2021 – Edition 11 – December 3

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.

2024 Conference 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 12, 2024

Participation by industry executives with senior executive branch officials is limited to annual conference sponsors.

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8:30 a.m. | Coffee & Light Breakfast

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9:00 a.m. | Introductory Briefing

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10:00 a.m. | U.S. Department of Transportation

Elliott Black, Facilitator, Aerospace Supply Chain Resiliency Task Force, Office of the Under Secretary for Transportation Policy, U.S. Department of Transportation

ARSA is a member of the congressional-mandated task force examining the resiliency of the aerospace supply chain. Black will facilitate a group discussion about issues impacting the maintenance sector supply chain, including workforce, government policy, access to materials, geopolitical challenges, etc.

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11:00 a.m. | Break

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11:15 a.m. | U.S. Department of State

Heidi Gomez, Deputy Assistant Secretary for Transportation Affairs, Bureau of Economic and Business Affairs

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12:00 p.m. | Access to Maintenance Data: The ICA ARC

Josh Krotec, Senior Vice President, First Aviation and Member, ARSA Board of Directors 

Krotec has been named industry co-chair of the newly established Instructions for Continued Airworthiness Aviation Rulemaking Committee, which was created at ARSA’s request to address the availability of maintenance data.  He will discuss the ARC’s mandate and objectives, and opportunities to influence the ARC’s work.

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12:45 p.m. | Lunch & Midday Break

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2:00 p.m. | U.S. Department of Commerce

Scott Kennedy, Director, Office of Transportation & Machinery, International Trade Administration

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3:00 p.m. | Break

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3:00 p.m. | Economic Impacts

Livia Hayes, Director, Market Intelligence Team, Transportation and Services Practice, Oliver Wyman

Hayes will review the findings of the most recent Oliver Wyman MRO industry forecast and lead a roundtable discussion of factors and trends impacting demand for maintenance services.

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4:00 p.m. | Wrap Up Discussion

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Legislative Day: Wednesday, March 13, 2024

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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7:30 a.m. | Registration & Breakfast

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8:00 a.m. | Welcome & Introductions

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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.

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9:00 a.m. | National Defense Authorization Act Opportunities

ARSA is pursuing legislation as part of the annual Pentagon budget and policy bill to enhance competition and opportunities for small businesses in Department of Defense aircraft maintenance contracting.

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Josh Krotec, Senior Vice President, First Aviation and ARSA Immediate Past President

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Alex de Gunten, Senior Vice President for Government & Industry Affairs, HEICO and 2024 ARSA Government Affairs Chairman

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9:45 a.m. | Break

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10:00 a.m. | FAA Reauthorization: Industry Perspectives 

Representatives of ARSA ally organizations discuss their priorities in the current FAA reauthorization and share insights about the likelihood of an FAA bill being enacted in 2024. 

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Karen Huggard, Vice President of Government Affairs, National Air Transportation Association 

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Jarrod Thompson, Vice President for Legislative and Regulatory Policy, Airlines for America 

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Sterling Wiggins, Senior Director, Transportation, Infrastructure, and Supply Chains, U.S. Chamber of Commerce

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Adam Weiss, Counsel (Minority), U.S. House Transportation & Infrastructure Committee Subcommittee on Aviation

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11:00 a.m. | Release of 2024 Global Fleet & MRO Market Report

Livia Hayes, Director, Market Intelligence Team, Transportation and Services Practice, Oliver Wyman

Uktarsh Mishra, Market Intelligence Specialist, Oliver Wyman CAVOK

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11:30 p.m. | Wrap Up Discussion & Presentation of 2024 Legislative Leadership Award to Garret Graves (R-La.)

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12:00 p.m. | Lunch

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1:00 p.m. | Congressional Meetings Begin

Participants head to Capitol Hill for scheduled meetings with members of Congress and staffers covering subject matter or geographic jurisdictions impacting participant home/facility locations. NOTE: participants schedule their meetings directly with the relevant offices; instructions are provided in advance of the event.

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TBD | Presentation of ARSA Legislative Leadership Award (Special Invitation Only)

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4:00 p.m. | Symposium Registration Open (for non-Legislative Day attendees)

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5:30 p.m. | Ice Breaker Reception

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7:00 p.m. | Special Invitation Dinner

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Annual Repair Symposium: Thursday, March 14, 2024

The centerpiece of Conference week, ARSA convenes a full day of substantive panel discussions covering key regulatory compliance and business issues.

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7:30 a.m. | Registration & Breakfast

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8:00 a.m. | Welcome & Introductory Remarks

ARSA is the voice of the global aviation maintenance industry. How the association advocates your interests with legislators, regulators, and the media sets the stage for corporate growth. Information on how advancement of the industry’s collective interests enables individual companies to shine more brightly.

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8:30 a.m. | Session 1: Fireside Chat with AVS-1

David Boulter, Associate Administrator for Aviation Safety, FAA

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9:00 a.m. | Break

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9:15 a.m. | Session 2: Opening Salvo – Conversations with the Regulators

International aviation safety agencies will provide updates on the regulations, policies, and procedures of importance to the global aerospace sector. 

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Lawrence Josuá Fernandes Costa, Continuing Airworthiness Certification Manager, Department of Flight Standards, ANAC Brazil [In person]

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Ludovic Aron, Washington Representative, EASA [In person]

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Karl Specht, Principal Coordinator Organisation Approvals, EASA [Online]

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Dan Elgas, Director, Policy and Standards Division (AIR-600), Aircraft Certification Service, FAA [In person]

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Tim Adams, Deputy Director, Office of Safety Standards, Flight Standards Service, FAA [in person]

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Jackie Black, Manager, Aircraft Maintenance Division, Flight Standards Service, FAA [in person]

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Jeffrey Phipps, Chief, Operational Airworthiness (AARTN), Transport Canada Civil Aviation [In person]

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Neil Williams, Head of Airworthiness, Policy & Rulemaking, United Kingdom Civil Aviation Authority [In person]

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12:30 p.m. | Lunch with Special Guest

Billy Nolen, Chief Safety Officer, Archer Aviation

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2:00 p.m. | Session 3: Defining the Career

Using known pathways and the current regulations, panelists lay out templates for international maintenance technician recruitment, training, and retention.

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Ryan Goertzen, Vice President of Workforce Development, AAR

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Barrington Irving, Founder & CEO, The Flying Classroom and Founder of the Barrington Irving Technical Training School

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Crystal Maguire, Executive Director, Aviation Technician Education Council

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3:00 p.m. | ARSA Quiz Show

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3:30 p.m. | Break

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4:00 p.m. | Session 4: Training First

Based on recommendations from SOCAC’s Workforce Development and Training (WDAT) Working Group and the ongoing work of the ARAC Repairman Working Group, panelists will explain how industry can push the government to accept standards for competency and skill development.

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

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Member Day: Friday, March 15, 2024

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 choosing from one of several concurrent breakout sessions.

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8:00 a.m. | Annual Membership Meeting & Breakfast

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9:30 a.m. | Break

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10:00 a.m. | Training: Regulations for Supervisors & Inspectors

This session reviews the cardinal regulatory knowledge necessary for repair station personnel to be “thoroughly familiar with the applicable regulations in this chapter.” ARSA’s training team is rolling out the course for the benefit of Conference attendees.

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12:00 p.m. | Conference Ends

Attendance Options (In-Person & Livestream)

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. Access to the livestream in 2024 will be available only to "Conference Ambassadors." These "Ambassadors" are contacts identified by in-person participants to bring the event back to their home facilities.

Sponsorship

For information about committing your organization to the Annual Conference (we can already look ahead to 2025), contact ARSA Vice President of Operations Brett Levanto.

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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, sponsorship rights and 10 registrations to an ARSA training session, 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 2024):

• 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

2023 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, 5 registrations to an ARSA training session, 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 2024):

• 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

2023 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):

• Nametag Lanyards
• Hotel Room Keys
• Annual Repair Symposium – Coffee Break (5)

2023 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.

2023 Supporter

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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.

2023 Contributors

Location & Accommodations

ARSA's block of rooms for Conference participants at the Ritz-Carlton, Pentagon City in Arlington, Virginia is now closed. 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). To try and book a room independently, go to the hotel's website or call 703.415.5000.

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Those seeking other options may consider these hotels (there are no ARSA-related specials or promotions at these locations):

Embassy Suites by Hilton Crystal City National Airport 1393 S Eads St. Arlington, Virginia, 22202

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Residence Inn Arlington Capital View 2850 South Potomac Avenue Arlington, Virginia, 22202

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DoubleTree by Hilton Hotel Washington DC – Crystal City 300 Army Navy Drive Arlington, Virginia, 22202

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Crowne Plaza Washington National Airport 1480 Crystal Drive Arlington, Virginia, 22202

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Hampton Inn & Suites Reagan National Airport 2000 Richmond Highway Arlington, Virginia, 22202

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Radisson Hotel Reagan National Airport 2020 Richmond Hwy Arlington, VA 22202

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Holiday Inn National Airport/Crystal City 2650 Richmond Highway Arlington, Virginia, 22202

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.

Anti-Viral Measures

The ARSA team encourages all Annual Conference in-person participants to take measures appropriate to their personal comfort, medical risk, and other needs related to personal health. The following resources are available for attendee reference:

The Ritz-Carlton

The site of all substantive and social gatherings related to the ARSA Conference. The Ritz-Carlton, Pentagon City follows the Marriott International "Commitment to Clean." The guidance includes protocols and elevated practices and can be found at whattoexpect.marriott.com/waspc.

Virginia

With the exception of any Legislative Day meetings held on Capitol Hill (scheduled individually by participants), the entirety of the Annual Conference takes place in the Commonwealth of Virginia. Guidance related coronavirus protocols can be found at www.vdh.virginia.gov/coronavirus/protect-yourself.

Washington, D.C.

No Annual Conference activities open to general participation take place in Washington, D.C. Conference attendees going into the city for business or personal reasons should consult coronavirus.dc.gov for policy and guidance related to the pandemic.

U.S. CDC

According to the Centers for Disease Control and Prevention, both Arlington County (the location of the Ritz-Carlton, Pentagon City) and Washington, D.C. are classified as "medium" for community transmission. See county-by-county assessments and guidance at www.cdc.gov/coronavirus.

Going Livestream

If any in-person registrant wishes to opt out of participation because of personal health concerns (including illness) they may switch to livestream access at any time. Access to the livestream is available to all participants via the Digital Companion, a password-protected webpage for participants to access the agenda, speaker information and presentation resources.

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.

Participant Resources & Recording Availability

Materials and Recordings

The Digital Companion (the much discussed online resource for event materials and resources, to which access information is sent to attendees via email and provided from the lectern on each day) is the location for PDFs of all presentations as well as links to additional resources discussed during the event. It also includes an attendee directory (in the “General Resources” area) and information about accessing the livestream sessions and raw recordings.

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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.

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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).

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.

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.

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

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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