2019 – Edition 9 – October 4

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
ARSA Works
Legal Brief
ARSA on the Hill
Getting Facetime
Training
Membership
Resources
Industry Calendar

Sarah Says

Feeling the Bern?

By Sarah MacLeod, Executive Director

For those that have not read the letter senator and presidential hopeful Bernie Sanders wrote to Doug Parker, CEO of American Airlines, you need to do so now. If its content and tone don’t convince you that repair stations will once again face negative legislative policy that will directly impact your bottom line, you will be in the fire soon.

The response in the link above and this month’s ARSA on the Hill articles provide the aviation industry, and particularly repair stations, the tools and ammunition to fight the negative images created by misleading and downright false information. Facts and data from individual companies can prevent and will at least lessen legislative mandates that will directly impact the ability to offer aviation design, production and maintenance services worldwide.

In case anyone needs reminding, aviation is an international market and the country of registry controls the maintenance. Aviation maintenance providers must be able to service aircraft and parts wherever they fly or are located in the world. For any repair station to stand by and let more and more unnecessary barriers be erected in the name of safety is disgraceful and frankly, irresponsible. The business of aviation maintenance must be recognized as the essential economic driver it is and the story must be told by every viable repair station.

ARSA has made it extremely easy to become involved—all the tools needed to get your story in front of congressional representatives and senators can be found on the association’s website: arsa.org/legislative/get-involved. You don’t have to be a member to use the resources; in fact, every member should not only use the tools, but also forward the link to every other maintenance provider they know.

Sitting on our hands and complaining about how the legislators and media beat up on the safest form of transportation does not stop the “Bern” or any other fear mongering source from pouring on the heat. It is time to fight fire with fire and burn away the false image of aviation safety being lessened by contract maintenance.

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ARSA Works

Act Now

Association members, allies and industry colleagues must support ARSA’s current initiatives to improve aviation policy. Here’s your to-do list for October 2019 (click each page link for more information and instructions):

Help an ARSA-led coalition get money from Congress for technician workforce grants…

Grant Funding in the Works, Needs Help
On Sept. 19, the Senate Appropriations Committee passed its version of the 2020 Transportation, Housing and Urban Development and Related Agencies (T-HUD) appropriations bill. It included a total of $5 million in funding for both the technician and related pilot education grant programs authorized in last year’s FAA law – half of the total authorized level. In June, the House version included full funding for both programs ($10 million total).

Use a good, but too-well hidden, example from the FAA as a model for engaging with local students…

Aviation STEM Events Can’t Be Hidden Gems
On Sept. 26, the FAA’s Aviation Safety Office (AVS) hosted its second STEM Careers Symposium at the agency’s headquarters in Washington, D.C. The event brought hundreds of local middle and high school students from the nation’s capital to 800 Independence Avenue for demonstrations, presentations and exhibits on aviation careers, skills and the government’s oversight of U.S. airspace.

Update the data powering one of the industry’s most-important workforce projections…

Help Define Current Maintenance Workforce and Its Needs
The workforce crisis is already reality for those maintenance providers already struggling to find and retain technical talent. Given the continued, pressing need for attention, Oliver Wyman is working to refresh its analysis by expanding the the reach of its data assessment and is calling on the maintenance community for assistance by providing current employee demographic information.

Help Define Current Maintenance Workforce and Its Needs

In 2017, ARSA’s Global Fleet & MRO Market Assessment included vital projections regarding the maintenance technician workforce supply issues. The analysis by Oliver Wyman, which indicated AMT demand would exceed supply by 2022 and fall nine percent short by 2027, provided the association, its allies and members with a key talking point in the effort to attract attention to the issue. That effort resulted in the successful industry-wide campaign to get Congress to authorize a workforce grant program.

The workforce crisis is already reality for those maintenance providers already struggling to find and retain technical talent. Given the continued, pressing need for attention, Oliver Wyman is working to refresh its analysis by expanding the the reach of its data assessment and is calling on the maintenance community for assistance by providing current employee demographic information.

Here’s how to help:

(1) Download a copy of Oliver Wyman’s data collection spreadsheet by clicking here (Excel file will download from your browser).

(2) Complete the spreadsheet’s applicable data tabs to the extent possible, consistent with your company policies. Companies with large populations can shorten entries by grouping employees with nearly identical demographics and indicating how many people are covered in the line.

(3) Send all questions, responses and completed files as attachment to AviationMarketIntelligence@oliverwyman.com with a CC to arsa@arsa.org.

Oliver Wyman has set an Oct. 31 deadline for data submission.

For more information and resources illustrating the maintenance industry and its needs, visit ARSA’s Data & Advocacy page.

ARSA SMS Comments Focus on Micromanagement, Due Process

ARSA filed comments on Sept. 6 in response to European Aviation Safety Agency (EASA) Notice of Proposed Amendment (NPA) 2019-05, Embodiment of safety management system (SMS) requirements into Parts 145 and 21 of EASA’s rules.

The proposed changes would initially apply only to approved maintenance organizations within the European Union and to those outside the EU regulated directly by EASA (i.e., not to facilities that hold certificates pursuant to a bilateral aviation safety agreement). However, it’s likely SMS will become a “special condition” required by EASA for AMOs holding certificates through a bilateral. It’s therefore important for repair stations serving European customers to be aware of the potential rule changes, regardless of where located.

ARSA told EASA that the association shares the agency’s objective of improving aviation safety and generally supports encouraging AMOs to adopt SMS policies. The association also commended EASA for recognizing the complexity associated with managing compliance within companies with multiple certificates and that a one-size-fits all solution is inappropriate for a diverse industry made up of companies with various sizes and specialties.

However, ARSA is concerned that certain provisions of the NPA run contrary to the philosophy underlying SMS, suggest a lack of confidence in the systems required by the new rules, would create new and unnecessary burdens for certificate holders and regulators and would potentially undermine safety. For example, the proposed regulation would require certificate holders to obtain prior approval by the competent authority for many types of organization changes, including personnel involved in safety management.

ARSA believes a fundamental concept underlying SMS is that safety depends on the organization and its processes, not individuals. “Requiring the regulator to approve personnel changes made in accordance with the company’s SMS defeats the purpose of the system and the proposed regulatory changes,” ARSA said.

“It is the company’s responsibility, not that of regulators, to manage operations and make decisions about who is best suited to ensure compliance, safety and the company’s success. If the company has properly designed and implemented its SMS, the new employees appointed to key positions should be presumed qualified and trained.”

ARSA said the new approval requirements “would give regulators unprecedented authority over internal personnel changes, diverting competent authority resources and undermining the ability of certificate holders to manage their businesses on a daily basis. Finally, by requiring the regulator’s approval of personnel changes, the new rule will undermine safety by thwarting a company’s ability to remove a team member whose acts or omissions run contrary to the company’s SMS.”

ARSA’s comments also expressed other concerns, including that expanded occurrence reporting requirements are too broad leading to over-reporting and clogging the regulators’ reporting system and that the rules would not afford sufficient due process to AMOs facing certificate actions.

If your company submitted comments to EASA on SMS, please send a copy to christian.klein@arsa.org.

To read ARSA’s full comments, click here.

To view a PDF file of the comments as submitted through EASA’s Comment Response Tool, click here.

Share your SMS experience or plans via last month’s “quick question,” which is still collecting data:

Quick Question – SMS Implementation

Researching & Illustrating the Maintenance Workforce

The challenge of finding and retaining skilled technical workers has gained national attention.

An ARSA-led coalition of more than 40 leading industry organizations is poised to get funding for the workforce development programs the group successfully advocated for in last year’s FAA reauthorization law.

The FAA has been hosting events, arranging task forces and committees and hosting students to spread the word about aviation careers.

The industry is building community partnerships in support of improved technical skill pipelines.

Individuals from ARSA member companies regularly contact the association in search of resources to help describe the challenges facing the industry. All can speak eloquently of their personal experience, often highlighting the current state of workforce development with stories of their own career development – explaining how traditionally-reliable pipelines for talent are no longer sufficient.

What they need, though, is help creating a larger context. Some resources can help. The following list is a useful start – take advantage of it and share your own information with ARSA:

(1) This year’s state-by-state data sheet compiled for ARSA by Oliver Wyman, along with the executive summary of this year’s complete report: arsa.org/market-assessment.
(2) Two infographics ARSA produced based on “quick questions” regarding technician onboarding and certification breakdown in the workforce:
(a) Time to Onboard a New Technician.
(b) Technician Workforce by Certification.
(3) Salary data from the Bureau of Labor Statistics: www.bls.gov/ooh/installation-maintenance-and-repair/aircraft-and-avionics-equipment-mechanics-and-technicians.htm.
(4) “My Next Move,” a resource sponsored by the Labor Department that provides analysis related to the employment outlook for aircraft mechanics and service technicians: www.mynextmove.org/profile/summary/49-3011.00.
(5) ARSA’s Workforce Legislative Action Center: arsa.org/legislative/grant-program-action-center.
(6) The “Pipeline Report” produced by the Aviation Technician Education Council, which has great data on industry turnover and demographics, including certification: www.atec-amt.org/pipeline-report.
(7) The FAA’s Aviation and Space Education (AVSED) program website, which has resources for engaging students and teachers regarding the miracle of flight and the magical possibility of aerospace careers: www.faa.gov/education.

There is no perfect data source for capturing the aviation maintenance workforce and describing each issue. Each has drawbacks and blind spots, but taken as a whole and combined with personal observation, they help to tell a powerful story.

Final Documents/Your Two Cents

This list includes Federal Register publications, such as final rules, Advisory Circulars and policy statements, as well as proposed rules and policies of interest to ARSA members.

To view the list, click here.

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Legal Brief

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

Since You Keep Asking

By Sarah MacLeod, Executive Director

The “Member Asked” in the August 2019 edition of the hotline was 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. In the month since its publication, ARSA’s team has received more questions regarding these activities.

Since both involve maintenance manuals or instructions for continued airworthiness, the answers are not easy or straight-forward.

The first involved a letter from a manufacturer questioning the repair station’s ability to perform work on certain articles, since the maintenance manuals were proprietary, and the manufacturer had never provided the repair station permission or access to that information. The letter demanded the repair station cease and desist use or further bad things would happen.

The second involved a type and production certificate holder that is demanding more money for access to customer-specific information regarding maintenance of aircraft.

If a repair station is using data that (1) the FAA considers instructions for continued airworthiness (ICA) and (2) was obtained from or specifically for its airline or owner/operator customer to maintain that customer’s articles, the FAA is clear that design and production approval holders cannot restrict access.

The association has not delved into the specifics of the member scenarios as contracts and business arrangements are legal matters; ARSA is devoted to informing its members about regulatory compliance. Therefore, the particulars of each company’s situation must be reviewed by competent legal counsel to determine the contractual obligations between the air carrier or owner/operator and its chosen repair station. However, during that legal review, the policy issued by the FAA regarding unacceptable restrictions to maintenance data must be fully understood and appreciated.

The association has discussed potential scenarios with several contract and business lawyers who believe that any restrictions between the air carrier or owner/operator and its chosen maintenance providers in contracts with design and production approval holders would be extremely problematic in light of the FAA’s policy. While the specific facts must be analyzed, contract clauses can be deemed void as against public policy if litigated. That fact can certainly be used in discussions with customers and manufacturers.

On the other hand, anyone has the right to protect their proprietary property against “unauthorized” use through appropriate contractual language. In other words, the manufacturers can restrict allowable uses to only the specified owner/operator (and their repair providers), and also can prohibit any use of that data for the purpose of developing independent repairs or manufacturing parts.

Many air carriers and owner/operators are unaware that the policy makes clear any restriction to sharing maintenance information that the FAA considers ICA is unacceptable. The policy contains two important statements:

• It is not appropriate for a DAH to place limitations on the use of its ICA between the owner/operator and the maintenance provider, whether the maintenance provider is rated or not, to perform that maintenance. 
• While not exhaustive, the FAA finds the following practices of using restrictive language in the ICA or through restrictive access or use agreements unacceptable under the provisions of 14 CFR § 50(b) and related ICA airworthiness requirements:

(1) Requiring the owner/operator to only install DAH-produced or authorized replacement parts, articles, appliances, or materials.
(2) Requiring that alterations or repairs must be provided or otherwise authorized by the DAH.
(3) Requiring the use of only maintenance providers or other persons authorized by the DAH to implement the ICA.
(4) Establishing, or attempting to establish, any restriction on the owner/operator to disclose or provide the ICA to persons authorized by the FAA to implement the ICA.

Repair stations that are receiving or have received ICA from the owner/operator or air carrier customer can develop letters explaining the FAA policy and asking for clear instructions to the manufacturer from the customer to that effect. While the association cannot construct an informational letter for all members, it stands ready to help with referrals to appropriate commercial resources after understanding each unique situation.

To see all of the association’s work related to ensuring reasonable availability of ICA, visit the issue page on ARSA.org.

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ARSA on the Hill

Repair Stations Under Fire on the Hill

With Congress back in session after the August recess, it’s been a busy September on Capitol Hill. There’s good news and bad news for the maintenance industry.

Across this month’s “ARSA on the Hill” section, Executive Vice President Christian A. Klein outlines the issues:

• New aviation workforce grant programs are a step closer to being funded.
• ARSA’s statement in conjunction with this month’s aviation subcommittee hearing highlights the association’s workforce priorities.
• A new House bill seeks to shame airlines that use repair stations.
• Comments by the House transportation committee chairman underscore risks to contract maintenance.

Use Klein’s analysis and ARSA resources to take action in support of the international aviation industry and – most importantly – aviation safety.

As always, ARSA is standing by answer any questions. Don’t hesitate to reach out to Klein at christian.klein@arsa.org.

House Bill Seeks to Shame Airlines that Use Repair Stations

Reps. John Garamendi (D-Calif.) and Lee Zeldin (R-N.Y.) introduced the Aircraft Maintenance Outsourcing Disclosure Act (H.R. 4374) on Sept. 19. The bill is a slightly updated version of legislation that Garamendi and then-Senator Claire McCaskill (D-Mo.) introduced during the last Congress. It seeks to shame airlines that use contract maintenance by requiring carriers to jump through a litany of hoops to inform passengers about where heavy maintenance is performed on each individual plane in the airline’s fleet.

Air carriers would be required to report on tickets and boarding passes (“to the greatest extent practicable”) the specific location and date that each aircraft most recently underwent heavy maintenance. They’d also be required to “disclose the percentage of airframes in the fleet of the air carrier typically assigned to each specific route that are maintained in the United States and the percentage of such airframes maintained abroad, including the 3 most common countries in which such airframes are maintained abroad, listed by workhours.”

The information would be required to be made available on a flight-by-flight basis on airline websites, when passengers purchase tickets and with the electronic confirmation of a ticket purchase. The information would also have to be communicated to passengers upon request when they purchase tickets by phone or at a ticket counter.

Both passenger and cargo airlines would also be required to post a list of all of the specific locations where their aircraft have undergone heavy maintenance in the past three years, listed by total workhours and all of the specific locations where heavy maintenance is carried out for the air carrier under an existing contract. Each year they would also be required to provide the FAA with a report detailing:

• A minimum of one year of maintenance history, including line maintenance, for each aircraft that has operated in scheduled passenger or cargo air transportation during the previous year.
• The percentage and total number of mechanics carrying out maintenance on aircraft for the air carrier during the previous year who are employees and who are not employees of the air carrier.
• The percentage and total number of FAA-certificated mechanics carrying out maintenance on aircraft for the air carrier during the previous year who are based and who are not based in the United States.
• The percentage and total number of technicians, regardless of certification, carrying out maintenance on aircraft for the air carrier during the previous year who are based and who are not based in the United States.
• The percentage and total number of technicians carrying out maintenance on aircraft for the air carrier during the previous year who are and who are not certificated by the FAA.
• Any other maintenance and safety information the FAA deems appropriate.

Facts Versus Folly

So, what’s Garamendi’s rationale for the bill? In a press release, his office said:

“Recent airline accidents raise serious concerns about the increasing trend of maintenance being outsourced, particularly to countries in Central America and Southeast Asia. These foreign outsourcers do not have to be FAA certified, and are not subject to the drug and alcohol testing required in the United States for mechanics. Outsourcing has also eliminated thousands of middle-class jobs in the United States and created significant safety concerns for passengers.”

Almost every statement in that paragraph is flawed and most are downright wrong.

Safety’s not an issue: the safest period in the history of civil aviation in the United States has coincided with an increase in domestic and foreign contract maintenance. Not counting the 9-11 terrorist attacks, between 1999 and 2009, there were 484 fatalities resulting from accidents in the United States involving part 121 carriers; in the past decade there has been only one.

FAA certification: What are they talking about?? Of course foreign repair stations have to be FAA-certificated! Under 14 CFR § 43.3, U.S.-registered aircraft must be maintained by FAA-approved “persons” (although Canadian approved maintenance organizations working under the bilateral don’t need a certificate from the FAA, they’re still “approved” through FAA regulations). 14 CFR part 145 subpart B prescribes the same certification standards for foreign and domestic repair stations. And regardless of where the maintenance is performed, all FAA-certificated facilities work to the standards for maintenance, preventive maintenance and alteration established by 14 CFR § 43.13 (“the condition of the aircraft, airframe, aircraft engine, propeller, or appliance worked on will be at least equal to its original or properly altered condition …”).

Drug testing: Yes, the FAA hasn’t yet rolled out congressionally-mandated drug and alcohol testing rules for foreign repair station employees, but when they’re working outside the United States, mechanics employed by U.S. air carriers aren’t required to be tested either. In fact, they are required to be removed from the “pool” of employees required to be tested.

Workforce: Contract maintenance hasn’t eliminated jobs, it’s creating them. Around the country, repair stations employ more than 188,000 Americans. U.S. aviation maintenance jobs haven’t gone overseas, they’ve gone across the street or around the corner to other U.S. companies. And it’s not as though aircraft mechanics are having trouble finding work at the moment!

“A Massively Wasteful Diversion of Resources”

Rep. Garamendi says his bill, “prioritizes transparency for passengers and supports the creation of new middle-class jobs in the United States.” In fact, it is a massively wasteful diversion of airline resources with absolutely no safety benefit. It’s a thinly veiled effort and misguided attempt to shame airlines that use contract maintenance.

The bill’s sponsors and the fear-mongers that requested its introduction, apparently think there will be outrage when the public discovers who’s keeping their aircraft safe and flying. We think they’re way off base. Members of the public care about ticket prices and on-time departures; the financial realities are not on the side of the uninformed outraged airline protagonists.

The legislation is the latest in a long line of attacks on repair stations by labor organizations, particularly unions representing mechanics. The Garamendi-Zeldin bill is endorsed by the Transport Workers Union of America, International Brotherhood of Teamsters (Airlines Division), Business Travel Coalition, International Association of Machinists and Aerospace Workers, Professional Aviation Safety Specialists, the Aircraft Mechanics Fraternal Association and the Association of Professional Flight Attendants.

DeFazio Comments at Hearing Underscore Risks

There is no doubt that the bill is the first step in a renewed effort to discourage, restrict or prevent U.S. air carriers from using repair stations, particularly those outside the United States. In the current political environment, bad legislative mandates are a bigger risk than it has been in years.

The recent Max accidents have thrust aviation safety into the public spotlight. President Trump’s rhetoric has undermined support for free trade on Capitol Hill. The unfinished FAA D&A rulemaking creates a perfect policy hook for repair station opponents. And Rep. Peter DeFazio (D-Ore.), the chairman of the House Transportation & Infrastructure Committee, is a long-standing opponent of the industry.

DeFazio made no secret of his personal views at the Sept. 26 House aviation subcommittee hearing on FAA reauthorization implementation. In a ridiculous attenuation of logic, DeFazio used the recent incident in which an American airlines mechanic in Miami allegedly tried to sabotage a plane to raise security concerns about foreign repair stations. In his opening remarks at the hearing DeFazio (who’s remarks on maintenance begin at minute 26:10 of the video linked here) said:

“We just had an incident last week of what appears to be a terrorist action on domestic soil by a domestic employee. And, you know, I have for years … expressed concerns … about foreign repair stations.

“And we did some visits. And, you know, we can’t do unannounced visits because the State Department says, ‘Oh well, then they could do unannounced visits here.’ Who cares! We don’t have anything to hide, I hope!

“They don’t do drug testing as is required by law, they don’t do alcohol, drug, and they don’t do background checks.

“And now we’re doing massive, massive amounts of maintenance overseas. This is an incredible vulnerability. Just like this guy tried to sabotage the plane there, what about someone doing a D check down in one of these foreign repair stations. That’s a way to take down a plane without having to get on board and without having to access the flight deck.

“These are safety critical, potentially life-threatening rules that we need and we need them as quickly as possible.”

Workforce Priorities Key to ARSA Hearing Statement

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 said that, while it “considers several provisions in the FAA law related to certification and oversight to be significant, we have chosen to focus these comments on workforce issues because neither the agency nor the industry can function effectively without well-trained and capable employees.”  

ARSA’s statement highlighted the most important workforce-related provisions of the bill, including those creating the new grant programs, directing the FAA to examine ways to improve repairman certificates, updating part 147, improving and giving industry access to FAA training, and workforce-related GAO reports and stakeholder bodies.   

To read the full text of ARSA’s statement, which serves as a great summary of the association’s workforce priorities, click here. 

Grant Funding in the Works, Needs Help

ARSA and its allies are a step closer to getting funding for the technician workforce grant programs created by last year’s FAA reauthorization bill. The grant program, which was conceived by ARSA, would provide up to $5 million per year to support a wide variety of initiatives to attract new talent to the maintenance industry and train the next generation of technicians.

Although the FAA bill authorized the grant program for five years (2019 to 2023), Congress still has to appropriate money for it on an annual basis. The fiscal year 2020 Transportation, Housing and Urban Development and Related Agencies (T-HUD) appropriations bill passed by the House in June (H.R. 3163) would provide full funding for the technician and a related pilot education grant programs ($10 million total). This month, the Senate Appropriations Committee passed its own version of the T-HUD bill. It included a total of $5 million for both programs, half the authorized amount.

While it’s disappointing the Senate bill doesn’t provide full funding, it’s a step in the right direction. The fact there’s money in both bills significantly increases the likelihood the program will be funded for FY 2020. The big question is whether Congress will provide the full amount or something less. The coalition ARSA is leading to secure funding will be pushing for the highest number possible. Of course, ultimately securing the money will depend on how the broader appropriations process plays out (recall that last year talks broke down leading to the longest partial government shutdown in U.S. history).

To find out what you can do to help move the ball down the field, visit ARSA’s Workforce Legislation Action Center.

What’s Next and What Can You Do?

Boeing investigations are still playing out, but some sort of legislative response is a virtual certainty. The big question is whether whatever transportation leaders in the House and Senate introduce will be targeted at real problems or whether it’ll be a massive grab bag of random initiatives that didn’t make it into last year’s FAA reauthorization bill. If recent history is any indicator, it’s by no means out of the question that language preventing new foreign repair station certifications until the D&A rules are issued will be part of the fall out.

ARSA constantly battles anything that sheds false light on the maintenance industry, but the real concern is about where the rhetoric leads. Legislation that mandates action by the FAA within specified periods of time always have unintended consequences and untold costs.

Here is how you can take up the flag for the safest form of transportation:

• If you’re a repair station in California or New York, let Garamendi’s (who’s from California) and Rep. Zeldin’s (from New York) offices know you think their bill is a bad idea. (Click on their names to get email addresses for their key staffers.) Use the themes in the article about the bill to help build your case.
• Regardless of where in the United States you’re located, use this list to let your members of Congress know that the hostile rhetoric about your industry is blatantly untrue. Create and use a company profile to tell them what you do, how many people you employ and the company’s community involvement. Use ARSA’s economic data to explain how bill impacts the industry is in your state. Tell them to reject legislation targeting repair stations. Just knowing they have a repair station in their state or district makes a big difference in how lawmakers think about maintenance issues.
• If you’re located outside the United States, contact your U.S. business partners (customers and suppliers) and urge them to get involved in this effort…and forward this information to all your colleagues at companies that aren’t ARSA members encouraging them to join the association or at least to use its many legislative resources.

As always, ARSA is standing by answer any questions. Don’t hesitate to reach out to ARSA Executive Vice President Christian A. Klein at christian.klein@arsa.org.

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Getting Facetime

Aviation STEM Events Can’t Be Hidden Gems

On Sept. 26, the FAA’s Aviation Safety Office (AVS) hosted its second STEM Careers Symposium at the agency’s headquarters in Washington, D.C. The event brought hundreds of local middle and high school students from the nation’s capital to 800 Independence Avenue for demonstrations, presentations and exhibits on aviation careers, skills and the government’s oversight of U.S. airspace.

After a welcome from Sunny Lee Fanning, FAA executive director of the Office of Quality, Integration and Executive Services, students divided by age group to take turns visiting the exhibition space in the Bessie Coleman Conference Center and participating in presentations in the Elwood Richard “Pete” Quesada Auditorium. There were lunch breaks and discussions and standing-room-only crowds for a packed agenda that wrapped up quickly as students ran to catch mid-afternoon buses back to their campuses.

“The FAA has produced a good model for student engagement,” said Brett Levanto, ARSA vice president of operations, who attended the event. “They kept the kids moving, engaged them with questions, gave them activities and brought out a series of young, smart, engaging presenters with local ties and personal stories that were familiar for a D.C.-area student.”

Describing ARSA’s purpose at the event – part of the association’s broader effort to support the aviation workforce, which includes both industry and government personnel needs – Levanto noted a number of goals:

(1) Get involved with the FAA’s and others’ existing activities related to stimulating interest in aviation, urging strong representation for maintenance interests.

(2) Help to highlight and distribute available resources, tools and strategies for connecting with new groups of potential industry applicants.

(3) Connect with the various government offices, interest groups and individuals encouraging workforce growth, taking advantage of their work and using them to amplify ARSA’s own efforts for building the next generation of aviation professionals.

“Today was a lot of fun, but we’ve got to do a much better job getting the word out,” Levanto said. “I’m only here because [ARSA] happened to learn about this event via an offhand reference in an email on another topic. We can’t afford to have these secrets anymore; it’s time to start shouting from rooftops. If we do that from this rooftop, at 800 Independence Avenue, the aviation world will hear.”

Groups Represented at the Event

Booz Allen Hamilton Transportation
Code Ninjas
D.C. Flight Club
FAA Aviation and Space Education
FAA Office of Accident Investigation and Prevention (AVP)
United Airlines
University of Maryland Robotics Team

Resources/Activities Shared During Event*

Airport Surface Anomaly Investigation Capability
Aviation Career Academies
Forces in Flight (National Air & Space Museum)
NASAO Art Contest
Real World Design Challenge

Lessons for ARSA Members

The event provides a useful model for any industry stakeholder looking to engage with local students of any age. Coupled with a facility tour or school visit and with participation from local STEM and other groups promoting hands-on skills development, companies could partner with schools, Boy or Girl Scout troops or other community bodies to host similar events.

Stay tuned for more updates and resources from ARSA. In the meantime, visit www.faa.gov/education to see more information and resources regarding STEM and aviation skills outreach.

Bigger than Big Data

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.”

Levanto reviewed the maintenance community’s personnel needs and how they align (or conflict) with the expansive interests of advanced analytics in aviation. His presentation set the stage for a continued discussion about the human factors at play in technical advancement and how the industry must address its workforce challenges.

Asking for a show of hands, Levanto counted attendants who had ever worked as a mechanic, maintenance engineer or aircraft technician and then for those who currently engage directly with technical personnel. Observing the very few with personal experience and the minority connecting with technicians, he underscored the human impact on both data generation and analytical application in maintenance.

ARSA VP of Operations Brett Levanto queries the Big Data Americas audience regarding personal experience with aircraft maintenance.

Using that baseline, Levanto explained the broader need for technical skills in the industry, recruitment challenges facing aviation employers and the demands on all involved to change how aviation careers are considered.

“The maintenance community is trapped,” he said. “It still relies on old paradigms for recruitment and talent development, overvaluing certifications, failing to consider changing competency requirements and struggling under outdated training rules – and depending far too much on them – all while failing to consider the changing needs of the talent market.”

As evidence for change, he cited the industry-wide effort to overhaul the FAA’s “Overview of the Aviation Maintenance Profession” and its successful coalition building in support of new talent development programs. Levanto explained that proponents of advanced analytics must learn to see their own needs, as aviation stakeholders, in the context of that broader profession.

During the following panel discussion, Levanto joined colleagues from Embry Riddle Aeronautical University, Cirium and Qatar Airways to discuss workforce development. He used this additional time to challenge cultural perspectives on technical careers, question the need for FAA oversight of aircraft maintenance technician schools and compare different sorts of data and technical “literacy” required by various tiers in the maintenance chain.

The event’s most interesting other development related to data ownership. Despite repeated assertions that aerospace businesses are devoted to collaboration, Shawn Gregg, general manager of predictive technology engineering for Delta Air Lines, asserted that business-minded operators will share data only in consideration of business needs and outcomes. This realistic perspective – that commercial entities will be strategic in use/control of any resource that has either direct or indirect value – surprised some in the audience but provided a sensible grounding for further exploration of information-sharing issues.

The second day wrapped with multiple sessions on cybersecurity awareness anchored by presenters from industry consultancy Oliver Wyman, which produces ARSA’s annual market assessment.

ARSA VP of Operations Brett Levanto participates in a panel discussion at the Big Data Americas event.

The presenters explained data integrity risks and offered strategies for mitigating them at every link in chain of maintenance and operations; noting that customers, air carriers and suppliers will avoid unsecure organizations. The security challenge was then illustrated by Daniel Stein, branch chief in the Department of Homeland Security’s Cybersecurity and Infrastructure Security Agency, who said: “There are two types of organizations out there, those who have been breached and those who don’t know it.”

Overall, Levanto found the event to be an expansive exploration of factors surrounding technical advancement in aviation.

“Since this is my second year [participating in Big Data Americas], it was great to see a true willingness to realistically consider challenges, like skills gaps, data ownership or cybersecurity threats, alongside exciting and much-hyped advancements in technology,” Levanto said, also highlighting the value of U.S. government participation via presentations from both the FAA (on recordkeeping and aircraft health system monitoring) and Homeland Security (on cybersecurity workforce risks and solutions). “I see my role here as connecting the ‘big data big thinkers’ in this room with the people working on actual shop floors and flight lines. This group came to make those and many other kinds of connections, taking insights from across the aviation community and beyond.”

To learn more about the Big Data Series, visit: www.flightglobalconferences.com/ehome/bigdataseries.

MacLeod Presents at GA Engine Summit

On Sept. 17-18, ARSA Executive Director Sarah MacLeod participated in the FAA’s 2019 General Aviation Engine Summit at the agency’s New England Regional Office in Burlington, Massachusetts. MacLeod presented on two topics: (1) service bulletins incorporated by reference in airworthiness directives and (2) replacement parts in non-critical applications.

In addition to MacLeod’s presentations, the agenda included content on the following topics:

• Certification Process Guide
• Airman Certification Standards for Mechanics
• Electronic Controls
• Type Certificated Products in Amateur Built Aircraft
• Modernization of Special Airworthiness Certificates (MOSAIC)
• CECI Updates
• Electric Propulsion Standards Development
• Continued Operational Safety Process

To view MacLeod’s presentation material, which she was able to provide without missing the human factors training session recorded on Sept. 17 (“The Dirty Dozen in Depth – Lack of Teamwork”), click here.

For more information about the event GA engine-related topics, contact ARSA.

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Training

“Dirty Dozen in Depth” Series Passes Halfway Point

Now that the Sept. 26 session on “Lack of Resources” and the Oct. 2 session on “Pressure” are both available on demand, ARSA’s ongoing human factors training series exploring “the dirty dozen in depth” has passed the halfway point. With eight sessions available on demand for immediate registration and viewing – running the total for all human factors content to ten – four live events remain open for registration.

On Sept. 3, the FAA accepted the entire series for Inspection Authorization renewal credit under § 65.93(a)(4). All 14 hours of the association’s sessions on human factors in aviation maintenance are now accepted for IA renewal credit.

To review each session’s details – the eight upcoming live events as well as the six already available on demand – and register, utilize the links provided in the lists below. To purchase multiple sessions at a discounted price, click here to view options for purchasing via a “tiered bundle.”

The human factors series joins eight other ARSA training sessions that are acceptable for IA renewal credit. To view all of the association’s accepted courses, click here. If you have questions regarding any of ARSA’s training resources, contact Brett Levanto.

Already On Demand – Human Factors Training Series

Each on-demand session is available for immediate viewing; registration provides all session materials as well as access to the recording for 90 days.

Remaining Live Sessions – The Dirty Dozen in Depth

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.

Learn from ARSA’s Experts at HELI-EXPO 2020

From January 26-29, 2020, ARSA’s great regulatory minds will be at HAI HELI-EXPO 2020 in Anaheim, California.

Image courtesy HAI. Click for event information.

Marshall S. Filler and Sarah MacLeod, the association’s foremost experts in regulatory compliance (and managing members of the firm of Obadal, Filler, MacLeod & Klein, P.L.C.) will lead a number of professional education courses as well as three “Rotor Safety Challenge” presentations.

Click here to register for the event and stay tuned to www.rotor.org/home/heli-expo/education for registration information.

Professional Education Courses

Note: These sessions are provided by Filler and MacLeod in their roles as managing members for OFM&K.

Regulatory Comprehension for Operations

Sunday, January 26, 2020 – 8:00 a.m. to 12:00 p.m. PST

This session covers the FAA’s general authority and process for promulgating rules as well as the agency’s authority and organization, then walks through the requirements in Title 14 of the Code of Federal Regulations to explain how its various components are linked together in a “regulatory chain” that must be comprehended by aviation businesses. Topics specific to operations include part 91, subpart D special flight operations including operating limitations for restricted category aircraft; part 91, subpart H operations of U.S.-registered aircraft outside the United States; part 133 external load operations; part 135, subpart L helicopter air ambulance equipment, operations and training requirements; part 136 commercial air tours and national parks air tour management, part 137 agricultural aircraft operations and public aircraft operations as defined in 49 U.S.C. §§ 40125 and 40102.

Regulatory Comprehension for Maintenance

Sunday, January 26, 2020 – 1:00 p.m. to 5:00 p.m. PST

This session covers the FAA’s organization, authority and process for promulgating rules, then walks through the general requirements in 14 CFR to explain how its various components link together in a “regulatory chain” that must be comprehended by aviation businesses. Topics specific to maintenance include part 43 maintenance, preventive maintenance, rebuilding and alteration; part 65, subpart D mechanics (certification); part 65, subpart E repairmen (certification); and part 145 repair stations.

Regulations Affecting Aircraft Part Purchase and Sale

Monday, January 27, 2020 – 8:00 a.m. to 12:00 p.m. PST

This course reviews the civil aviation regulations in 14 CFR that impact the purchase, sale, receiving, stocking, inspection and installation of civil aviation articles for maintenance purposes. It also overviews other guidance as well as regulatory and contractual requirements that should be considered.

Public Aircraft Operations

Monday, January 27, 2020 – 1:00 p.m. to 5:00 p.m. PST

This course provides instruction on the statutory provisions and FAA guidance governing public aircraft operations. It covers the basic requirements for an aircraft to be operated as a public aircraft, what constitutes an eligible governmental function, and the practical implications of using the same aircraft to conduct both civil and public operations. It also discusses the FAA policy regarding operations conducted under contract for a government entity.

Rotor Safety Challenge Sessions

Note: These sessions are provided on behalf of ARSA.

Building a Professional Relationship with the Government

Tuesday, January 28, 2020 – 8:00 a.m. to 9:00 a.m. PST

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

Best Practices in Maintenance Recordkeeping

Wednesday, January 29, 2020 – 9:15 a.m. to 10:15 a.m.

This session explores the regulatory responsibilities of creating and maintaining maintenance records. It will help participants to define:

• Regulatory responsibilities of the operator versus the maintenance provider in creating and maintaining maintenance records
• How obligations can be shifted by contract but not under aviation safety regulations
• Maintenance recordkeeping regulations, the documents essential to making airworthiness determinations.

Self Disclosure – Avoiding Self Exposure

Wednesday, January 29, 2020 – 1:30 p.m. to 2:30 p.m.

This session reviews the elements of the FAA’s self-disclosure programs and provides methods for addressing non-compliance with creating unnecessary scrutiny.

Whether you are able to participate in Anaheim or not, much of the material presented by MacLeod and Filler at HELI-EXPO is available through ARSA’s online training program. To review the library of available courses and register for immediate access to on-demand sessions, click here. You also may review the session information below for links to related classes.

Regulatory Compliance Training

Test your knowledge of 14 CFR §§ 65.3, 65.13 & 65.21 – Foreign certifications, temporary certificates and changes of address.

Click here to download the training sheet.

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Membership

Service Spotlight – Erickson Earns Master Mechanic Distinction

Chris Erickson (left) receives the Charles Taylor Master Mechanic Award from Curt Cowley, Portland FSDO FAASTeam manager.

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.

The Charles Taylor Master Mechanic Award recognizes the lifetime accomplishments of senior mechanics and is named in honor of Mr. Charles Taylor, the first aviation mechanic in powered flight. Taylor served as the Wright brothers’ mechanic and is credited with designing and building the engine for their first successful aircraft. To be eligible for the award, nominees must:

• Hold a U.S. Civil Aviation Authority (CAA) or Federal Aviation Administration (FAA) mechanic or repairman certificate.
• Have 50 or more years of civil and military maintenance experience.
• Be a U.S. citizen.
• Have NOT had any airman certificate revoked. Revocation of any airman certificate will disqualify a nominee.

Erickson (the master mechanic) began his aircraft maintenance career in September 1969 at Big Bend Community College in Moses Lake, Washington. He has held numerous positions at Erickson (the company) since arriving as a Sikorsky S-64 crew chief in 1981. In the decade after completing school, he had served as a Sikorsky crew chief at Carson Helicopters, Boise Cascade Corporation and Siller Brothers. He joined ARSA’s board in 2002 and represented the interests of both helicopter and engine businesses for nearly two decades; he will complete his service to the association at this October’s annual meeting in Washington, D.C.

“50 years…a well-deserved lifetime achievement award,” said Marshall S. Filler, ARSA managing director and general counsel, when the association heard the news. “It is always gratifying when an ARSA member receives such an accolade. But when it’s one of the association’s longstanding board members and industry compliance leaders, it carries a special meaning. Congratulations, Chris and keep them Cranes flying!.”

By recognizing the industry’s most experienced and dedicated personnel, the master mechanic award showcases individual commitment and aviation excellence in general. This is a very important part of highlighting the career paths available for technical personnel and growing a sustainable workforce.

If you know a certificated mechanic or repairman with 50 or more years’ experience, get them nominated today.

Click here to get started.

Be an Involved Constituent

If the 2018 FAA reauthorization process demonstrated anything, it’s that there is incredible power in educating members of Congress about how the industry works. If the current political climate in Washington demonstrates anything (review this month’s “ARSA on the Hill” section if you’re not sure what that means), more of that education is desperately needed. The easiest way to ensure that your lawmakers want to help your business is to make sure they understand the positive impact your company has on the both local economy and aviation safety is to host them at your company’s facilities. 

While ARSA’s legislative team works hard for you daily, nothing substitutes for a constituent’s personal involvement in the legislative and political process. Since the campaign cycle is almost never-ending, it is always a good time to review the ways you can engage your lawmakers:

ARSA’s Klein Hails FAA Bill as “Historic Victory”

Finding Your Lawmakers

To find your representative and senators, visit www.govtrack.us/congress/members/map. You can find your legislators by entering your address and zip code. The search will bring up your representatives and senators. Clicking on respective links allows you to view a background and contact information page for each of your elected officials, including websites, Twitter and Facebook pages and Washington, D.C. phone info.

State/District Offices

The place to start is the role district offices play in a congressional staff. A district office (U.S. senators and staff often refer to it as “state offices”) represents the home base for your U.S. House and Senate representatives. It employs dedicated individuals from the local community who answer constituent concerns. The staff is ready to answer questions about legislation, provide information about district activities, set up an appointment with your representative and help with other matters of importance or interest.

To access information about their home offices, you’ll need to visit their websites for further information – usually under a “contact” or “office locations” heading. Most representatives and senators have more than one district office, making your visit even more convenient. Remember your company and residence might be in different congressional districts or states; if so, you may engage multiple sets of elected officials representing your home and business.

Visit the home office to inform your lawmakers and staff of issues important to your business – let them know you are there and you represent votes! Opening the door to an ongoing dialogue through this local contact is easy, but if you are still feeling uncomfortable about making politics local, contact ARSA for assistance. 

Town Hall Meetings

Many representatives or their supporters host town hall or other community meetings. These fora provide an opportunity to gain insight into your representative’s priorities as well as his or her position on national, international and community issues. Most importantly, these events are a chance to initiate meaningful dialogue.

To get information on events scheduled or occurring in your area, contact the staff at the district office. You may also learn of an event through your local paper, newscast or congressional office’s newsletter or website.

When attending a town hall meeting, be prepared to make the most of the event. Here are a few suggestions:

Speak Up and Be Prepared. Be ready to ask thoughtful, concise questions. Have data to support your concerns and positions. This will ensure you are remembered by the representative and staff.

Make it Personal. It is important to establish yourself not just as a constituent but as a representative of other voters. Tell your representative about your company – the type of work it does and number of employees. Know how a policy will affect you or your family, business or community and provide firsthand accounts of that impact.

Talk to Staff. Members usually bring several members of their staff to meetings. Be sure to interact with them, particularly if you are unable to interact with the representative. In all cases, obtain their business cards or at write down names, titles and contact information.

Leave Paper. Create a company profile from ARSA’s Legislative Page (download the template: http://arsa.org/wp-content/uploads/2013/07/ARSA-CompanyProfile-20130722.docx). Provide it along with any documents that support your position or concerns, including ARSA’s legislative priorities, to the representative or staff member.

Follow Up. Be persistent (but also polite) in following up with your representative after an in-person event. Remember that creating a dialogue is only the first step, maintaining that dialogue is key.

Attend Multiple Events. Also have other people from your company attend meetings, so that the representative can hear about the issue from multiple voices with the same concerns.

Use in-person events to form a relationship with your representative and staff. The more often you are seen and heard, the more likely the member will heed your concerns. Town hall meetings are a good way to stay in touch with your elected officials and keep yourself updated on what action being taken by your government, be it local, state or federal.

Reminder: To find your representative and senators, visit www.govtrack.us/congress/members/map.  You can find your legislators by entering your address and zip code. The search will bring up your representatives and senators. Clicking on respective links allows you to view a background and contact information page for each of your elected officials, including websites, Twitter and Facebook pages and Washington, D.C. phone info.

Facility Visits

Facility visits give members of Congress and legislative staff an opportunity to see first-hand and up close what your company does and how it fits into the aviation industry. It’s also an opportunity for lawmakers to meet your employees (whose votes they want to win) and to show their commitment to the local business community.

The best time for a facility visit is during congressional recesses. Since legislators are now back at work through the fall, it’s a great time to follow up on past engagement or lay the foundation for a future field trip. Here are simple steps for you to follow when inviting lawmakers for a facility visit. Remember that representatives and senators have tremendous demands on their time, so you must be flexible in scheduling a tour and even be willing to have a congressional staffer come and visit.

Steps to inviting your member of Congress:

Locate scheduler contact information. Go to http://arsa.org/wp-content/uploads/2018/10/ARSA-Schedulers-20181004.xlsx and search the excel spreadsheet for your lawmakers’ schedulers. If the scheduler isn’t listed, please contact ARSA.

Draft an email to the scheduler. Use ARSA’s facility visit request template and be sure to enter pertinent information where indicated. Either place on company letterhead and send as an attachment or copy into the body of an email.

Let us know you’ve sent the request. Either copy christian.klein@arsa.org on your request or send a copy after the fact so the legislative team can follow up.

If you don’t receive a response. One week after sending the letter to your lawmaker, call their congressional office to verify that they received your invitation. Tell them your name, what company you’re from and when you sent the request; then ask about the likelihood of a tour, possible timing and be sure to offer that staff may come if the member is not available. Congressional staff are the “issue experts” for members, and it’s just as important that they understand your business!

Schedule the meeting/visit. Once the site visit or meeting is scheduled, let ARSA’s legislative team know. We’ll send you an ARSA briefing packet with information about specific issues you may want to raise, as well as useful background information about your congressional representative.

Enjoy! Make sure you capture the event with photographs. You can share these photos with the visiting member of Congress, who may even display a photo in his or her office. Give them a hat, t-shirt, or other takeaway with your company’s logo so they’ll remember the visit.

Let ARSA know what happened. Whether it’s a facility visit or office meeting, let ARSA know you’ve been in touch. As a politically active member, you may even be featured in ARSA’s communications! (See the Sept. 6, 2019 “hotline highlight” for a great example.) Be sure to forward us some of those pictures too!

Keep communication going. Setting up a visit or meeting is an important first step. However, many members find keeping an open dialogue with their congressional staff is beneficial to their business, and the industry. Although we encourage you to talk about the issues important to the industry, businesses face problems every day and sometimes congressional intervention can help. So be sure to keep those communication lines open!

Taking the initiative to invite a member of Congress to your facility is an easy and fun way to raise the profile of your company and your industry. And it’s a great way to build relationships with legislators that will serve your interests down the road.

If you have any questions about planning or scheduling a tour, let ARSA help.  

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 September:

New Members (Member Category)

CrossPoint Testing and Inspection, R01
Avionics Sales Corporation, R01

Renewing Members (Member Category, Member Since)

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

Quick Question – Credit Card Fees

ARSA’s management team is preparing the association’s 2020 budget. As it does every year, the team is exploring every way to limit expenditures and is considering the $20,000 that must be set aside annually to cover credit card transaction fees.

ARSA cannot – and would not – pass this purely administrative cost on to any member, its only means of eliminating this cost would be to cease accepting credit card payments. The association cannot – and would not – take this step if it would massively disrupt or inconvenience the members on which it depends.

Help the team consider this cost by answering this month’s “quick question”:

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

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

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

A Member Asked…

Q: Order 8300.14 (Repair Station Repair/Process Specifications) was cancelled in 2015. Does that mean that the ability for repair stations to develop and obtain [standing] FAA approval for its own repairs has been eliminated?

A: No, you can still develop your own repairs; current guidance is contained in Order 8300.16 – Major Repair and Alteration Data Approval and it is very informative to review Order 8110.37F – Designated Engineering Representative (DER) Handbook.

Furthermore, the REGULATIONS have not been cancelled (we will never have such luck). The repair station can still develop its own methods, techniques and practices while performing work to the performance standard of § 43.13.

If those methods, techniques and practices result in major repairs or alterations, the repair station can get technical data approved under § 145.201 demonstrating the actions return the article to at least its original or a properly altered condition.

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 Operations 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

Brexit Resource Page

On June 23, 2016, citizens of the United Kingdom voted to withdraw from the European Union in a national referendum. As the process of making that withdrawal happen drags on. This page is provided as a resource for the aviation maintenance community regarding the transition. Brexit Resource Page

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 Portal

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.

Industry Calendar

the hotline is the monthly publication of the Aeronautical Repair Station Association (ARSA), the not-for-profit international trade association for certificated repair stations. It is for the exclusive use of ARSA members and federal employees on the ARSA mailing list. For a membership application, please call 703.739.9543 or visit arsa.org/membership/join. For information about previous editions, submit a request through arsa.org/contact. This material is provided for educational and informational purposes only. It does not constitute legal, consulting, tax or any other type of professional advice. Law, regulations, guidance and government policies change frequently. While ARSA updates this material, we do not guarantee its accuracy. In addition, the application of this material to a particular situation is always dependent on the facts and circumstances involved. The use of this material is therefore at your own risk. All content in the hotline, except where indicated otherwise, is the property of ARSA. This content may not be reproduced, distributed or displayed, nor may derivatives or presentations be created from it in whole or in part, in any manner without the prior written consent of ARSA. ARSA grants its members a non-exclusive license to reproduce the content of the hotline. Employees of member organizations are the only parties authorized to receive a duplicate of the hotline. ARSA reserves all remaining rights and will use any means necessary to protect its intellectual property.

© 2019 Aeronautical Repair Station Association