuing or renewing repair station certificates in countries designated as Category 2 under the International Aviation Safety Assessment Program (and ban U.S. air carriers from using maintenance contractors in those countries).
- Require the FAA to directly certificate workers at foreign repair stations.
- Impose a moratorium on the issuance of new FAA repair station certificates outside the United States if the agency does not complete all the tasks directed by the bill and pending foreign repair station-related rulemakings within one year of the bill’s enactment (a laundry list so long the FAA will never meet the deadline).
House T&I Chairman Peter DeFazio (D-Ore.) introduced the bill on Nov. 15 and brought it up for a committee vote just five days later. No hearings were ever held to discuss the bill or committee concerns about repair station oversight. Given the “no huddle offense” strategy that Chairman DeFazio and his airline mechanic union allies employed to get the bill through committee, there’s a strong possibility they could try to get it to the House floor for a vote before the end of the year. Given that all T&I Committee Democrats and seven Republicans voted in favor, if it were taken up by the House today, it would likely pass.
If the bill becomes law, U.S. repair stations with foreign approvals and their employees would almost certainly be targets of the retaliation by foreign authorities. U.S. commercial and general aviation operations outside the country would be disrupted because of a shortage – or complete lack of – FAA certificated maintenance facilities in destination countries. And U.S. manufacturers seeking to provide product support in growing foreign markets would be prevented from obtaining FAA certification at those overseas facilities.
ARSA is leading a coalition of industry organizations and companies to oppose the bill. In addition to meeting with congressional offices to voice concerns and coordinating a letter in advance of the committee vote, ARSA has developed additional materials (see the remainder of this page’s content) to support our members’ and allies’ advocacy. With the specter of a House vote looming, time is of the essence. Your personal engagement is critical to stop H.R. 5119 from becoming law.
More information about the bill and what you can to do prevent it from becoming law is available via arsa.org/hr5119.
Welcome & Welcome Back – New & Renewing Members [Full Year]
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 2019.
Silver Sky Aviation, R01
LAUNCH Technical Workforce Solutions, R01
Aero Products Component Services, Inc., R03
Aircraft Armature Inc. dba TSA Rewinds Florida, Inc., R02
Sumitomo Precision USA Repair Station, R01
Rocky Mountain Propellers, Inc., R01
Aery Aviation, LLC, Assoc
Ronald Cannoles, Affil
24Jets dba Alirio Aircraft Services, Inc., R01
ALA – Advanced Logistics For Aerospace, Inc. dba ALA North America, Assoc
T&C Aviation Enterprises, Inc., R01
The Zee Company Inc., R02
Airborne Maintenance & Engineering Services dba PEMCO World Air Services, R05
Bridger Aviation Repair, LLC, R01
FlyBoyz Aviation, LLC, R01
Mel Marengo, Edu
Renewing Members (Member Since)
Aero Tire & Tank, LLC, R02, 2012
Aerosource, Inc. – SAFRAN, R03, 2006
Aerotech Engineering Consultants, Affil, 2016
Airbus North America, Inc., Assoc, 1995
All Nippon Airways Company, Ltd., Assoc, 2001
Alpha Aircraft Services of America, R01, 2012
Austin Aerotech Inc., R02, 2012
Av8 Group dba Av8 MRO, LLC, R01, 2014
Aviation Instruments Repair Specialists (AIRS), Inc., R03, 1994
B&E Aircraft Component Repair, Inc., R04, 2005
Barfield Precision Electronics, LLC, R04, 1996
Central Cylinder Service, Inc., R01, 1985
Continental Aircraft Support, Inc., R03, 2004
Delta TechOps, Corp, 2002
DERS Group Svc LLC, Affil, 2001
Gables Engineering, Inc., Assoc, 1995
Gyros Unlimited dba North Bay Aviation, R03, 2011
INAir Aviation Services Company, R02, 2003
JetRight Aviation Maintenance, R02, 2015
Lone Mountain Aircraft, R01, 2017
Master Air Parts, Inc., R02, 2013
Papillon Airways, R03, 2011
PPG Industries Inc.-dba PPG Aerospace Transparencies, R02, 2005
S3 Repair Services, LLC, R01, 2010
Skytech Aviation, Inc., R02, 2013
Southwest Turbine Inc., R03, 2018
Tarrant County College, Edu, 2017
TPS Aerospace, LLC, dba Aviation Industry Repair, R02, 2015
Turbine Controls, Inc., R04, 1988
Western Aero Repair, Inc., R03, 2011
World Class Accessory, Inc., R01, 2007
AerSale, Inc.-Aero Mechanical Industries, R04, 2011
Air-Cert, Inc., R01, 1990
Aircraft & Component Technical Services, R01, 2009
Airgroup Dynamics, Inc., R03, 2007
AIRTOMIC, LLC, R03, 2018
BBA Aviation, Corp, 2013
C&S Propeller, LLC, R01, 2016
Cobalt Aero Services, R01, 2012
Consolidated Turbine Specialists, LLC, R03, 2018
E.B. Airfoils, LLC., R03, 2001
Erickson Incorporated dba Erickson Air-Crane, R05, 1997
Genesis Aviation, Inc., R04, 1994
JAS Services/Team J.A.S., R01, 2004
North Star Aerospace, Inc., R01, 2006
PAS MRO, Inc., R01, 2013
Rapco, Inc., Assoc, 1990
Southwest Airlines, R06, 2005
The Giles Group, Affil, 2013
Lufthansa Technik AG, Corp, 2001
Moog, Inc., Corp, 1997
Accurate Accessories, LLC, R01, 2002
AERO Component Repair, LLC, R01, 2011
Asko Processing, Inc., R04, 1996
Avborne Accessory Group, Inc.-dba Avborne Component Solutions, R04, 2013
Aviation Propellers, Inc., R02, 2011
Aviation Safety Products, Inc., R01, 2013
Barfield, Inc., R05, 1995
Cargo Systems, Inc., R01, 1999
Harman’s Repair Station, Inc., R01, 2012
IAR Technical Services LLC, R03, 2017
Mingo Aerospace, LLC, R03, 2005
Nelson Engineering Co., R02, 2013
Ohlinger Industries, Inc., R04, 2006
SONICO, Inc., R03, 1995
Aero Endeavors LLC dba Reliable Aerostructures, R01, 2017
AeroParts Manufacturing & Repair, Inc., R04, 2016
Aerospace Turbine Rotables, Inc., R01, 2016
AgustaWestland Philadelphia Corp., R04, 2012
Aircraft Electric Motors, Inc., R04, 1984
Airline Component Parts, Inc., R02, 1999
AMETEK Aircraft Parts & Accessories, Inc. dba AMETEK B&S , R03, 1985
A.O.G. Reaction, Inc., R02, 1993
Aviation Avionics & Instruments, Inc., R03, 2012
Avionics Shop, Inc., R01, 2011
Buckeye Turbines, LLC, R01, 1997
Chromalloy, Corporate, 1993
Compressed Gas Systems, LLC, R02, 2012
Dassault Falcon Jet, Associate, 1999
DFW Instrument Corporation, R02, 2013
Dr. Robert Marx, Educational, 2018
Gardner Aviation Specialist, Inc. dba Precision Aircraft Services, R02, 2018
Quality Aviation Instruments, Inc. dba QAI , R02, 2012
Scott Richard Aircraft Maintenance, R02, 2010
S.E.A.L. Aviation, LLC, R02, 2014
Southern Oregon Skyways, Inc. dba Jet Center MFR, R02, 2006
Star Aviation, Inc., R01, 2012
Stein Seal Company, R02, 2017
Thales Avionics, Inc., R04, 2006
AeroKool Aviation Corporation, R04, 2017
Aerospace Quality Research & Development 145, LLC, R01, 2006
AgustaWestland Philadelphia Corp., R04, 2012
Aircraft Tooling, Inc., R02, 2004
Coopesa, R.L., R06, 1996
Fleet Support Services, Inc., R01, 2013
Hancock Enterprises Inc., R01, 2020
Jet Aviation Specialists, LLC, R03, 1999
L. J. Walch Co., Inc., R03, 1985
Metro Aviation, Assoc, 2003
Pac West Helicopters, Inc., R02, 2009
Pacific Aero Tech, LLC, R04, 1994
Piedmont Propulsion Systems, LLC, R03, 2011
Performance Repair Group, R02, 2013
R.W. Raddatz, Inc., R02, 2004
Shoreline Marine, Inc., dba Safetech – Humble, R02, 2002
SkyWest Airlines, Assoc, 2010
Timberline Helicopters, Inc., Assoc, 2013
Triumph Airborne Structures LLC, Corp, 2003
Twin Manufacturing Co., dba TWIN MRO, R04, 1993
ACSS Repair & Overhaul, R02, 2002
Aeroworx, R02, 2010
Aviation Component Solutions, Assoc, 2005
Aviation Repair Resources, Inc. (ARR), R02, 2009
Eastern Airlines Technic Co., Ltd., R04, 2017
EXTEX Engineered Products-A Kaman Company, Assoc, 2002
F&E Aircraft Maintenance (Miami) L.L.C dba Global Maintenance Technologies dba FEAM, R05, 2012
Ford Instruments & Accessories, LLC, R01, 2012
Houston Aircraft Instruments, Inc., R01, 2002
InterSky Precision Instruments, LLC, R02, 2016
Ozark Aeroworks, LLC, R03, 2015
S & T Aircraft Accessories, Inc., R01, 2003
Paz Aviation, Inc., R02, 2016
The Aviation Group, Inc., R01, 2011
The Pennsylvania State University, R01, 2016
TMx Aero, LLC, R01, 2018
Warner Propeller and Governor Co., LLC, R02, 2010
Wencor, LLC, Corp, 2018
AAR Corp, Corp, 1985
Aero Accessories & Repair, Inc., R03, 2016
Aero-Mark MRO, LLC-dba Certified Aviation Services, R02, 2015
Aerospace Testing Engineering & Certification Inc.-dba AeroTEC, Assoc, 2017
Air Transport Components, LLC, R04, 2015
AllFlight Corp., R03, 2011
Citadel Completions, LLC, R04, 2018
Engine Disassembly Services, Inc. dba Engine Overhaul Services, R01, 2018
E.U.A. Air Support, Inc., R01, 2003
Gyro Specialist, Inc., R01, 2011
Helicopter Services of Nevada LLC, R01, 2005
Lynden Air Cargo, LLC, Assoc, 2000
MTU Maintenance Hannover GmbH, R06, 2007
NAASCO Northeast Corporation, 2002, R02
NFF Avionics Services, Inc., R02, 2010
Pacific Aerospace, LLC, R01, 2005
Southern Utah University, EDU, 2017
Southwest Airmotive Corp, R01, 2012
Aero Instruments & Avionics, Inc., R04, 1991
Aero-Marine Technologies, Inc., R01, 2001
Aerotron AirPower, Inc. dba Fokker Aerotron, R04, 1990
Air Cargo Equipment, Inc., R01, 2010
Aircraft Systems Division of Com-Jet Corp, R03, 2011
Airframe Components by Williams, Inc., R02, 2003
Ameron Global Product Support, R02, 2004
Aviation Repair Solutions, Inc., R02, 2006
Berkley International, In, R01, 2007
Camtronics, LLC, R03, 2012
Flight Deck Specialists, Inc., R01, 2002
General MRO Aerospace, R03, 2015
The Boeing Company, Corp, 1996
C J Aviation, Inc., R01, 2017
Dan Brauhn-Indian Hills Community College, Edu, 2015
HEICO Aerospace Corporation, Corp, 1992
Marvel-Schebler Aircraft Carburetors, LLC, R02, 2011
National Flight Services, Inc., R03, 2018
Regional Avionics Repair, LLC, R02, 2006
Signature Engines, Inc., R01, 2003
Sunshine Aero Industries, Inc., R01, 2003
United Technologies Corporation, Corp, 1997
Aero Design Services, Inc., Affil, 2000
Air Technology Engines, Inc., R02, 2006
Aircraft Ducting Repair, Inc., R03, 2002
Aircraft Lighting International, R01, 2018
Ametek Ameron, LLC dba Ameron Global Product Support, R01, 1989
B&E Aircraft Component Repair, Inc., R03, 2005
B. V. Aviation, Inc. dba Universal Turbine Parts, R03, 2018
Bemidji Aviation Services, Inc., R04, 2017
Calvin Taff Electronics, Inc., R01, 2003
Commercial Aircraft Interiors, LLC, R04, 2010
CorpAir Supply Company, Inc. dba AVMATS, R02, 2001
First Class Air Repair, R02, 2016
Gateway Alliance Co. d/b/a Affinity Aeronautical Solutions, R01, 2018
General MRO Aerospace, Inc., R03, 2015
Gulfstream Aerospace Corporation, Corp, 1999
International Turbine Industries, LLC, R02, 2010
JET Aircraft Maintenance, Inc., R04, 1997
Miami Aircraft Structures, Inc., R01, 2003
IBM Flight Operations, Assoc, 1997
Nampa Valley Helicopters, Inc., R02, 1993
Pacific Turbine Brisbane, R03, 2018
Royal Technical Group, Inc., R01,
SAI Flight Support Company, R02, 2000
Thomas Global Systems, LLC, R01, 2012
Turbine Standard, Ltd., R03, 2003
UNICAL 145, R04, 2012
Unicorp Systems, Inc., R03, 2003
VT Mobile Aerospace Engineering, Inc., R06, 2006
AE&C Services, LLC, R02, 2017
Aeronautical Technology, Inc. dba Precision Aero, R03, 1993
Aircraft Inspection Services, Inc., R01, 2013
Amway Aviation dba Alticor, Inc., R02, 2018
AOG Aircraft Service Inc., R01, 2018
Arkwin Industries, Inc., R03, 1994
Avocet Aviation Services, LLC, R03, 2014
CanRep Inc., R02, 2018
Commercial Jet, Inc., R04, 2010
Cross-Check Aviation, R03, 2003
Curtiss Wright Controls, Inc., R03, 2012
Dassault Falcon Jet do Brasil, R02, 2010
Dassault Falcon Jet-Wilmington Corp., R05, 2002
Eagle Creek Aviation Services, R04, 2016
Empire Airlines, Inc. d/b/a Empire Aerospace, R03, 2002
EuroTec Vertical Flight Solutions, LLC, R02, 2004
Federal Express Corporation, Assoc, 2000
Florida Jet Center, Inc., R02, 2013
Global Parts Aero Services, R01, 2012
Gulf Aerospace, Inc., R02, 2005
Helicopter Accessory Service East Inc., R01, 2018
Jordan Propeller Service, Inc., R02, 2002
KLM Royal Dutch Airlines-Engineering & Maintenance, Assoc, 2010
Mach II Maintenance, R04, 2018
Midway Aerospace, R02, 2004
Midwest Turbine Services, R01, 2015
Millennium International, R03, 2013
MTI Aviation, Inc., R01, 2011
PPG Industries Inc.-dba PPG Aerospace, R02, 2005
Schaeffler Aerospace USA Corporation, R02, 2012
Southern Air Repair Corp., R01, 2016
S Tec Corporation, R02, 2016
Soniq Aerospace, LP, R01, 2016
Southwind Aviation Supply, LLC, R01, 2008
Team Aerospace, Inc., R01, 2005
Tech-Aire Instruments, Inc., R01, 2012
Trace Aviation, R02, 2017
Unipak Aviation, LLC, R02, 2003
Aerospace Turbine Rotables, Inc., R04, 2011
Airforce Turbine Service, Ltd., R03, 2010
Aviation Blade Services Inc., R02, 2018
Columbia Helicopters, Inc., R05, 1998
First Aviation Services, Inc., Assoc, 2014
Fieldtech Avionics & Instruments, Inc., R03, 2016
Gyros Unlimited dba North Bay Aviation, R03, 2011
HAECO Americas, Corp, 2000
Ikhana Aircraft Services, R04, 2003
Intrepid Aerospace, Inc., R02, 2016
Kellstrom Repair Services, Inc., R03, 2016
MT Texas, LLC, R03, 1990
New Image Aero Interiors-dba NIA Interiors, R01, 2017
Palm Beach Aircraft Propeller, Inc., R02, 2001
Rapco Fleet Support, Inc., R01, 2008
REB Technologies Inc., dba REBTECH, R02, 2003
Repairtech International, Inc., R03, 1992
Rotron, Inc., dba Ametek Rotron, R02, 2016
Safran Nacelles Services Americas, R02, 2017
Tennessee Aircraft Company, Inc., R01, 2012
Turbines, Inc., R02, 2017
Yuba-Sutter Aviation, R01, 2018
Action Aero Inc, R03, 2018
Aero Products Component Services, Inc., R03, 2013
AerSale, Inc. dba AerSale Component Solutions, R02, 2011
Air Shunt Instruments, Inc., R02, 1999
Austin Aerotech Repair Services Inc., R01, 2012
Brothers Aviation Maintenance Services, Inc., R01, 2010
Component Repair Technologies, Inc., R05, 1995
Delta TechOps, Corp, 2002
Embry-Riddle Aeronautical University, R01, 2012
Fire-Tec Aero Systems, LLC, R02, 2013
Gables Engineering, Inc., Assoc, 1995
Genesis Aviation, Inc., R04, 1994
IHI Corporation, R06, 2019
Inflatables International, Inc., R01, 2002
MRO Holdings, Corp, 2017
PAS MRO, Inc., R02, 2013
Papillon Airways, R03, 2011
Peter Stonefield, Affil, 2010
SIA Engineering Company, Ltd., R05, 1997
Structural Evaluation Technologies, Inc. dba SET Aero, R02, 2013
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 from December 2019.
2019 in Review
Each story will take you to the hotline in which it appeared (which means readers should beware the timeliness of references and seek follow up on key issues). Peruse those editions by clicking each headline and see what 2019 really meant for the men and women who keep the world safely in flight every day.
Thoroughness is a requirement in aviation and a standard to which ARSA holds itself. The focus on details does not eradicate failure, it enhances the responsibility to watch for, report and correct mistakes at all phases of an operation or objective.
The latest International Safety Conference co-hosted by the FAA and EASA is evidence that the gathering must transform.
ARSA is pleased that Airbus has formally withdrawn its plan to charge repair stations a royalty for the use of the company’s maintenance data. There’s never been a better time to educate owner/operator customers about the problems you have getting ICA and how it directly impacts the continued airworthiness of an aircraft or other product.
The commercial agreement between IATA and CFMI took effect on Feb. 28, 2019, seven months after its signature. Two week’s later, ARSA’s 2019 “Executive to Executive Briefings” participants attended a special session regarding the deal. (Note: The 2020 “E2E” will kick of ARSA’s Annual Conference on Mar. 10; attendance is open only to event sponsors.)
On May 20, ARSA joined 12 other aviation industry organizations in delivering a letter to the White House seeking recognition of Friday, May 24 as Aircraft Maintenance Technician Day. Four days later, the president issued a message remembering Charlie Taylor and commemorating those doing his work in the world right now. (Bonus content: Podcast on Celebrating AMTs)
ARSA’s 2019 study determined there are 1,507 repair stations with EASA approval across 47 of the 50 states, up from 1,437 in 2018. Overall, roughly one out of every three U.S. repair stations holds European certification.
On July 24, ARSA received a response from the FAA regarding the association’s joint effort with the Aircraft Electronics Association to purge agency guidance of a requirement for repair station applicants to submit a “letter of compliance.”
ARSA filed comments on Sept. 6 in response to EASA Notice of Proposed Amendment 2019-05, Embodiment of safety management system requirements into Parts 145 and 21 of EASA’s rules.
The OMB-recommended reminder that guidance “is not mandatory and does not constitute a regulation,” does not absolve the industry from its duty to hold the government to that limitation.
On July 12, the U.S. Court of Appeals for the District of Columbia Circuit issued its decision in Kornitzky Group v. Daniel Elwell – coming to the correct conclusion for the wrong reason. ARSA has followed the case for the past year, now providing analysis to help repair stations understand what was decided and to whom it matters.
Know the limits of obligations to provide maintenance data.
A simple comparison of the new MAG 7 to its predecessor MAG 6 suggests the entire document has been revised; the reality is less traumatic.
ARSA on the Hill
Appropriators in the U.S. House are enthusiastic about aviation industry grant programs, but plenty of work remains before money can be made available. Elsewhere in the Capitol, elected officials continue to wrestle with the role of the FAA and the fate of its nominee for administrator.
With much fanfare and famous protagonists present on June 4, aviation maintenance unions and consumer advocate “allies” announced intentions to introduce legislation targeting contract maintenance and raising airline costs.
ARSA made workforce development the central theme in the association’s statement submitted in conjunction with a Sept. 26 House aviation subcommittee hearing on FAA reauthorization implementation.
ARSA is on high alert given concerns that the bill, which would cause massive disruptions for repair stations, air carriers and manufacturers, could be considered by the full House before the end of the year. The association hosted a Dec. 5 webinar to brief members on the bill’s status and encourage opposition.
Walk through the association’s coverage of aviation-related fallout from the 35-day government shutdown. In order to be prepared for the next one, try to make a little sense out of what happened in January.
On March 14, the Civil Aviation Authority of the United Kingdom posted details of new implementing procedures agreed to under the bilateral aviation safety agreement between the UK and the United States.
Steve Dickson, former senior vice president of flight operations for Delta Air Lines, was sworn in as the FAA administrator by Transportation Secretary Elaine L. Chao on Aug. 12.
On Nov. 26, the Federal Register published notices regarding new aviation workforce development grant programs created by Sec. 625 of last year’s FAA reauthorization law.
Relive or review the events of the Annual Conference. Scroll through quick highlights and photos or check out the complete updates in the appropriate sections of the March 2019 edition of the hotline.
On May 16, the Certification Authorities for Bilateral Agreements and Certification Policy met with industry representatives to discuss the latest initiatives affecting the four regulatory authorities of the Certification Management Team.
On July 16, the U.S. Federal Trade Commission hosted “Nixing the Fix: Workshop on Repair Restrictions” in Washington, D.C. Seeking new venues to shed light on the challenges faced by repair stations when trying to obtain maintenance manuals – and the FAA’s unwillingness to enforce the relevant regulations – ARSA coordinated industry attendance at the event.
On Sept. 11-12, ARSA Vice President of Operations Brett Levanto participated in FlightGlobal’s Aerospace Big Data Americas in Miami. During the event’s second day, Levanto spoke and then participated in a panel discussion on “bridging data science and maintenance.”
On Nov. 13, the Department of Transportation hosted the first meeting of the Safety Oversight and Certification Advisory Committee. ARSA Executive Director Sarah MacLeod was at the table.
From March 20-22, ARSA Regular Member AeroKool Aviation Corporation– which has become an exemplar of proactive membership as a Platinum Sponsor of the 2019 Annual Conference – carried the association along on its participation in SkyWest Airlines annual Mini Indy races.
In early May, Component Repair Technologies welcomed candidates and parents to the Student Opportunities in Aviation Repair (S.O.A.R.) program taking place in June. The open house included a facility tour, a S.O.A.R. program overview and served as “signing day,” commending the students for choosing to enter the workforce directly after high school graduation.
There’s an old saying: Give a man a fish and you feed him for a day; teach a man to fish and you feed him for a lifetime. That philosophy is at the core of ARSA’s advocacy work; it’s exemplified by long-time supporter Bob Arnett.
On Sept. 16, the FAA presented the Charles Taylor Master Mechanic Award to Chris Erickson, senior quality manager for Erickson, Inc. and outgoing member of ARSA’s board of directors.
On Nov. 22, ARSA helped to recognize the retirement of two colleagues from member company Lynden Air Cargo. Jeff Pull and Paul Willing have long been steadfast supporters of aviation safety and committed backers of ARSA’s work on behalf of the entire aviation maintenance community.
Produced at the end of 2018, these three sessions build on the association’s “dealing with the government” resources to provide applied skills in managing letters of investigation and notices of proposed civil penalty. This process begins before an official letter or notice is received – known around ARSA as “prophylactic lawyering.”
The association values your time and energy, so it redisgned the training webpage to help you more-quickly search the more than 70 hours of ARSA online training available in the library.
ARSA’s growing library of human factors training has reached a milestone: completion of “the Dirty Dozen in Depth” series. The twelve sessions joined two original association-presented classes reviewing general human factors concepts. All will be available on-demand and all are accepted by the FAA for IA renewal credit.
Test your knowledge of 14 CFR Part 65 – Airmen Other than Flight Crewmembers [the complete series of training sheets]. To access this training sheet, click “Read More” and download the document via the link on the hotline’s landing page.
Exploring and supporting the value of repairman’s certificates is a key part of the association’s effort to grow the workforce of the future. It provides a career pathway for skilled, but non-certificated persons, to serve the aviation maintenance community. Help in this effort.
As part of its efforts to support aviation workforce development, ARSA is working to chronicle the careers of people in the industry. The purpose of this work is to demonstrate how the maintenance community can provide more than just a “job,” but an opportunity for passionate individuals to develop skills while growing personally and professionally.
In support of comments made to EASA’s SMS rulemaking in September, ARSA sought to capture a “snapshot” of ongoing industry efforts. See the response provided by 38 repair stations and add your insight to the growing data.
A Member Asked
I’m am trying to get technicians to stop using “in accordance with” (I/A/W) when completing a maintenance record entry. From a regulatory standpoint what is the main issue for not using I/A/W? I want to give the workforce a good reason to stop other than, “Because I said so.”
This column is dedicated to two queries the association received regarding recent design and production approval holder activities regarding (1) protection of “intellectual property” and (2) charging money for access to customer-specific information. Since both involve maintenance manuals or instructions for continued airworthiness, the answers are not easy or straight-forward. Editor’s Note: The discussion would continue across several months’ worth of ARSA communications.
In reading ARSA’s comments on the latest changes to the U.S.-EU MAG and their impacts on the current revision of the association’s Model RSQM EASA Supplement, Human Factors (HF) recurrent training is described as an annual requirement, but I found no such requirement mentioned in the MAG.
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.
Keep up to date on ARSA’s analysis and resources related to the Maintenance Annex Guidance issued under the bilateral agreement between the United States and the European Union.
Help combat a bill introduced in the U.S. Congress that would disrupt the global aviation industry.
Every year, more people are flying. The expansion of the global middle class and improvements in technology have opened aviation markets – for passengers and cargo – to a broader public than ever before. As the the flying public gets larger, more men and women are desperately needed to keep the world safely in flight.
See what ARSA has asked and what’s been answered and participate in the conversation about what’s going on in the aviation maintenance world.
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.
|MRO Latin America||1/22-23/2020||Cartagena, Columbia|
|MRO Middle East Summit & Expo||2/24-26/2020||Dubai, UAE|
|ARSA Annual Conference||3/10-13/2020||Washington, DC|
|MRO Australasia||3/10-12/2020||Brisbane, Australia|
|AEA International Convention and Trade Show||3/24-27/2020||Nashville, TN|
|ATEC Annual Conference||3/29-4/1/2020||Fort Worth, TX|
|MRO Americas||4/28-30/2020||Dallas, TX|
|Farnborough Air Show||7/20-24/2020||Farnborough, UK|
|Business Aviation Convention & Exhibition (NBAA-BACE)||10/6-8/2020||Orlando, FL|
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