2021 – Edition 1 – February 5

Table of Contents

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

Sarah Says
2021 Annual Conference
Anti-Viral Measures
ARSA Works
Regulatory Update
Legal Brief
ARSA on the Hill
Training
Membership
Resources
Industry Calendar

Sarah Says

Upon Reflection

By Sarah MacLeod, Executive Director

The end of the first month of the year brings my birthday: a 24-hour period of reflection. I look back over much more than the past year or even decade and I look forward to more than the next twelve months.

I use my current knowledge to assess failures and the steps taken over the years to lessen or mitigate those known hazards. The analysis is both professional and personal. The professional endeavor deals with facts first; in the administration of the trade association that would be the number of dollars generated by membership and more importantly the number of members that renew!

The satisfaction and engagement of the membership is paramount to ARSA’s success. The ability to retain a company’s financial investment means providing a discernible return in the most trying times. The measures taken by the association’s team over the last two years has increased renewal rates from 76.9 to 82.5 percent – an incredible achievement in an extremely trying year.

That professional achievement is built on almost four decades of watching and studying the birth of the aviation industry and agencies since their inception, then working tirelessly for the businesses bearing the weight of their oversight. This experience allows the association to manage the intersection of business and government to its members’ advantage. Following the entire “regulatory creation” process demands applying the proper emphasis on legislative efforts to ensure whatever is passed to the regulator can be managed.

To wit, the “new” executive order entitled “Revocation of Certain Executive Orders Concerning Federal Regulation” is a clear message that government agencies will no longer be “hemmed” in by the supposed limits imposed by the last president. All the work performed by the industry and the federal agencies to assess performance measures, promises of “transparency” and adherence to the plain language of the regulations is for naught. While this all sounds drastic for business, it means that agency employees that were shuffling paper and being over scrutinized by the Department of Transportation can now get back to the “real” work of getting the regulations and policy aligned.

Executive Orders come and go. They are often burdensome to an agency rather than liberating for the regulated parties. The executive branch has full prosecutorial authority over its regulations and can refuse to enforce any that are not required by law. Executive orders are merely the method by which those decisions are transmitted to agencies. Such presidential declarations must be taken for the political message being conveyed; federal agencies are the method by which many goals of a current administration will be forecast.

That is why the association does not play party politics in its legislative activities and continues to manage the regulatory fallout of any enacted legislation. As I reflect and look forward, by professional measures, the team I am lucky enough to call on – from my direct friends and colleagues at the law firm and the association’s board to those around the world – has stood me and the association in good stead for nearly four decades and will do so in the future.

Since my personal success is tied to my professional success, it is a more difficult nut to crack satisfactorily. As many know, my husband is Marshall Filler, law partner and managing director of the trade association; an intricate and intimate relationship to assess. I am happy to report that age brings the ability to know with absolute certainty that the only constant is change. No matter what is happening “now,” it is already gone, and the future is the next discernible second of my life.

That future brings the possibility of and ability to change and it must be embraced. There are many adages regarding that reality, and it sure is difficult for humans to manage, but it is a truth that I hold at the end of every birthday’s 24-hour reflective period. And I work every year on getting my personal “now” closer to the real second in time to minimize and mitigate future negative outcomes.

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2021 Annual Conference

Register Now

Registration Form | Event Information | Sponsors

March 9-12, 2021
Washington, D.C., Arlington, Virginia & Online

Registration is open for the 2021 ARSA Annual Conference. The association’s team is planning a “hybrid” event with both in-person and virtual attendance options. It will be hosted from March 9-12, 2021.

Learn more about the event and register by visiting arsa.org/news-media/events/arsa-conference or reviewing the content below.

Information

Simple Agenda

Unless otherwise noted, all Annual Conference activities take place at the Ritz-Carlton, Pentagon City in Arlington, Virginia. Stay tuned for agenda updates as the event gets closer.

Executive to Executive Briefings: Tuesday, March 18, 2025

Participation by industry executives with senior executive branch officials is limited to annual conference sponsors at the Administratium, Platinum, Gold, or Silver levels. In past years, meeting participants included representatives from the U.S. Departments of Commerce, Defense, Labor, State, and Transportation as well as the fellow trade associations and industry interest groups.

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Legislative Day: Wednesday, March 19, 2025

The day dedicated to educating both the aviation maintenance industry and elected officials. Learn (or brush up) on what ARSA does and what you can do so you're ready for afternoon visits with targeted Capitol Hill legislators and staff.

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Annual Repair Symposium: Thursday, March 20, 2025

The centerpiece of Conference week, ARSA convenes a full day of substantive panel discussions covering key regulatory compliance and business issues. After the keynote address, regulators from across the world join the full-morning "Opening Salvo" conversation, followed by lunch and an afternoon of practical regulatory and business discussion.

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Member Day: Friday, March 21, 2025

ARSA's leadership briefs members on the state of the association as well as goals and priorities for the coming year. Participants then close out the event by participating in breakout and/or training sessions focused on key aerospace topics. The Conference ends by 12:00 p.m. EDT.

Attendance & Pricing

In-Person

All substantive and social activities were hosted at the Ritz-Carlton, Pentagon City in Arlington, Virginia. Legislative Day participants will head to Capitol Hill for meetings with congressional offices as appropriate.

Livestream

The majority of Conference events will be available to livestream viewers via a Vimeo web-player embedded into a page on ARSA.org. All in-person registrants will be able to name a "Conference Ambassador" as a contact to access the livestream and bring the event back to their home facilities. Paying registrants for livestream access may share with multiple company contacts. Livestream participation will include a mechanism for submitting questions to onsite personnel.

Pricing

Executive to Executive Briefings
Open to Administratium, Platinum, Gold, and Silver-level sponsors.
Legislative Day – Wednesday, March 19
	Members		Non-Members
	First	Additional	First	Additional
In-person	$400	$360	$600	$540
Livestream Free with in-person registration.	$400		$600
Symposium – Thursday, March 20
In-person	$900	$810	$1,250	$1,125
Livestream Free with in-person registration.	$900		$1,250
Legislative Day & Symposium Bundle
In-person	$1,100	$990	$1,500	$1,350
Livestream Free with in-person registration.	$1,100		$1,500
The Super Bundle (Silver Sponsorship, E2E, Legislative Day, & Symposium)
In-person	$4,200		$4,500
Livestream Free with in-person registration.
Member Meeting & Training/Breakouts – Friday, March 21
In-person	Free with Symposium registration.
Livestream

(1) See sponsorship opportunities for exclusive access to the Executive to Executive Briefings (E2E) on Tuesday, March 12 and other complimentary benefits.

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(2) Registration fees may be waived for government personnel, members of the media, speakers, and other support personnel or special guests upon approval by the ARSA event team.

Sponsorship

For information about committing your organization to the Annual Conference, contact ARSA Vice President of Operations Brett Levanto. To download a sponsorship overview containing the information below, click here.

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Administratium – $20,000

What is Administratium? An element aerospace professionals see every day (click here to learn more). Notation in all publicity, marketing and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, specific thank you in ARSA periodicals, additional advertising placement via ARSA’s communications, complimentary registrations for three (3) participants in the Executive to Executive Briefings as well as three (3) in Legislative Day, and free livestream access for personnel unable to attend in person. At the Administratium Level, sponsors may select one of the following* to specifically support (please note the list in this document does not reflect current availability):

• Annual Repair Symposium – Ice Breaker Reception
• Annual Repair Symposium – Thursday Happy Hour
• General Sponsorship

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Platinum – $10,000

Notation in all publicity, marketing and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, specific thank you in ARSA periodicals, complimentary registrations for three (3) participants in the Executive to Executive Briefings as well as three (3) in Legislative Day, and free livestream access for personnel unable to attend in person. At the Platinum Level, sponsors may select one of the following to specifically support (may not reflect current availability for 2025):

• Online Conference Experience
• Executive to Executive Briefings
• Legislative Day – All Day
• Congressional Directories/Resources
• General Sponsorship

* All sponsorship support selections are subject to availability. The ARSA events team will discuss alternative suggestions.

2024 Platinum Sponsors

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Gold – $7,500

Notation in all publicity, marketing and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, specific thank you in ARSA periodicals, complimentary registrations for two (2) participants in the Executive to Executive Briefings as well as two (2) in Legislative Day, and free livestream access for personnel unable to attend in person. At the Gold Level, sponsors may select one of the following to specifically support (may not reflect current availability for 2025):

• Legislative Priorities Brochures/Resources
• Digital Companion/Electronic Materials
• Legislative Day – Continental Breakfast
• Legislative Day – Congressional Briefing and Luncheon
• Annual Repair Symposium – Continental Breakfast
• Annual Repair Symposium – Luncheon with Special Guest
• Nametag Lanyards
• Hotel Room Keys
• General Sponsorship

2024 Gold Sponsors

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Silver – $3,500

Notation in all publicity, marketing, and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, complimentary registrations for one (1) participant in the Executive-to-Executive Briefings as well as one (1) in Legislative Day. At the Silver Level, sponsors may select one of the following to specifically support (may not reflect current availability for 2024):

• Annual Repair Symposium – Coffee Break (5)
• General Sponsorship

2024 Silver Sponsors

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Supporter – $2,500

Notation in all publicity, marketing, and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, specific email alerts to association contacts), and recognition in event materials and from the podium.

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Contributor – $500 to $2,499 (or equivalent support)

Notation in some publicity, marketing, and periodicals (e.g., the hotline, Dispatch), and recognition in event materials and from the podium.

2024 Contributors

Location & Accommodations (Book by Feb. 21)

ARSA has reserved a block of rooms for Conference participants at the Ritz-Carlton, Pentagon City in Arlington, Virginia. The hotel hosts most of the activities related to the ARSA Conference and is convenient to the Metro as well as Washington Reagan National Airport (DCA). The deadline for reservations made in this block is Feb. 21, 2025.

To reserve your room(s), visit https://book.passkey.com/go/ARSAAnnualConf2025.

Attendees may also call the dedicated group desk +1.800.422.2410. Reference the ARSA Annual Conference when making reservations. 

Awards

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 Leo, the award bearing his name, and those who have received it.

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The Legislative Leadership Award

The association regularly recognizes members of Congress who have provided outstanding support to the aviation maintenance community by supporting policies beneficial to the industry. Honorees have each been key in moving forward specific legislation advancing priorities championed by ARSA on behalf of its members.

Click here to see past updates regarding Legislative Leadership Award recipients.

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The "Golden Shovel" Award

From time to time, ARSA recognizes individuals – usually at the time of their retirement – who have spent their careers in steadfast devotion to good business, good safety, and good oversight. In the colorful illustration of Executive Director Sarah MacLeod, these professionals have spent their lives shoveling against the tide of government bureaucracy; their achievement in never giving up is acknowledged through the "Golden Shovel Award."

Click here to learn more about the "Shovel" and see who has received it.

Looking Back at 2024 (Photos & Recordings)

Considering attending in 2025 and want to get a sense of the experience? Feeling nostalgic for last year's event? A few ways to look back at 2024...

Event Photos

ARSA has created a Google Album including photos taken during the 2024 Annual Conference, which allows participants to share their own photos (Sharing event photos constitutes consenting to their use/distribution in association with Conference-related publicity for this or future events, at ARSA’s discretion). To see the album, click here.

Select Recordings

The following selections were highlighted in ARSA's member newsletter, the hotline. Click the headline link to view the recording in the March edition.

Legislative Day Briefing – Global Fleet & MRO Market Report

The team from Oliver Wyman CAVOK presented their findings to Legislative Day participants on March 13, illustrating the current and projected states of the North American and global aircraft fleets and related impacts on maintenance demand.

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Legislative Day Briefing – Perspectives on Reauthorization

Attendees used these insights (and all the March 13 content) in their meetings on the Hill; all members can benefit from the cross-industry expertise of this lobbyist panel.

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Symposium Briefing – What Has ARSA Done Lately

The brief session includes key updates from the association’s year as well as instruction for maximizing membership value.

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Symposium Briefing – In the Fire with AVS-1

There were no real flames on stage, but an intense and engaged discussion of the state of the aviation industry. View a clip from the exchange where Sarah MacLeod and David Boulter discuss SMS, training, and more.

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Symposium Briefing – Training First

The Symposium portion of the Annual Conference wrapped on March 14 with an hour-long session on how we learn and what we can learn about improving training and personnel development.

Registration

To submit a sponsorship commitment, register or change or cancel an existing registration, complete the following form. After submission you will be redirected to a separate completion page. If you attempt to submit the form and this page reloads, please check for errors in your entries (usually an item has been skipped accidentally) and resubmit.

Sponsor Salute

Registration Form | Event Information | Sponsors

Platinum

Gold

Silver

Contributor

What You’ll See

Registration Form | Event Information | Sponsors

March 9-12, 2021
Washington, D.C., Arlington, Virginia & Online

The 2021 Conference will be different…but also very much the same as previous years. The “hybrid” nature of the event, which provides options for in-person or online attendance, will introduce new technology (remote connectivity tools!). Regardless, the camera lenses, computer screens and human eyes will experience the world-class content that has always been the cornerstone of the maintenance community’s premier event.

Get a feel of the recent past through the following short videos produced by Hothouse Media, which use footage and interviews filmed during the 2019 and 2020 events. Learn more about this year’s plan and reserve your place by visiting arsa.org/news-media/events/arsa-conference.

2020 Annual Conference – ARSA: A Factor in Industry Success

2019 Annual Conference – Catch a Glimpse

Familiar Tools

Registration Form | Event Information | Sponsors

March 9-12, 2021
Washington, D.C., Arlington, Virginia & Online

ARSA is working with InReach Continuing Education Solutions, which provides the training platform used for the association’s training program, to deliver the online portion of the 2021  Annual Conference.

Any of the association’s hundreds of training users will be quite familiar with InReach’s system and how to access ARSA content through it. For those who want to learn about – or brush up on – the experience, this is the perfect time to learn by registering for a session.

To learn about the online training program, visit arsa.org/training-2/arsa-training or review the menus below. Regardless of how you get to know the tools, be sure you’re registered to utilize them during the Annual Conference from March 9-12.

ARSA Online Training

Annual Meeting Announcement

Registration Form | Event Information | Sponsors

March 9-12, 2021
Washington, D.C., Arlington, Virginia & Online

The ARSA Annual Member Meeting is held in conjunction with the Annual Conference; this year it will take place during the Breakfast and Annual Report on Friday, March 12 at 8:00 a.m.

ARSA President Gary Fortner will address members regarding the state of the association. After Fortner’s presentation, attendees are welcomed and encouraged to raise 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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Anti-Viral Measures

Feedback on PSP Extension

To keep tabs on all of ARSA’s work related to the current pandemic, visit arsa.org/anti-viral-measures.

On Jan. 8, the U.S. Department of Treasury published the Payroll Support Program Extension (PSP2) application for passenger air carriers and contractors.

The ARSA-supported program was originally created in March 2020 as part of the Coronavirus Aid, Relief and Economic Security (CARES) Act and has since provided assistance to more than 600 companies. PSP2 was created by the Consolidated Appropriations Act when it was enacted in December 2020.

Treasury closed the application portal at the end of January. While the agency had initially stated applications could be received after the Jan. 25 deadline – noting that late submissions might not be considered – it then shut down the system claiming the PSP2 was “oversubscribed.”

After the program’s rollout, ARSA was contacted by the U.S. Government Accountability Office (GAO) seeking feedback about the program. The GAO asked the following questions:

(1) What worked well and what has not worked as well for your members when applying for and receiving PSP2 funds (e.g., application process, guidance, communication from Treasury staff)?
(2) What are you members’ views on the requirements new to PSP2 (e.g., recalling employees)?
(3) Given the size of PSP2 payments and outlook for the aviation sector, will this be enough to allow your members’ to stay in business until passenger demand for air travel and related services recover? Please explain.
(4) What has worked well and what has not worked as well for your members with regard to Treasury’s process for monitoring compliance with the initial Payroll Support Program (PSP1) agreement terms, such as Treasury’s guidance, recipient portal, or outreach/enforcement?

The association’s team has collected input from several key members, if you have experience with either round of the Payroll Support Program you are encouraged to share it with ARSA.

Click the logo to go to the PSP2 information page.

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ARSA Works

Closing Out 2020

Each quarter the board of directors receives reports on the association’s activities and finances. Step into a board member’s shoes by reviewing the financial health and operations, legislative and regulatory reports highlighting advocacy on behalf of aviation safety between October and December 2020.

Financial Health

The association finished 2020 on budget. Considering the difficult business conditions experienced across the industry, the sustainment of member renewals and recruitment of new companies highlighted the industry’s continued commitment to the association.

Regulatory Advocacy

• Followed NTSB decision on ARSA effort to intervene before Board in two cases concerning repairman certificate denials.
• Delivered preliminary report of ARAC Part 145 Working Group.
• Reported release of change 8 to the U.S.-EU Maintenance Annex Guidance (MAG 8).
• Engaged EASA regarding release to service under EU rules of aircraft with “protype” parts installed following issuance of a design approval consistent with the data referenced on the “prototype” EASA Form 1s/FAA 8130-3s, etc.
• Reported on FAA Notice 8900.574, concerning “non-mandatory revision” to OpSpecs paragraphs for FAA-certificated repair stations located in the United Kingdom.
• Reported on FAA and UK CAA presentations regarding agreements taking effect after Jan. 1, 2021 related to the United Kingdom’s departure from the European Union.
• Maintained pressure on FAA to initiate aviation maintenance workforce grant program.
• Worked with FAA to create task to review and make recommendations on training for Safety Oversight and Certification Advisory Committee (SOCAC) subcommittee—follow on action from work with Aviation Rulemaking Advisory Committee preliminary report in second bullet above.

Legislative and Lobbying

• Successfully lobbied Congress for:
  • Additional economic relief for the aviation maintenance sector, resulting in extension of Paycheck Protection and Payroll Support Programs.
  • Legislation directing FAA to replace outdated aviation technician school regulations with performance-based rule.
  • Full funding for aviation maintenance workforce and pilot education grant programs created by 2018 FAA law.
• Supported bipartisan effort to create new public-private cost share program to provide economic relief to aviation manufactures and repair stations.
• Executed agreement for enhanced ARSA congressional database and grassroots platform.
• Participated in fundraiser for House Transportation & Infrastructure Committee Ranking Member Sam Graves (R-Mo.).

Communications and Surveys

ARSA in the News – Selected Industry Coverage

A4A And Aviation Week Present 2020 MRO Awards
October 28, 2020 | Aviation Week
Three MRO luminaries, including ARSA Executive Director Sarah MacLeod, received awards at Aviation Week Network’s virtual MRO Transatlantic event on Oct. 28.

2020 Aviation Maintenance Technician Award Recipients
November 13, 2020 | AviationPros
The newly incorporated Choose Aerospace, a coalition of stakeholders pursuing greater awareness of opportunities in aviation maintenance, is proud to announce its inaugural slate of scholarship and award recipients.

Using Aviation to Help Veterans Adjust to Civilian Life
November 18, 2020 | AOPA
VIPER is in the process of launching the VIPER Aviation Maintenance Program, working with the FAA, the Aircraft Mechanics Fraternal Association, the Aeronautical Repair Station Association, and other groups on its design.

ARSA-placed Industry Editorials

Surveys

Quick questions re: Engaging Elected Officials (October; 4 responses), 2021 Conference Planning (November/December; 61 Responses).

Events, Meetings and Training

Events

Opened registration for the 2021 Annual Conference.

Meetings

• Sarah participated in six meetings of FAA’s Aviation Rulemaking Advisory Committee (ARAC) and working groups.
• Brett and Sarah coordinated six meetings related to ARSA’s repair station manual compilation.
• Brett participated in eight FAA Youth Access to American Jobs in Aviation Task Force and subcommittee meetings.
• Christian participated in dozens of lobbying coalition meetings related to aviation workforce and economic relief legislation.
• Sarah participated in a Helicopter Association International (HAI) “Ask an Aviation Attorney” HAI@Work webinar (Oct. 1).
• Christian and Brett held coordination meetings with Oliver Wyman (Oct. 9, Nov. 13, Dec. 11).
• Christian presented to the Regional Aviation of Russian and CIS 2020 Conference (Oct. 20).
• Christian participated in a Runway to Recovery Coalition meetings (Oct. 20, Nov. 17, Dec. 1).
• Marshall participated in the Quadrilateral Maintenance Management Team industry meetings (Oct. 23, 26).
• Brett participated in a meeting with representatives from Veteran Internships Providing Employment Readiness (VIPER) to discuss military-to-industry transition (Oct. 30).
• Sarah participated in an FAA Safety Oversight and Certification Oversight Committee and related subcommittee meetings (Nov. 4, Dec. 1, Dec. 16).
• Sarah participated in a FAA Flight Standards Transparency, Performance, Accountability, Efficiency Aviation Rulemaking Committee meeting (Nov. 4).
• Brett presented on the impact of COVID-19 on repair station staffing as part of the Global Airline Training and Simulation Conference (Nov. 10).
• Sarah participated in a Safety Oversight and Certification Aviation Rulemaking Committee Sub Team Reports meeting (Nov. 19).
• Christian and Brett participated in a briefing by FAA and UK CAA about BREXIT implications for the maintenance sector (Dec. 2).
• Marshall participated in EASA Engineering and Maintenance Technical Committee meetings (Dec. 3, Dec. 4).
• Christian participated in TSA’s Aviation Security Advisory Committee annual public meeting (Dec. 10).

Board Administrative

The board approved a resolution to move forward with distribution and sales of the new ARSA Model RSQM Compilation in conjunction with the law firm which manages the association and produced the content of the documents.

FAA Opens Grant Program Applications

On Jan. 19, the FAA announced it was officially accepting applications for both of the new aviation workforce development grant programs mandated by the FAA Reauthorization Act of 2018.

The Aircraft Pilots Workforce Development Grants provide money to expand the pilot workforce and educate students to become pilots, aerospace engineers or unmanned aircraft systems operators. The Aviation Maintenance Technical Workers Workforce Development Grants will help prepare a more inclusive talent pool of aviation maintenance technicians. Applicants from academia and the aviation community can submit applications through www.grants.gov through March 22.

Eligible organizations may apply for grants ranging from $25,000 to $500,000 for any single grant per fiscal year.

The Notice of Funding Opportunity for each grant provides detailed information on eligibility, deadlines, evaluation criteria and application procedures. To ensure fair and open competition for the grants, answers to public questions will be posted on the FAA website at www.faa.gov/go/awd. Potential applicants are encouraged to visit the site to review answers to frequently asked questions, eligibility requirements and guidelines that may assist them to complete their grant application.

ARSA and its allies have been working with the agency throughout its development of the program. The association’s understanding is this first round of grants will disburse funds appropriated for 2020, which had been authorized by Congress but not expended. Since the  programs were again fully funded for FY 2021 (as part of the year-end omnibus), there will be another solicitation later in the year to utilize the 2021 funds. While the government’s plans may change and for the sake of demonstrating the importance of workforce investments, interested parties should move quickly to submit an application.

In the months ahead, ARSA will be encouraging Congress to once again fully fund the programs for FY 2022 while monitoring implementation to ensure the grants serve the collective objective of a strong, well-trained aviation workforce.

Key links and resources for the maintenance community:

(1) FAA Aviation Workforce Grant Programs Information Page
(2) FAA Application Procedures for Workforce Development Grants
(3) Notice of Funding Opportunity for the Aviation Maintenance Workforce Grant Program

ARSA Executive Vice President Christian A. Klein issued the following statement in recognition of the opening of applications:

“The launch of the grant programs is another important step towards solving the maintenance industry’s long-standing workforce challenges. ARSA appreciates the bipartisan support the programs have received on Capitol Hill and the partnership of our many allies from across the aviation industry who helped us reach this milestone.

“Unfortunately, we find ourselves in very different circumstances than when the program was conceived more than three years ago. Today, in addition to fostering collaboration between schools, businesses, unions and government to recruit and prepare the next generation for successful aviation careers as maintenance technicians, these grants will also help rebuild our workforce in the wake of unprecedented economic disruption.

“We hope ARSA members will step up, partner with others in their communities and seize the important opportunity these new programs represent.”

Eligible organizations may apply for grants ranging from $25,000 to $500,000 for any single grant per fiscal year. Applications are due into www.grants.gov by March 22 and do not require the previous submission of a notice of intent (which the FAA had encouraged – but not required – be done by Jan. 29).

For more information on the program development and a chronicle of ARSA’s leadership of the effort beginning in 2018, visit arsa.org/grant-program.

For a detailed review of the grant application process, read this month’s “Legal Brief.”

Reviewing US-EU MAG Change 8

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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Regulatory Update

FAA Activates “Dynamic Regulatory System”

On Jan. 15, the FAA made its new Dynamic Regulatory System (DRS) available to the public. The system combines more than 65 document types from more than a dozen different repositories into a single searchable application, centralizing guidance material from the Flight Standards Information System (FSIMS) and the agency’s Regulatory and Guidance Library (RGL). The system is updated every 24 hours and includes pending and current versions of all documents along with their revision history and links to the Code of Federal Regulations provision on which the document is based.

The agency has stated it will continue to add features and document types to the DRS, eventually “sunsetting” FSIMS and the RGL. 

To access the system, visit drs.faa.gov.

Releasing UK-registered Aircraft for Service

To ensure aircraft registered in the United Kingdom can be approved for return to service by EASA-approved part 145 certificate holders, the U.K. CAA issued Decision No. 3. The decision follows the requirements of a 2013 EASA regulatory interpretation requiring the “foreign authority” affirmatively state that an EASA part 145 certificate holder release is acceptable.

The U.K. CAA requires:

(1) The EASA part 145 certificate be issued before December 31, 2020. After that date, for US located repair stations, the U.S.-U.K. BASA and Maintenance Agreement Guidance (MAG) applies to U.S. based repair stations.
(2) That particular language be used in the “maintenance release” document.

To access the complete U.K. CAA Decision No. 3 document, click here.

To review the EASA 2013 regulatory interpretation, click here.

Repair stations in the US need to familiarize themselves with the U.S.-U.K. MAG. To download a copy, click here.

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

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Legal Brief

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

Grant Application Circuitous but Worthwhile

By Christian A. Klein, Executive Vice President

The association-driven grant program to support aviation maintenance workforce development passed a major milestone with the FAA’s release of the long-awaited Notice of Funding Opportunity (NOFO). The program created by the 2018 FAA Reauthorization Law (Sec. 625) is now officially up and running for grant applications of between $25,000 and $500,000.

The application process might look intimidating and complex, but not to an industry that runs on government processes, forms and documentation. With this overview and a detailed review of the NOFO and its sources and resources, ARSA members can submit strong applications.

Where can I obtain information and the program and how to apply?

Since the article cites page numbers in the NOFO, the first step is to retrieve and keep that document handy.

To access the NOFO and related program information:

(1) Click here OR go to grants.gov, search for “20-FAA-AWD-AM-1” and click the “20-FAA-AWD-AM-1” link under “Matching Results.”
(2) From the maintenance workforce grant program main page, you can obtain relevant documents and forms to apply.

• The NOFO is on the “Related Documents” tab.
• The various application forms are on the “Package” tab and can be accessed by clicking the “Preview” link.

There are several other web pages with more information:

• If you have no experience with federal grant programs, general information about the application process can be found here: grants.gov/web/grants/applicants.html.
• Information on this program has been developed by the agency, including:
  • FAA Aviation Workforce Development Grant Program Website: faa.gov/go/awd
  • Aviation Workforce Development Grant Program – Maintenance Program FAQs: faa.gov/about/office_org/headquarters_offices/ang/grants/awd/technical/faqs/

Who is eligible to apply?

One or more of any of the following entities (pages 7 to 9):

• An organization that holds an FAA certificate issued under 14 CFR parts 21, 121, 135 or 145.
• A labor organization representing aviation maintenance workers.
• An accredited institution of higher education or a high school or secondary school.
• A state or local governmental unit.

While the law contemplated joint applications (i.e., by an aviation company/union, school, AND governmental entity), the FAA is allowing individual applicants, while encouraging partnerships. The NOFO (pages 8-9) states that:

Individual entities, teams, and new providers able to prove they meet the eligibility requirements may apply for a grant.  The Government encourages applicants to partner with others as appropriate to satisfy Congressional intent in the Act and to otherwise meet the requirements of the merit criteria, without limitation, to help the applicant provide additional opportunities, assistance and resources to ensure success and sustainability of the proposed project.

Entities may only submit one application as a “lead” applicant but can participate in more as a non-lead member (page 7). As with most government grants, entities that have been debarred or suspended from doing business with the federal government are disqualified from participating in the program (page 9).

When are applications due?

Submission must be by 11:59pm eastern time on March 22, 2001 (page 2).

How much money is available?

The NOFO makes a total of $5 million dollars available, which the FAA is drawing from the funds appropriated by Congress for 2020. The minimum grant award is $25,000, the maximum is $500,000 with no cost-share or matching contributions required (page 9). Looking forward, Congress has already appropriated an additional $5 million for 2021 so the agency plans an additional application cycle later in the year to disburse the next round of money.

How may grant money be used?

The law was drafted to support a wide variety of recruitment and training initiatives. In addition to the specified activities, the law and NOFO include a catch-all category for initiatives that “otherwise enhance aviation maintenance technical education or the aviation maintenance industry workforce” (page 5-6). Specific program concepts include those that:

• Establish new educational programs that teach technical skills used in aviation maintenance, including purchasing equipment, or to improve existing programs.
• Establish scholarships or apprenticeships for individuals pursuing employment in the aviation maintenance industry.
• Support outreach about careers in the aviation maintenance industry to primary, secondary or post-secondary school students or to communities underrepresented in the industry.
• Support educational opportunities related to aviation maintenance in economically disadvantaged geographic areas.
• Support transition to careers in aviation maintenance, including for members of the Armed Forces.

Grant money may not be used to offset pre-award costs or application expenses or for facility construction or research. Administrative costs may not exceed 10 percent of the grant award. Applicants can elect to accept a cap of 10 percent on de minimis indirect costs or negotiate an alternative rate with the government (page 15).

How soon must the money be spent?

Generally, money must be expended by the recipient within 12 to 18 months of the award (page 7).

How much oversight will the FAA perform of grant awardees?

In addition to regular progress reports and a final report due within 90 days of the end of performance period, the agency reserves the right to conduct site visits of application institutions and facilities to observe curriculum delivery and review all documents related to grant performance (page 7).

What technical requirements are associated with the grant application process?

Applicants must be registered in the federal government’s System for Award Management (SAM) (page 17). (Creating an individual user account to register your entity is free.)

When submitting the application, a Unique Entity Identifier (UEI, also called a DUNS Number) is required (page 12) and can be obtained through fedgov.dnb.com/webform.

Grants.gov, the online system for submitting application also requires registration.

Many ARSA members already do business with the federal government, so the company may be registered in SAM and have a UEI/DUNS number. Coordinate internally to avoid duplicate registrations and the resultant confusion or delay.

What must be included in the application?

Appendix II of the NOFO (page 29) contains a checklist of the documents and information that must be submitted. All referenced forms are accessible online (see, ”Where can I obtain information and the program and how to apply?” above). The application package must include:

• SAM registration information.
• The entity’s UEI/DUNS number.
• Documentation showing the applicant’s proof of eligibility (e.g., a copy of your FAA certificate).
• A copy of the lead applicant’s most recent audit (if available).
• A signed cover letter from the applicant (lead) and all non-lead co-applicants providing a narrative description of the project (see below).
• Contact information for the project lead.
• A completed Standard Form (SF) 424 (“Application for Federal Assistance”)
• Budget information, including a completed SF-424A (“Budget Information for Non-Construction Programs” and budget narrative.
• SF-424B (“Assurances for Non-Construction Programs”).
• Project Abstract Summary, including a completed Eligible Project Attachment form.
• SF-LLL (“Disclosure of Lobbying Activities”).
• Project/Performance Site Locations form.
• Key Contacts/personnel attachment form.
• ACH Vendor Payment Enrollment form.

What must be included in the narrative description?

The narrative cannot be longer than 25 pages, it must be double-spaced, use 12-point Times New Roman font, have one-inch margins and page numbers on the lower right corner of each page (page 10). The content must include:

• An abstract briefly describing the project and why it is eligible for funding (i.e., that it will support one or more of the types of activities for which grants may be used).
• Applicant (lead) information, including (as appropriate) information about non-lead partner organizations describing the role of each.
• Any conflicts of interest and how they will be mitigated.
• A detailed project overview, including a description of activities, benefits, performance goals and metrics, an explanation of applicant’s ability to carry out the project, what resources the applicant will provide to support the project, how activities will be monitored, assessed, and documented and a project timeline.
• A specific funding request (supported by the various budget documents).

How will the FAA judge applications?

The agency has identified the following as factors it will use to judge applications, so be sure to address them in your narrative (page 16 – 17):

(1) Project plan. Is the plan clear and achievable? Has the applicant included a budget, a schedule of activities and a description of objectives, performance measurements and the roles various partners (if applicable)?
(2) Applicant resources. Does the applicant have facilities, equipment and human resources to successfully complete the project?
(3) Project impact. To what extent does the proposed project support the education and recruitment of aviation maintenance technical workers and the development of the industry’s workforce? Are the objectives and outcomes clearly identified? Can the program be repeated by other entities? What partnerships and collaborative strategies are envisioned?
(4) Project administration. Has the applicant provided a clear and achievable plan to control expenses and described how project activities will be monitored, assessed, and documented?

All federal programs are complicated, but members identified technician shortage as the biggest strategic threat to the industry; with repair stations foregoing more than $1 billion per year in lost business opportunity. ARSA delivered the means to receive help.

As maintenance activity increase, the technician shortage will be more acute. Now is the time to address workforce challenges by using federal resources for long-term dividends.

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ARSA on the Hill

The Next Round

By Christian A. Klein, Executive Vice President

After weeks of political chaos, the 117^th Congress is finally up and running. The November elections left both chambers in Democratic hands. The House of Representatives by a smaller minority; and with the January’s special elections in Georgia costing the GOP two Senate seats leaving Vice President Kamala Harris with the tie breaking vote.

As the hotline went to press, the Senate’s leaders had agreed to a power-sharing deal modeled on rules from 20 years ago; the last time the chamber was split down the middle.  Democrats will control chairmanships, but committees will have the same number of members from both parties.  Republican and Democratic committee staff budgets will also be equal.  Democrats, however, can break legislative logjams when committees are deadlocked.

Minor Changes to Key Committees

Leadership on key committees affecting aviation has changed very little.  Sen. Maria Cantwell (D-Wash.), formerly the ranking Democrat on the Senate Commerce, Science & Transportation Committee will be chair with the former Chairman Roger Wicker (R-Miss.) as the ranking member.  The two have a good working relationship with a bipartisan approach to aviation policy, so we expect the Commerce Committee to continue to function as it has. Senate aviation subcommittee leaders will be named shortly.

Nothing changes on the House side of Capitol Hill: Rep. Peter DeFazio (D-Ore.) remains chair of the House Transportation & Infrastructure Committee; Rep. Sam Graves (R-Mo.) stays the ranking member. Rep. Rick Larsen (D-Wash.) is the aviation subcommittee chair and Rep. Garrett Graves (R-La.), the ranking member.

More Relief for Aviation Under Discussion

After approving President Biden’s cabinet, the first order of business for the new Congress is another stimulus/economic relief package. The clock is ticking; important parts of the deal reached in December expire in mid-March.

President Biden has proposed a $1.9 trillion plan. Republicans rejected that big a package but have left the door open to a smaller deal. To ensure a stimulus package can move forward without GOP support, Democrats can use reconciliation, which allows budget-related legislation to pass the Senate with a simple majority. The device used by Republicans during the 115^th Congress to pass President Trump’s tax reform bill.

The omnibus bill passed in December extended federal relief that benefited many ARSA members, including the Paycheck Protection and Payroll Support Programs. For others in the aviation supply chain that do not qualify, ARSA has allied with other organizations to promote more comprehensive relief that would broadly benefit maintainers and manufacturers.

The Aviation Manufacturing Jobs Protection Act was reintroduced in January by House aviation subcommittee chairman Larsen and Rep. Ron Estes (R-Ks.). The bill would authorize the Department of Transportation to enter six-month, renewable cost-sharing agreements with eligible companies to keep at risk workers on the payroll.  The legislation was modified from last year’s version to allow money to be used for training, which ARSA members have identified as a priority for recalled and new-hire workers.

ARSA is building support to include the language in the economic relief package discussed above.

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Training

Make ARSA Training Work for 2021

ARSA’s online training program represents its most-valuable benefit to the aviation industry: knowledge gained through training and experience. The association’s team has turned its decades of work on behalf of aviation maintenance into more than 80 hours of on-demand content.

While sessions are available for registration at any time – ARSA member discounts available – companies can also incorporate the association’s training into their regular programs:

(1) Subscription. Make up-front, bulk purchases of training hours. The details of each subscription can be customized, including focus on specific subject areas (e.g., human factors) or options for specially-priced session access after the initial hours have been used.

(2) “Championing” a session. Guarantee a certain number of attendees for training in a particular topic that will also be made available for general registration. Variations include open registration for a live session (i.e., company personnel participate at the same time as general registrants) or a company-specific live event for which a recorded version (not including any company-specific information) is made available for on-demand registration.

(3) Tailored training. Contract ARSA’s management firm Obadal, Filler, MacLeod & Klein, P.L.C. to produce or modify training specific to your organization. The team can then re-record it (or offer it as a separate live session) for ARSA’s training program. Tailored programs are priced differently from ARSA’s hourly rate and are administered by OFM&K, which allows for a client engagement and related attorney-client privilege for all discussion.

Click here to go directly to the training platform (operated by ARSA’s management firm) and begin reviewing available sessions.

For more information about ARSA’s training program, review the menus below. If you have questions or would like to learn more about ways to integrate ARSA training into your own program, contact Vice President of Operations Brett Levanto (brett.levanto@arsa.org).

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.

ARSA Training for IA Renewal

In early 2020, the FAA informed ARSA of a 24-month extension to the expiration dates for each of the association’s online training sessions found acceptable for Inspection Authorization renewal credit under 14 CFR § 65.93. The original eight IA renewal sessions produced by ARSA will now remain acceptable until 2023:

Click here to purchase all eight sessions (plus one required prerequisite) at a “bundled” discount – let ARSA take care of your IA renewal requirements this year.

ICA – The Basics
IA Course Acceptance: C-IND-IM-170830-K-010-002
This session provides an overview of the regulatory basis for ICA, including what documents are considered ICA and the obligations of design approval holders to prepare, furnish and otherwise make them available under 14 CFR § 21.50(b). It also covers the related regulations that apply to operators and maintenance providers regarding the use of ICA and their availability. Finally, it shows how the FAA has interpreted some of the more important ICA requirements in Order 8110.54.

ICA – Case Study: Testing Your Knowledge
IA Course Acceptance: C-IND-IM-170830-K-010-001
This session tests the participants’ knowledge of the ICA regulations in Title 14 CFR and FAA guidance by presenting several hypothetical case studies. Each one will focus on one or more of the significant ICA regulatory principles. 

Major/Minor – Major Pain Over a Minor Issue
IA Course Acceptance: C-IND-IM-170830-K-010-003
This session reviews the regulations that govern the terms “major” and “minor” in the world of civil aviation repairs and alterations. Learn the regulatory facts and how to train your FAA inspector so this minor issue doesn’t become a major pain in the derrière.

Part 21 – Overview
IA Course Acceptance: C-IND-IM-170830-K-010-004
This session provides an overview of the aviation safety regulations governing design and production of civil aviation products and articles as well as airworthiness certification of civil aircraft.

Part 65 – Getting a Mechanic’s Certificate
IA Course Acceptance: C-IND-IM-170830-K-010-005
This session reviews the requirements of 14 CFR part 65 subpart D, which concerns aviation mechanics. It walks through the requirements for an individual to apply for a mechanic’s certificate, then defines the privileges and limitations bestowed on that individual by his or her certificate. Finally, it covers the enhancements to a mechanic’s privileges produced by obtaining Inspection Authorization.

Recordkeeping for Mechanics
IA Course Acceptance: C-IND-IM-170830-K-010-006
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.

Regulations Impacting the Purchase of Aircraft Parts
IA Course Acceptance: C-IND-IM-170830-K-010-007
This session reviews the civil aviation regulations in Title 14 Code of Federal Regulations that impact the purchase of civil aviation parts, as well as other requirements that should be considered.

What is “Acceptable to the Administrator”? – The Performance Rules of § 43.13
IA Course Acceptance: C-IND-IM-170830-K-010-008
This session provides an overview of the regulations that use the language “acceptable to” the Federal Aviation Administration and how to determine what makes something acceptable to the agency.

More accepted training…

In addition to these eight sessions, ARSA has current FAA acceptance for 14 other hours of training from its Human Factors series.

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 §§ 11.21 & 11.23 general rulemaking procedures.

Click here to download the training sheet.

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Membership

ARSA Member Survey Coming Soon

ARSA’s 2021 annual member survey invitation will be sent in February to the email address of every member primary contact. The message will be subjected “ARSA Member Survey Invitation” and come from arsa@arsa.org. Ensure the invitation makes it to your primary contact and that it gets the attention it deserves.

Responses to this year’s survey will be particularly important. Not only will data help improve ARSA services and support its work – as it always does – it will also build the useful description of pandemic impacts provided by “Part II” of the 2020 Member Survey. Please help by keeping an eye out for the invitation and then submitting…or stimulating your primary contact to submit on your company’s behalf.

(If you don’t know who the primary contact is, or don’t think the invitation got through, we can help.)

Colleagues Remember – Leo Weston

Since the announcement of Leo Weston’s passing in November of 2020, ARSA has been in touch with colleagues regarding remembrances and honors for the lifelong aviator. As a dedicated servant to the industry and instrumental figure in the association’s founding, Weston’s impact on others was deep; many who knew him have been working to carry on his work and keep his memory.

The first of those efforts has been a resounding success. Led by his fellow volunteer docents at the National Air and Space Museum’s Steven F. Udvar-Hazy Center, the Smithsonian has raised $25,000 – meeting its fundraising goal – to honor Weston with a plaque on the Pratt & Whitney Twin Wasp R-2000 engine on display in the facility’s “engine row.”

The short biography used in association with fundraising effort was drafted by ARSA to celebrate Weston’s commitment to the industry:

Leo dedicated his career to the aviation industry. He enlisted in the Army/Air Corps after high school and went on to work for Atlantic Aviation, Pan American Airlines, and the U.S. Overseas Airlines. Later in his career, Leo was offered a position at the Federal Aviation Administration (FAA). Leo’s final career post was as an Aircraft Maintenance Inspector at the FAA Headquarters in Washington, DC, where he advocated for the creation of an organization to represent the interests of maintenance providers. The Aeronautical Repair Station Association (ARSA) was founded as a result, and in recognition of Leo’s role, the Leo Weston Award for Excellence in Service to Aviation Safety was created. The award honors individuals who embody Leo’s commitment to the industry. 

Weston’s fellow docents deserve grateful praise for their leadership and fundraising success. ARSA will continue to support any effort to recognize him and is working with other contacts to determine how else he can be remembered.

ARSA is also collecting memories of Weston’s life and work. If you knew or worked with him and have a story to tell, share it with the association.

To read the full announcement from November, visit arsa.org/arsa-remembers.

Leo in his “native habitat,” in front of a Pratt & Whitney R-2800 radial engine installed in a P-47 Thunderbolt. The “Dependable Engines” logo is clearly visible. In the background is a Curtiss-Wright R-3350 on the Enola Gay. The engines in the museum are quiet, but Leo brought them to life. Photo courtesy Joe Thomas.

Industry Input on Youth Engagement

Last July, ARSA Vice President of Operations Brett Levanto was appointed to the Department of Transportation’s Youth Access to American Jobs in Aviation Task Force. Since the task force began its work in the late fall of 2020, Levanto and his fellow appointees have been collecting information regarding experiences with youth engagement, career development, workforce needs and industry readiness.

To assist in that work, the association requests input from its members and industry colleagues through the survey below.  It was designed by the task force’s subcommittee on trends, on which Levanto serves, and includes a series of open ended questions about programs, practices, successes and impediments for engaging youth.

In your responses, consider both your professional and personal experience. While the questions focus on aviation, you are encouraged to share good or bad experiences or insights from other industries, particularly if there is reasonable crossover into aerospace work.

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

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.

To learn more about the Task Force’s work, visit arsa.org/youthtaskforce.

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

Aircraft Technologies Group, Inc., R01
Aviation & Marketing International, Inc., R01
Colorado Northwestern Community College, EDU
Federal Aerospace Institute LLC, EDU
James Campanella, Affil
Daniel, Michael, EDU
Pem-Air, LLC, R02
US Technicians, Inc., R01
Valcor Engineering Corporation, R01

Renewing Members

Aerotech Engineering Consultants, Affil, 2016
Air Shunt Instruments, Inc., R02, 1999
Aircraft Component Repair, Inc., R03, 1987
ATP USA, Inc, R01, 2017
Austin Aerotech Repair Services Inc., R01, 2012
Aviation Avionics & Instruments, Inc., R03, 2012
Aviation Instruments Repair Specialists (AIRS), Inc., R03, 1994
Barfield Precision Electronics, LLC, R04, 1996
Brothers Aviation Maintenance Services, Inc., R01, 2016
Central Cylinder Service, Inc., R01, 1985
Cobalt Aero Services, R03, 2012
Consolidated Turbine Specialists, LLC, R03, 2018
Delta TechOps, Corp, 2002
Gardner Aviation Specialist, Inc. dba Precision Aircraft Services, R01, 2018
Helicopter Services, Inc., R01, 2019
Honda Aircraft Company, LLC, R04, 2018
Ikhana Group, Inc. dba Ikhana Aircraft Holdings, LLC, R04, 2003
Liebherr-Aerospace Saline, Inc., R05, 2006
Mach II Maintenance, R04, 2018
Marx, Dr. Robert, EDU, 2018
Mid-Continent Instruments & Avionics, R04, 1998
Moog, Inc., Corp, 1997
NORDAM Group LLC-Repair Division, Corp, 1984
Rapco, Inc., Assoc, 1990
Rotortech Services, Inc., R02, 2019
Skytech Aviation, Inc., R01, 2013
Southwest Turbine, Inc., R02, 2018
Southwind Aviation Supply, LLC, R02, 2008
Tailwind Inspection, Inc., R01, 2006
Tarrant County College, EDU, 2017
Team J.A.S., Inc., R02, 2004
The Giles Group, Affil, 2013
World Class Accessory, Inc., R01, 2007

A Member Asked…

Q: We hold FAA-PMA on a part by license agreement with a manufacturer, what is the requirement for what we should put on the 8130-3 in block 12 with approval issued for FAA/EASA dual release? We are having some internal debates and we’ve gotten some conflicting guidance from our local FAA office(s) on this subject. 

A: The straightforward answer to your question is in the “order” on how to complete an FAA Form 8130-3 for dual release. At the bottom of page 3-7 Order 8130.21H lists examples of the information that EASA expects in Block 12.

The analysis that gets you to that answer starts with compliance to § 43.9, since repair stations that have EASA part 145 certificate issued under the bilateral must comply with the domestic requirements in 14 CFR part 43 and 145 first.

For FAA purposes – a “single release” if you will – there are no requirements to put even the revision level of the CMM in the description of work performed required by
§ 43.9(a)(1). That “interpretation” can be found in the FAA’s Dynamic Regulatory System – search RCCB Decisions and look for the one dated Feb. 4, 2016: Revision Dates on Maintenance Manuals.

Next, the repair station has to look at 14 CFR part 145, which requires compliance with the air carrier customer’s directions under § 145.205; those customers normally require not only the CMM listed, by revision but also the service bulletins and replacement parts used. If the repair station’s quality manual says it is going to do something a certain way (like fill out the form in accordance with Order 8130.21H), it must follow its own requirements under §§ 145.207, 145.209 and 145.211.

Finally, we look at the MAG, and more importantly to the business, the EU operator requirements. Both EASA and EU customers expect a list of parts replaced and/or the entire “work order” that provides more detail on the repairs done and the parts replaced. If the replacement article is “life-limited” additional verbiage in Block 12 will be expected.

Thank you for asking ARSA—I hope the information answers your question and gave you a path for researching similar “issues” that may arise.

Member questions should be submitted directly to the association’s team via arsa.org/contact.

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

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.

Anti-Viral Measures

For the use of its members and the larger aviation community, ARSA is maintaining this page as a resource for pandemic-related updates on policy initiatives and business needs. It is the association’s central point of communication on the topic

H.R. 5119 – Contract Maintenance Under Attack

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

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

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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