2020 – Edition 11 – December 7
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.
Taking ARSA’s Word
By Brett Levanto, Vice President of Operations
It’s been quite a year. I can’t count the number of trials and tribulations, nor will I pretend December’s end will put difficulties behind us.
My focus is ARSA’s gains in the face of those challenges. Hosting a successful 2020 Annual Conference (and already looking ahead to 2021). Pushing back against hostile legislation. Realizing a key effort to channel funding for aviation career development. Creating opportunity from the crisis for better oversight and business.
The particulars prove that ARSA’s guiding principles work. The association is both a “repository of knowledge on the history, intent and plain language of the aviation safety regulations” and an advocate for good government before legislative bodies. The board and executive director’s long-standing tenets ensure the team maintains sanity during hardship in pursuit of overarching clarity.
ARSA’s work improves the business of repair stations in good times and bad. The association’s training, publications (model manuals, forms, supplements), newsletters and tireless advocacy on Capitol Hill as well as in the halls of government agencies all make aviation safety better through knowledge and hard work.
You don’t have to take our word for it.
Affirmations are constant, but recent feedback from long-time member Lynden Air Cargo regarding the association’s multi-year effort for recognition and open use of “remote technology” stands out. In March and April, ARSA saw through a multi-year effort for FAA recognition of “remote connectivity technology and tools.” The arrival of the pandemic didn’t change the rules, which supported the association’s core argument all along, it just pressed the government to affirm that “if something isn’t prohibited, it’s allowed.” Lynden seized on ARSA’s work early and shared a document outlining the company’s capability to perform remote inspection for a wide range of requirements.
“Prior to the Covid-19 Pandemic, there was already someone busy in Washington, D.C. working with the FAA on methods to conduct remote inspections using Video and Communications Technology, or VCT. It was our friend and colleague Sarah MacLeod of the Aeronautical Repair Station Association that worked to ensure FAA allows certain required inspections to be conducted remotely without the inspector’s physical presence.”
That’s right. Through its leadership, this association is positioned to serve the industry whenever crisis strikes. Rather than getting lost in an overwhelming cycle of unprecedented news, ARSA focused on the details and made simple but valuable progress. “If you’ve got a phone, you’ve got an inspector,” Sarah told me to title our first piece on remote connectivity back in March. As the FAA learned, the association’s knowledge had it right and the industry is served.
And that’s how ARSA works.
|Lynden Air Cargo has been an ARSA associate member since 2000, renewing in July to begin its 20th year in support of the association. The company includes a range of surface transportation services in addition to its aviation arm. In it’s own words, the company’s “clear mission” has always been “Put the customer first, deliver quality, and be the best at what you do.” Learn more at www.lynden.com/lac.|
2021 Annual Conference
March 9-12, 2021
Washington, D.C., Arlington, Virginia & Online
Registration will open soon for the 2021 ARSA Annual Conference. The association’s team is planning a “hybrid” event with both in-person and virtual attendance options.
The event will be hosted in and around Washington, D.C. from March 9-12, 2021. While the association works to ensure a valuable, substantively-enriching experience for all of its attendees, members and colleagues should make sure their calendars are blocked for those four days in March. (Click here to download an Outlook Calendar appointment to block your time.)
ARSA has also begun its sponsorship campaign for the annual event. While past sponsors and supporters are already reserving their usual commitments, those interested in learning about how to invest in the association and highlight their own business should contact Vice President of Operations Brett Levanto.
You can also help the association continue its preparation by responding to its ongoing “quick question”:
If the embedded survey does not appear/load, open the survey independently by visiting: https://www.surveymonkey.com/r/2021ARSAConferencePlan.
Note: The survey below is in an embedded window and you may need to scroll down within the window to see/click the “Submit” button.
Further Extensions to Air Carrier Training Requirement Exemptions
To keep tabs on all of ARSA’s work related to the current pandemic, visit arsa.org/anti-viral-measures.
Note: ARSA has been posting guidance, exemptions and other resources to arsa.org/faa-strategy as they become available. Review below to see new content.
In late November, the FAA issued two key updates related to existing exemptions from certain air carrier training requirements:
Updated Nov. 30: Avoiding Touching Certain Cabin/Cockpit Equipment Under Part 121 Training Requirements (Extension issued through July 31, 2020) (Additional extension issued through Nov. 30, 2020) (Additional Extension issued through Mar. 31. 2021)
Updated Nov. 30: Avoiding Touching Certain Cabin/Cockpit Equipment Under Part 135 Training Requirements (Extension issued through July 31, 2020) (Additional extension issued through Nov. 30, 2020) (Additional Extension issued through Mar. 31. 2021)
For regular updates from the agency on pandemic-related matters, visit www.faa.gov/coronavirus.
Greasy Hands & Complex Problem Solving – 2020 Scholarship Winner C. Owen Ritzman
In November, ARSA awarded its 2020 scholarship to C. Owen Ritzman of Southern Utah University. Ritzman is an AMT student whose love of getting his hands dirty is matched only by his excitement at solving complex engineering problems.
The grant is part of Choose Aerospace’s 2020 Aviation Maintenance Scholarship and Award Program. ARSA and its partner organizations combined to sponsor more than $25,000 worth of scholarships, textbooks, training systems and testing fee credits for educators and future aviators.
Ritzman took the time to share the impact of his experiences so far and his hopes for the future. His answers to a few simple questions illustrate his curiosity and commitment to hard work; a story that began in his father’s garage and will hopefully continue in shops or hangars for decades to come.
(1) What made you decide to pursue aviation maintenance training?
When I was five or six years old, my dad bought a new truck and invited me to help him put the running boards on. I can’t imagine that I was really any help, but I specifically remember being so proud that I had gotten grease on my hands from helping. I colored black spots on my hands with crayon for a few days so that I could show all of my friends how cool it was!
As I got a little older, I told my parents that I wanted to be a car mechanic. They lovingly suggested that I keep that as a hobby. Through high school, I went through a lot of different degree and career plans. Engineer, national park ranger, wildlife biologist and even helicopter pilot. I quickly discovered that the last one made me sick. But when I was investigating piloting at Southern Utah University, I discovered the newly founded AMT program and that quickly proved to be the answer to my love of mechanical work and my desire to not be limited to an auto shop for my whole life.
(2) What experience or experiences did you have before you started at SUU that have been most valuable to you during school?
I would consider two things of most value to me prior to my experience here at SUU. The first is the countless hours I spent in the garage with my dad or on my own, learning the ins and outs of how cars worked. Without that basis of how tools work, how engines work, and how to problem solve, I would be lost in aviation.
I would say the critical thinking I was able to learn in high school is of even more value, however. Aircraft require a higher level of precision than anything I ever wrenched on in my driveway. Being able to have the mathematical, reading, writing and communication skills I learned through high school have been invaluable to me in AMT school. Though I wouldn’t have entered this field without my mechanical background, I would never last without the critical thinking ability.
(3) What have you found to be most surprising/unexpected about AMT school?
Before I started AMT school, I didn’t realize how fragile aircraft actually are. As I have had the chance to work hands-on, I have discovered just how easily something very important and very expensive can break. I had always imagined aircraft being tough, solid, and hard to break, but mindlessly pushing on the wrong thing can do extensive damage.
Because of this, we spend much more time in classroom instruction than I ever expected. I came prepared for an environment where we would rarely be in lecture but quickly realized that without that time, we would be wasting precious resources once we actually began hands-on work. It was well worth the wait too!
(4) Other than becoming an ARSA member, what are your goals for life after school?
Of course, at my age, plans are constantly changing, but my biggest goals after I finish my schooling are to be able to support a family and live somewhere that I can admire every day. One of the most attractive things to me about working with aviation was the amount of versatility it offers. There is work to be had all across the country. Granted, young inexperienced workers often have to take what they can get. But I am confident that as I gain more and more experience, this field will lead me to the exact places that I want to be.
(5) To help ARSA’s members understand the value of the scholarship, tell us about the expenses you have to cover while at school.
In all honesty, in AMT school, expenses rack up quickly! I was fortunate enough to be offered an academic scholarship from SUU that covers a large part of my standard tuition. However, because of the amazing access we have at SUU to hands-on learning, the fees associated with classes add up to about 160 percent more than an average student would be paying here.
Another thing that added up very quickly was tools. Despite spending hours working on cars, most of the tools I used were not mine. I would estimate that I have already invested about $1,200 in tools. Some of these are very basic, cheap tools to get me through school, and others are high-end precision tools like torque wrenches.
On top of all of this, there are normal living expenses: gas, groceries, rent, car repairs, dates, recreation, etc. Scholarships like the one offered by ARSA make a huge difference in mitigating these expenses. They make it possible to afford the education while still taking care of everything else. And trust me- the money you pay is well worth the education!
(6) If you learned that someone was considering school/career choices and they asked you about aviation maintenance, what would you say?
If someone was considering aviation maintenance, I would tell them that it’s a pretty fool-proof option. There will always be work in this field, so long as they are willing to do just that— work! But even more enticing, it provides an opportunity to do genuinely important tasks every single day. There are few feelings better than seeing your own effort and knowledge put into action. And what better way for it to be in action than flying through the air?
To learn more about the Choose Aerospace Scholarships and Awards Program, click here.
For more information on ARSA’s broader efforts to support industry career development, visit arsa.org/workforce.
To see previous winners of the ARSA scholarship, visit arsa.org/scholarship.
Ritzman’s inspiration at work…
The challenge of turning youthful energy into aviation career ambition demands early and constant contact with students. The best age to introduce a child to aviation and aerospace is “as soon as possible” and then never stopping that engagement.
As the United States gets ready to pause for its annual observance of Thanksgiving, ARSA encourages its members to use time with family – even if it’s via an online connection – to share the wonders of the industry and the excitement of a future in it.
Looking for a place to start? Try the “Learning Lab” of the Smithsonian National Air and Space Museum. Its public resources can entertain and instruct children of all ages; from getting off the ground to orbiting the Earth to venturing the cosmos, inspiration awaits at learninglab.si.edu/org/airandspace.
If you really want to heed to call to start young, venture into the “Flights of Fancy” story time series:
|Click here for the “Bessie Coleman” gallery.||Click here for the “Three High Flying Friends” gallery.|
Looking Back to Move Forward on Workforce Policy
On Nov. 10, ARSA Vice President of Operations Brett Levanto participated in Global ATS-V. The international event was the online replacement for multiple aviation training trade shows overseen annually by the Halldale Group. Levanto and Ryan Goertzen of ARSA enterprise member AAR Corp. provided context and perspective on repair station workforce needs in their session on “The Impact of COVID-19 on Staffing Today and Tomorrow.”
Responding to pressures from the global pandemic, Halldale reimagined not only presentation methods but also event content for Global ATS-V. Combining the presenters and resources from a number of regional training symposia into a single around-the-clock and across-the-globe series of panels and discussions, the event’s theme has also been updated to reflect the unprecedented times: “Reset, Restart, Rebuild – Collaborating to Develop the Future of Aviation Training.”
Levanto and Goertzen spent the first 41 minutes of their presentation enjoying their pre-recorded discussion encouraging event viewers to “remember where we were.” After their recorded versions said farewell, the pair went live for a moderated Q&A with FAA Chief Scientific and Technology Advisor for Human Factors Bill Johnson.
Session 9: Maintenance – Repair Stations: The Impact of Covid-19 on Staffing Today and Tomorrow
The pandemic and related aviation business crisis has caused some to question whether we need no longer worry about the industry’s workforce. Furloughs, layoffs, early retirements and other reductions have allowed employers to worry less about finding new talent while instead trying to keep current employees on the payroll. While key stakeholders – including the US government, thanks to mandates from Congress and FAA focus – have remained committed to long-term aviation career development, here’s a challenge for anyone with doubts: Remember where we were when all this started.
To download a PDF copy of the session materials (promised repeatedly by Levanto during his insistence viewers explore linked resources in the presentation), click here.
For general information about Global ATS-V, session recordings and other Halldale events, visit www.gats-event.com.
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.
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.
Brexit Agreements Take Effect Jan. 1
By Christian A. Klein, Executive Vice President
The FAA and United Kingdom (UK) Civil Aviation Authority (CAA) are working to minimize regulatory disruptions on both sides of the pond in light of the UK’s departure from the European Union (EU) earlier this year. Although a transition period has been in effect since January 2020 pursuant to the Withdrawal Agreement, that will end at midnight on December 31, 2020 unless extended by the respective governments (which is possible but not likely). The two sides are continuing to negotiate the details of their bilateral relationship in 2021 and beyond with aviation being one of many industries being addressed in those high-level talks.
Therefore, effective Jan. 1, 2021, the legal basis for regulatory cooperation between the FAA and UK CAA will most likely change from the U.S.-EU bilateral aviation safety agreement (BASA) to the BASA inked between the United States and UK in 1995 and the Maintenance Implementation Procedures (MIP) between the FAA and UK CAA signed on Nov. 19.
U.S.-based repair stations certificated by EASA
The two agencies have agreed the FAA-EASA MAG provides an acceptable method of compliance for the FAA-UK CAA MIP for the next two years. Therefore, the UK CAA will not issue its own certificates to U.S.-located facilities at this time. When domestic repair stations approve work performed on an article (other than an aircraft) for return to service on Form 8130-3, the UK will accept FAA-EASA dual releases and EASA single releases (without any additional verbiage needed). However, if a U.S. repair station is working on a UK-registered aircraft, its maintenance release will have to cite UK CAA Part-145 rather than EASA Part-145 (even though those rules will be identical).
UK-based EASA Approved Maintenance Organizations certificated by the FAA
Regulators are working to minimize disruptions for the 167 FAA-certificated repair stations in the UK. For example, the FAA supplements and operations specifications (OpsSpecs) paragraph will need to be revised to remove references to EASA. Maintenance organizations will have 90 days to make those changes to their FAA Supplements and will receive notices from the FAA on exactly what is required. The OpsSpecs update will be accomplished as part of the certificate renewal process. After Dec. 31, 2020, FAA-certificated repair stations in the UK cannot use EASA Form 1 for the release to service but must use UK CAA Form 1 with the appropriate single/dual release indications and language. (Single releases on FAA Form 8130-3 will also be allowed.) However, the FAA will recognize EASA Form 1 with FAA releases issued by UK repair stations prior to Jan. 1, 2021.
New FAA-UK CAA Implementation Procedures for Airworthiness (IPA) governing, among other things, design, production and export activities, were signed Nov. 17 and will be unveiled shortly. We are told the IPA contains validation processes very similar to those in the current FAA-EASA Technical Implementation Procedures (TIP).
The IPA will provide a streamlined validation process for design changes by type certificate or supplemental type certificate holders and reciprocal acceptance of minor design changes, technical standard order (TSO) articles, parts manufacturer approval (PMA) articles and design data for repairs and alterations (except for alterations of critical components). Henceforth, applications for validation of UK products will be submitted to the FAA by the UK CAA rather than EASA. The FAA will work directly with UK CAA (instead of EASA) to audit the production oversight system.
NOTE: This article is based on information derived from various FAA and UK CAA presentation slides. As of Dec. 9, the official agreement documents have not been published for public consumption. Look for additional coverage and analysis when the documents are made public.
To review the presentation given by the FAA Aircraft Certification Service on Dec. 2, click here.
To review the presentation given by the UK CAA Design & Certification Team on Dec. 2, click here.
To access ARSA’s information page on Brexit, click here.
ARSA on the Hill
So Little Time
By Christian A. Klein, Executive Vice President
The last few weeks of 2020 will be busy as Capitol Hill works to finish key pieces of legislation, including FAA certification reform, FY 2021 appropriations and COVID relief. The pandemic and political atmospherics are making the process more complicated than usual and time is running out.
The good news is that ARSA’s top appropriations priority – funding for the aviation maintenance workforce grant program – is authorized at $5 million per year through FY 2023 and was fully funded by Congress for FY 2020. Given that both Senate and House FY 2021 transportation appropriations bills include full funding and the FAA is set to launch the program any day now, ARSA is optimistic that the money will ultimately be forthcoming. As the maintenance industry weathers the pandemic and looks towards rebuilding its workforce, resources to recruit and train technicians are more important than ever.
Part 147 Reform Added to Senate FAA Bill
Congressional transportation leaders have been working for months to enact FAA certification reform to address problems identified by the Boeing MAX investigations. Both the House and Senate versions of the legislation took important steps in the past month. The House passed the Aircraft Certification Reform and Accountability Act (H.R. 8408) on Nov. 17 and the Senate Commerce, Science and Transportation Committee approved the Aircraft Safety and Certification Reform Act of 2020 (S. 3969) the next day.
With the many similarities, there are also important differences between the bills. Because the full Senate has not yet voted, there won’t be a traditional conference committee; instead, committee leaders and staff will work to resolve differences behind the scenes with the hope that they can reach agreement and either pass a compromise bill quickly through both chambers or attach it to some other must-pass piece of legislation before the end of the year.
One important difference relates to aviation workforce development. The Senate bill includes legislation championed by ARSA and our allies at the Aviation Technician Education Council (ATEC) and Aircraft Machinists Fraternal Association (AMFA) that would force the FAA to update it’s 50-year-old regulation governing aviation technician schools. The current regulation’s antiquated standards limit knowledge, with many graduates unprepared for careers in the maintenance industry, and employers are forced to provide considerable additional training.
ARSA, ATEC and AMFA have mounted a joint lobbying campaign to build bipartisan support for the Promoting Aviation Regulations for Technical Training (PARTT) 147 Act (H.R. 5427 and S. 3043) on Capitol Hill. The legislation is being championed by Sens. Jim Inhofe (R-Okla.), Tammy Duckworth (D-Ill.), Jerry Moran (R-Ks.) and Cheri Bustos (D-Ill.).
While the inclusion of the language in the Senate bill is an important victory, whether it becomes law this year depends on the outcome of negotiations between the House and Senate if the legislation makes it across the finish line this year.
Appropriations Deadline Looms
One must-do item left on Congress’ list is finalizing fiscal year (FY) 2021 appropriations. The federal government is currently operating under a short-term continuing resolution (CR) that expires Dec. 11. House and Senate appropriators have apparently agreed on top-line spending numbers, but there are still many politically divisive issues left. The most likely scenario is another CR. The duration will depend on how close negotiators are to a final deal. If an agreement is within reach, the CR could last a couple days or weeks; if House Democrats, Senate Republicans and the White House are still far apart, the can may be kicked to late January or February.
Despite Signs of Progress, Pandemic Relief Hangs in Limbo
The maintenance industry has lost an estimated 50,000 workers since the beginning of the pandemic and 2020 repair station business activity will likely be half of what it was in 2019. While the CARES Act gave many maintenance companies access to grants, loans and tax preferences, that relief has come and gone and more layoffs loom.
ARSA is pressing to secure additional relief by urging lawmakers to reauthorize the Paycheck Protection Program (PPP) for small businesses and Payroll Support Program (PSP) for airlines and contractors. We want the latter program extended to cover maintenance activity “off airport”.
The association is also working in a coalition with the Aerospace Industries Association, General Aviation Manufacturers Association and others to create a new public-private partnerships to save aerospace jobs. The legislation (S. 3705/H.R. 8002) which is championed by Sens. Moran and Mark Warner (D-Va.) and Reps. Ron Estes (R-Ks.) and Rick Larsen (D-Wash.) would make federal funds available to aviation manufacturers and repair stations to help retain workers identified as at-risk of losing their jobs because of the pandemic economic disruptions.
House Speaker Nancy Pelosi (D-Calif.), Senate Majority Leader Mitch McConnell (R-Ky.) and Treasury Secretary Steve Mnuchin have been unable to agree on the size and scope of another relief bill. However, a bipartisan group of lawmakers calling themselves, “the Problem Solvers Caucus” have proposed a $908 billion package would renew the PSP and PPP. As the hotline went to press, President-Elect Joe Biden and Democratic congressional leaders were lining up behind the proposal as an interim measure that would buy the new administration and Congress time to develop a bigger relief plan.
COVID, Politics Complicate Process
Accomplishing so many priorities (not to mention another big “must do” bill we haven’t even mentioned – the FY 2021 National Defense Authorization Act) in just a few weeks is difficult under any circumstances. Adding COVID-19, the presidential transition and the Senate run-off elections in Georgia makes it more challenging.
Stay tuned to ARSA as the clock runs down on the 116th Congress. And if you’re interested in becoming more involved in ARSA’s legislative activities in 2021, shoot us a note.
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.
Complete Human Factors Training Series – The Dirty Dozen in Depth
ARSA’s library of human factors training includes two overview sessions followed by 12 hours of “in-depth” explorations of the “dirty dozen” in aviation maintenance. The series was presented by ARSA Executive Director Sarah MacLeod, Executive Vice President Christian A. Klein and Vice President of Operations Brett Levanto. For each element of “the Dirty Dozen,” the series provides a 60-minute session providing:
(1) Basic definitions and context.
(2) Aviation safety regulatory references.
All of ARSA’s human factors training sessions have been accepted by the FAA for Inspection Authorization renewal credit under § 65.93(a)(4). To purchase multiple sessions at a discounted price, click here to view options for purchasing via a “tiered bundle.”
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.
|Human Factors in Context||Click here.|
|The Dirty Dozen – Human Factors Overview||Click here.|
|The Dirty Dozen in Depth – Communication||Click here.|
|The Dirty Dozen in Depth – Complacency||Click here.|
|The Dirty Dozen in Depth – Lack of Knowledge||Click here.|
|The Dirty Dozen in Depth – Distraction||Click here.|
|The Dirty Dozen in Depth – Lack of Teamwork||Click here.|
|The Dirty Dozen in Depth – Fatigue||Click here.|
|The Dirty Dozen in Depth – Lack of Resources||Click here.|
|The Dirty Dozen in Depth – Pressure||Click here.|
|The Dirty Dozen in Depth – Lack of Assertiveness||Click here.|
|The Dirty Dozen in Depth – Stress||Click here.|
|The Dirty Dozen in Depth – Lack of Awareness||Click here.|
|The Dirty Dozen in Depth – Norms||Click here.|
Registration for an ARSA-provided training session includes:
- Unlimited access for 90 days to the recording.
- 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.
What training do you need? Contact ARSA to let the association know and help get it developed.
Can You Define “Appliance”? (15 min. sessions)
Test and bolster your regulatory reading skills with this series of three 15-minute sessions critically reviewing the regulations in 14 CFR. The sessions use the term “appliance,” which appears in countless places across the aviation safety rules, as the focus on this exploration.
The sessions should be viewed in order and may be purchased together for a discounted price by clicking here. Please note that since these sessions are less than an hour long, special pricing applies:
Session 1: “Appliance” Defined
This session provides participants a lesson in reading regulations with a critical eye. Many aviation terms used during the “normal” course of a day are taken for granted. Meanings and expectations are set by “tribal knowledge” rather than first-hand review. This session helps ensure each word in a aviation safety regulation is read carefully so any exceptions or conditions are understood.
Session 2: “Appliance” Applied
This session provides participants information on when and how the word “appliance” is used within the design, production, operation and maintenance rules.
Session 3: “Appliance” – Yes, No or Maybe
This session provides participants the opportunity to test their knowledge of whether an article is an appliance by using case studies.
Registration for an ARSA-provided training session includes:
- Unlimited access for 90 days to the recording (registrants may contact ARSA directly with questions or comments).
- A copy of the presentation and all reference material with links to relevant resources and citations.
- Upon completion of the class as well as any test material, a completion certificate.
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.
What training do you need? Contact ARSA to let the association know and help get it developed.
Regulatory Compliance Training
Test your knowledge of 14 CFR §§ 11.15, 11.17 & 11.19, general rulemaking requirements related to exemptions and special conditions.
ARSA Remembers – Leo Weston
NOTE: Since the initial announcement of Weston’s passing, ARSA has been receiving notes from members and colleagues remembering his impact on their lives and careers. If you knew or worked with Weston and have a story to tell, share it with ARSA.
On Nov. 28, Leo Weston, whose passion for aviation began in high school, spanned the world and lasted until his final days, passed away at home in the presence of his wife, Bernadette.
Immediately after graduating from Philadelphia’s North Catholic High School, where he learned basic aviation and engineering working on the school’s “fleet” of Piper J-3 Cubs, Weston enlisted in the U.S. Air Force. He was a mechanic and crew chief through an initial four-year enlistment as well as a recall tour in Korea.
After discharging from active duty in 1952, Weston attended Spartan School of Aeronautics in Tulsa, Oklahoma earning his Mechanic’s certificate with airframe and powerplant ratings. His civil aviation career began with Atlantic Aviation in Philadelphia before becoming a flight engineer for Pan American.
After enduring multiple furloughs, Weston began his federal civilian service with the FAA in 1964. He served in several training and management roles before transferring to the agency’s Headquarters in Washington, D.C. in 1974. His tirelessly support of the repair station community across four decades concluded with yeoman’s efforts on international harmonization before his retirement in the early 2000s.
“His dedication was matched with exceptional insight,” ARSA Executive Director Sarah MacLeod pronounced, remembering the incentive he provided in the formation of the association. “Not only did he set the foundation for the eventual international recognition of repair stations by spawning the ‘joint airworthiness regulations,’ but he also actively encouraged ARSA to become the repository of knowledge on the history, intent and plain language of aviation safety requirements. While Leo always had an opinion, it never outweighed an applicant, certificate holder, or female lawyer’s approach to showing compliance. He was as willing to learn as he was to educate; he embodied the ‘critical thinking’ sought, but so rarely found in government or industry.”
To honor Weston’s central role in the association’s formation and to recognize dedication to the public served by the international aviation maintenance community and national aviation authorities, in 2005 ARSA established the “Leo Weston Award for Excellence in Service to Aviation Safety.” The award commends individuals who embody his commitment to the industry and good government.
After his retirement Weston became a volunteer docent at the Smithsonian National Air and Space Museum’s Steven F. Udvar-Hazy Center in Chantilly, Virginia. Giving countless tours to visitors, student groups and fellow aviation enthusiasts, ensures Weston’s impact will continue well beyond any recognition bestowed publicly.
“[Leo] was the actual ‘Leo Weston Award’ for the docents at the Udvar-Hazy Center,” said fellow volunteer Joe Thomas. “When he was 90, he was giving tours to ten-year olds…[who] will have the memory of that tour for possibly 80 more years. Between Leo’s life and the students’ lives we have a period of maybe 180 years, bringing life to the phrase ‘I touch the future: I teach’. We continue to be inspired by him.”
For more information about arrangements and remembrances, click here.
Welcome & Welcome Back – New & Renewing Members
ARSA’s members give the association life – its work on behalf of the maintenance community depends on the commitment of these organizations. Here’s to the companies that joined or renewed in November:
James W. Mason, EDU
Aero Products Component Services, Inc., R03
Airborne Maintenance and Engineering Services, Inc., R06
Alaska Airlines, Assoc
CanRep Inc., R02
Component Repair Technologies, Inc., R05
Fire-Tec Aero Systems, LLC, R02
Gyros Unlimited dba North Bay Aviation, R03
Heliblade, LLC, R01
Helicopter Accessory Service East Inc., R01
MRO Holdings, Corp
Inflatables International, Inc., R01
Nelson Engineering Co., R02
Rapco Fleet Support, Inc., R01
SC Accessories, LLC, R02
SDM Avionics LLC, R01
Team Aerospace, Inc., R01
Trace Aviation, R02
A Member Asked…
Q: A table listing special tools and equipment in a component maintenance manual (CMM) has a notation for a particular item. The notation states: “No alternatives are permitted.”
Is this restriction valid? I am not aware of anything in the regulations stating the use of equivalents can be restricted by the manufacturer of an article.
A: There is no doubt that some aviation safety inspectors will take the position that the manufacturer’s CMM is the “law” and that if it says no substitutes, it means just that.
I would suggest if that is the case, you and the inspector carefully read the regulations that govern all work performed on aircraft with a U.S. certificate of airworthiness contained in 14 CFR part 43.
Section 43.13(a) and (b) say (I’ve added the emphasis):
(a) Each person performing maintenance, alteration, or preventive maintenance on an aircraft, engine, propeller, or appliance shall use the methods, techniques, and practices prescribed in the current manufacturer’s maintenance manual or Instructions for Continued Airworthiness prepared by its manufacturer, or other methods, techniques, and practices acceptable to the Administrator, except as noted in § 43.16. He shall use the tools, equipment, and test apparatus necessary to assure completion of the work in accordance with accepted industry practices. If special equipment or test apparatus is recommended by the manufacturer involved, he must use that equipment or apparatus or its equivalent acceptable to the Administrator.
(b) Each person maintaining or altering, or performing preventive maintenance, shall do that work in such a manner and use materials of such a quality, that 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 (with regard to aerodynamic function, structural strength, resistance to vibration and deterioration, and other qualities affecting airworthiness).
The regulations for part 145 are a bit more restrictive. Section 145.201(a)(1) says that the repair station may “[p]erform maintenance, preventive maintenance, or alterations in accordance with part 43 on any article for which it is rated and within the limitations in its operations specifications.”
Section 145.109(c) has more limiting language than what is highlighted in red in section 43.13(a) – the 145 section states: “The equipment, tools, and material must be those recommended by the manufacturer of the article or must be at least equivalent to those recommended by the manufacturer and acceptable to the FAA.” So, even if the equipment, tools or material aren’t “special”, the repair station must be able to establish what it is using is equivalent.
In the end the regulations allow the use of equivalencies—of course, that doesn’t mean that those were read and understood. If that were the case, I have a feeling you would not be asking…
Member questions should be submitted directly to the association’s team via arsa.org/contact.
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|MRO Middle East Summit & Expo||3/1-3/2021||Dubai, UAE|
|ARSA Annual Conference||3/9-12/2021||Washington, DC|
|AEA International Convention & Trade Show||3/18-18/2021||Dallas, TX|
|HAI Heli-Expo||3/22-25/2021||New Orleans, LA|
|World Aviation Training Summit (23rd)||4/20-22/2021||Orlando, FL|
|Aviation Safety Infoshare||4/20-22/2021||St. Louis, MO|
|MRO Americas||4/27-29/2021||Orlando, FL|
|EASA-FAA International Aviation Safety Conference||6/2021||TBD|
|MRO BEER||6/2021||Istanbul, Turkey|
|RAA 45th Annual Convention||9/25-28/2021||Phoenix, AZ|
|Business Aviation Convention & Exhibition (NBAA-BACE)||10/12-14/2021||Las Vegas, NV|
|MRO Europe||10/19-21/2021||Amsterdam, The Netherlands|
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