2021 – Edition 9 – October 1
Table of Contents
Note: The order of material varies in hotline emails, but is always presented the same on this landing page. Readers scrolling through content on or printing this page will find it organized consistent with the table of contents.
Sarah Says
Anti-Viral Measures
ARSA Works
Quality Time
Legal Brief
ARSA on the Hill
Training
Membership
Resources
Industry Calendar
Sarah Says
During, After, Next…and Meanwhile
By Sarah MacLeod, Executive Director
The worldwide pandemic is not “over” and when it is, the effects will reverberate for years; we might just be able to “recover” before the next one circles the world.
In the meantime, companies need to stay in business, which means ensuring a workforce capable of pulling through the recovery and probably the next worldwide emergency while moving into the future of unmanned aerial systems and electric aircraft.
The trade association is asked many questions about aviation “business” that are outside ARSA’s wheelhouse but are certainly important to its members. In the last several months, two overarching queries have been made—
First, what are “others” in the aviation industry doing about “vaccines”? Although the association is not going to take a position on whether a business should require its workforce to be vaccinated, ARSA will provide information on what “others” are doing and on how to assess the situation regarding this and future epidemic situations. The main question companies do need to ask is economic: Is it better to have confidence in the number and ability of workers to (a) show up and (b) not risk others than it is to lose those that will not comply with a personal choice mandate? There is no right or wrong answer, the bottom line is what needs to be evaluated and it needs input from human resources, employees, employment counsel, and others to make a good decision for your company and your employees.
Next, ARSA is getting questions regarding “green” changes in the maintenance industry – and there are articles on what companies are doing in that arena throughout the trade press. Always willing to stay ahead of trends real and imaginary, ARSA will keep its members informed of opportunities unique to aviation maintenance.
In the meantime, most individuals and corporate entities are taking “green” measures, some mandated by the federal or state governments, some because the economic assessment is positive, and others because of political or even emotional reasons. The most obvious is recycling – never mind that there is no place to send lots of the materials – which is generally mandated for businesses by cities and states. The construction industry is required to install low-flow water devices; businesses that retrofit are putting in water-saving measures and devices, solar arrays, native and natural areas in parking lots, on patios, and rooftops. Lighting and light bulbs have changed, radiant heat and geothermal choices are becoming more common, and we anticipate “green” measures will receive more government support in the next few years both in monetary rewards and mandates.
The association tracks these developments through member input. When it seeks feedback from its members, it appreciates the attention given to completing the survey(s). In these cases, the surveys help us provide you information in a timely and complete manner – not just on regulatory and legislative issues on aviation safety compliance but those that will impact businesses and individuals universally.
Give us 10 minutes and complete one or more “Quick Questions.”
Anti-Viral Measures
DOT Announces $482 Million in Jobs Program Awards
To keep tabs on all of ARSA’s work related to the pandemic, visit arsa.org/anti-viral-measures.
On Sept. 14, the U.S. Department of Transportation announced it will offer $482.3 million in funding to 313 businesses in 37 states and Puerto Rico under the Aviation Manufacturing Jobs Protection (AMJP) Program. DOT estimates the investment will protect as many as 22,500 jobs nationwide.
In addition to fulfilling requirements of the AMJP Program mandated by Congress in the American Rescue Plan Act of 2021, the awards reflect two key DOT priorities – economic strength and equity. Many of the recipients are small businesses: Of the 313 companies receiving funds, 188 of them (60 percent) had fewer than 100 employees at the end of calendar year 2020, and 252 of them (80 percent) had fewer than 250 employees.
AMJP funds can be used to pay up to half of the payroll costs for certain categories of employees engaged in manufacturing or repair, for up to six months. In return, the business must make several commitments, including not to involuntarily furlough or lay off personnel (or reduce pay or benefits) within that group during the time the business is receiving AMJP payroll support.
To access a full list of round one awardees, click here.
The applications for the second round of funding closed September 1st and additional funding recipients will be announced later this fall. ARSA encourages members who applied for assistance to share their experience with the association (and those who did not apply to explain their decision) via arsa.org/contact.
The AMJP awards are separate from grants to be issued by the FAA for technician and pilot career development programs. For more information on those grants – the initial round of selections has not yet been announced – visit arsa.org/grant-program.
For more information on the AMJP Program, visit www.transportation.gov/AMJP.
ARSA Works
CMT Expands ARSA’s Global Reach
One of the ways the association engages with industry and regulators to iron out problems in bilateral relationships is by participating in regular meetings of the Certification Management Team (CMT).
While meetings between aviation authorities are nothing new, the CMT was formalized in 2015 when the FAA, EASA, Transport Canada Civil Aviation (TCCA) and Brazil’s National Civil Aviation Agency (ANAC) signed a charter creating a framework to manage technical, policy and bilateral agreement certification, manufacturing, export and continued airworthiness issues among the four authorities.
The CMT’s strategic focus areas are:
- Partnership leveraging. Relying on each other’s certification systems to reduce or eliminate duplicative validation efforts.
- Continued confidence building. Identifying and resolving potential differences between regulatory systems and leveraging partner certification findings to improve efficiencies and free up oversight resources.
- Global leadership. Leading the international community in developing common standards and policies aimed at ensuring the safety of the flying public while embracing new and novel technologies developed by the globalized aviation industry.
- Certification policy alignment. Aligning existing certification policies to allow for the seamless transfer of aviation products and efficient oversight of the industry while maintaining the highest safety standards.
The CMT includes five Certification Authorities Groups (CAGs) focused on specific areas (bilateral agreement and certification, general aviation, transport airplane, rotorcraft products and propulsion products).
Aside from creating a forum for regulators to interface, CMT is also a vehicle for collective industry engagement. In the run up to each annual meeting, aviation industry companies and trade associations meet to discuss common priorities to present to the authorities.
This year’s CMT meetings took place the week of Sept. 20, with bilateral meetings on the 20th and 21st, authority meetings on the 22nd and 23rd and a joint meeting with industry on Sept. 24. ARSA was represented at the pre-meetings and CMT Industry day by Managing Director & General Counsel Marshall S. Filler and Executive Vice President Christian Klein.
Industry representatives expressed strong support for the CMT’s efforts, noting that better coordination between authorities has led to improvements in some areas (e.g., streamlined validations for basic projects and increased use of remote test witnessing). However, manufacturers involved in validation projects pointed to areas where authority coordination should be improved. For example, by better articulating the respective level of involvement in a validation project earlier in the process, sticking to agreed deadlines, improving management oversight and resource allocation and adherence to TIP/IPA elements.
Specific industry recommendations for the CMT included developing and implementing validation performance metrics, creating industry-authority bilateral implementation forums to address bilateral issues more quickly, and accelerating the use of validation work plans.
Filler used the meeting as an opportunity to urge action on ARSA’s request that the U.S./EU Technical Implementation Procedures and Maintenance Annex Guidance be changed to allow automatic acceptance by EASA of technical data used to support minor alterations for noncritical components. ARSA coordinated a letter to the FAA and EASA in September 2020 from 15 leading aviation organizations requesting the change; to date the authorities have not responded or taken action.
In addition to CMT, ARSA also actively participates in the Maintenance Management Team (MMT), a parallel body focusing on maintenance issues. Preparations are under way for the MMT meeting taking place in November. Stay tuned to the hotline for coverage.
Getting Feet in the Certification Door
In July, Choose Aerospace delivered to the FAA a petition for exemption from the experience requirements of § 65.77. The organization is dedicated to technical career development and counts ARSA among its supporting coalition; the petition seeks to allow high school students completing a special aviation maintenance curriculum to sit for the mechanic general written test.
Allowing the exemption would “put [Choose Aerospace program] graduates on a path to certification either through direct employment or transfer credit opportunities,” the petition said. It compared the relief sought to early “successes” realized by pilot trainees, who may begin testing independent of an FAA-certificated pilot school. After passing the general written test, each aspiring AMT would have 24 months to pass the remaining prescribed tests as required by § 65.71(a)(3), meeting the experience requirements of
§ 65.77 in order to do so.
“The petition offers a solution to a looming aviation technical workforce crisis that will have devastating consequences on the aviation industry and the flying public if it comes to fruition,” the submission said. “The ability for students to take the general written test—independent of an AMTS or relevant work experience—would transform workforce development programs into true career pathways and help fill empty AMTS seats in several ways.”
The petition has been posted to the Federal Register and is open for comment.
To download and review the complete submission, click here.
A Veteran at Lifelong Learning – 2021 Scholarship Winner Fawn Carrington
In September, ARSA awarded its 2021 scholarship to Fawn Carrington of Tulsa Technology Center. Carrington is an Air Force veteran committed to aviation education for life.
The grant is part of Choose Aerospace’s 2021 Aviation Maintenance Scholarship and Award Program. ARSA and its partner organizations combined tens of thousands of dollars’ worth of scholarships, textbooks, training systems and testing fee credits for educators and future aviators.
Carrington took the time to tell the repair station community about what’s gotten her this far and where she hopes to go. Her story reflects gratitude for the help she’s gotten and commitment to the lifelong learning needed for success in the constantly-evolving aviation world.
(1) What made you decide to pursue aviation maintenance training?
Having contributed nine years to supporting the United States Air Force as a munition’s systems technician, I was privileged to see what is involved to ensure aircraft
have what they need to complete their missions safely. I was impressed with the aircraft maintenance technicians from the first time I witnessed them hard at work. I became intrigued with the jobs they had and developed a respect for their dedication and unwavering work ethic.
(2) What experience or experiences did you have before you started at Tulsa Tech that have been most valuable to you during school?
I learned to be mechanically inclined as a teenager working on my first vehicles. I would obtain the service manuals and figure out how to do my own maintenance. Having this experience has helped me to work through my school projects with ease and to help others along the way.
(3) What have you found to be most surprising/unexpected about AMT school?
The most surprising is the usage of math in many areas of aircraft maintenance. The math is learnable, even by those who think they are “not good at math.” Everyone I have seen from all levels of experience have been able to excel at the work given.
(4) Other than becoming an ARSA member, what are your goals for life after school?
It is my goal to continue my aviation education for life whilst serving the industry in any way I can. I have an A.S. in Aerospace Administration and intend to complete my B.S. in Aviation Science following my Airframe and Powerplant certifications.
(5) To help ARSA’s members understand the value of the scholarship, tell us about the expenses you have to cover while at school.
Receiving ARSA’s 2021 scholarship has made me proud and grateful as it nearly covers my final tuition needed to complete the aviation powerplant program on schedule. The reward allows me more time to focus on my studies for upcoming certification exams.
(6) If you learned that someone was considering school/career choices and they asked you about aviation maintenance, what would you say?
If anyone has a curiosity or passion for aviation, whether they intend to obtain their private pilot’s license or not, should pursue an aviation maintenance program. It is as fun and useful as it is interesting to learn about the aerodynamics and practices involved in making these flying machines fly. The aircraft we have flying today are truly amazing and the learning never stops with changes in technology and the progress our community is making with NextGen.
To learn more about the Choose Aerospace Scholarships and Awards Program, click here.
For more information on ARSA’s broader efforts to support industry career development, visit arsa.org/workforce.
Want to congratulate Fawn? Recruit her? Learn more about how to find great candidates like her? Contact ARSA for a referral.
TSA Highlights Insider Threats
September was National Insider Threat Awareness Month (NITAM). An “insider threat” is posed by individuals with privileged access to sensitive areas and/or information who intentionally or unwittingly misuse or allow others to misuse the access to exploit vulnerabilities in transportation security.
TSA issued security rules for repair stations in January 2014. Title 49 CFR part 1554 applies to all FAA-certificated repair stations (except those located on U.S. or foreign government military bases) and requires compliance with TSA Security directives and unannounced TSA inspections; there are additional rules for repair stations located on or adjacent to airports. Learn more at arsa.org/security.
Mitigating insider threats is an important security strategy. This year’s national NITAM theme was “Cultural Awareness and Insider Threat.” Insiders at risk of causing harm to themselves or others often display concerning behaviors that result from a combination of personal situations and/or an inability to cope with work and life stressors. TSA believes that by promoting awareness and understanding of cultural differences within the workforce, organizations, and individuals can avoid social missteps and prevent unintentional harm that can lead to increased risk of insider threats.
Some indicators an individual could become an insider threat are:
- Physical or verbal aggression or threats.
- Sudden unexplained decline in performance.
- Repeated policy or directive violations.
- Extreme change in their financial situation.
- Modifying information technology systems without authorization.
- Bypassing security controls.
- Exhibiting curious patterns or histories of database inquiries.
- Improperly disclosing classified or sensitive information.
- Behaviors that raise concerns that an individual may commit an unlawful act.
Instances of possible or potential insider threats can be reported to organizational security officers, to the Department of Homeland Security through its “If You See Something, Say Something” website, by email or calling the TSA Insider Threat Hotline at (855) 257-6919.
The following federal government resources assist the industry in mitigating the insider threat to transportation security:
- National Insider Threat Taskforce Program Maturity Framework.
- National Insider Threat Taskforce training resources.
- Department of Homeland Security Insider Threat Program resources.
- TSA Insider Threat roadmap.
- Resource links from the National Insider Threat Special Interest Group.
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.
On the Move
2022 Annual Conference – Save the Date
March 8-11, 2022
Arlington, Virginia and Washington, D.C. with Livestream Options for Online Participants
What began decades ago as ARSA’s Annual Repair Symposium has evolved into a week-long event including executive branch briefings, grassroots legislative advocacy and world-class regulatory compliance and business content. The event provides a regular venue for members and invited guests from around the world to network and discuss issues that matter to the repair station community.
For four days each March, the association brings the aviation world to the nation’s capital.
Stay tuned for updates; registration will open in December 2021.
Executive to Executive Briefings: Tuesday, March 18, 2025
Participation by industry executives with senior executive branch officials is limited to annual conference sponsors at the Administratium, Platinum, Gold, or Silver levels. In past years, meeting participants included representatives from the U.S. Departments of Commerce, Defense, Labor, State, and Transportation as well as the fellow trade associations and industry interest groups.Legislative Day: Wednesday, March 19, 2025
The day dedicated to educating both the aviation maintenance industry and elected officials. Learn (or brush up) on what ARSA does and what you can do so you're ready for afternoon visits with targeted Capitol Hill legislators and staff.Annual Repair Symposium: Thursday, March 20, 2025
The centerpiece of Conference week, ARSA convenes a full day of substantive panel discussions covering key regulatory compliance and business issues. After the keynote address, regulators from across the world join the full-morning "Opening Salvo" conversation, followed by lunch and an afternoon of practical regulatory and business discussion.Member Day: Friday, March 21, 2025
ARSA's leadership briefs members on the state of the association as well as goals and priorities for the coming year. Participants then close out the event by participating in breakout and/or training sessions focused on key aerospace topics. The Conference ends by 12:00 p.m. EDT.In-Person
All substantive and social activities were hosted at the Ritz-Carlton, Pentagon City in Arlington, Virginia. Legislative Day participants will head to Capitol Hill for meetings with congressional offices as appropriate.
Livestream
The majority of Conference events will be available to livestream viewers via a Vimeo web-player embedded into a page on ARSA.org. All in-person registrants will be able to name a "Conference Ambassador" as a contact to access the livestream and bring the event back to their home facilities. Paying registrants for livestream access may share with multiple company contacts. Livestream participation will include a mechanism for submitting questions to onsite personnel.
Pricing
Executive to Executive Briefings | ||||
Open to Administratium, Platinum, Gold, and Silver-level sponsors. | ||||
Legislative Day – Wednesday, March 19 | ||||
Members | Non-Members | |||
First | Additional | First | Additional | |
In-person | $400 | $360 | $600 | $540 |
Livestream Free with in-person registration. | $400 | $600 | ||
Symposium – Thursday, March 20 | ||||
In-person | $900 | $810 | $1,250 | $1,125 |
Livestream Free with in-person registration. | $900 | $1,250 | ||
Legislative Day & Symposium Bundle | ||||
In-person | $1,100 | $990 | $1,500 | $1,350 |
Livestream Free with in-person registration. | $1,100 | $1,500 | ||
The Super Bundle (Silver Sponsorship, E2E, Legislative Day, & Symposium) | ||||
In-person | $4,200 | $4,500 | ||
Livestream Free with in-person registration. | ||||
Member Meeting & Training/Breakouts – Friday, March 21 | ||||
In-person | Free with Symposium registration. | |||
Livestream |
(2) Registration fees may be waived for government personnel, members of the media, speakers, and other support personnel or special guests upon approval by the ARSA event team.
Administratium – $20,000
What is Administratium? An element aerospace professionals see every day (click here to learn more). Notation in all publicity, marketing and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, specific thank you in ARSA periodicals, additional advertising placement via ARSA’s communications, complimentary registrations for three (3) participants in the Executive to Executive Briefings as well as three (3) in Legislative Day, and free livestream access for personnel unable to attend in person. At the Administratium Level, sponsors may select one of the following* to specifically support (please note the list in this document does not reflect current availability):- Annual Repair Symposium – Ice Breaker Reception
- Annual Repair Symposium – Thursday Happy Hour
- General Sponsorship
Platinum – $10,000
Notation in all publicity, marketing and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, specific thank you in ARSA periodicals, complimentary registrations for three (3) participants in the Executive to Executive Briefings as well as three (3) in Legislative Day, and free livestream access for personnel unable to attend in person. At the Platinum Level, sponsors may select one of the following to specifically support (may not reflect current availability for 2025):- Online Conference Experience
- Executive to Executive Briefings
- Legislative Day – All Day
- Congressional Directories/Resources
- General Sponsorship
2024 Platinum Sponsors
Gold – $7,500
Notation in all publicity, marketing and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, specific thank you in ARSA periodicals, complimentary registrations for two (2) participants in the Executive to Executive Briefings as well as two (2) in Legislative Day, and free livestream access for personnel unable to attend in person. At the Gold Level, sponsors may select one of the following to specifically support (may not reflect current availability for 2025):- Legislative Priorities Brochures/Resources
- Digital Companion/Electronic Materials
- Legislative Day – Continental Breakfast
- Legislative Day – Congressional Briefing and Luncheon
- Annual Repair Symposium – Continental Breakfast
- Annual Repair Symposium – Luncheon with Special Guest
- Nametag Lanyards
- Hotel Room Keys
- General Sponsorship
2024 Gold Sponsors
Silver – $3,500
Notation in all publicity, marketing, and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, complimentary registrations for one (1) participant in the Executive-to-Executive Briefings as well as one (1) in Legislative Day. At the Silver Level, sponsors may select one of the following to specifically support (may not reflect current availability for 2024):- Annual Repair Symposium – Coffee Break (5)
- General Sponsorship
2024 Silver Sponsors
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.Contributor – $500 to $2,499 (or equivalent support)
Notation in some publicity, marketing, and periodicals (e.g., the hotline, Dispatch), and recognition in event materials and from the podium.2024 Contributors
ARSA has reserved a block of rooms for Conference participants at the Ritz-Carlton, Pentagon City in Arlington, Virginia. The hotel hosts most of the activities related to the ARSA Conference and is convenient to the Metro as well as Washington Reagan National Airport (DCA). The deadline for reservations made in this block is Feb. 21, 2025.
To reserve your room(s), visit https://book.passkey.com/go/ARSAAnnualConf2025.
Attendees may also call the dedicated group desk +1.800.422.2410. Reference the ARSA Annual Conference when making reservations.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.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.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.Event Photos
ARSA has created a Google Album including photos taken during the 2024 Annual Conference, which allows participants to share their own photos (Sharing event photos constitutes consenting to their use/distribution in association with Conference-related publicity for this or future events, at ARSA’s discretion). To see the album, click here.Select Recordings
The following selections were highlighted in ARSA's member newsletter, the hotline. Click the headline link to view the recording in the March edition.Legislative Day Briefing – Global Fleet & MRO Market Report
The team from Oliver Wyman CAVOK presented their findings to Legislative Day participants on March 13, illustrating the current and projected states of the North American and global aircraft fleets and related impacts on maintenance demand.
Legislative Day Briefing – Perspectives on Reauthorization
Attendees used these insights (and all the March 13 content) in their meetings on the Hill; all members can benefit from the cross-industry expertise of this lobbyist panel.
Symposium Briefing – What Has ARSA Done Lately
The brief session includes key updates from the association’s year as well as instruction for maximizing membership value.
Symposium Briefing – In the Fire with AVS-1
There were no real flames on stage, but an intense and engaged discussion of the state of the aviation industry. View a clip from the exchange where Sarah MacLeod and David Boulter discuss SMS, training, and more.
Symposium Briefing – Training First
The Symposium portion of the Annual Conference wrapped on March 14 with an hour-long session on how we learn and what we can learn about improving training and personnel development.
A Talent Showcase
The 2022 Aerospace Maintenance Competition will be held in conjunction with MRO Americas from April 25-28 in Dallas, Texas.
The AMC provides an opportunity for current and future maintenance professionals to showcase their abilities and see how they stack up against their peers around the world. The event also offers industry employers a chance to support and benefit from the skill and competitive spirit of these professionals.
ARSA encourages its members to support the event in multiple ways:
(1) Compete
Five-member teams complete in one of six categories:
- Commercial Airlines
- General Aviation
- Military
- Repair and Manufacturing
- School
- Space
Registration is open. Add your company to the list of expected competitors for 2022 or consider supporting a school team if you regularly work with a training institution. Click here to get started.
(2) Sponsor
The AMC provides three main ways to invest in the competitors’ experience. Companies may provide for a competitive event, offer prizes or products for participants, or commit to a corporate sponsorship. Each opportunity requires specific support from the sponsoring organization and provides related exposure and benefits. For more information, visit www.aerospacecompetition.com/sponsor.
(3) Recruit
Companies with access to the AMC’s “recruitment row” will get prime access to the 125+ student competitors at the 2022 event. In addition to a table in the competition space, recruiters get advance access to a database of competitor resumes. To learn how to get your space on the row, visit www.aerospacecompetition.com/recruit.
(4) Introduce
The AMC is more than a showcase for current and budding aviation talent, it is a way to show off for younger students who should consider industry careers. Competition officials welcome visits from student groups, clubs, and aviation organizations. Businesses in the Dallas area should local educators to contact event organizers for more information.
(5) Celebrate
If you will be at MRO Americas, visit the AMC floor and enjoy the competitors’ skills and the sponsors investment. If you’re not, follow along from a distance at www.aerospacecompetition.com. Ask yourself how you and your company can take advantage of this incredible platform in the years to come.
ARSA Goes Regional … Globally
ARSA Executive Vice President Christian Klein participated in two regional aviation conferences in September: the Regional Airline Association’s (RAA) 2021 Leaders Conference and Regional Aviation of Russia and the CIS 2021.
Klein’s comments at the RAA meeting on Sept. 27 in Washington, D.C. were as part of a workforce panel with representatives from RAA, the FAA, Cape Air, Horizon Air, PSA Airlines and Republic Airways. Klein discussed ARSA’s successful efforts to heighten awareness about the technician shortage, share member workforce development best practices and obtain federal assistance for industry recruitment and training initiatives.
Themes that emerged from the panel were:
- Everyone has a role in addressing the problem. Companies can scale programs to size and resources. Larger organizations can develop extensive apprenticeship and mentoring programs, small companies can build relationships with high schools and community colleges with employees serving as recruitment ambassadors.
- Focus on retention as much as recruitment. Recruitment and training represent significant investment, so companies must work as hard to keep employees as to recruit them. Different strategies are needed for different segments of the workforce. For example, Klein relayed that ARSA member AAR recently introduced an all-female technician cohort, each member of which has a female mentor in the company.
- Reduce barriers to entry. Training and certification requirements are barriers to pursuing aviation careers. ARSA’s initiative to improve repairman certification, FAA’s pending update to its rule governing aviation maintenance technician training schools), and industry efforts to smooth the transition from military to civilian careers are all about reducing barriers.
- Increase investment. As a society, we need to cultivate a technically proficient workforce. Cultivating a technically proficient workforce is a long term effort. That means giving more resources to schools, providing equipment to support technical training and encouraging the government to do more (e.g., expanding the aviation workforce grant program).
- Start early. The earlier students (and parents, teachers, and guidance counselors) learn about career opportunities in the global, high-tech aviation sector, the more likely joining that workforce becomes.
- Keep policies up-to-date. In our rapidly evolving legal and cultural environment, it’s important to stay on top of company policy and training materials to ensure they are in step with the times.
Klein’s remarks to the Russian regional airline sector, delivered virtually on Sept. 23, focused on the health of the global aviation maintenance industry in the wake of the pandemic. Citing data from Oliver Wyman (ARSA’s economic research partner) and ARSA’s own surveys, Klein said while business activity for repair stations fell by close to 50 percent in 2020, the U.S. maintenance industry survived due in part to significant federal assistance.
The active global fleet is now back to 90 percent of pre-COVID levels, Klein reported. Recovery has been strongest in Eastern Europe, China, and North America, with growth in all other regions except Southeast Asia. He also described risks and opportunities for the aviation sector, including sustainability, electrification, and regulatory harmonization.
Workforce was also a hot topic at the Russian conference given technology-driven industries around the world are facing the same recruitment and retention challenges. Klein described ARSA’s public relations and lobbying activities to build awareness, share best practices and get government, schools, industry, and labor to work together.
Klein’s next speaking engagements are at the Aviation Council of Pennsylvania’s annual conference in Harrisburg on Oct. 26 (in person) and AviationWeek’s AeroEngines Europe conference in Stavinger, Norway on Dec. 1 (virtual).
FAA Global Leadership Meeting Recordings Available
On Sept. 22 and 23, the FAA hosted its 8th Annual Global Leadership Meeting. The event focused on “Restart and Recovery” and was presented online; session recordings are available for review on the agency’s YouTube channel.
In addition to the usual safety and engagement talking points and acknowledgments of duty to the global traveling public, the meeting included detailed substantive discussion of pandemic recovery, career development, and sustainability – all issues closely followed by ARSA and its members.
“Don’t let the lessons of the past prevent us from thinking of the solutions of the future,” said Clive Brown, chief of the CDC’s Quarantine and Boarder Health Services Branch. Speaking during the panel on public health and pandemic response, Brown explained that future health safety challenges will increase complexity for international transportation. The lesson is applicable across the aviation regulatory chain: Experience should not be a limiting factor against innovation.
See Brown’s presentation as well as participants from the FAA, ICAO, aviation companies and trade associations by accessing the recorded sessions (find specific panels and presentations by reviewing the agenda):
- Entire Event (Playlist)
- Sept. 22 Morning Session
- Sept. 22 Afternoon Session
- Sept. 23 Morning Session
- Sept. 23 Afternoon Session
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.
EO Extends Vaccination Requirement to Federal Contractors
By Christian A. Klein, Executive Vice President
Last month’s “Legal Brief” provided information on presidential executive orders (EOs) that implement policy to direct the activities of federal departments and agencies. The attention was on an EO meant to improve competition, which ARSA is leveraging to highlight FAA’s non-enforcement of maintenance manual availability rules and improve small business access to Department of Defense maintenance contracts.
The issuance of two EOs aimed at fighting the COVID pandemic made the news recently; the first directed federal agencies to require COVID vaccinations for direct employees; the second extended the mandate to private employers doing business with the government and all subcontractors (at any tier).
The second EO sets as condition for doing business with the federal government that contractors agree in writing to comply with all guidance published by the Safer Federal Workforce Task Force. The condition applies to contractor and subcontractor locations at which “an individual is working on or in connection with a Federal Government contract or contract-like instrument.” The condition will be required in new contracts and contract-like instruments, new solicitations, the renewal of existing agreements and the exercise of an option on certain existing contracts.
For “contract” the EO adopts the same definition employed by the Department of Labor in its 2021 rule increasing the minimum wage for government contractors. applying the minimum wage to such agreements, to wit,
[A]ll contracts and any subcontracts of any tier thereunder, whether negotiated or advertised, including any procurement actions, lease agreements, cooperative agreements, provider agreements, intergovernmental service agreements, service agreements, licenses, permits, or any other type of agreement, regardless of nomenclature, type, or particular form, and whether entered into verbally or in writing. The term contract shall be interpreted broadly as to include, but not be limited to, any contract within the definition provided in the Federal Acquisition Regulation (FAR) at 48 CFR chapter 1 or applicable Federal statutes. This definition includes, but is not limited to, any contract that may be covered under any Federal procurement statute.
The order does not apply to:
- Grants
- Certain agreements with Indian tribes
- Contracts whose value is equal to or less than the simplified acquisition threshold (generally, but not always, $250,000; see definition in 48 CFR 2.101).
- Employees who perform work outside the United States.
- Subcontracts solely for the provision of products.
The task force issued new guidance for federal contractors and subcontractors on Sept. 24 requiring:
- Vaccinations for covered employees (except in circumstances in which an employee is legally entitled to an accommodation); with full vaccination taking place no later than Dec. 8, 2021.
- Masking and social distancing by covered employees and visitors in contractor workplaces.
- The designation by contractors of a person or persons to coordinate COVID-related workplace safety efforts.
In addition to the guidance, the task force has created an FAQ document to help contractors implement the new requirements.
More than half of companies responding to ARSA’s 2021 member survey were involved in military contracts and more than a third were primary or subcontractors to other federal agencies. September’s developments underscore the broad potential reach of EOs and the need for ARSA members involved in government contracts to pay attention to White House directives.
ARSA on the Hill
Contacting Congress is Easy
Thanks to generous support from ARSA member Aircraft Electric Motors, the association has an important tool to increase aviation maintenance professionals’ impact on Capitol Hill.
The association’s Legislative Action Center allows members to learn more about association priorities, get lawmaker contact information, and send prepared notes to Congress on hot issues. Current alert topics include:
- Access to maintenance manuals,
- Improving transparency and due process at the FAA,
- Improving competition for DOD maintenance contracts, and
- Supporting aviation workforce development.
Aside from making it easy to contact Congress, the Legislative Action Center allows ARSA staff to follow up.
Visit the site today and make your voice heard.
The ARSA Congressional Action Center is provided through the generous support of 2021 Annual Conference Sponsor Aircraft Electric Motors. AEM has long been committed to the association and service to the maintenance community through resources for engaging elected officials. Learn more about the company – and take a factory tour – at aem.us.
Dems Seek Deals as Shutdown Looms
It’s a chaotic time on Capitol Hill as Democrats try to pass both a $1 trillion infrastructure bill and a $3.5 trillion domestic spending package that includes major parts of the Biden economic agenda paid for with tax increases on wealthier Americans and corporations.
While infrastructure enjoys bipartisan support, lawmakers’ stance on the Biden economic package splits along party lines. Democratic leaders promised their caucus the two pieces of legislation would be considered together, so squabbling over the $3.5 billion package is delaying a House infrastructure vote (the Senate already passed the bill with bipartisan support). Moderate Democratic senators are balking at the economic plan’s price tag and pushing the country too far to the left; progressives are opposed to voting on the infrastructure bill without a House-Senate deal to pass the other piece of legislation.
Where the wrangling leads is anybody’s guess. With the president’s approval ratings in a slump after the chaotic withdrawal from Afghanistan, Democrats desperately need a “win.” Without a deal on the economic package, there’s a risk that Democratic voters will lose confidence with mid-term congressional elections just over a year away.
Congress is also grappling over two “must do” items: funding the government for FY 2022 and raising the debt ceiling. lthough FY 2021 ends on Sept. 30, in what’s become the norm, none of the 12 appropriations bills to fund government operations for the coming year have been finalized (the Senate hasn’t voted on any).
As the hotline went to press, Senate leaders announced they’d crafted a deal to keep the FAA and other parts of the federal government operating through early December. As in past years, expect the drama over FY 2022 spending to continue up until the Christmas holidays with all the unfinished appropriations being rolled into a single, massive continuing resolution.
As if the risk of another government shutdown weren’t bad enough, the Oct. 18 deadline to increase or suspend the federal debt limit is rapidly approaching. Raising the debt wouldn’t authorize new spending; rather, it would allow the federal government to borrow money to meet obligations it’s already incurred. Treasury Secretary Janet Yellin has warned of “catastrophic” consequences if the country defaults. Higher interest rates, stock market volatility and a suspension of food assistance, Medicare and Social Security payments are major risks.
Even though the debt limit was increased three times during the Trump administration, Republicans are opposed. It’s political gamesmanship; the party is trying to force Democrats to combine the debt limit increase with the big domestic spending bill and pass it on a partisan vote through a process called reconciliation (which can’t be filibustered). That would make it easier for Republicans to cast Democrats as the party of big spending, debt, and deficits during next year’s election.
Lobbyists are shaking their heads a muttering that DC has reach a new level of dysfunction. It’s going to be a busy, acrimonious fall on Capitol Hill.
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. |
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.
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).
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.
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.
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
(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.
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.
Thinking Simpler on IA Renewal
On Sept. 28, the FAA published a draft Advisory Circular directed at training providers seeking acceptance of Inspection Authorization renewal credit (AC 65-IART).
For several years, ARSA has been encouraging the FAA to streamline its procedures related to IA renewal course acceptability. Citing the relative simplicity of § 65.93(a)(4), the flexibility afforded the words “acceptable to” under the rules and the value of broad access to professional training, the association has urged the agency to eliminate cumbersome, time-bound reviews of individual training sessions.
In early 2020, the agency paused acceptance of new courses – extending currently acceptable training – and began an official review of its procedures. The draft AC provides a public avenue for comment on that review, which will also include overhaul of internal agency guidance in Order 8900.1 and release of a new course acceptance form. ARSA will use the opportunity to encourage the FAA to further simplify its process by focusing on provider acceptability rather than individual course review.
Interested members should share IA renewal experiences with the association. Whether from IA holders, employers, or training providers, lessons learned with the existing system can help illustrate the need for change. Send thoughts directly to Vice President of Operations Brett Levanto (brett.levanto@arsa.org) with the subject line “Overhauling IA Renewal.”
The agency will accept comments until Oct. 28. For information about the draft AC, click here.
Contract Maintenance – Functions and Vendors
This session provides information on obtaining approval of maintenance functions and selecting and categorizing maintenance function vendors properly under 14 CFR part 145.
Instructor: Sarah MacLeod
On Demand – Available Anytime
Click here to register and get access 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.
Can You Define “Appliance”? (15 min. sessions)
This series of three 15-minute sessions introduces how to critically read the regulations in 14 CFR. The sessions use the term “appliance,” which appears in countless places across the aviation safety rules, as the focus on this exploration.
The sessions should be viewed in order and may be purchased together for a discounted price by clicking here. Please note that since these sessions are less than an hour long, special pricing applies:
Session 1: “Appliance” Defined
This session provides participants a lesson in reading regulations with a critical eye. Many aviation terms used during the “normal” course of a day are taken for granted. Meanings and expectations are set by “tribal knowledge” rather than first-hand review. This session helps ensure each word in a aviation safety regulation is read carefully so any exceptions or conditions are understood.
Click here to register and get access for 90 days.
Session 2: “Appliance” Applied
This session provides participants information on when and how the word “appliance” is used within the design, production, operation and maintenance rules.
Click here to register and get access for 90 days.
Session 3: “Appliance” – Yes, No or Maybe
This session provides participants the opportunity to test their knowledge of whether an article is an appliance by using case studies.
Click here to register and get access 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.
Regulatory Compliance Training
Test your knowledge of 14 CFR §§ 11.38, public comment procedures for special conditions.
Click here to download the training sheet.
Membership
Here’s Jacquie
In September, ARSA welcomed Jacquie Modin-Dunbar to its team. Jacquie assumed the role of administrative services manager upon joining the association’s management firm as an executive assistant.
As she learns about ARSA, its members and the roles it plays on behalf of the maintenance community, the association encourages members to get to know her. To help, she invested some of her onboarding time into answering a few questions:
(1) Introduce yourself. What’s something that ARSA’s members should know about you?
I am currently in and originally from Fargo, North Dakota but have moved around and lived on both coasts. I love to learn about new things, be exposed to new areas, and am very grateful for all I have experienced.
Growing up in the Midwest, you are isolated in many ways. When I moved to California, it was a whole new world to me. I realized what I thought was “normal”…well it wasn’t normal to everyone. Then I moved with the military to North Carolina – another eye opening experience that expanded my knowledge even more.
Outside of where I have lived, my education has given me the opportunity to work in many different industries: finance, television, sales (vacuum and knives door-to-door), car dealerships, and hospitals (with some other stops here and there). Every opportunity has made me grow. Now I look forward to this adventure with ARSA.
(2) In your few weeks with the association, what have you learned? What was surprising?
From what I have learned about the association, it supports its members. The team ensures it is up to date on education, safety, and compliance issues and open to new movements in the aviation industry. The association tries to secure the knowledge for its members so that they can concentrate on the job at hand. The amazing thing to me, is the amount of knowledge as well as how much goes into these businesses that an average person does not think about unless they are affiliated with the industry.
(3) What’s something you’ve learned or a skill you’ve developed in your previous work experience that will be valuable in your support of ARSA.
As previously mentioned, my experience and education has afforded me the opportunity to grow as an individual. The skill that I have learned in my life that I feel that will help is dedication. To me, that encompasses understanding, motivation and (more than anything) remembering that we are all human, regardless of what the task is at-hand. Having this mindset allows any objective to be reached successfully.
(4) Do you have any hobbies? What do you do in your free time?
I love to travel. Experiences are everything to me. I like to spend time with family, try new foods, see new things, watch sports, cook, and to truly enjoy life.
(5) What’s a favorite place you’ve visited or lived?
The favorite place that I have lived would definitely be California. It was my first move away from home to attend school and taught me so much – bad and good – at such a young age. It was the first place that truly opened my eyes.
I don’t think that I have a favorite place that I have visited, not yet! I have had the opportunity to visit that many places, but I hope to see many more!
Quick Question – Sustainability
The association has received an increasing number of inquiries regarding sustainable practices in aviation maintenance. Industry media outlets are now giving cover treatment to “sustainability” and relating the practice to other advances in business and technology.
Help ARSA track development in this area by answering this “quick question”:
If the embedded survey does not appear/load, open the survey independently by visiting: https://www.surveymonkey.com/r/avmro-sustainability.
Note: The survey below is in an embedded window and you may need to scroll down within the window to see/click the “Submit” button.
Click here to see what questions have been asked and answered…and keep a lookout for more.
For more information about this or any other question, contact Brett Levanto (brett.levanto@arsa.org).
Welcome & Welcome Back – New & Renewing Members
ARSA’s members give the association life – its work on behalf of the maintenance community depends on the commitment of these organizations. Here’s to the companies that joined or renewed in September:
New Members
Sherwood Avionics & Accessories, Inc. dba Sherwood Aviation, R04
Renewing Members
AerSale Goodyear Aircraft Operations Center, 2015, R04
Aero Instruments & Avionics, Inc., 1991, R04
Air Cargo Equipment, Inc., 2010, R01
Air Technology Engines, Inc., R03, 2006
Aircraft Ducting Repair, Inc., R03, 2002
Airforce Turbine Service, Ltd., R02, 2010
Airfrance Industries-KLM Engineering & Maintenance, Assoc, 2010
Arkwin Industries, Inc., R02, 1995
Calvin Taff Electronics, Inc., R01, 2003
Commercial Jet, Inc., R04, 1999
Dassault Falcon Jet do Brazil, R02, 2010
EuroTec Vertical Flight Solutions, LLC, R02, 2004
Federal Express Corporation, Assoc, 2000
Florida Jet Center, Inc., R02, 2013
Global Parts Aero Services, R01, 2012
HAECO Americas, Corp, 2000
IBM Flight Operations, Assoc, 1997
Miami Aircraft Structures, Inc., R02, 2003
Midway Aircraft Instrument Corporation dba Midway Aerospace, R02, 2004
Midwest Turbine Service, LLC, R01, 2015
Millennium Internationa, R02, 2013
MTI Aviation, Inc., R01, 2011
Pacific Turbine Brisbane, R03, 2018
Palm Beach Aircraft Propellers, Inc., R02, 2001
Peter Stonefield, Affil, 2010
Rapco Fleet Support, Inc., R01, 2008
Raytheon Technologies Corporation, Corp, 1997
S & K Aerospace dba AE & C Services. LLC, R01, 2017
Safran Nacelles Services Americas, LLC, R01, 2017
Schaeffler Aerospace USA Corporation, R01, 2012
Structural Evaluation Technologies Inc. dba SETAero, R02, 2018
Tech-Aire Instruments, Inc., R01, 2012
Thomas Global Systems, LLC, R01, 2012
Trace Aviation, R02, 2017
Yuba-Sutter Aviation, R01, 2018
Zee Company, Inc., R02, 2019
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).
A Member Asked…
Q: We have more overhaul work than we can handle (mostly due to difficulty finding and retaining employees).
We are looking into sending some units out to be fully overhauled by one of our sub-contractors, but the customer contract states that we are to be the certifying repair station.
At what point can we complete the overhaul work and state we finished the unit? Would we need to have the sub-contractor overhaul all the individual piece parts (or perform a certain percentage of the overall work) and we complete final assembly? Can we “over cert” this unit with our own 8130-3 stating overhaul?
A: Under 14 CFR § 145.201(a)(2), a repair station may “[a]rrange [contract] with another person to perform [work] on any article for which the repair station is rated and within the limitations in its operations specifications.”
Work is arranged by—
- Getting the “maintenance function” – which can include all the “steps” in an overhaul – approved ( 145.217(a)(1)) as set forth in your RSQM (§ 145.209(h)(1)).
- Getting the vendor on the maintenance function contractor list ( 145.217(a)(2).
- Provide the vendor list to the FAA as set forth in the RSQM ( 145.209(h)(1)-(2)).
If the agency balks at approving up to and including overhaul, you can agree to have the individual “maintenance steps” listed and have the contractor do everything but the final test and approval for return to service, basically treating them like a non-certificated source under § 145.217(b). I know several repair stations can take full advantage of § 145.201(a)(2), over-tagging another company’s work.
Members can obtain a copy of the letter (template) ARSA has developed for requesting maintenance function approvals and keeping the maintenance function vendor list. The order form is on arsa.org/publications.
You also can review ARSA’s on-demand training session “Contract Maintenance: Functions and Vendors” (featured in the Training Section of this edition of the hotline).
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
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.
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.
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
Business Aviation Convention & Exhibition (NBAA-BACE) | 10/12-14/2021 | Las Vegas, NV |
MRO Europe | 10/19-21/2021 | Amsterdam, The Netherlands |
FSANA’s Designated Pilot Examiner Symposium | 10/26-27/2021 | Nashville, TN |
Fall 2021 Aviation Safety InfoShare | 11/2-4/2021 | Pittsburgh, PA |
MARPA Annual Conference | 11/3-4/2021 | Orlando, FL |
LABACE 2021 | 11/9-11/2021 | Sao Paulo, Brazil |
DUBAI Airshow | 11/14-18/2021 | DWC, Dubai Airshow Site |
EASA Rotorcraft and VTOL Symposium | 12/9/2021 | Online |
EASA-FAA International Aviation Safety Conference | TBD/2022 | TBD |
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 |
EASA Rotorcraft and VTOL Symposium | 11/16-18/2022 | Koelnmesse, Germany |
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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