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2021 – Edition 11 – December 3

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Table of Contents

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

From ARSA’s President
Anti-Viral Measures
ARSA Works
2022 Annual Conference
Legal Brief
ARSA on the Hill
Training
Membership
Resources
Industry Calendar


From ARSA’s President

Name Your Conference Ambassadors

Fellow ARSA member,

Last month, I introduced myself as ARSA’s president. I would like the opportunity to meet you in person: Please join me and the rest of the ARSA board of directors at the association’s 2022 Annual Conference.

The international aviation maintenance community’s premier substantive event will be held March 8-11, 2022, in and around Washington, D.C. While a return to in-person engagement is a relief, it’s more exciting to use lessons from the past two years to expand the Conference’s reach.

Though we always planned to return to hosting an in-person Conference, the success of the 2021 virtual Conference made clear that live broadcasting must become a component of every association event. That means the ARSA team will turn the Ritz-Carlton into a soundstage and present a three-day, live television-style broadcast covering the legislative, regulatory, and business issues that matter to our industry. From the anchor’s desk, the association’s executive team will once again welcome guests in-person and around the world to a live audience at the Ritz and to participants’ home bases. If last year is any example, it will be an entertaining and informative show whether you choose to participate in-person or virtually.

To take advantage of the new dynamic, I’m announcing the “Conference Ambassador” program. Every in-person registrant can identify an individual at the registered facility location for complimentary access to the livestream, virtual event. That Ambassador can share sessions with other colleagues, forward questions and comments through the in-person attendee while sharing key updates and resources.

Through Conference Ambassadors new contacts and generations become knowledgeable about the industry, the civil aviation authorities and the association’s impact on the international repair station community. Through that introduction they can receive ARSA benefits directly, become more knowledgeable in our collective work, and hopefully get a personal introduction to the participants and speakers at the next event.

Of course, if nobody at your company can make the trip to Washington D.C., you should register to access the livestream from your facility; however you participate, we are all looking forward to seeing and hearing from you.

Learn more about the 2022 Annual Conference and register today. Click here to get started.

Sincerely,

Terrell Siegfried
2022 ARSA president | NORDAM assistant general counsel and corporate secretary

 


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Anti-Viral Measures

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

DOT Opens Third Round of Jobs Program Applications

On Nov. 8, the U.S. Department of Transportation announced it has re-opened applications for the Aviation Manufacturing Jobs Protection (AMJP) Program for a third and final round of awards. The government will review applications in the order received until Dec. 13 at exactly 7:59 p.m. EST.

DOT reopened the application process because of continued questions about the relationship between the AMJP and the Employee Retention Tax Credit (ERTC) programs; the same confusion prompted the second round of summer applications. The announcement provided the following explanation:

“Although the American Rescue Plan Act of 2021 authorized the continuation of ERTCs beyond July 1, 2021, it did so through a separate statutory provision rather than extending the original provision under the CARES Act.  Therefore, ERTCs accrued after July 1, 2021 do not affect DOT’s ability to award an AMJP agreement to an otherwise eligible applicant.

Companies with approved applications may not apply again but those that have been found ineligible or disqualified may re-submit. The general requirements remain the same, including active registration in the System for Award Management (SAM).  For more information:

  • Review the program website at www.transportation.gov/amjp.
  • View one of the recorded webinars from May, July, August or November (each less than an hour, all available at no cost).
  • Stay tuned for updates on the program website.
  • For questions about SAM registration, call 866.606.8220 or go to sam.gov/content/home.
  • For help with the GrantSolutions platform, call 301.818.5210 or email dot.amjp@grantsolutions.gov.
  • For questions about AMJP, email AMJP@dot.gov.

Click the DOT Logo to go to the application process webpage.

 


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ARSA Works

MMT Update

The annual Maintenance Management Team (MMT) meeting took place online the first week of November. MMT is a coordinating body for the world’s four leading civil aviation authorities: the FAA, EASA, TCCA and ANAC Brazil.

While MMT regulator-on-regulator sessions are closed to non-governmental attendees, the meeting includes an Industry Day for authority and stakeholder engagement. ARSA was represented at the recent Industry Day by Managing Director & General Counsel Marshall Filler and Executive Vice President Christian Klein.

Highlights were:

  • Expanding MMT. While no authorities had petitioned to join MMT and no expansion is planned, authorities (such as the UK CAA) could become participants.
  • Collaboration strategy. Industry and authority representatives are continuing to discuss ways to formalize and regularize MMT’s activity cycle, define administrative responsibilities (coordinating meetings, tracking tasks, etc.) and improve coordination between meetings.
  • Status of bilateral agreements.
    • Revision 1 to Annex B of the EASA-ANAC bilateral is pending the exchange of notes between the EU and Brazil; Maintenance Annex Guidance (MAG) Revision 2 is awaiting adoption of Annex B in 2022.
    • Changes to Annex B of the EASA-TCCA bilateral will be complete in the second quarter of 2022; authorities are meeting in January 2022 to work on completing MAG Revision 3 by the end of 2022. The two authorities are working on mutual recognition of each other’s component approved maintenance organization (AMO) certificates. Under MAG Revision 2, which is currently in force, such certificates are valid until surrendered, suspended or revoked. In other words, they do not require renewal.
    • MAG Change 8 to the EASA-FAA bilateral was signed Nov. 2020 and entered into force March 2021. Regulators are already looking towards the next change; with EASA’s new requirement that European AMOs adopt safety management systems (SMS). European regulators want a special condition requiring U.S. repair stations to adopt SMS.
    • FAA and TCCA are coordinating on Maintenance Implementation Procedures (MIP) Revision 2 for signature in mid-2022.
    • TCCA and ANAC have made considerable progress towards mutual recognition of each other’s repair station certificates. Canadian component AMOs may work on products under ANAC’s regulatory jurisdiction without a manual supplement and Brazilian certificate.

Facilities maintaining Brazilian-registered aircraft, engines and propellors will still be subject to the requirements of the TCCA-ANAC Technical Arrangement – Maintenance (TA-M). The two authorities are working to update the TA-M with the goal to finalize by early 2023. Regulators expressed confidence that greater mutual recognition is on the horizon.

  • FAA and ANAC are working to finalize a new MAG and will publish both a MIP and MAG simultaneously at some future date.
  • FAA mutual recognition. Klein presented on the ARSA-led U.S. industry effort to change FAA regulations to allow the agency to accept foreign certificates. He explained that, except for Canada, existing FAA rules require the agency to issue certificates to maintenance organizations located outside the United States. Bilateral agreements are not considered treaties by the United States and therefore cannot supersede U.S. laws or regulations. As a result, even if the FAA wanted to agree to mutual acceptance of certificates with another authority as part of a bilateral, FAA’s own rules prohibit it from doing so.

In April 2020, ARSA and 14 allied organizations petitioned the FAA to amend 14 CFR part 43 to enable the FAA to accept foreign AMO certificates and related approvals for return to service under a bilateral without the FAA issuing a part 145 certificate. Klein explained the proposed amendments would remove the barrier to mutual acceptance and reciprocity, give FAA the same discretion as its bilateral partners to recognize foreign certificates, align maintenance oversight with production and air carrier approvals, maintain the certification process for foreign AMOs in jurisdictions with which the U.S. does not have a bilateral and free FAA resources to focus on operational safety rather than duplicative oversight.

Unfortunately, the FAA has not prioritized the rulemaking petition and has taken no action.

  • Chris Markou, head of operational cost management in the International Air Transport Association’s (IATA) Engineering & Maintenance Group, reviewed IATA’s Digitization Vision 2020. The objective of IATA’s efforts is to deliver “fully digitized” aircraft, i.e., all documentation is in an airline’s system digitally without the need to convert files and/or paper to other formats. Markou discussed the hurdles the industry must overcome, including developing and accepting standards, determining data rights, updating regulations, developing appropriate technologies, and addressing cybersecurity concerns.
  • Industry representatives discussed the need for a harmonized approach to SMS and urged that International Industry Standard SM-0001 be a means of compliance. Among MMT members, SMS is currently only included in the draft FAA-ANAC and existing FAA-TCCA agreements.

Industry encouraged regulators to ensure that SMS requirements be scalable to avoid unnecessary burdens on small and medium size entities.

 


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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2022 Annual Conference

Register Now

March 8-11, 2022

Registration | Information

Arlington, Virginia and Washington, D.C. with Livestream Options for Online Participants

Experience the maintenance community’s premier event. Join ARSA members and invited guests from around the world to engage governments, network with peers and improve the state of the aviation world.

 


Planning Ahead

The repair station community’s premier substantive event returns to in-person attendance, using the lessons of the pandemic to spread the event’s reach around the world.

Help ARSA’s team plan for the 2022 Annual Conference.

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

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

Learn more about the Conference using the menus below and click here to access the registration form.

Pricing
Attendance costs are the same for both options; in-person registrants receive free livestream access.

Legislative Day -- Wed., March 9
Members: $350 or Free with Symposium Registration
Non-Members: $600 or Free with Symposium Registration

Symposium -- Thur., March 10
Members: $850
Non-Members: $1,100

Member Meeting & Breakouts -- Fri., March 11
Members: Free with Symposium Registration
Non-members: Free with Symposium Registration


Attendance
ARSA's team is planning for in-person participation at the 2022 Annual Conference. Association members will be welcome to return to the nation's capital for four days of networking and professional engagement.

To help spread the event's impact and benefit from the lessons of 2021, a livestream option will be available for participants unable to travel to Washington, D.C. In-person attendees will identify "Conference Ambassadors" back at their facility to access the livestream.

Executive to Executive Briefings: Tuesday, March 8, 2022

Industry executives participate in meetings with senior executive branch officials organized by ARSA. Participation is limited to annual conference sponsors, with the number of slots available to each sponsoring organizations dependent on level of support. The ARSA team is coordinating meetings with...
Nick Calio, President & CEO, Airlines for America
Monica Gorman, Deputy Assistant Secretary for Manufacturing, U.S. Department of Commerce
John Ladd, Administrator, Employment & Training Administration, U.S. Department of Labor
Annie Petsonik, Principal Deputy Assistant Secretary for Aviation and International Affairs, U.S. Department of Transportation
Richard Yoneoka, Acting Deputy Assistant Secretary for Transportation, U.S. Department of Transportation
Executive Office of the President, the White House

Legislative Day: Wednesday, March 9, 2022

After a morning of briefings and policy updates. Legislative Day participants meet with members of Congress as well as office and committee staffers to connect the impact of the maintenance community to each state and congressional district. The day will include ARSA's release of its Annual Global Fleet & MRO Market Assessment, produced by Oliver Wyman, as well as the presentation of the association's Legislative Leadership Award.
8:15 a.m. | It's All About Your Industry and Your Company

Find out what’s at stake in Washington for your company and your industry, where things stand, and what you can do to impact the process.


9:oo a.m. | Congressional Meetings Begin

Attendees schedule independent meetings with representatives, senators, and key staff; ARSA team members facilitate those meetings and coordinate briefings from the House and Senate aviation subcommittees.


Time TBD | Presentation of ARSA's 2022 Legislative Leadership Award to Rick Larsen (D, Wash.) and Garrett Graves (R, La.)
Time TBD | Release of the 2022 Global Fleet & MRO Market Report, produced by Oliver Wyman
4:00 p.m. | Symposium Registration Opens (for non-Legislative Day attendees)
5:30 p.m. | Ice Breaker Reception

Annual Repair Symposium: Thursday, March 10, 2022

The centerpiece of Conference week, ARSA convenes a full day of substantive panel discussions covering key regulatory compliance and business issues.
8:00 a.m. | Welcome & Introductory Remarks

Find out how the association is advocating for your interests with legislators, regulators, and the media. Information on how you can help advance the industry’s collective interests.

Sarah MacLeod, Executive Director, ARSA


8:30 a.m. | Keynote Address

A senior FAA leader returns to the Conference stage to reflect on the agency’s work. He will report on caree development efforts, and share how the government wants to grow its own competencies while supporting an advancing industry.

Brad Mims, Deputy Administrator, FAA (invited)


9:15 a.m | Opening Salvo – Conversations with the Regulators

International agencies will provide updates on the regulations, policies and procedures governing the maintenance industry.

Ludovic Aron, Washington Representative, EASA


Robert (Rico) Carty, Acting Executive Director, Flight Standards Service, FAA (invited)


João Garcia, Head, Department of Flight Standards, ANAC Brazil (invited)


Li Heping, Director, Continuous Airworthiness & Maintenance, CAAC (China) (invited)


Earl Lawrence, Executive Director, Aircraft Certification Service, FAA (invited)


David Malins, Head, Airworthiness, UK CAA (invited)


Jeffrey Phipps, Chief, Operational Airworthiness, TCCA (Canada) (invited)


Neil Williams, Safety Policy Manager, Operations, UK CAA (invited)


Shijun Xue, Deputy Director General, Flight Standards, CAAC (China) (invited)


12:30 p.m. | Lunch with Special Guest
2:00 p.m. | Building Ourselves

Labor and workforce development organizations from aviation as well as other industries share strategies, programs and experiences for investing in skill and professional development.


3:00 p.m. | ARSA Jeopardy
4:00 p.m. | The "Other" SMS

In ARSA's walls it means the "Sarah [MacLeod] Management System", but FAA personnel discuss administration of Safety Management Systems in aviation.

Tom Hillesland, Aviation Safety Inspector, SMS Program Office, FAA


Tiffany LaTour, Assistant Manager, SMS Program Office, FAA


5:00 p.m. | Club Lounge Happy Hour

Member Day: Friday, March 11, 2022

ARSA's leadership briefs members on the state of the association as well as goals and priorities for the coming year. The ARSA team then closes out the event by walking through a series of key initiatives and updates from the association's work on behalf of the industry.
8:00 a.m. | Annual Membership Meeting & Breakfast
  • Call to Order
  • State of the Association
  • Questions
  • Adjournment

10:00 a.m. | Breakout Sessions

The ARSA Workshop – Updates on the association's work and guidance for maximizing member engagement and support of the industry.


The Workforce Workshop –  Discussion of key issues in aviation (and general technical) career development.


12:00 p.m. | Conference Ends

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, a thank you in ARSA periodicals, ten hours of free online training, complimentary registrations for three participants for the Executive to Executive Briefings as well as three participants in Legislative Day. At the Platinum Level, sponsors may select one of the following to specifically support (please note the list in this document does not reflect current availability):
  • Online Conference Experience
  • Executive to Executive Briefings
  • Legislative Day – All Day
  • Annual Repair Symposium – Ice Breaker Reception
  • Annual Repair Symposium – Club Lounge Happy Hour
  • Congressional Directories/Resources
Projected value of benefits and services (advertising, training, complimentary event attendance): At least $9,500

Thank you to the 2021 Platinum Sponsors
Coopesa
HAECO Americas
Moog Aircraft Group
Wencor Group

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, five hours of free online training, complementary registration options include two participants for the Executive to Executive Briefings as well as two participants in Legislative Day. At the Gold Level, sponsors may select one of the following to specifically support (please note the list in this document does not reflect current availability):
  • Congressional Directories/Resources
  • 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
Projected value of benefits and services (advertising, training, complimentary event attendance): At least $6,750.

Thank you to the 2021 Gold Sponsors
Aircraft Electric Motors
Component Repair Technologies
First Aviation Services, Inc.
The NORDAM Group, LLC

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, complementary registration options include one participant for the Executive to Executive Briefings as well as one participant in Legislative Day. At the Silver Level, sponsors may select one of the following to specifically support (please note the list in this document does not reflect current availability):
  • Nametag Lanyards
  • Hotel Room Keys
  • Annual Repair Symposium – Coffee Break
Projected value of benefits and services (advertising, complimentary event attendance): At least $3,200.

Thank you to the 2021 Silver Sponsors
AAR Corp.
HEICO
Lynden Air Cargo
Turbine Controls

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. Projected value of benefits and services (advertising): At least $1,750.

Contributor – $500-$2,499 (or equivalent in-kind support as appropriate)

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

Thank you to the 2021 Contributors
Aviation NETworX
The Giles Group
Obadal, Filler, MacLeod & Klein, P.L.C.

A block of rooms is available at the Ritz-Carlton, Pentagon City in Arlington, Virginia. The hotel will host most of the activities related to the ARSA Conference and is convenient to the Metro as well as Washington Reagan National Airport (DCA).

Book Today: Click here to access the Ritz-Carlton's event page.

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.

Weston and his wife Bernadette in 2017.

“His dedication was matched with exceptional insight,” ARSA Executive Director Sarah MacLeod said after Weston's death in 2020, 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.”
Click here to learn more about the award.
For information about the 2020 Weston Award honoree, click here.

Purchasing On-Demand Recordings of the 2021 Conference

(1) Go to the online training platform utilized by the ARSA training program (click here or go to potomaclaw.inreachce.com).
(2) Select sessions and complete the checkout/registration process.
(3) Prices start at $20 and vary based on recording length.
(4) Purchased recordings will be available for 90 days of unlimited viewing.
(5) Session access includes all materials and the ability to contact the association with questions.
If you have questions at any time, contact the association.

 


ARSA-onlinetraining


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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.

Layman Lawyer – Persistence No Matter the Task

By Brett Levanto, Vice President of Operations

Aviation is an ongoing lesson in persistence. ARSA’s seen years-long efforts pay off (see, “Approval Only Needed Once”, for example).

In August’s article regarding my “layman lawyer” exchange with the FAA about its issuance of an airworthiness directive against a parachute, I closed with this final “gate” on the slalom course of regulatory interpretation:

“Don’t give in or up. The first response from the agency was wrong and should not be allowed to stand. Value is obtained only by continuing until the answer is right.”

Unfortunately, the next round of communication with the FAA did not bring a better analysis. After three months’ deliberation, the acting chief counsel repeated the same incomplete evaluation initially given in July. He then unilaterally closed the door: “I will not be devoting additional time or resources into a further review of this matter,” he said.

Regardless of his plans, this “layman lawyer” has raised the concern to the Department of Transportation’s Office of General Counsel. With all due respect to the government’s resources, it’s difficult to imagine that any substantive time was devoted to the matter in the first place. ARSA does not believe in allowing the government to blatantly ignore the authority provided by the plain language of the law, no matter how trivial the specifics.

While standing by for response to the next round of engagement (see the letter and its attachments), members should review the avenues for escalating issues:

(1) The Consistency and Standardization Initiative provides a pathway for questioning actions by aviation safety offices, providing a method for certificate holders to systemically address disagreements with local inspectors (I wrote about the program in 2015, calling it “‘we the government’ at its stultifying best”).

(2) The Regulatory Consistency Communication Board offers an avenue for stakeholders to raise issues of policy or regulatory inconsistency; issues raised should involve either Aircraft Certification or Flight Standards Service oversight.

As with all good things, using these systems takes time (six years in the CSI example above). Getting to the right answer is worth it, it just takes persistence.

Help continue this discussion. Submit your “layman lawyer” experiences or questions via arsa.org/contact.

 


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ARSA on the Hill

Unfinished Business

Congress has a lot of unfinished business.

While the recent passage of President Biden’s infrastructure plan was a significant achievement, more controversy is contained in the “must do” items include FY 2022 appropriations (the new fiscal year began on Oct. 1) and raising the debt ceiling.

The ongoing debate over the White House’s massive social spending plan is expected to consume considerable bandwidth between now and Dec. 31. Congress will no doubt be punting appropriations to the new year.

Here’s a quick rundown of ARSA’s activities on Capitol Hill:

Manual Education

This summer, ARSA educated lawmakers and congressional staff about FAA’s inconsistent enforcement of its instructions for continued airworthiness (ICA)/maintenance manual rules.

The FAA zealously enforces rules requiring repair stations to have current ICA available when performing work but (at least to ARSA’s knowledge) has never enforced rules requiring design approval holders to make ICA available. As a result, repair stations have been subjected to onerous licensing schemes, outrageous manual pricing, and outright refusals to provide regulatorily-required data. (For more on the issue and a detailed history of ARSA’s decades of ICA engagement, go to arsa.org/regulatory/faa/design/ica-efforts.)

ARSA is not pursuing a legislative solution to the ICA problem; rather, it is asking Congress to use its oversight authority to urge FAA to bring stakeholders to the table, clarify obligations, and create mechanisms to ensure access, receive and resolve complaints and enforce compliance.

Visit ARSA’s Legislative Action Center (provided thanks to support from Aircraft Electric Motors) to educate representatives and senators about your experience with the ICA issue.

Maintenance Workforce Development

The $2 trillion Infrastructure Investment and Jobs Act (H.R. 3684) signed by Biden on Nov. 15 creates a new ARSA-endorsed federal program to support transportation workforce development.

Sec. 5507 of the bill authorizes $5 million for five years for a new transportation jobs outreach initiative to be administered by the U.S. Department of Transportation (DOT). The authorization allows DOT to increase awareness of career opportunities in the transportation sector, including mechanics and technicians, and to target diverse segments of the population.

The program was originally proposed by House Aviation Subcommittee Chairman Rick Larsen (D-Wash.), former House Transportation & Infrastructure Chairman Don Young (R-Alaska) and Rep. Angie Craig (D-Minn.). While the program is not focused solely on aviation maintenance, Larsen has been a champion for technician workforce development. ARSA is grateful that he specifically called out maintenance jobs in his bill and that he and others are continuing to identify opportunities to address the technician shortage.

FAA and Boeing Accountability

Larsen, House Transportation & Infrastructure (T&I) Committee Chairman Peter DeFazio (D-Ore.) and aviation subcommittee member Greg Stanton (D-Ariz.) want to know more about FAA’s efforts to hold Boeing accountable for two issues regarding the 737 MAX.

In the letter to FAA Administrator Steve Dickson on Nov. 29, the lawmakers asked what FAA has done, if anything, to hold Boeing accountable for apparent violations of its approved 737 MAX type design, as well as downplaying the significance of the Maneuvering Characteristics Augmentation System (MCAS) connected to the two 737 MAX crashes. “[W]e are deeply troubled by the absence of rigorous accountability for Boeing’s past transgressions related to the 737 MAX and the FAA’s failure to hold those who violated the public’s trust accountable,” the lawmakers wrote to Dickson.

More at larsen.house.gov/news/documentsingle.aspx?DocumentID=2566.

DeFazio’s Exit

In related news, DeFazio announced his retirement from Congress at the end of 2022 and Larsen quickly announced his candidacy to succeed DeFazio as the T&I Committee’s top Democrat. Look for more coverage and analysis.

 


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.

 


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Training

Make ARSA Training Work

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).

Price: One-hour sessions are $75 for ARSA Members and $150 Non-Members. Classes with special pricing are indicated on this page. (Member prices provided to certain associations through reciprocal arrangements. Sessions will often be available at lower prices through bundles, coupons and other special opportunities.)
Government employees: Contact ARSA directly for auditing opportunities.
Registration: Registration and payment may be processed directly through the training platform/course catalog (free account creation required).
Technical questions and assistance: Click here for FAQ and technical support from training platform vendor.
Refunds: No refunds are granted for ARSA training sessions. When classes are canceled, registrants can choose from future courses of equal value. If a registrant is unable to attend a live session, their registration allows access to the on-demand, recorded version of the webinar.
IA Approval: A number of ARSA training sessions have been accepted for Inspection Authorization (IA) renewal credit. These sessions are denoted on their registration page with their FAA course acceptance number (in red).
Benefits: Registration for an ARSA-provided training session includes:
  • Access to the live class session on the scheduled date (if applicable).
  • Unlimited access to the on-demand, recorded version of the webinar to be made available after the live session is complete (or at time of purchase, for on-demand classes).
  • A copy of the presentation and all reference material with links to relevant resources and citations.
  • A certificate* upon completion of the session as well as any required test material.
*Only registered participants are eligible to receive a completion certificate for each session. Certificates are delivered automatically via email after the completion criteria – usually viewing the session and submitting an associated test – are met.
OFM&K Training Portal: All of ARSA's training sessions are provided through OFM&K's training portal. As the training provider of choice for ARSA and a trusted resource for the aviation community, the firm's training materials represent a vital tool for entities pursuing regulatory compliance and business success. All of the courses are administered via PotomacLaw.InreachCE.com, which is not part of ARSA's website.

Complying with Part 145 – “Soup to Nuts” (Four Hours) Instructor: Sarah MacLeod Description: Specially recorded with a hand-picked audience for interactive discussion, this session thoroughly reviews 14 CFR part 145, discusses the application of the rule and overviews some practical implications of obtaining and maintaining a repair station certificate. Pricing Note: This is a four-hour session and is $300 for members and $600 for non-members. Click here to register and get access for 90 days.

Sessions Accepted for IA Renewal Credit Eight of ARSA's on-demand training sessions have been accepted by the FAA for Inspection Authorization renewal credit under 14 CFR § 65.93. Each session is currently available for registration and immediate access: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. Click here to purchase all eight sessions (plus one required prerequisite) at a “bundled” discount.

The following general subject areas are covered by sessions currently available in ARSA's training library. Search these and other topics directly via the online training portal (click here to get started).

Aircraft Parts


Audit Activism & Prophylactic Lawyering


Drug & Alcohol Testing


Human Factors


Instructions for Continued Airworthiness


Parts 21, 43, 65, 145 (and others)


Public Aircraft"Going Global" - International Regulatory Law


Grassroots Advocacy


Recordkeeping – "Finishing the Job with Proper Paperwork"


The Fourth Branch of Government (Administrative Agencies and Procedures)


Self Disclosure Programs and Practices

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.

 



Relive the 2021 Annual Conference

In March 2021, ARSA hosted its first-ever online Annual Conference. From it’s “production studio” in Arlington, Virginia, the association’s team welcomed participants from around the world and provided members with the same world class substantive discussion they would have gotten in any other year.

As registration opens for 2022 – a welcome return to in-person event hosting (with livestream options) – ARSA invites members to benefit from the content produced earlier this year by accessing session recordings.

Day   Access
Legislative Day, March 10   Training Platform
Symposium, March 11   Training Platform
Member Meeting, March 12   Training Platform

Purchasing On-Demand Recordings

(1) Go to the online training platform utilized by the ARSA training program (click here or go to potomaclaw.inreachce.com).
(2) Select sessions and complete the checkout/registration process.
(3) Prices start at $20 and vary based on recording length.
(4) Purchased recordings will be available for 90 days of unlimited viewing.
(5) Session access includes all materials and the ability to contact the association with questions.

 


Complete Human Factors Training Series – The Dirty Dozen in Depth

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.
(3) Examples.
(4) Mitigations.
(5) Exercises.

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.”

If you have questions regarding this series or any of ARSA’s training resources, contact Brett Levanto. For more information about ARSA’s online training program, click here.

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.

Session Title

 

Registration/Information

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 includes:

  • Access to the on-demand, recording for unlimited viewing over 90 days.
  • 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.

 


From the FAA – Failure to Follow Procedures

ARSA invites members to take advantage of the FAA’s training session “FFP: The Buck Stops with Me.” Here’s the session description from the agency:

While aviation maintenance personnel are fully aware of the consequences of failing to follow procedures (FFP) – and have likely received training on this issue – FFP continues to be one of the leading safety issues in aviation maintenance.

The purpose of the “FFP: The Buck Stops with Me” course is to help aviation maintenance personnel better understand and appreciate how an organization’s culture affects safety with respect to FFP. Once learners have completed the course, they will be equipped with the tools to champion a commitment to reduce FFP events in their working environments.

For session information and to register, click here.

 


Regulatory Compliance Training

Test your knowledge of 14 CFR §§ 11.40 & 11.41, participating in the rulemaking process.

Click here to download the training sheet.

 


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Membership

Quick Question – Event Selection

Why do you go to an industry meeting or event?

As ARSA (and its membership) turns its eyes towards the 2022 Annual Conference, the association once again seeks your insight regarding the value of gatherings (online or in-person). Help the effort by answering this month’s “quick question.”

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

Access the survey by visiting: https://www.surveymonkey.com/r/qq-event-selection.

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

 


Welcome Back – 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 renewed in November:

Renewing Members

Aero Products Component Services, Inc., R03, 2019
Aircraft Technologies Group, Inc., R01, 2021
Austin Aerotech Repair Services Inc., R01, 2012
Component Repair Technologies, Inc., R05, 1995
Fire-Tec Aero Systems, LLC, R01, 2013
Gateway Alliance Co. dba Affinity Aeronautical Solutions, LLC, R02, 2018
Daniel, Michael, Affil, 2020
Helicopter Services, Inc., R01, 2019
Liebherr-Aerospace Saline, Inc., R05, 2006
MRO Holdings, Corp, 2017
Papillon Airways, R03, 2011
Turbines, Inc., R02, 2017
US Technicians, Inc., R01, 2021

 


A Member Asked Reported…Letters of Compliance

In light of ARSA’s efforts to curtail the practice, [a member] passed along its experiences.

In 2019 during a recertification of our repair station, (due to an FAA error in the repair station number assignment), FSDO personnel required a “Letter of Compliance” by making it known that not providing one would cause delays in the recertification.

Now, in the certification process for a satellite repair station with the same FSDO, we are facing the same “requirement”, but, worse, the format from 2019 is now unacceptable.

While ARSA’s joint effort with the Aircraft Electronics Association successfully removed the requirement from Order 8900.1 for repair stations (there is still a reference to the letter for part 135 operators), some agency personnel are unofficially enforcing the practice.

First, to help the association make good on its advocacy for the industry, members should always report these deviations through arsa.org/contact.

Second, to read the full background on ARSA’s work related to the “letter of compliance,” visit arsa.org/letter-of-compliance.

Third, the “letter of compliance” is a “best practice” for ensuring and showing where compliance for each element of 14 CFR parts 43, 65, 120, and 145 can be found and it eases the aviation inspector’s paperwork burden. The association has developed model templates for just such activity. The following publications are available free of charge to individuals from association member organizations:

  • Advisory 2017-01: Importing Aircraft Parts for Repair Duty Free
  • Communications Tracking Log
  • Government Relations Chart
  • Form E100: New Article Inspection Form
  • Manual Compliance Cross Reference Documents (C.A.S.E., TCCA, EASA Special Conditions & Supplement Guidance, Relevant 14 CFR parts)
  • Press Release Template
  • Petition for Exemption from 145.109(d) Toolkit
  • Repair Station Forms Manual and Forms
  • Repair Station Security Compliance Checklist
  • Repair Station Security Fact Sheet
  • Small Business Administration Ombudsman Comment Toolkit for ICA Issues
  • Working Away Advisory Original Issue

Finally, what the association abhors is the absolute certainty that failure to make the government’s job easier will slow the certification process. The agency’s internal “safety assurance system” (SAS) is a time consuming, burdensome paper-pushing methodology for certification and oversight activities. Without a document that cross-references compliance “showings” to the regulatory (minimum) requirements, the aviation safety inspector will need to read the documentation and “find” compliance.

“Requiring” a “letter of compliance” because of bureaucratic processes is why John F. Kennedy’s “Ask not what your country can do for you – ask what you can do for your country” rings so true.

 


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.

Brexit

On June 23, 2016, citizens of the United Kingdom voted to withdraw from the European Union in a national referendum. Fifty-two percent of voters voted for the UK to “leave” the political and economic union joining it to 27 other member states.

Resources for Dealing with the Government

As a repair station, dealing with the government, particularly the Federal Aviation Administration (FAA) is inevitable. Building a good relationship with government officials in good times will help keep the bad times at bay.

Industry News Roundup

ARSA monitors media coverage on aviation maintenance to spread the word about the valuable role repair stations play globally by providing jobs and economic opportunities and in civic engagement. These are some of this month’s top stories highlighting the industry’s contributions. You can explore these stories through ARSA’s Dispatch news portal.

 


Industry Calendar

Conference Dates Location
EASA Rotorcraft and VTOL Symposium 12/9/2021 Online
EASA-FAA International Aviation Safety Conference TBD/2022 TBD
Aero-Engines Americas 1/26-28/2022 Miami, FL
MRO Latin America 2/9-10/2022 Cancún, MX
MRO Middle East 2/22-23/2022 Dubai, UAE
HAI Heli-Expo 3/7-10/2022 Dallas, TX
ARSA Annual Conference 3/8-11/2022 Washington, DC
WAI Annual Women in Aviation Conference 3/17-19/2022 Nashville, TN
ATEC Annual Conference 3/20-23/2022 Fort Worth, TX
AEA International Convention and Trade Show 3/28-31/2022 New Orleans, LA
Purdue University National Aviation Symposium 4/6-8/2022 West Lafayette, IN
ABACE 4/12-14/2022 Shanghai
MRO Americas 4/26-28/2022 Dallas, TX
NBAA Maintenance Conference 5/3-5/2022 San Antonio, TX
EBAA-EBACE2022 5/23-25/2022 Geneva, Switzerland
MRO BEER 6/15-16/2022 Istanbul, Turkey
MRO Asia-Pacific 9/20-22/2022 Singapore
NBAA Business Aviation Convention & Exhibition (NBAA-BACE) 10/18-20/2022 San Antonio, TX
EASA Rotorcraft and VTOL Symposium 11/16-18/2022 Koelnmesse, Germany

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

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