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2020 – Edition 1 – February 7

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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.

2020 Annual Conference
ARSA Works
Legal Brief
ARSA on the Hill

Regulatory Update
Training
Membership
Resources
Industry Calendar


2020 Annual Conference

Value Expressed

By Christian A. Klein, Executive Vice President

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March 10-13, 2020 (Add to Outlook Calendar)
Washington, D.C. & Arlington, Virginia

Aviation leaders from around the globe will descend on Washington, D.C. the week of March 9 for what’s shaping up to be the best–and most important–ARSA Annual Conference in years.

The annual meeting has come a long way since the mid-1990s when I, as the lowest person on the totem pole, put my newly-minted law degree to work flipping overhead projector transparencies for speakers. A two-day meeting focused exclusively on regulatory issues has matured into a four-day conference with a broader scope (and, happily for me, better technology!).

To be sure, regulatory issues are still on the symposium portion of the conference, but the event now includes executive and legislative sessions–a full day with top-level administration offices (the Executive to Executive or “E2E” day), the release of the annual ARSA/Oliver Wyman market report  and the grassroots engagement of Legislative Day, when dozens of industry leaders head to Capitol Hill to advance our industry’s congressional agenda. 

The Executive to Executive Briefings

Three years ago, ARSA’s team turned the Fall Strategic Leadership Conference–a venue for executive-level engagement with senior U.S. government personnel–into a component of the association’s annual spring event. That decision turned “Legislative Day and the Annual Repair Symposium” into the “Annual Conference.”

On “E2E” day, a small cadre of ARSA’s most-committed supporters (meeting slots are available only for event sponsors) cover considerable ground in the nation’s capital to meet with key policy officials. This year, participants will make stops at the Department of Labor’s Office of Apprenticeship, Department of State’s Bureau of Economic Affairs and Department of Transportation’s Policy Office, with a break for lunch with colleagues at Airlines for America. Additional meetings are in development with the Department of Commerce’s International Trade Administration and the Department of Defense.

Legislative Day

Legislative Day will be one of the most important in recent memory. The maintenance industry is facing the most significant legislative threat in a decade from the Safe Aircraft Maintenance Standards Act (H.R. 5119), an anti-repair station bill approved by the House Transportation & Infrastructure Committee in November. The legislation is aimed at disrupting the relationship between airlines and maintenance vendors, increasing costs for–and preventing the use of–foreign repair stations and undermining decades of progress in the area of global regulatory cooperation. (For more about the bill, see this month’s ARSA on the Hill).

Along with securing full funding for the aviation workforce grant program that ARSA helped create in last year’s FAA bill, defeating H.R. 5119 is the top legislative priority. The threat is real, the risks are significant, and we need all hands on deck at this year’s Legislative Day to ensure policymakers understand our concerns.

The Symposium

One of the most popular elements on the agenda is the symposium’s “opening salvo” panel, during which regulators from the world’s leading aviation authorities discuss recent developments and are peppered by questions from the audience and ARSA team members. Since last year’s conference, we’ve seen changes to both the U.S.-Canada maintenance implementation procedures and U.S.-European Union maintenance annex guidance (MAG) in addition to EASA opinions on ICA and parts documentation, to name just a few key issues. So, there’s a lot to catch up on in the international regulatory space.

In recent years, ARSA has made industry career development a priority. Not only is workforce policy central to regulatory, legislative and public relations activities, but discussions about technician recruitment and training have become central to the symposium agenda. This year, Brett Levanto will lead a panel discussion on how repair stations can tap into government resources and then Brett and I will facilitate a breakout session “workshop” to discuss what is and isn’t working when it comes to this important topic.

New technologies are rapidly coming online and being adopted by repair stations around the world. Sarah MacLeod will lead a discussion focused on the regulatory implications of these new tools…remember: What’s not prohibited is allowed!

And that’s just some of the content!

The meeting is about more than just learning and impacting policy. Networking is also a key component and the agenda includes multiple receptions, invitation-only meals and ample coffee breaks to enhance connections with other industry leaders and share ideas.

ARSA’s small team puts its heart and soul into producing an interesting, informative and thought provoking meeting for its members. If you’re a regular attendee, we look forward to seeing you and hope you’ll bring at least one new person along for the ride. If you’ve never been before (or haven’t attended in while), we’d love to see you this year. It’ll be worth the trip and worth your time.

But don’t take my word for it–watch this quick video and then register.

 

 


Sponsors Recognized

Sponsors

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March 10-13, 2020 (Add to Outlook Calendar)
Washington, D.C. & Arlington, Virginia

The following list includes all paid sponsors for 2020 as of this posting. To see all the organizations that have committed to sponsoring, visit the event page. To learn more about a specific sponsor, click the appropriate logo.

Platinum Sponsors

        Lufthansa Technik
Moog         Wencor

Gold Sponsors

       
             

Silver Sponsors

         

Contributors

AOG Reaction

  Jet Group   OFM&K   SAFRAN

 


Agenda Explored

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March 10-13, 2020 (Add to Outlook Calendar)
Washington, D.C. & Arlington, Virginia

 

Two years ago, ARSA’s team expanded the conference’s agenda to include four days of meetings, presentations, panel discussions, networking and professional engagement. The new schedule provides engagement with the U.S. government’s executive branch (during the “E2E” briefings), advocacy for the interests of the maintenance community on Capitol Hill (during Legislative Day) and expanding regulatory and business knowledge through direct discussion with representatives from international aviation authorities (during the symposium sessions and breakouts).

Want to know how you can participate in all of this activity? Review the event information right here:

Executive to Executive Briefings: Tuesday, March 9, 2021

Industry executives participate in meetings with senior executive branch officials organized by ARSA. Participation is limited to annual conference sponsors, with the number of slots available to each sponsoring organizations dependent on level of support.

Legislative Day: Wednesday, March 10, 2021

After a morning of briefings and policy updates. Legislative Day participants meet with members of Congress as well as personal 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 – CAVOK, as well as the presentation of the association's Legislative Leadership Award.

Annual Repair Symposium: Thursday, March 11, 2021

The centerpiece of Conference week, ARSA convenes a full day of substantive panel discussions covering key regulatory compliance and business issues. Each year, the day features an extensive "Opening Salvo" review of maintenance and certification matters with representatives from international NAAs including the FAA, EASA, Transport Canada and ANAC Brazil. Additional participants from government organizations and private industry round out the full schedule.

Annual Member Meeting & Breakouts: Friday, March 12, 2021

ARSA's 2021 President – the association's senior volunteer leader – provides the "state of the association" address before the floor is opened for member questions and engagement regarding key issues facing the aviation community. After breakfast, participants may choose from multiple breakout sessions to explore specific topics, which include workforce development, government reform efforts, policy engagement and business matters.
The Leo Weston Award for Excellence in Government Service First bestowed on Leo Weston himself in 2005, the Weston award honors an instrumental figure in ARSA's birth by recognizing individuals who embody his commitment to the industry's safety and success. The symposium provides a venue for association members and invited guests from around the world to network and discuss issues that matter to the aviation maintenance industry. It is the perfect time to respect the history of the repair station community and honor the good works of those who support it. Click here to learn more about the award. For information about the 2020 Weston Award honoree, click here.
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.

Image result for washingtondc.org logo Click the image for more information from the official tourism site of Washington, D.C.

 


Registration Explained

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March 10-13, 2020 (Add to Outlook Calendar)
Washington, D.C. & Arlington, Virginia

Knowing what to expect after registering will help you make the most of the maintenance community’s premier event (and if you’ve already registered, it’ll help you assure everything is in order).

(1) Immediately after you submit a registration form, the system will automatically email you a confirmation of your submission. Regardless of how many individuals are registered via the form (each submission can accommodate up to five), a single confirmation will be sent to the person named at the top of the form. The email will come from arsa@arsa.org and provide a review of all the information entered into the form.

(2) The ARSA events team will review your submission for completeness and accuracy, contacting you regarding any required updates or additions. (If no edits are required, you will receive your invoice.)

(3) The events team will produce and deliver an invoice for the appropriate registration and/or sponsorship fees. If you noted in the form’s comments section that an administrative support person or finance specialist should be included, that person will be CC’d on the invoice delivery message.

(4) Pay your invoiced registration/sponsorship fee (payment instructions provided on invoice).

(5) Book your room (see below for instructions; the hotel is filling up).

(6) Legislative Day attendees should plan for their grassroots advocacy by reaching out to their members of Congress to schedule meetings. For those needing instruction, ARSA’s legislative team will provide a guidance document.

(7) Individuals from sponsoring companies should identify (and inform Christian Klein and Brett Levanto) who will represent the company at the Executive to Executive Briefing Day on March 10.

(8) Ensure your travel arrangements and other logistics are in place. Get ready for a personally enjoyable and professionally enriching stop in the American capital city.

As of Feb. 6, registrations have been received from the following companies…make sure yours gets on the list (this list does not include speakers or government representatives):

A.O.G. Reaction
AAR Aircrft Services, Inc.-Miami
Aero Instruments & Avionics, Inc.
AeroKool Aviation Corporation
Airborne Maintenance and Engineering Services, Inc.
Aircraft Electric Motors, Inc.
Alaska Airlines
All Nippon Airways Company, Ltd.
Aviation Repair Resources, Inc.
Aviation Repair Solutions, Inc.
Aviation Week
Barfield Precision Electronics, LLC
CD Aviation Services
Citadel Completions LLC
Collins Aerospace
Columbia Helicopters, Inc.
Component Repair Technologies, Inc.
Compressed Gas Systems
Continental Aircraft Support, Inc.
Coopesa, R.L.
Delta TechOps
E.B. Airfoils, LLC.
Earp Aviation Repairs LLC
Erickson Incorporated dba Erickson Air-Crane Co., L.L.C.
First Aviation Services Inc.
FlightSafety International
Fortner Engineering & Manufacturing, Inc. (Wencor Group)
Genesis Aviation, Inc.
Gogo LLC
HEICO
      Honeywell
Hong Kong Aircraft Engineering Co., Limited
Jet Aircraft Maintenance, Inc.
Jet Center MFR
Jordan Propeller Service, Inc.
KLM Engineering & Maintenance
L. J. Walch Co., Inc.
Lufthansa Technik AG
Lynden Air Cargo, LLC
Mid-Continent Instruments and Avionics
Moog Inc.
MTU Maintenance Hannover GmbH
Oliver Wyman CAVOK
PPG Aerospace Transparencies
Pratt & Whitney – Columbus Engine Center
QAI Aerospace
Repairtech International, Inc.
Signature Aviation
SONICO, Inc.
Southwest Turbine Inc.
StandardAero Alliance, Inc.
Stein Seal Company
Thales
The Boeing Compnay
The NORDAM Group, LLC-Repair Division
Transport Canada, Civil Aviation
Triumph Actuation Systems
Turbine Controls, Inc.
Wencor, LLC
Windsor Airmotive West Chester Division-Barnes Aerospace

 


Rooms Booked (Is Yours?)

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March 10-13, 2020 (Add to Outlook Calendar)
Washington, D.C. & Arlington, Virginia

As Executive Vice President Christian Klein would (and does) say, the 2020 Annual Conference is on track to be the most successful ever.

This means that space is at a premium, particularly within the block available at the Ritz-Carlton Pentagon City. If you have not yet made your travel plans, here’s what you should do right now to see if there’s any room left at the inn:

(1) Register for the conference, if you haven’t already.

(2) Contact the Ritz-Carlton directly for booking (+1.703.415.5000) and explain you’re part of ARSA’s 2020 Annual Conference. If rooms are available, even outside of the block reserved for attendees, the reservation staff will help with preferred rates.

(3) If you need to search for other options, view the “Location & Accommodations” information on the Conference event page for assistance.

Wherever you’re going to lay your head at night, make sure to get your rest. Conference week will keep you busy.

 


Annual Member Meeting Announced

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March 10-13, 2020 (Add to Outlook Calendar)
Washington, D.C. & Arlington, Virginia

The ARSA Annual Member Meeting is held in conjunction with the Conference; this year it will take place during the Breakfast and Annual Report on Friday, March 13 at 8:00 a.m. at the Ritz-Carlton, Pentagon City in Arlington, Virginia.

ARSA President Ian Cheyne will address members regarding the state of the association. After Cheyne’s presentation, attendees are welcomed and encouraged to discuss matters relevant to ARSA and the industry it represents.

If you are unable to attend – conference registration is open – but would like to submit comments/questions to ARSA’s board, please do so via the mechanisms available on arsa.org/contact.

 


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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 February 2020 (click each page link for more information and instructions):

Make sure you have a place to sleep at the Annual Conference…

Room at the Inn
Registration is open for ARSA’s 2020 Annual Conference, which will be held in and around the nation’s capital from March 10-13. As Executive Vice President Christian Klein would (and does) say, the event is on track to be the most successful ever.

Protect the industry from crippling congressional overreach…

ARSA, Allies Brief World Diplomats on H.R. 5119 Risks to Global Aviation
On Jan. 22, ARSA Executive Vice President Christian Klein led a delegation of aviation association executives to the Royal Netherlands Embassy in Washington, D.C. The group briefed foreign diplomats on risks to global aviation posed by the Safe Aircraft Maintenance Standards Act (H.R. 5119). More than two dozen transportation attachés attended the meeting with ARSA and representatives from the International Air Transport Association, the Aerospace Industries Association and the General Aviation Manufacturers Association.

Tell the FAA to end the unnecessary requirement for “current” maintenance data…

Support ARSA Rulemaking Petition to Limit “Current” Data Burden
The association encourages its members to comment in support of the petition.

 


What ARSA Has Done Lately – Fourth Quarter 2019

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 October and December 2019:

Regulatory Advocacy

  • Submitted petition for rulemaking to remove “current” maintenance data requirement by deleting the second sentence from § 145.109(d).
  • Developed and provided members with detailed summaries of change 7 to the U.S.-EU Maintenance Annex Guidance.
  • Invited members to comment on EASA regulatory impact assessment methodology
  • Submitted VP of Regulatory Affairs Joe Corrao to EASA as new primary representative to the Engineering & Maintenance Technical Committee.
  • Opposed efforts – subsequently withdrawn – by an airframe manufacturer to impose a surcharge to access maintenance and repair data.
  • Provided trade media with preliminary comments on EASA Opinion 07/2019 concerning ICA and installation of parts and appliances released without an EASA Form 1 or equivalent.
  • Submitted a Freedom of Information Act (FOIA) request for copies of FAA’s “Risk Based Resource Targeting Alternative” (RBRTa) and “Risk Based Resource Targeting ODA” (RBRTo) data collection forms (blank).

Legislative and Lobbying

Communications and Surveys

ARSA in the News – Selected Industry Coverage

Boeing 737 MAX Fiasco Brings New Scrutiny To “Insane” Gap In Oversight Of Foreign Repair Stations
Nov. 20, 2019
Forbes
The Boeing 737 MAX fiasco has brought airline labor unions new hope that they can finally change the way foreign aviation maintenance bases are regulated.

Foreign Aircraft Repair Stations Return to Hill Spotlight
Nov. 27, 2019
Politico
The bottom line: It looks like there could be enough momentum for the legislation to pass the House, but Senate passage is problematic given the lack of Republican support and powerful interests lined up against it.

Congress Fully Funds New Aviation Maintenance Workforce Grant Program
Dec. 17, 2019
AviationPros
In a major victory for the aviation maintenance industry, the FY 2020 appropriations deal unveiled by House and Senate negotiators Dec. 16 includes full funding for a new aviation technician workforce development program.

ARSA-placed Industry Editorials

AMT Magazine Only the Paranoid Survive: Overcoming Complacency
October Edition | Christian A. Klein
Do Your Homework
November/December Edition | Brett Levanto
Aviation Week Regulators Should Focus On Facts And Cooperation
October Edition | Sarah MacLeod
Restricting Airworthiness Info Access Is Against FAA Policy
November Edition | Sarah MacLeod
The Aftermarket Is Facing Congressional Scrutiny
December Edition | Christian A. Klein
DOM Magazine Meet Me Halfway
October Edition | Sarah MacLeod
Inventing the Same Wheel
November Edition | Brett Levanto
Just Admit It!
December Edition | Sarah MacLeod, Christian A. Klein, Brett Levanto

Surveys

Events, Meetings and Training

Meetings

  • Oct. 9: Christian, Sarah and Brett participated in a conference call with International Air Transport Association staff regarding design approval holder issues.
  • Oct. 24 & 25: Marshall participated in the Maintenance Management Team meeting Cologne.
  • Nov. 6: Christian participated in the Cargo Airline Association’s legislative meeting and congressional reception.
  • Nov. 7: Christian and Sarah participated in meeting with UTC leadership and representatives from the Aerospace Industries Association and the General Aviation Manufacturers Association regarding pending legislative and regulatory issues.
  • Nov. 13: Brett participated in the Joint Services Aviation Maintenance Technician Credentialing Council meeting.
  • Nov. 13: Sarah participated in the FAA Safety Oversight and Certification Advisory Committee meeting.
  • Nov. 14: Christian and Brett participated in a conference call regarding workforce development opportunities with Ed Jung, vice president of operations and maintenance at CVG airport.
  • Nov. 14: Christian and Brett met with Bud Oakey, president of the Virginia Business Aviation Association.
  • Nov. 18: Christian, Brett, Sarah, Joe and Marshall met with EASA U.S. representative Thomas Mickler.
  • Nov. 21: Christian, Brett, Sarah and Joe met with the Department of Commerce’s International Trade Administration aerospace team.
  • Nov. 5: Marshall participated in the EASA EM.TEC meeting in Cologne.
  • Nov. 10: Christian participated in the TSA Aviation Security Advisory Committee meeting.
  • Nov. 12: Sarah participated in the FAA Aviation Rulemaking Advisory Committee meeting.
  • Nov. 13: Christian and Brett participated in conference call with Oliver Wyman regarding ongoing collaboration.
  • Nov. 19: Brett participated in the Choose Aerospace Steering Committee conference call.

Training

 


Support ARSA Rulemaking Petition to Limit “Current” Data Burden

On Dec. 23, 2019, ARSA submitted a petition for rulemaking to delete the last sentence of 14 CFR § 145.109(d). This sentence requires repair stations – and no other maintenance providers – to maintain libraries of “current” data, even when current data are not required for the work being performed; even when “current” data are wrong for the specifics of the work.

Three days later, FAA assigned ARSA’s petition to the rulemaking docket. The docket number is FAA-2019-1106 and it is now open for comment.

The association encourages its members to comment in support of the petition. To do so, access the docket on the Federal Register by visiting: https://www.regulations.gov/docket?D=FAA-2019-1106.

For background on the effort, review the content on arsa.org/145-109.

 


Focus on Healing Our Friend

On Jan. 10, U.S. Department of Transportation Inspector General Calvin L. Scovel, III announced his retirement from federal service to focus on his family and to battle prostate cancer. Scovel has served as the department’s chief internal auditor and investigator since 2006, making him the longest tenured IG in the DOT’s history. A review of his career path and the accolades and achievements along the way reveal that the ability to negotiate the hot winds of the executive, legislative and media for thirteen years was based upon hard work, knowledge and fairness.

During Scovel’s tenure, ARSA enjoyed a professional and productive relationship with the IG’s office. The association regularly provided insight, resources and industry connections for the office’s research teams and included its personnel in annual events. Most recently, Scovel provided the keynote address at ARSA’s 2018 Annual Conference.

“Calvin Scovel – ‘call me Cal’ – and I enjoy the same sense of humor, which is often based upon the irony associated with his office auditing another government agency,” ARSA Executive Director Sarah MacLeod said. “ARSA was always welcome in his office where constructive criticism was not dismissed out-of-hand. Although the association and government will miss his wise and steady counsel, he has certainly earned time with his family, which will create a more conducive climate for healing.”

To acknowledge his departure, ARSA looks back to Scovel’s “friendly visit” to its Annual Conference in 2018. The event was recounted for the members on via the March 2018 edition of the hotline by Kevin George, who demonstrates his boss’ personal touch with each familiar reference to “Cal’s” work:

the hotline March 2018 – 'Quality Time'

(Click here) Recapping the IG’s 'Friendly Visit' to Symposium

From the “Quality Time” section…

Editor’s note: The views and opinions expressed by contributing authors do not necessarily state or reflect those of ARSA and shall not be used for endorsement purposes. 

Recapping the IG’s “Friendly Visit” to Symposium

By Kevin F. George, Aviation Safety Audits Project Manager, U.S. Department of Transportation

On March 15, DOT Inspector General Calvin Scovel, III delivered a speech on the IG office’s work on aircraft repair stations at ARSA’s Annual Repair Symposium in Arlington, Virginia. Executive Director Sarah MacLeod invited Cal to be the keynote speaker at the event, which is part of the association’s work to improve aviation safety and security and shape public policy through collaboration with the FAA and other world regulators.

Cal began by noting that the U.S. aviation system, which handles more than 30,000 flights a day, has a remarkable safety record and that the aircraft maintenance professionals play an important role in ensuring the nation’s aircraft are maintained appropriately and operate safely. He explained that OIG’s auditors and investigators also work tirelessly to improve the performance and integrity of DOT’s programs and ensure a safe, efficient and effective national transportation system. Cal reminded the group that we do not audit air carriers or repair stations. Our focus is on the FAA, and we visit air carriers and repair stations to assess how, when and where the agency conducts its oversight role.

DOT Inspector General Calvin Scovel, III provides his keynote address on March 15 during ARSA’s Annual Repair Symposium.

Cal then took the audience on a stroll down memory lane by recollecting the last 20-plus years of OIG’s work on repair stations:

In a 2003 report, for example, we called for the FAA to adopt a risk-based approach to repair station oversight because inspectors cannot realistically visit all repair stations in the world every year.

In 2008, we identified inconsistencies in how air carriers defined heavy aircraft maintenance repairs; as a result, the FAA—with ARSA’s help—developed a more uniform definition that helped improve its oversight of all repair stations. This is a clear example of the importance of effective FAA and industry cooperation in aviation safety matters.

In 2013, we reported that while the FAA had made progress, its oversight system was not yet truly “risk based” because repair stations were not always inspected based on risk. Inspectors continued to conduct their oversight annually at many foreign repair stations whether there was risk or not.

He also spoke about our 2015 review of the U.S./EU aviation safety agreement; aviation authorities in 18 European countries now perform direct oversight and certification of repair stations on the FAA’s behalf. This reciprocal agreement also permits FAA inspectors to conduct oversight of EU-certificated repair stations in the United States. But most important, it allows the FAA to more effectively use its scarce inspector resources where they are needed the most.

Next Cal focused on an issue that is the “bread and butter” of the aviation industry: ensuring that aircraft are maintained safely. That means keeping a watchful eye out for unapproved parts, which pose serious risks to aircraft when they enter the aviation supply chain. Our 2017 report identified multiple inaccuracies in the FAA’s database of unapproved parts. Furthermore, the FAA does not take action to confirm that airlines and repair stations actually remove unapproved parts from the supply chain. In fact, as AIG Matthew Hampton told the House Subcommittee on Aviation in February, we are currently investigating 65,000 unapproved Boeing parts that were for sale on eBay and found their way back into the supply chain.

Cal concluded by stating that while we don’t have any new audit work planned for repair stations, we have a few ongoing projects that may be of interest to the aircraft maintenance industry—air carrier maintenance, aircraft registry and the aviation drug abatement program.

The Office of the Inspector General conducts audits and investigations on behalf of the American public to improve the performance and integrity of DOT’s programs to ensure a safe, efficient, and effective national transportation system. To learn more and access reports and advisories, visit www.oig.dot.gov.

 


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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.

The DOT’s Gift of Clarity

By Joseph Corrao, Vice President of Regulatory Affairs

The U.S. Department of Transportation (DOT) published an industry holiday present in the Federal Register with a new rule bringing clarity to rulemaking, guidance and enforcement. The regulation applies to all DOT operating agencies, including the FAA, and directly impacts making or changing regulations and guidance, and conducting enforcement activities.

The DOT insists that “this final rule merely incorporates existing internal procedures…into the Code of Federal Regulations…”. While true, a rule carries more weight than the “internal procedures” which are applied or forgotten when it suited agency personnel. Evidence of that hit-or-miss approach is evident by the fact that the rulemaking action was the result of “a December 20, 2018, petition…from the New Civil Liberties Alliance that asked the Department to promulgate regulations prohibiting departmental components from issuing, relying on, or defending improper agency guidance.” (Emphasis added.) Now that DOT has formalized these procedures, greater consistency can result—but only if the “public” that the agencies serve hold them accountable. (As of this writing, the electronic Code of Federal Regulations has not yet incorporated the new rule. When it does, you’ll find the core of the new rule in part 5.) it looks like they have been updated. When linking do not link “part” or the “CFR” only the title and the number.

The new rule answers previously vexing questions.

While a rulemaking action is underway, are FAA personnel permitted to meet or speak with private sector stakeholders to hear their views on the pending rulemaking action? The answer is clearly yes.[1]

Anyone can petition FAA to change a rule or grant an exemption, is that it?[2] The rule makes clear the public can submit petitions to issue, change or remove guidance or initiate a regulatory review.[3] It also instructs DOT agencies on how to conduct a regulatory review and how to determine that an old regulation has outlived its usefulness.[4]

Guidance issued by DOT agencies can be more closely and consistently scrutinized by federal leaders, lawyers and the industry. “Guidance” is defined broadly; the rule notes that “guidance may come in a variety of forms, including (but not limited to) letters, memoranda, circulars, bulletins, advisories, and may include video, audio, and Web-based formats.”[5]

Additionally, in a significant and very welcome development, guidance is subject to economic evaluation.[6] DOT acknowledges–in rule text, not just in the preamble!–that “guidance may induce private parties to alter their conduct to conform to recommended standards or practices, thereby incurring costs beyond the costs of complying with existing statutes and regulations.”[7] The new rule directs DOT agencies to estimate these costs and balance them against the benefits of the guidance. The new rule even mandates public notice and comment for proposed guidance in many circumstances.[8]

Enforcement receives equally welcome treatment. The department states that it “will not initiate enforcement actions as a ‘fishing expedition’ to find potential violations of law in the absence of sufficient evidence in hand to support the assertion of a violation.”[9] That sounds a lot like a “probable cause” standard.

In a legally stunning development, DOT states it “will not rely on judge-made rules of judicial discretion, such as the Chevron doctrine, as a device or excuse for straining the limits of a statutory grant of enforcement authority.”[10] That may be inside baseball for lawyers, but it has great significance for anyone in the crosshairs of an FAA enforcement action. It means that DOT lawyers will not permit agency personnel to take legally questionable positions just because a reviewing court might suspend its reasoning ability to let it happen.

While the new rule does not repeal FAA’s existing rules for rulemaking or enforcement, 14 CFR part 11 and part 13; rather it is best to think of DOT’s new regulation as supplementing FAA’s current rules, and where the old and new yield different results, the new controls.

The holiday surprise offers a smile on every page, almost in every paragraph. Reading it unwraps a whole set of gifts.

End Notes

[1] 49 CFR § 5.19
[2] 14 CFR § 11.61 et seq.
[3] 49 CFR §§ 5.13(c), 5.43
[4] 49 CFR §§ 5.9, 5.13(d)
[5] 49 CFR § 5.25(c)
[6] 49 CFR §§ 5.33 to 5.39
[7] 49 CFR § 5.33
[8] 49 CFR § 5.41
[9] 49 CFR § 5.67
[10] 49 CFR § 5.65

 


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ARSA on the Hill

Let’s Do it Again

By Christian A. Klein, Executive Vice President

Key points this month:

  • 2nd Session of 116th Congress kicks off with packed agenda
  • Here we go again: With 2020 appropriations process done and aviation workforce grant program fully funded, the process starts all over
  • ARSA’s ramped up opposition to the anti-repair station bill … what have YOU done?

Both 2018 and 2019 were remarkably successful years for ARSA’s legislative advocacy efforts. The new year is already off to busy start in Washington, D.C.

It’s an election year, which means the there’s less time to legislate given that members of Congress will be spending more time in their districts than last year. ARSA expects the House Transportation & Infrastructure (T&I) Committee to unveil aviation safety legislation related to the Boeing MAX accidents and FAA certification in the coming weeks. But there are other high priority, must-do items on the committee’s agenda that are going to consume time and attention, including the reauthorization of the federal highway and transit programs (worth more than $55 billion per year) and the Water Resources Development Act, which funds Army Corps of Engineers navigation and flood control programs.

ARSA has two top priorities for the year: building on the success of aviation workforce initiatives and preventing the enactment of the anti-repair station bill approved by the House T&I Committee in November.

To read ARSA’s entire legislative agenda for the 2nd session of the 116th Congress, click here.

Want to Learn More About ARSA PAC?

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

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

Click here to give ARSA your consent today.

 


Full Funding for the Workforce Grant Programs

The year ended on a high note for ARSA, as Congress appropriated full funding for new aviation maintenance workforce grant program that ARSA led the charge to create as part of the 2018 FAA reauthorization bill. The $5 million appropriated for FY 2020, will provide grants of up to $500,000 to schools, businesses, labor organizations and governmental entities that collaborate to recruit and train technicians. Unfortunately, the FAA hasn’t created a grant application process, through a Federal Register notice published late last year suggests that the agency is moving in that direction.

The FAA bill authorized $25 million for the grant program over five years (FYs 2019 to 2023). However, Congress must appropriate money to fund it each year. The 2020 appropriations process finished very late (FY 2019 ended on Sept. 30, but the president didn’t sign the FY 2020 appropriations bill for transportation programs into law until Dec. 20). That means there’s barely time to catch a breath before the FY 2021 process kicks off in the coming weeks.

ARSA will again be coordinating coalition activities with the goal of securing full funding for the program for FY 2021 (which begins on Oct. 1). Do your part and help kick start the process by using ARSA’s Workforce Legislation Action Center to send a quick note to your congressman and senators expressing support.

 


Anti-Repair Station Bill Would Cause Major Disruptions

2019 saw the emergence of the most significant legislative threat to contact maintenance in more than a decade. The Safe Aircraft Maintenance Standards Act (H.R. 5119) was introduced by House T&I Committee Chairman Peter DeFazio (D-Ore.) on Nov. 15 and rushed through his committee with no hearings or opportunities for industry comment just five days later.

If the bill becomes law, the more than 1,500 U.S. repair stations with foreign approvals and their employees would almost certainly be targets of retaliation by foreign authorities. Foreign repair stations would be subject to new and unnecessary requirements that do nothing to further safety. The bill includes an immediate ban on new repair station certifications and renewals in certain countries. U.S. air carriers and their maintenance vendors would be subject to burdensome new recordkeeping requirements. U.S. commercial and general aviation operations outside the country would be disrupted because of a shortage – or complete lack of – FAA-certificated maintenance facilities in destination countries. U.S. manufacturers seeking to provide product support in growing foreign markets would be prevented from obtaining FAA certification at those overseas facilities.

Additionally, FAA resources – already stretched thin – would be diverted to activities with little or no safety benefit. And if the FAA fails to complete a large (and virtually impossible) laundry list of tasks within one year of the bill’s enactment, the agency would be barred for certificating new facilities outside the United States.

To read more about what the bill would do, click here.

Coordinating the Message on H.R. 5119

(Click here) From 1/30/20 - ARSA, Allies Brief World Diplomats on H.R. 5119 Risks to Global Aviation

January 30, 2020

On Jan. 22, ARSA Executive Vice President Christian Klein led a delegation of aviation association executives to the Royal Netherlands Embassy in Washington, D.C. The group briefed foreign diplomats on risks to global aviation posed by the Safe Aircraft Maintenance Standards Act (H.R. 5119). More than two dozen transportation attachés attended the meeting with ARSA and representatives from the International Air Transport Association, the Aerospace Industries Association and the General Aviation Manufacturers Association.

During the briefing, Klein and his colleagues discussed the status and impact of the legislation, which would significantly disrupt the relationship between – and impose new burdens on – U.S. airlines and their maintenance contractors (particularly those overseas) and make it more difficult for U.S. aerospace companies to operate globally.

Klein told the group that aside from the direct impact on industry, the legislation would threaten bilateral aviation safety agreements between the United States and its partners, undue decades of progress in the area of regulatory cooperation and increase oversight and compliances costs for government and industry.

More information about the bill, ARSA’s efforts to prevent it from becoming law and what you can do to help is available in the association’s online action center at arsa.org/legislative/hr5119-actioncenter. ARSA encourages its international members to contact their foreign ministries and embassies in Washington, D.C. and encourage their diplomats to engage on this issue.  Contact information for embassies is at www.embassy.org/embassies.

To review the presentation given by Klein and his associates, click here.

ARSA is leading a coalition of air carriers and manufacturers in opposition to the bill. Our activities in December included developing a website and collateral to support member and partner engagement, hosting Dec. 5 webinar for ARSA members (recording availably by clicking on the link), drafting and coordinating Dec. 17 opposition letter to House leadership and distributing to all House offices and designing the coalition’s lobbying strategy.

Although the bill hasn’t progressed beyond the committee stage in the House and we’ve heard nothing about a possible companion bill, ARSA isn’t taking any chances and has kept up the pressure since the new year. In January, ARSA created new resources to support member media outreach about the bill, hosted a webinar for media relations professionals from the industry and our partner organizations to discuss communications strategies, led a delegation that briefed the assembly of embassy aviation and transportation attaches about the risks the bill poses to global safety cooperation and coordinated more than a dozen meetings with key congressional offices.

Although ARSA is doing everything it can to defeat the bill, our resources are extremely limited and your personal engagement is critical to helping ensure it doesn’t become law.

Here are some things you can do to help:

  • Send a letter to the editor of your local paper objecting to H.R. 5119. Click here for a Word document with draft letters to the editor (including employment and economic data) for all 50 states (just cut and paste). Click here for editorial page contact information for publications in your state.
  • Click here to download a template message that can be used to communicate with your congressional representatives and let them know that there are repair stations in their state that will be impacted by H.R. 5119. You can find out who your representatives are by going https://www.govtrack.us/congress/members and download a list of aviation staffers in each office by clicking here.
  • If you’re a non-U.S. company, contact your embassy in Washington, D.C. and urge your diplomats to engage on this issue.
  • Tell your colleagues at non-member companies to join ARSA. We are the voice for the industry. The more members we have, the more effective advocates we’ll be for you. Don’t be shy about sending us member recruitment suggestions.
  • Host a member of Congress at your facility to SHOW them what your company and colleagues do. ARSA is standing by to help.
  • Learn more about how ARSA PAC supports our advocacy efforts on your behalf and give us permission to ask for your support (Note: ARSA accepts PAC contributions only from owners and senior executives of U.S. member companies that have given written permission to be solicited in accordance with the Federal Election Campaign Act. This is not a solicitation.)

 


Make Your Own Mark

Sponsors

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Registration

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Information

March 10-13, 2020 (Add to Outlook Calendar)
Washington, D.C. & Arlington, Virginia

Legislative Day (March 11) has become an important part of the Annual Conference and a vital opportunity to make the maintenance industry’s voice heard on Capitol Hill.

H.R. 5119 be front and center during our Hill meetings. Support the association’s advocacy for you by registering now for the conference.

 


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Regulatory Update

U.S. & Japan Extend IPA Implementation Date

On Jan. 30, the FAA Aircraft Certification Service’s International Division announced an extension of the compliance date for revision 1 to the Implementation Procedures for Airworthiness (IPA) between the agency and the Japan Civil Aviation Bureau (JCAB). The new implementation date is March 30, 2020.

“The Authorities acknowledge the unanticipated circumstances and delays that led to the decision to extend this period and recognize the importance of fulfilling the necessary regulatory requirements to support the proper implementation of the IPA,” the announcement said.

Until the new deadline, all Japan-related validation applications submitted to the FAA will utilize the IPA signed in April 2009 (see below).

To access revision 1 of the IPA, which will become effective on March 30, click here.

To review the FAA’s announcement, click here.

To visit the FAA’s listing of bilateral agreements and related documentation, click here.

For questions related to the FAA-JCAB IPA, contact:

For the FAA

Aircraft Certification Service
International Division, AIR-40
E-mail: 9-AWA-AVS-AIR400@faa.gov

For the JCAB

Aviation Safety and Security Department
Airworthiness Division
E-mail: hqt-CAB-GIJ-KKA@gxb.mlit.go.jp

 


FAA Assures “No Change” In Immediate Brexit Aftermath

On Jan. 30, FAA Associate Administrator for Aviation Safety Ali Bahrami distributed a letter to the aviation community regarding the forthcoming departure of the United Kingdom from the European Union. Citing several years of effort between U.S. and British regulators, Bahrami affirmed that the political separation will have no immediate impact on transatlantic aviation business.

“[There] will be no change to the current procedures associated with the exchange of aviation goods and services between the United States and the UK,” Bahrami said. “The FAA, the UK Civil Aviation Authority…and the European Union Aviation Safety Agency…will continue to use the procedures established in the U.S.-EU Safety Agreement and EASA will continue to represent the UK CAA as its technical agent.”

Bahrami noted that more work must be done as the UK and EU negotiate their long-term relationship. This effort, including refining the U.S.-UK regulatory relationship, will continue up to and through the Dec. 31 end of the “Brexit” transition period.

To read Bahrami’s letter, click here.

To access ARSA’s information page on Brexit, click here.

 


DOT Rule Revises Rulemaking, Guidance Development

On Dec. 27, the U.S. Federal Register published a Department of Transportation final rule regarding “administrative rulemaking, guidance and enforcement procedures.” The new rule applies to the FAA as well as other DOT operating agencies and the elements of the Office of the Secretary of Transportation, all of which must abide by the new rule when they make or change regulations, issue or change guidance, and conduct enforcement investigations and actions.

“This final rule sets forth a comprehensive revision and update of the department’s regulations on rulemaking procedures and consolidates all of [its] existing administrative procedures in one location,” the agency said. “This final rule also incorporates and reflects … current policies and procedures relating to the issuance of rulemaking documents. In addition, this update codifies … internal procedural requirements governing the review and clearance of guidance documents and the initiation and conduct of enforcement actions, including administrative enforcement proceedings and judicial enforcement actions brought in federal court.”

To access the Federal Register docket and review the rule, click here.

For a complete review, refer to this month’s Legal Brief.

 


FAA Airman Testing System Changes

On Jan. 13, the FAA implemented its new Airman Certification Testing Service (ACTS). All applicants for airman certification must utilize the ACTS to register for an appropriate tracking number, though individuals seeking mechanic certificates or Inspection Authorization will continue using paper certification forms after initial account creation.

In early January, the FAA released a series of resources providing instruction for ACTS use. As explained on the agency’s informational webpage – and in a supporting webinar – the new system is the product of a contract awarded in 2019 to PSI Services.

“The ACTS contract provides a comprehensive, best practices approach to enhance the overall quality of FAA Airman Knowledge Testing,” the agency said. “The ACTS vendor supports the FAA in development, assessment, maintenance, and delivery of airman knowledge tests. The vendor also enhances knowledge test items, knowledge tests, and supplementary material with automated state-of-the-art technology and academic expertise.”

What is Actually Changing?

Not much, especially for mechanic and IA applicants whose actual testing process will not yet be run through the new system.

All certificate applicants must register an account with the Integrated Airman Certification and Rating Application (IACRA). The system will provide each applicant with an FAA Tracking Number (FTN), which must be available throughout the testing process and will become the means through which the applicant’s progress is recorded.

Airman Knowledge Test Reports (AKTR) will now be available through IACRA. These reports will no longer have an embossment or raised seal, but may easily be re-printed in the event one is lost or damaged. The system will store all testing progress information for each applicant, which may be accessed by referencing his or her FTN.

Individuals already holding a mechanic’s certificate or IA have had an FTN generated for them. Should a certificate holder require additional FAA testing, i.e., adding a rating, applying for IA, he or she will need to retrieve the number from IACRA.

For more information on ACTS, visit www.faa.gov/training_testing/testing/acts or send questions to airmanknowledgetesting@faa.gov.

 



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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Training

ARSA Training Benefit for HELI-EXPO Course Attendees

From Jan. 26-29, ARSA’s great regulatory minds were at HAI HELI-EXPO 2020 in Anaheim, California. Individuals with certificates from their courses will be given access to one free hour of ARSA online training.

Find out how…

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.) lead a number of professional education courses as well as three “Rotor Safety Challenge” presentations.

Any participant who completed one of their professional education courses (which were provided on behalf of OFM&K) and submits his or her completion certificate to ARSA Vice President of Operations Brett Levanto (brett.levanto@arsa.org) will be given a code to access one free hour of ARSA online training.

For anyone who wasn’t able to benefit from Filler and MacLeod’s expertise in Anaheim, the association has ample opportunity to take a seat in one of their online courses. Among the 80+ sessions available in ARSA’s online training library, the following might be of particular interest (and are available on-demand for immediate access):

Building a Professional Government Relationship
This session provides a roadmap for building a useful relationship with civil aviation authorities. It begins by describing the rules that should always be considered when engaging with aviation safety regulators, then provides instruction on how to introduce your company and maintain consistent contact – not just when there’s a problem. It concludes by providing strategies for maintaining a professional relationship with regulators.
Click here to register and get access for 90 days.

Public Aircraft Operations
This three-part series on the regulations and guidance for public aircraft operation will provide in-depth analysis and case-study review of various requirements. Sessions must be purchased together and viewed in order, completion of each pre-requisite – either via a live session or on-demand recording – is required for access to subsequent classes.
Session 1 – The Law and Regulations
Session 2 – FAA Guidance
Session 3 – Case Study 
Click here for package information.

Recordkeeping for Mechanics
This session defines the regulatory responsibilities of the operator versus the maintenance provider in creating and maintaining maintenance records, including how obligations can be shifted by contract, but not under aviation safety regulations. It also covers maintenance recordkeeping regulations; the documents essential to making airworthiness determinations.
Click here to register and get access for 90 days.

Recordkeeping for Repair Stations
This session delineates the differences between operator maintenance records and those required to be created, maintained and provided by repair stations.
Click here to register and get access for 90 days.

Regulations Impacting the Purchase of Aircraft Parts
The course reviews the civil aviation regulations in 14 CFR that impact the purchase of civil aviation parts, as well as other requirements that should be considered when making such purchases.
Click here to register and get 90-days of access to the recording.

Regulations Impacting the Receiving, Inspection and Stocking of Aircraft Parts
The course reviews the civil aviation regulations in 14 CFR that impact the receiving, inspecting and stocking of civil aviation articles for maintenance purposes, as well as other requirements that should be considered.
Click here to register and get 90-days of access to the recording.

Regulations Impacting the Sale of Aircraft Parts
The course reviews the civil aviation regulations in 14 CFR that impact the sale of civil aviation articles, as well as other requirements that should be considered when selling parts.
Click here to register and get 90-days of access to the recording.

Self Disclosure – The Elements
This session will review the elements of self-disclosure established by the FAA. It will cover the who, what, why, when, where and how of filing a voluntary self-disclosure report with the agency. Additionally, it will cover how the agency is to handle the report and its expectations for follow up actions.
Click here to register and get access for 90 days.

Self Disclosure – How to Avoid Self-Exposure
This session will review the best methods for investigating a potential non-compliance, including how to distinguish between business and regulatory requirements and how to use language that relates facts to the regulations without creating unnecessary consternation or scrutiny. To obtain the most from this session, participants must have a basic knowledge of the FAA’s program elements.
Click here to register and get access for 90 days.

Registration for an ARSA-provided training session includes:

  • Unlimited access for 90 days to the recording made available after the live session is complete.
  • A copy of the presentation and all reference material with links to relevant resources and citations.
  • A certificate upon completion of the class, as well as any test material.

The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit potomaclaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.

 



Make a Difference in Washington

The Constitution’s First Amendment protects the right “to petition the government for a redress of grievances.” Unfortunately, the average citizen never directly engages their lawmakers on issues important to their personal, professional or community needs. The session will overview basic strategies for communicating with key lawmakers and their staff to become an effective advocate for their interests.

It will also provide a basic overview of the activities contained in ARSA’s Legislative Day on March 11 and will provide useful guidance for 2020 attendees (the session was recorded in 2016 – it is not specific to this year’s event).

Click here to register for immediate access.

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.

 


Regulatory Compliance Training

Test your knowledge of 14 CFR § 1.1 – Definitions and Abbreviations [selected definitions beginning with “A”].

Click here to download the training sheet.

 


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Membership

Showing Class – CRT University Begins First Semester

On Jan. 24, ARSA Member and 2020 Conference Gold Sponsor Component Repair Technologies (CRT), of Mentor, Ohio, launched the first semester of CRT University, an onsite associate degree program in partnership with Lorain County Community College (LCCC). CRT and LCCC have developed a program specifically tailored to employees who are interested in obtaining a technical degree while leveraging the knowledge and expertise gained through employment and on-the-job experience.

The inaugural class includes ten current CRT employees who will take three classes per semester towards an Associate Degree of Applied Science in Mechanical Engineering Technology. The program will take roughly three and a half years to complete and all classes will be taken either online or onsite at CRT. Employees in the program are paid for their time in class and the full cost of tuition is covered by CRT. Onsite courses will be taught by CRT employees who have undergone a process to become adjunct faculty of LCCC.

“We could not be more excited about the launch of CRT University” says CRT Human Resources Manager John Gallagher. “We think this is a huge win for CRT, our employees and Lorain County Community College. This type of collaboration benefits everyone involved. CRT employees who might not otherwise utilize tuition assistance can further their educational path right in the workplace. LCCC can partner with a business two counties away and CRT employees with a desire to teach can become adjunct college professors in their current workplace. It’s amazing when you step back and realize how many barriers have removed here.”

 “In our industry we are constantly training and evaluating the team to make sure we are adhering to quality standards while also arming our workforce with the skills they need to succeed. What makes CRT University unique is that we are not just meeting traditional employee development needs, we are combining the full force of an accredited university with real world practical application. Employees will expand on the skills and competencies they are already using, learn the principles behind them and be able to immediately apply what they learn.” said Cory Hutter, training supervisor.

To learn about another program at CRT – S.O.A.R. – launched last year to work with job candidates and parents, click here to read the May 2019 edition of the hotline.

For more information about the S.O.A.R. program, contact Kristin Conteen or John Gallagher.

Component Repair Technologies, Inc. (CRT) is an FAA certificated repair station specializing in gas turbine engine component repairs for air, land, and sea. Our wide variety of processes and skilled employees have positioned us as leaders in the aviation, industrial, and marine turbine component repair industry. CRT has built a reputation for quality and responsive service by providing precision turbine engine component inspection, repair and overhaul services for the world’s leading turbine engine manufacturers and major airlines since 1985. Visit componentrepair.com for more information.

 


Don’t Let Technology Keep You From ARSA

Thanks to spam filters, firewalls and quarantines, it can sometimes be difficult to get into your inbox – help us get through. Get access to every newsletter, update and reminder by ensure that the following domains don’t get flagged as spam:

@arsa.org (direct emails/alerts)
@potomac-law.com (messages from members of ARSA’s management team)
@multibriefs.com (periodicals/newsletters)
@sendgrid.net (automated membership reminders from ARSA’s database)

Know What to Look For

Weekly: The Dispatch newsletter is distributed every Wednesday.
Monthly: The hotline newsletter is distributed the first week of each month.
Various:  Member alerts are distributed as necessary – usually the association sends two or three each month.
Membership Term Dependent: Renewal reminders begin flowing out of the system 90 days before the expiration of membership term.

Avoid Duplication

From time to time and for various reasons, members report duplicate delivery of ARSA emails. If this happens to you, contact Brett Levanto to explore the problem and try to correct it.

To learn more about ARSA’s communications efforts – including how to advertise – visit arsa.org/news-media. For assistance with technical issues, consult your organization’s IT department/assistant as necessary.

 


Serving Through Survey Responses – Oliver Wyman and ARSA

The first quarter of the year brings two key opportunities to share insight in service of the aviation maintenance community. ARSA encourages its members to invest some time and thought into these two industry surveys:

(1) ARSA’s Annual Member Survey. The association gathers intelligence on issues facing the international aviation maintenance community and its economic outlook. Responses improve the association’s services and provide data to support advocacy on behalf of the global aviation industry.

The first invitation will be delivered to the inboxes of all primary contacts during the week of Feb. 10. (If you don’t know who the primary contact is, we can help.) Ensure the invitation makes it to your primary contact and that it gets the attention it deserves. Direct any questions to brett.levanto@arsa.org.

(2) Oliver Wyman’s MRO Survey. 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 should take no more 15 minutes and can be accessed from your mobile device or computer. It will close on Feb. 14.

Participants will be given the option to receive a summary of the survey results in addition to the full report launched at this year’s MRO Americas in Dallas.

To participate, please visit: http://oliverwyman.co1.qualtrics.com/jfe/form/SV_9H9dbxb6CDDuOsR

Responses are confidential and all information provided by participants will be reported in aggregate only. Questions about the survey may be directed to our research team at: MROsurvey@oliverwyman.com.

The 2020 Global Fleet & MRO Market Assessment, prepared by Oliver Wyman, will be unveiled in March during ARSA’s Annual Conference. Click here to register now.

 


Quick Question – “The Opening Salvo” & Beyond

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.

The “opening salvo” is now nestled into a full, four-day schedule of meetings, presentations and interaction. 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. Use this month’s “quick question” to share the points, topics or questions you’d like covered at this year’s event:

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).

 


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)

Acme Aerospace, Inc., R01
Talon Aviation, Inc. dba Talon Air, R01
Michael Daniel, Edu

Renewing Members (Member Category, Member Since)

1st Choice Aerospace, Inc, R02, 2006
AeroParts Manufacturing & Repair, Inc., R04, 2016
Airborne Maintenance and Engineering Services, Inc., R06, 2010
Airbus North America, Inc., Assoc, 1995
Aircraft Component Repair, Inc., R03, 1987
Airgroup Dynamics, Inc., R03, 2007
Air Shunt Instruments, Inc., R02, 1999
Alpha Aircraft Services of America, R01, 2012
ATP USA, Inc, R01, 2017
Av8 Group dba Av8 MRO, LLC, R01, 2014
Avborne Accessory Group, Inc.-dba Avborne Component Solutions, R04, 2013
Aviation Instruments Repair Specialists (AIRS), Inc., R03, 1994
AvidAir Helicopter Supply, Inc., R01, 2011
Brothers Aviation Maintenance Services, Inc., R01, 2010
C&S Propeller, LLC, R01, 2016
Central Cylinder Service, Inc., R01, 1985
Continental Aircraft Support, Inc., R03, 2004
Flight Level Components LLC, R01, 2017
Fortner Accessory Service Corp., R01, 2002
Honda Aircraft Company, LLC, R04, 2018
INAir Aviation Services Company, R02, 2003
Mid-Continent Instrument Co., Inc. dba Mid-Continent, R04, 1998
Ohlinger Industries, Inc., R04, 2006
Rapco, Inc., Assoc, 1990
Rocky Mountain Propellers, Inc., R01, 2019
S.E.A.L. Aviation, LLC, R03, 2014
Skytech Aviation, Inc., R01, 2013
Southwest Turbine Inc., R02, 2018
StandardAero Alliance, Inc., Corp, 2010
Team J.A.S., Inc., R02, 2004
TPS Aerospace, LLC, dba Aviation Industry Repair, R02, 2015

 


A Member Asked…

Q: An area of P/N XYZ was repairable per Engine Shop Manual (ESM) Revision 42. Revision 43 of the ESM deems it unrepairable. (Note: No rational for this change was provide.) The part is not life-limited, and there are no airworthiness directives or airworthiness limitations that apply.

We have an inventory of parts that are unrepairable according to the “current” manual. We have a customer that would like us to repair these parts to Revision 42. The purchase order will specify that request. Can we do this?

A: Yes, the agency has made clear over and over again that earlier versions of manuals contain methods, techniques and practices acceptable to the agency under § 43.13(a) unless there is an AD that changes the instructions. If you need the legal interpretations, go to: www.faa.gov/about/office_org/headquarters_offices/agc/practice_areas/regulations/interpretations and put “43.13” in the keyword search field. It should return about half dozen interpretations on the subject.

The regulation that requires “current” manuals is § 145.109(d); just because a repair station (and only repair stations) have to possess current data does not mean it needs to be followed–earlier instructions can be used as well as engineering orders from air carriers or repairs you have developed.

The legal opinions are also cited in ARSA’s petition for rulemaking on the subject which can be found here: arsa.org/145-109. (The petition has been docketed and the agency is accepting public comments.)

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.

Brexit Resource Page

On June 23, 2016, citizens of the United Kingdom voted to withdraw from the European Union in a national referendum. After years of wrestling with the results of that vote, the separation has officially arrived.

H.R. 5119 – Contract Maintenance Under Attack

Help combat a bill introduced in the U.S. Congress that would disrupt the global aviation industry.

The U.S.-EU MAG

Keep up to date on ARSA’s analysis and resources related to the Maintenance Annex Guidance issued under the bilateral agreement between the United States and the European Union.

Industry News 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

Conference Dates Location
MRO Middle East Summit & Expo 2/24-26/2020 Dubai, UAE
ARSA Annual Conference 3/10-13/2020 Washington, DC
MRO Australasia 3/10-12/2020 Brisbane, Australia
AEA International Convention and Trade Show 3/24-27/2020 Nashville, TN
ATEC Annual Conference 3/29-4/1/2020 Fort Worth, TX
MRO Americas 4/28-30/2020 Dallas, TX
Farnborough Air Show 7/20-24/2020 Farnborough, UK
Business Aviation Convention & Exhibition (NBAA-BACE) 10/6-8/2020 Orlando, FL
MARPA Annual Conference 10/21-22/2020 Orlando, FL
MRO Europe 10/27-29/2020 Fira Barcelona Gran Via, Spain
 
 

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

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