2019 – Edition 1 – February 8

Table of Contents

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

Sarah Says
2019 Annual Conference
ARSA Works
Legal Briefs
ARSA on the Hill
Regulatory Update
Getting Facetime
Training
Membership
Resources
Industry Calendar

Sarah Says

An Ounce of Prevention

By Sarah MacLeod, Executive Director

The first government shut down of 2019 has ended, with the next one already threatened.

Without reservation, the association extends deep appreciation to government employees that worked without pay to ensure aviation safety remained uncompromised; particularly those “essential” individuals that communicated with other aviation safety agencies (namely EASA) to address continued compliance with international agreements.

Before and during the unfortunate hiatus, the association engaged in alternative planning for its Annual Conference, helped its members and the agency address immediate issues and tracked the progress and gradual return of FAA’s workforce (much of this progression can be viewed at arsa.org/shutdown).

In the aftermath, the association engaged with its members and other aviation groups on how best to prepare the industry for future FAA service interruptions. The most obvious answer is for every certificate holder to explore and, after study, develop a list of FAA designees needed to continue operations in the most efficient and effective manner. If that includes requesting designee status or expanding current capabilities, appropriate requests should be made to the agency as soon as practicable. Even if the approval is not granted, the request will provide the agency with information on how its inability to act directly impacts certificate holders and ultimately aviation services and safety.

For its part, ARSA will take a deep dive into delegated authority, starting with the law, working through rulemaking documents and ultimately guidance material. The project may not take top priority – workforce development has that key spot – but it will come to fruition. The goal will be to ensure that the agency and the industry are able to take full advantage of the FAA’s ability to delegate authority while ensuring appropriate oversight of the persons exercising that power.

The ability to withstand vagaries in government support certainly adds up to more than an ounce, and it certainly can help prevent disruptions in vital air transportation services.

2019 Annual Conference

Know the Schedule

Registration is officially open for ARSA’s 2019 Annual Conference. Make sure you’ve got the dates in your calendar (and that they are correct): March 12-15, 2019 in Arlington, Virginia and Washington, D.C.

Click here to register…or here for more information…then register.

Since last year’s event wrapped (you can see what happened under “the recent past” at arsa.org/conference) there have been contradicting dates published in a few different places. The most careful of ARSA’s readers have caught these discrepancies and helped the events team get dates in order.

Now that you know the correct dates (again: March 12-15…keep repeating them to yourself), here’s what you can do:

(1) If you see any other date published anywhere, let Brett Levanto know immediately (brett.levanto@arsa.org).
(2) Review the general schedule below. Attendees may determine which days will be most valuable for their professional and personal needs and register accordingly.
(3) Click here to register. (Or here for more information…then register).

The rooms have been reserved at the Ritz-Carlton (book yours before Feb. 18) and the 2019 schedule is set (though specific details may change). See what awaits you at the conference:

Tuesday, March 12: Executive to Executive Briefings

[Registration for this day is available only to sponsors at the Platinum, Gold and Silver levels.]

Industry executives will participate in meetings with senior executive branch officials organized by ARSA. The day will conclude with an exclusive IATA briefing on the status of international market competition issues and the agreement reached with CFMI on maintenance data availability.

Wednesday, March 13: Legislative Day

After a morning of briefings and policy updates, Legislative Day participants will fan out across Capitol Hill to meet with members of Congress and committee staffers to connect the impact of the maintenance community to each state and congressional district. The day will include ARSA’s release of its Annual Global Fleet & MRO Market Assessment, produced by Oliver Wyman, as well as the presentation of the association’s Legislative Leadership Award.

Thursday, March 14: Annual Repair Symposium

As always, ARSA’s regulatory experts will lead a full day of panel discussions and presentations on regulatory and business development matters. Invited participants from the FAA, EASA, Transport Canada and ANAC Brazil will join industry members to address issues impacting the ability of maintenance providers to work and grow.

Friday, March 15: Annual Member Meeting & Breakout Sessions

During breakfast, the president of ARSA’s Board of Directors will overview the state of the association and share priorities for the coming year. Participants will then select one of two sessions to complete their conference engagement: (1) an update on ARAC’s part 145 tasking or (2) a workshop on “creating careers” in aviation maintenance.

See the full agenda, learn about sponsorship opportunities and begin planning your trip: Click here to get started.

Book a Room

Annual Conference events are held in Washington, D.C. (at the offices of executive branch agencies, the White House and on Capitol Hill) as well as in Arlington, Virginia. Guest accommodations are available at the government rate through the Ritz-Carlton Pentagon City (1250 South Hayes Street, Arlington, VA 22202).

Click here to reserve your room by Feb. 18.

Of course, your room is only conveniently located if you’re coming to the conference: Click here to register…or here for more information…then register.

See the Sights

In addition to being a center of international politics and policy (and intrigue, depending on your particular perspective) the Washington, D.C.-area is a hub of history, entertainment and culture. While the ARSA team will keep you pretty busy during the Annual Conference, guests are encouraged to fill whatever down time they can find with the sights, sounds and tastes of the nation’s capital.

Click the image for more information from the official tourism site of Washington, D.C.

Of course, you’ll only need to know when the cherry blossoms peak if you’re coming to the conference: Click here to register…or here for more information…then register.

Engage the Speakers

As the ARSA team enters its final month of planning, confirmed speakers are now being added to each component of the conference’s four days of content. This year’s participants, speakers and panelists include representatives from the FAA, EASA, ANAC Brazil and Transport Canada in addition to officials from the U.S. Departments of State and Transportation and the Government Accountability Office. As usual, the association’s premier event will explore the corners of the aviation policy world.

The public agenda can be reviewed – and will continue to be updated  – on the event page. Keep track of who will be featured at the conference, share your thoughts on what should be discussed and reserve your spot to take part with them.

Of course, you only get to hear from and speak with key industry personnel if you’re coming to the conference: Click here to register…or here for more information…then register.

Salute the Sponsors

Thank you to the organizations that have stepped up support the repair station community’s premier event: ARSA’s 2019 Annual Conference. These companies are the perfect demonstration of the aviation world’s shared commitment to both good safety and good business (to learn more about a sponsoring organization, click the appropriate logo). There’s still time to join them: Learn more in the “Sponsorship Opportunities” tab on the event page.

Platinum Sponsors

Gold Sponsors

Silver Sponsors

Make sure you benefit from the investment of these industry leaders, click here to register…or here for more information…then register to attend the conference.

Attend the Annual Member Meeting

The ARSA Annual Member Meeting is held annually in conjunction with the Annual Conference; this year it will take place during the Breakfast and Annual Report on Friday, March 15 at 8:00 a.m. at the Ritz-Carlton, Pentagon City in Arlington, Virginia.

ARSA President David Latimer will address members regarding the state of the association. After Latimer’s presentation, attendees are welcomed and encouraged to discuss matters relevant to the association.

If you are unable to attend – conference registration is open – but would like to submit comments/questions to ARSA’s board, please use the form on arsa.member365.com/sharingnetwork/inquiries.

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ARSA Works

What ARSA Has Done Lately – Fourth Quarter 2018

Each quarter the board of directors receives reports on the association’s activities. Step into a board member’s shoes by reviewing the operations, legislative and regulatory reports highlighting advocacy on behalf of aviation safety between September and December 2018:

Meetings

• 3: Brett briefed the National Air Carrier Association (NACA) Maintenance Council during its meeting at NACA’s office in Arlington, Virginia.
• 4: Sarah participated in Southwest Airlines’ Audit Summit in Dallas, Texas.
• 17: Christian participated in a meeting on Brexit with UK CAA officials coordinated by the Aerospace Industries Association (AIA) at its office in Arlington, Virginia.
• 24: Christian and Sarah coordinated a meeting at ARSA’s offices of members concerned about manufacturer maintenance manual practices.
• Oct 30: Christian and Sarah coordinated a conference call for ARSA’s ad hoc working group on DoD acceptance of FAA approvals.
• 8-9: Marshall participated in the MMT (maintenance quadrilateral group) in Brasilia, Brazil.
• 13: Marshall participated in EASA’s Engineering & Maintenance Technical Committee (EM.TEC) meeting in Cologne, Germany.
• 19: Brett and Christian hosted AAR government affairs representative Colin Geraghty for lunch.
• 27: Christian attended a reception and panel discussion at the Austria Embassy about the future of transatlantic aviation relations.
• 4-5: Brett attended the Joint Services AMT Certification Council (JSAMTCC) meeting at FAA Headquarters at L’Enfant Plaza.
• 6: Christian participated in the TSA Aviation Safety Advisory Committee meeting.
• 6: Christian met with representatives of the Aviation Mechanics Fraternal Association.
• 10: Marshall participated in the December meeting of the Safety Oversight and Certification ARC Meeting at AIA offices in Arlington, Virginia.
• 11-13: Sarah co-chaired the first ARAC 145 Working Group meeting.
• 13: Sarah participated in the quarterly ARAC meeting.

Online Training

Created eight hours of new online training:

• What is an Appliance: A Lesson in Reading 14 CFR (Three 15-minute sessions recorded together with “hand-picked” audience and released as on-demand recordings)
• Part Marking – Part 45 and More
• Human Factors in Context
• Human Factors Overview – The Dirty Dozen
• The Dirty Dozen in Depth – Communication
• After the Audit, Before the LOI
• Receiving & Responding to an LOI
• Responding to a Notice of Proposed Civil Penalty

Regulatory

• Attended and reported on an October briefing by UK CAA on efforts to minimize disruptive impact of the country’s scheduled exit from the EU (Continued coverage and instruction including multiple “Legal Briefs” and continued maintenance of Brexit Issue Page.)
• Filed amicus brief to the U.S. Court of Appeals for the District of Columbia Circuit to support the “plain language of the minimum standards of the aviation safety regulations and the intent of those rules” in Kornitzky Group, LLC v. Daniel K. Elwell.
• Participated in the November Maintenance Management Team meeting in Brasilia, Brazil. Urged the MMT authorities to work toward full mutual recognition of each other’s maintenance organizations and discussed FAA-EASA MAG 6, the FAA-ANAC Brazil MIP, revisions to the TCCA-FAA MIP and potential complications of Brexit.
• Released a members-only toolkit providing a draft petition for exemption – and instructions for its submission – from the requirement under 14 CFR § 145.109(d) that repair stations have “current” manufacturer’s data available even when it is not needed and will not be used.
• Participated in the November EASA Engineering & Maintenance Technical Committee Meeting in Cologne, Germany. Discussed EASA FAQ on “occasional line maintenance,” potential Brexit implications, progress of EASA ICA NPA and the New Basic Regulation.
• Co-chaired first meeting of the working group tasked through ARAC to review and reconcile repair station regulations and guidance (the 145 Working Group).
• Submitted revision to repairman guidance to align with the plain language of the regulation for FAA consideration.

Legislative

• Succeeded in including ARSA objectives in FAA bill (see table above) and preventing anti-repair station regulatory mandates.
• Completed comprehensive analysis of FAA bill to identify implementation priorities.
• Coordinated facility visits and/or in-person ARSA PAC check presentation meetings with Reps. Carlos Curbelo (R-Fla.), Don Beyer (D-Va.), Greg Stanton (D-Ariz.) and Ted Budd (R-N.C.).
• Met with House Armed Services Committee staff regarding DoD regarding use of FAA approvals for commercial derivative aircraft maintenance.
• Identified and contracted with new congressional database service provider (CQ/Knowlegis).
• 2019 objectives:
  • Initiate campaign to obtain appropriations for technician grant program.
  • Introduce aviation maintenance industry to new members of Congress.
  • Conduct successful Legislative Day.

ARSA Remembers – Tony Broderick (1943-2018)

Anthony J. “Tony” Broderick Jr., the long-time voice for good government, reasonable safety oversight and wise leadership in the aviation industry, died on Dec. 30, 2018 in Bealeton, Virginia. He was 75.

Born in New York on Feb. 23, 1943, Mr. Broderick grew up in Levittown and graduated from Saint Bonaventure University in 1964 with a Bachelor of Science degree in physics. He then spent seven years in the private sector developing optical systems before joining the Department of Transportation’s Volpe Center in Cambridge, Massachusetts in 1971. Mr. Broderick’s work in several areas, including ozone reduction, led him to join the FAA in 1976, relocating his family to Warrenton, Virginia.

Tony spent the majority of his agency career in the FAA’s regulation and certification organization, playing a central role in several major regulatory initiatives. He helped develop international audit standards and regulate extended and polar operations while serving as the regulator’s clear voice for sensible interpretation of the aviation safety rules. He left the government in 1996, racking up countless personal honors and awards – including an Aviation Week & Space Technology Aerospace Laurel and later an Aviation Week-Flight Safety Foundation Distinguished Service Award as well as Flight International’s Aerospace Personality of the Year in 1995 – and later served as a technical advisor for a number of industry leaders before retiring in 2014.

“Tony possessed a unique combination of intelligence, dedication and honesty at the FAA’s highest-level career safety position,” said ARSA Managing Director and General Counsel Marshall S. Filler. “His decisions were almost always about the data even as the politics of aviation safety swirled around him. It is his example on which ARSA’s insistence on ‘good government’ is based.”

Tony is survived by wife; Sylvia; his children, Sean and Pia; his grandchildren, Isabelle and Magdalena; his sisters, Penelope and Christine; his brothers-in-law Jimmy and George, and numerous extended-family members. Sean has become known for his own work as a voice for the aviation industry, serving countless industry stakeholders and watchdogs including the American Association of Airport Executives, the Aviation Week Network and boutique marketing firm MKD Strategic, which he founded in 2016. Notably, Sean ran ARSA’s communications department in 2006 and remains a trusted resource, regularly reporting on the association’s support of the aviation community.

ARSA extends its condolences to the Broderick family and thankfulness to Tony for a life spent in service to his community, the aviation world and the global flying public.

To view Tony’s full obituary, visit: www.fauquiernow.com.

Those wishing to express their condolences and appreciation for Mr. Broderick’s life are encouraged provide a donation to Blue Ridge Christian Home, 7034 Catlett Road, Bealeton, Virginia 22712, or a memorial donation in his name to the Alzheimer’s Association.

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Legal Briefs

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

Court Questions Falsification in Kornitzky Case

By Christian A. Klein, Executive Vice President and Brett Levanto, Vice President of Operations

On Jan. 11, the U.S. Court of Appeals for the District of Columbia Circuit heard oral arguments in Kornitzky Group v. Daniel Elwell. The hearing considered the appeal of a National Transportation Safety Board Order revoking the repair station certificate of AeroBearings, L.L.C.

The order alleged falsification of multiple maintenance releases based on incomplete information in block 12 of FAA Form 8130-3. During the original proceedings, the inspector agreed there was no false or incorrect information in that block on any of questioned forms; the entries were simply incomplete. However, the Board found falsification based upon that fact that information was omitted.

In October 2018, ARSA filed an amicus brief in support of “the plain language of the minimum standards of the aviation safety regulations and the intent of those rules” in the case’s adjudication. The association’s brief covered several regulatory topics, in particular the “logical distinction between a complete maintenance record and a maintenance release.”

Shortly into the presentation by Christopher Richard Stevenson, counsel for the FAA, Judge Harry Edwards asked how the actions described in the NTSB’s order amounted to falsification under 14 CFR 145.12(a) rather than omission, which if performed knowingly to conceal facts would be covered by 145.12(b):

“I understand where you might go with [the falsification argument]…What is it that you think took [the omissions on the 8130s in question] to a higher level? It seems you’ve written 12(b) out of the regulations,” Edwards said, noting that under this line of reasoning, omission would amount to falsification in every case.

That simple question began a long exchange – far exceeding the ten minutes originally allotted to Stevenson – during which each of the three judges expressed skepticism regarding the falsification charge. They alternated asking Stevenson questions regarding the lack of intentionality (Judge Sri Srinivasan) and the information that was accurately provided on AeroBearings’ records (Judge A. Raymond Randolph).

As the discussion closed, Judge Edwards returned to his original question with continued skepticism. “What’s the international falsehood?” he asked. “I’m still missing it. In fact, I’m further away than when I first asked.”

It’s not known when the Court will rule in the case, but there are several possible outcomes. The court could uphold the NTSB decision. Although that would be bad for the company involved, it would not set a precedent beyond the facts and circumstances of the case at bar because the regulations are still clear about recordkeeping requirements. The court could also throw out the falsification argument and remand the case to the NTSB for further action consistent with the court’s decision.

To listen to a recording of the oral arguments, click here.

To read ARSA’s amicus brief, click here.

Stay tuned for the release of the court’s opinion on the case.

Clarifying “Accountability” Related to Falsification Case

ARSA is aware that the owner of AeroBearings has sent an email to “accountable managers” of numerous repair stations, including quite a few members. ARSA does not have a current relationship with the company or its owner; although the company was, at one time, a regular member. The association has no comment or observations regarding the information provided by AeroBearings or its owner. The association focuses on educating members on the legal process, which does not necessarily equate to justice.

To that end, ARSA filed an amicus brief with the appellate court to explain the law and practical ramifications of upholding the National Transportation Safety Board’s determination that “omitting” information from the approval for return to service document required by section 145.219(b) can constitute intentional falsification of maintenance records. ARSA team members attended the oral argument and will update the membership on the outcome of the matter.

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ARSA on the Hill

FAA Oversight Committees Take Shape

By Christian A. Klein, Executive Vice President

The U.S. government shutdown might have dominated the news over the past month, but behind the scenes the House and Senate were preparing to legislate over the next two years.

The Democratic takeover of the House added drama since chairmanship of all House committees must move from R to D. Although the GOP maintained control of the Senate, there’s still reshuffling.

ARSA prioritizes engagement with the House Transportation & Infrastructure and Senate Commerce, Science and Transportation Committees, which have jurisdiction over FAA. Although Congress enacted a new, multi-year FAA reauthorization law in 2018, the committees play an important role in shaping FAA policy and implementation of the new law, so it’s critical that these important panels know the role contract maintenance providers play in the economy.

As expected, Sen. Roger Wicker (R-Miss.) is the new chairman of the Senate Commerce Committee and Sen. Maria Cantwell (D-Wash.) will be the panel’s ranking Democrat. The Senate aviation and space subcommittee will be led by two members from states with a high concentration of repair stations. Sen. Ted Cruz (R-Texas) will chair the subcommittee and Sen. Kyrsten Sinema (D-Ariz.) will serve as its ranking member. The subcommittee’s other members for the 116^th Congress are:

Pieces are falling into place on the House side of Capitol Hill. Rep. Peter DeFazio (D-Ore.) is the T&I Committee’s new chairman. Given Chairman DeFazio’s past criticism of contract maintenance, we expect the repair station industry and FAA’s oversight to come back under scrutiny. The committee’s ranking Republican, Rep. Sam Graves (R-Mo.), is a pilot and aviation enthusiast who was the lead House sponsor of the legislation that created the new aviation workforce development grant program. Rep. Rick Larsen (D-Wash.) will be chairman of the House aviation subcommittee and Rep. Garret Graves (R-La.) will be ranking member. The T&I Committee announced 24 additional members for the 116^th Congress, most of whom are new to Capitol Hill:

Note: As the hotline went to press, the T&I Committee announced subcommittee assignments.  The committee’s press release is here: https://transportation.house.gov/news/press-releases/house-committee-on-transportation-and-infrastructure-holds-organizational-meeting-. The legislative team will take an in-depth look at the subcommittee’s composition next month.

In the weeks ahead, ARSA will be reaching out to these members of Congress to introduce or reintroduce the aviation maintenance industry. Members must also engage in the effort to educate about the industry’s value.

ARSA Kicks off Campaign to Fund Workforce Grant Programs

One of the association’s signature achievements last year was getting Congress to create a new program to recruit and train aviation maintenance technicians. The coalition ARSA built to get the program into law now must get funding through the appropriations process so the Department of Transportation can start providing grants.

First, President Trump must be convinced to include money in the administration’s proposed budget, which will be sent to Congress in February. The association gathered its coalition partners – added new organizations – and sent a letter to the White House and the secretary of transportation in support of both the technician and pilot programs.

Once the president’s budget is released, the focus will shift to the House and Senate appropriations committees, which control federal purse strings. Appropriators are preoccupied trying to work out a deal to fund the government for the rest of FY 2019 and prevent another shutdown, so the FY 2020 appropriations process will start later than usual. While the “deadlock” provides industry more time to build visibility and support, the clock is ticking.

Even with momentum and a growing group of allies, victory is far from certain. Given the growing federal budget deficit, money is tight and we’ll have to make a strong case for our programs being more deserving of funding than others.

Look for more information from ARSA about how you can help move the ball forward. In the meantime, register for ARSA’s Legislative Day on March 13 and join your industry colleagues in making the case for grant program funding and other maintenance industry priorities with your representatives and senators.

All Systems Go for ARSA Leg Day 2019

On March 13, maintenance industry leaders will converge on Capitol Hill for ARSA’s 2019 Legislative Day, part of the association’s Annual Conference.

During the congressionally-focused event, ARSA will give the association’s 2019 Legislative Leadership Award jointly to Reps. Sam Graves (R-Mo.) and Dan Lipinski (D-Ill.). These two senior members of the House Transportation & Infrastructure Committee the lead House cosponsors of legislation to create the new aviation technical workforce grant program (see “ARSA Kicks Off…” in this edition for related updates).

Throughout the day, ARSA will coordinate meetings with influential members of Congress and congressional staff while attendees participate in meetings with their home-state representatives and senators. During a luncheon in the Dirksen Senate Office Building, CAVOK will unveil the industry’s economic footprint.

Given all the new members of Congress and staff changes in recent weeks, it’s important for ARSA members to be part of the association’s advocacy for the maintenance industry. Click here for more information and to register now.

If you have questions about Legislative Day, please contact ARSA Executive Vice President Christian Klein at christian.klein@arsa.org.

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Regulatory Update

Managing a Shut-down Government

For 35 days, the partial shutdown of the U.S. federal government dominate the news – both political and mainstream. As the January hotline goes to press, the government is open (for now). The association is moving on by considering how its members can best fortify themselves against future interruptions in the FAA’s work (see “Sarah Says” in this edition). Doing so means making sense of what happened.

Review ARSA’s January coverage (with slight edits):

Shutdown Update: Part 145 EASA/FAA Certificate Extensions

January 30, 2019

The association received an exchange of letters between the FAA and EASA on how the agencies have agreed to issue part 145 extensions – the U.S.-based repair station members impacted by the shutdown should be informed of the extension by email.

If your company is impacted, and is (1) not one of the listed companies and/or (2) did not receive an email from EASA, please let the association know of any issues. EU-based repair stations should be receiving new certificates as promised; however, if a member company is having any issues, contact ARSA.

To review the letters and the FAA-provided list of affected repair stations, click here.

For assistance, contact ARSA using the member portal.

Another MAG Mess

January 14, 2019

Having heard on Jan. 14 the FAA was in the process of recalling aviation safety inspectors to work for no pay while wrangling over the government shutdown continues, ARSA sent an urgent message to key personnel in the FAA and EASA regarding continuity of certificates under the U.S.-EU bilateral agreement and Maintenance Annex Guidance. In the communication, ARSA Managing Director & General Counsel Marshall S. Filler suggested how the agencies could handle repair station/approved maintenance organization certification issues until the full restoration of U.S. government funding. 

The full text of Filler’s message was shared with ARSA members via direct alert on Jan. 14. Any member who did not receive the alert should contact Member Information Manager Kimberly Dimmick for assistance with database updates.

ARSA, Allies Urge End to Shutdown

January 10, 2019

On Jan. 10, ARSA joined other leading aviation organizations in calling on President Trump and Congress to reopen the federal government and end the shutdown that had lasted since Dec. 22, 2018. In a letter sent to executive and legislative branch leaders, the groups described how the shutdown hampered the $1.5 trillion civil aviation sector from functioning effectively.

The letter, which was coordinated by Airlines for America, detailed a range of negative impacts including on FAA staffing and morale, training for air traffic controllers, new aircraft certification and deliveries, renewal of European Aviation Safety Agency repair station approvals, pilot certification, mechanic testing and airport construction project approval. It also highlighted the personal hardship for the Transportation Security Administration and Customs and Border Protection employees upon whom the functioning of the aviation system depends and who were being forced to work without pay.

“Our elected leaders need to understand their political standoff has real world consequences for workers, companies and the economy,” ARSA Executive Vice President Christian A. Klein said of the industry-wide effort the reopen the government.

“The FAA has suspended certification of mechanics, repairman and repair stations, as well as other oversight work. Delays in getting new approvals or certificates can mean missed business and career opportunities and lost revenues. It’s only a matter of time before those impacts ripple through the workforce, affect air carrier operations and harm the local economies where repair stations are located,” Klein said.

To read the complete letter, click here.

In addition to ARSA and A4A, the following organizations – most of which have become regular working allies of the association through its regulatory and legislative advocacy – signed the letter:

The Shutdown – Who’s Working?

January 8, 2019

The Department of Transportation published information about which FAA functions were supposed to continue and which were to be suspended. Off the 24,208 FAA employees working without pay during the shutdown because their function is essential to “life and safety,” almost all (23,856) work in air traffic control; an additional 216 work in the Office of Aviation Safety, 61 work for the Office of Security and Hazardous Materials and 75 are in miscellaneous positions within the agency.

To review the agency document, click here.

According to the DOT summary document, aircraft certification services were to continue during the shutdown, but on a limited basis (no explanation was provided of what “limited” meant). Although “Flight Standards field inspections” are a function that would continue as exempted activity during the appropriations lapse, DOT noted that just “[o]ne manager per facility is excepted and inspectors are recalled over time; [f]acility manager will recall inspectors as necessary to maintain safety of the system.” FAA activities that were clearly suspended include airman certifications and rulemaking.

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

Full [ARSA] Exposure at IATA Legal Symposium

On March 8, ARSA Executive Director Sarah MacLeod will join other experts in aviation law for the International Air Transport Association’s (IATA) 2019 Legal Symposium in Rome, Italy. MacLeod will lend her insight to a panel discussion offering “full exposure” of the agreement between IATA and CFM International to increase engine maintenance competition.

Click here to go to the event webpage.

As described on its website, the legal symposium “is the world’s premier annual aviation law event, with a reputation for insight, relevance and value among in-house counsel, private practitioners and government lawyers alike.” Continuing ARSA’s long-established relationship with the international association, MacLeod will add her name to the list of “outstanding speakers” promised by the event’s organizers.

ARSA encourages members, allies and other aviation stakeholders with interests in international regulatory issues – particularly related to the availability of maintenance manuals – to consider joining the proceedings. For those unable to make the trip to Europe, participants in the March 12 Executive to Executive Briefings arranged as part of the ARSA Annual Conference will attend an IATA briefing on the CFMI agreement (click here to learn more about how to attend the Annual Conference).

Stay tuned for updates on MacLeod’s travels and insights shared (and gained) through her participation.

Klein, Levanto Complete Hour-Long European Tour

On Jan. 23, ARSA’s Christian A. Klein and Brett Levanto briefed the Embassy Aviation Attaches Assembly at the Royal Netherlands Embassy in Washington, D.C. The body, which meets regularly, is composed of policy representatives from the embassies of 35 countries as well as delegates from EASA and the European Commission (EC).

The ARSA team was invited to review and lead discussion on key issues facing the international aviation community. In their presentation, Klein and Levanto reviewed the state of the global industry, highlighted key points raised by ARSA members through the association’s various surveys and then helped delegates explore matters related to the 2018 FAA reauthorization law, international regulatory coordination, tariffs, Brexit and the partial shutdown of the U.S. federal government.

Taking advantage of Washington’s centrality to international aviation issues, the assembly provides a venue for the association to share insight and receive feedback from international government representatives in a personal setting. An ARSA team last addressed the body in 2014 related to the association’s efforts to assist the FAA with a congressionally-mandated rulemaking regarding international drug and alcohol testing. By continuing as a trusted source for information, the association renewed its value to the group whose members typically rotate off to other assignments every three to five years.

To review the presentation, click here.

If you have questions regarding international aviation policy engagement, click here to contact ARSA.

Training

Preparing for, Receiving & Responding to an LOI or NPCP

Produced at the end of 2018, these three online training 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 penalties. This process begins before an official letter or notice is received – a process known around ARSA as “prophylactic lawyering.” 

After the Audit and Before the LOI

Instructors: Sarah MacLeod, Christian A. Klein & Brett Levanto
Description: This session reviews the regulations, policies and procedures that generate letters of investigation and the best methods for responding to governmental questions.
Click here to register and get access for 90 days.

Receiving & Responding to an LOI

Instructors: Sarah MacLeod, Christian A. Klein & Brett Levanto
Description: This session reviews the regulations, policies and procedures that generate letters of investigation and provides some best practices for developing and delivering responses.
Click here to register and get access for 90 days.

Receiving & Responding to an NPCP

Instructors: Sarah MacLeod, Christian A. Klein & Brett Levanto
Description: This session reviews the regulations, policies and procedures that generate notices of proposed civil penalties and provides some best practices for developing and delivering responses.
Click to register and get access for 90 days.

Click here to purchase all three “prophylactic lawyering” sessions together and save.

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.

Three Sessions on Human Factors

ARSA is growing its library of human factors-related training sessions. The first three, which introduce key aspects of human factors in aviation maintenance, are now available for immediate on-demand viewing: 

Human Factors in Context

Instructors: Sarah MacLeod, Christian A. Klein & Brett Levanto
Description: This session provides a general introduction to “human factors” and puts their consideration into an aviation context. It reviews the general definitions and key components of human factors understanding and reviews the rules and guidance on the subject from various aviation regulatory and oversight organizations.

Click here to register and get access for 90 days.

The Dirty Dozen – Human Factors Overview

Instructors: Sarah MacLeod, Christian A. Klein & Brett Levanto
Description: This session introduces the “Dirty Dozen,” 12 common factors that impact human performance. It discusses these in the context of the aviation maintenance industry, describes how they lead to problems, suggests ways to mitigate consequences and explains how all 12 are interconnected.

Click here to register and get access for 90 days.

The Dirty Dozen In Depth – Communication

Instructors: Sarah MacLeod, Christian A. Klein & Brett Levanto
Description: This course discusses communication in the aviation maintenance environment, factors that can interfere with communication and ways to mitigate those factors.

Click here to register and get access for 90 days.

Click here to purchase all human factors content together and save.

The association will continue to expand its human factors-related session offerings in 2019. Stay tuned to this page.

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, PLC, the firm that manages ARSA. To go directly to OFMK’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.

Part Marking

Instructors: Sarah MacLeod, Christian A. Klein & Brett Levanto
Description: This session outlines the basic rules for aviation part marking and identification and reviews applicable guidance as it pertains specifically to the re-identification of parts while performing maintenance. It introduces the key requirements of 14 CFR part 45, Identification and Registration Marking.

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, PLC, the firm that manages ARSA. To go directly to OFMK’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.

Regulatory Compliance Training

Test your knowledge of 14 CFR § 65.92 – Inspection authorization duration.

Click here to download the training sheet.

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Membership

Serving Through Survey Responses – Oliver Wyman and ARSA

Oliver Wyman’s annual MRO survey’s response deadline has been extended. The global consulting firm has surveyed members of the maintenance, manufacturing, airline and aviation finance communities for more than a decade.  Through its partnership with ARSA – which produces the association’s annual market assessment – the survey team is inviting repair stations to participate.

The survey is open for responses until Feb. 12. Use the link below to access it and submit your response today.

Responding to Oliver Wyman’s questionnaire is the perfect warmup for ARSA’s Annual Member Survey – the first invitation will be delivered to the inboxes of all primary contacts during the week of Feb 11.

The entire aviation community, including ARSA and its members, benefits from good data. The time taken to respond is an investment that moves the industry forward:

(1) To access Oliver Wyman’s MRO Survey and submit your response, visit: https://oliverwyman.co1.qualtrics.com/jfe/form/SV_5jYWgaXl3LTp8aN. Direct any questions to the research team at MROsurvey@oliverwyman.com.

(2) Ensure the invitation for ARSA’s member survey will make it to your primary contact and that it gets the attention it deserves. (If you don’t know who the primary contact is, we can help.) Help your company submit its response. Direct any questions to brett.levanto@arsa.org.

The 2019 Global Fleet & MRO Market Assessment, prepared by Oliver Wyman, will be unveiled in March during ARSA’s Annual Conference. Click here to register now.

AMS Update – Event Registration

ARSA is collecting registrations for the 2019 Annual Conference – the Executive to Executive Briefings, Legislative Day and the Annual Repair Symposium – through its new secure online portal. The events team is learning about the system with every registration.

Here’s what you need to know to submit a registration form:

(1) Open the registration link by clicking here.

(2) The general event screen will open. Click the green “register now” button in the upper right corner.

Click to enlarge.

(3) If you are not logged in a prompt will appear asking for your email OR for you to indicate you are a member (which you should do). Then log in to the online portal using the email address that is associated with your membership (if you don’t know your password, click “Forgot you password?” to gain access).

(4) The event registration page will load, displaying all of the “tickets” associated with the event:

Click to enlarge.

First is each level of sponsorship – Platinum, Gold, Silver, Supporter, Contributor – interested sponsors may make their commitments through this registration process and immediately reserve the complimentary E2E Briefings (March 12) and Legislative Day (March 13) tickets available to them (see the “Sponsorship Opportunities” tab on the public event page to learn more).

Following the sponsor options come the tickets associated with direct registration for Legislative Day (March 13), the Annual Repair Symposium (March 14) and guests to the Club Lounge Happy Hour (March 14) as well as the selection of breakout sessions (March 15).

To reserve any kind of ticket, use the drop-down menu to the right of that ticket to indicate the number you wish to purchase. You will not be able to select a complimentary ticket without also having selected the associated sponsorship ticket.

Click “Continue to Step 2.”

(4) In the popup screen, review and confirm your ticket purchase selections.

(5) On the subsequent screen, click the green button to the right of each ticket in order to assign a registrant to that ticket. You do not need to take this step immediately, but may simply click “Continue” at the bottom of the screen to move on.

If you click “Assign Ticket,” a prompt will appear asking you to indicate that the ticket is yours, search the member database to assign it to another member or input the someone else’s information. Since you will be reserving member-priced tickets using this process, you may not enter the name of someone who does not represent an ARSA member organization. Contact Caroline Kneip (caroline.kneip@arsa.org) for help with contacts not listed in the database.

(6) Once you’ve assigned the ticket, you will be able to indicate your attendance at the meals associated with your registration by checking the appropriate boxes. Only indicate that you will attend a meal if you have registered for the associated portion of the conference (I.e., If you are only registering for legislative day, you should only indicate you will attend meals held as part of that event).

After making your meal assignments, click “Save.”

(7) When you have completed assigning all of your tickets, click “Continue.”

(8) On the payment screen, review your registration before selecting your payment method. When you click “Process Payment” you will either be directed to complete your credit card transaction or instructed the registration process is complete. If you indicated you would pay by check or ACH/wire transfer, you will be able to download a copy of your invoice/receipt for payment.

If you have questions or issues at any time during the registration process, contact Caroline Kneip (caroline.kneip@arsa.org).

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 January:

New Members (Member Category)

Mr. Warren Romine, Affil
Overhaul Accessory Inc., R02

Renewing Members (Member Category, 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

Quick Question – “The Opening Salvo”

Each year during the symposium portion of ARSA’s Annual Conference, Managing Director & General Counsel Marshall S. Filler and Executive Director Sarah MacLeod moderate an “opening salvo” session on maintenance and certification issues. The discussions, which have evolved into a two-plus hour intensive exploration of all regulatory matters impacting the maintenance community, is the cornerstone of the symposium’s value to the repair station community: direct engagement with international aviation authorities.

Filler and MacLeod have once again confirmed participation from the FAA, EASA, ANAC and Transport Canada – the aviation world’s quadrilateral group will be represented with ARSA in the nation’s capital. Aviation professionals should be planning their attendance (click here to register and for accommodation information) and should take a moment to help the association prepare by providing insight:

If the embedded survey does not appear/load, open the survey independently by visiting https://www.surveymonkey.com/r/ARSAConf-OS: 

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

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

Conference 2019 – See What Happened

A Member Asked…

The following member question was submitted on Jan. 11, 2019, at the time the partial shutdown of the U.S. federal government – which caused a lapse in FAA funding – was in its 20^th day.

Q: My EASA 145 Approval Certificate is nearing expiration and I am not able to communicate with my local FSDO or PAI (due to the government shutdown) in order to proceed with the renewal. I have emailed the EASA directly, but they claim nothing can be done until they hear back from the FAA on this issue. If EASA does not hear back from the FAA, then my EASA Approval is going to expire and I cannot issue dual release 8130s past that date. Are any other ARSA members facing this same situation and/or what does ARSA suggest? I am just looking for any way possible to keep our EASA approval current. Not being able to issue dual release 8130s would be detrimental to my small business!

A: We are working on it!

Note: The association engaged with both agencies as they worked to issue extensions for certificates impacted by the partial U.S. government shutdown. See just how ARSA “worked on it” in this edition of the hotline – particularly the Regulatory Update – and at arsa.org/shutdown.

Member questions should be submitted through the inquiry system run through ARSA’s new online member portal. Members can use their portal access to submit inquiries by logging in through arsa.member365.com/sharingnetwork.

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 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.

ICA Issue Page

Since its inception, ARSA has worked to ensure that basic safety information (i.e., Instructions for Continued Airworthiness [ICA], including component maintenance manuals [CMM]) is made available at a fair and reasonable price to operators, maintenance providers, and any other person required by 14 CFR to comply with those instructions. ICA Issue Page (Updated)

Brexit Resource Page (Updated)

On June 23, 2016, citizens of the United Kingdom voted to withdraw from the European Union in a national referendum. This page is provided as a resource for the aviation maintenance community regarding transition negotiations between the British government and the European Commission. Brexit Resource Page (Updated)

Careers In Aviation Maintenance

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.

Quick Question Archive

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.

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