2022 – Edition 10 – November 4

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.

The President’s Desk
ARSA Works
Legal Brief
ARSA on the Hill
Aviation Life Calendar
Training
Membership
Resources
Industry Calendar

The President’s Desk

Taking Charge Not Taking Over

In the run-up to October’s annual meeting of ARSA’s Board of Directors, I met with then-President Terrell Siegfried and the association’s executive team. Under the board’s electoral process, as the sitting vice president I was the presumptive candidate to succeed Terrell in the top volunteer position. The purpose of our meeting was to “wrap up” his year-long term and look ahead to mine.

The groundwork Terrell laid by focusing on membership development will endure – ARSA’s members are the weight behind its punch, as he is fond of noting – and I plan to help expand that focus to include all the ways ARSA empowers industry to take action for the collective good.

In all of my dealings with ARSA – beginning with my time as ad hoc government affairs chairman – I’ve quickly learned how to balance my business’ policy interests with the broader needs of everyone performing work under the aviation safety rules (whether in the United States or anywhere in the world). The association’s magic is in turning a chorus into a singular voice, one that calls out for improvements benefitting all maintenance providers.

As members, we best support this group engagement when we take charge of our own issues. “Taking charge” in this sense doesn’t mean dominating others but amplifying the concerns and needs of all. To ensure we all make the most of this opportunity, I intend to spend my term as president focusing on how ARSA’s growing membership can more effectively engage with regulators and legislators.

In that spirit, I’ll start my year with you by encouraging good use of the resources and tools that ARSA has already developed for us:

(1) Take an ARSA training class, then work with the team to incorporate these online sessions into your company’s training program (including developing new ones).

(2) Broaden ARSA’s reach by getting all contacts in your company registered in the member database. Make reviewing your organizational profile (which Kimberly Dimmick will send every renewal cycle) as important to that process as sending payment.

(3) Use ARSA publications. Both the free “tools for members” and the RSQM Compilation provide concrete benefit from the association’s years of experience; they will help you improve your own procedures and engage on issues that matter to us all.

(4) Show your face at the Annual Conference. Registration will open in December for the 2023 event, which will run from March 14 through 17.

There are a lot of ways to make the most of your ARSA membership. Following through is something you do not only for yourself and your business, but for all.

Josh Krotec 2023 ARSA president | First Aviation Services, Inc. senior vice president

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ARSA Works

The Times They Are a-Changin’

ARSA is taking back control of its periodical distribution and advertising sales. After 15 years of partnership with Multiview, Inc., the association’s team will be in full command of its communications for the first time since 2008.

The change presents a great opportunity for ARSA and will allow the team to open new resources for member contacts. It grants the association direct control of its distribution list (vital for its membership management) while sending newsletters directly from arsa@arsa.org (easy to clear through email filters) and the opportunity to run its own in-house advertising program (so advertisers know all of their investment goes to ARSA’s good work).

In the spirit of lending a hand to build the new road (as Bob Dylan sang), all members should support this transition by:

(1) Be alert to the delivery (or absence) of the two current ARSA newsletters:

On Nov. 9, ARSA will send the first Dispatch newsletter of the new era, with weekly editions each Wednesday.

The Dec. 2 edition of the hotline – the first Friday of each month – will come directly from arsa@arsa.org.

If you stop receiving these periodicals, contact ARSA immediately. The team is planning to add a new Daily Intelligence email produced by the association’s management firm to provide news, calendar, and regulatory updates every morning – stay tuned.

(2) Ensure your email systems have “marked safe” the @arsa.org email domain.

(3) Add arsa@arsa.org to your media or communications distribution list to ensure company’s news and updates are sent to the association.

(4) Check your budget and current advertising practices to make space for your company in ARSA’s newsletters or website (and encourage your suppliers to do so).

What ARSA Has Done Lately – Third Quarter 2022

Each quarter the board of directors receives reports on the association’s activities and fiscal health. Step into a board member’s shoes with this overview of the financial, operations, legislative and regulatory reports highlighting advocacy on behalf of aviation safety between July and September 2022.

Fiscal Health

The Board review the annual financials and approved a balanced budget for 2023.

Membership

• Champion program re-instituted by supplying board members with ARSA member flyer and stand.
• Kickoff of Member Getting Member

Regulatory Advocacy

• Reported on movement of airworthiness directives and other guidance documents to FAA Dynamic Regulatory System (DRS).
• Delivered special report from Part 145 Working Group to Aviation Rulemaking Advisory Committee (ARAC) on the ability of a repair station to work from multiple locations under a single quality system.
• Queried members about parts documentation experience related to U.S./EU bilateral.
• Continued efforts to resolve FAA/EASA bilateral parts documentation issues, including meeting on Aug. 16 with FAA leadership and drafting proposed FAA letter clarifying position.

Legislative and Lobbying

• Supported House passage of National Center for Advancement of Aviation Act (R. 3482/S. 1752).
• Monitored Global Aircraft Maintenance Safety Improvement Act (R. 7321).
• Coordinated with allies re: FAA reauthorization objectives (esp. workforce priorities).
• Identified member of Congress to send letter to FAA inquiring about status of proposed instructions for continued airworthiness (ICA) Aviation Rulemaking Advisory Committee (ARAC) task.
• Supported efforts to host members of Congress at facilities.
• ARSA PAC Contributed $1000 to House Transportation & Infrastructure Committee Ranking Member Sam Graves (R-Mo.) reelection campaign.

Communications and Surveys

ARSA in the News – Selected Industry Coverage

Looming Airline Mechanic Shortage Could Prolong Flight Disruptions
July 15, 2022
Travel Weekly
“If we don’t have enough technicians, you are going to see delays, cancellations, potentially fewer aircraft in operation,” Christian Klein, vice president of operations for the trade group Aeronautical Repair Station Association, told Travel Weekly earlier this year.

FAA Continues Doc Consolidation with AD Transfer
August 17, 2022
AIN Online
AD documents will only be available through the DRS, the Aeronautical Repair Station Association advised members, adding the FAA has added training tools for searching the ADs and use of the DRS.

FAA’s Part 147 Rule Change May Still Require “Gap” Training
September 24, 2022
AviationWeek
Brett Levanto, vice president of operations at the Aeronautical Repair Station Association, argued that for both the Part 147 rule change and other areas, “Inconsistency in regulatory interpretation might be the biggest problem plaguing the FAA and the industry.”

ARSA Flags Confusion Over New-part Validation Process
April 18, 2022 | Aviation Week
Some U.S.-based repair stations with EASA approvals are getting pushback from that agency and the FAA on an approved method of showing a new part is traceable to the manufacturer.

ARSA Industry Editorials

Surveys

Quick Questions—

• Parts Documentation for Bilateral Compliance (July – 51 responses)
• Why Go To An Event (August – one response)
• Lawyering Up (Sept. – seven responses)

Events, Meetings and Training

Events

Planned 2022 Annual Board meeting, including corporate members luncheon, ally and regulator roundtables.

External Meetings

• Sarah participated in multiple meetings of FAA’s Aviation Rulemaking Advisory Committee (ARAC) and working groups.
• Brett and Michael were involved in multiple meetings with Multiview regarding transition to ARSA advertising program self-management.
• Brett and Sarah participated in several meetings with repair station manual compilation purchasers.
• Christian attended Transportation Security Administration (TSA) Aviation Safety Advisory Committee (ASAC) and Insider Threat Subcommittee meetings.
• Sarah attended multiple meetings regarding Organization Designation Authorization (ODA) standards (NAS 9947).
• Christian took part in multiple FAA/TCCA/EASA/ANAC Maintenance Management Team coordination meetings.
• Christian and Brett held multiple coordination meetings with Oliver Wyman staff.
• Christian attended a House Aviation Subcommittee hearing on “The State of General Aviation” (Jul. 13).
• Brett attended Helicopter Association International’s “How to Attract and Retain a Quality Workforce” workshop (Aug. 11).
• Sarah, Marshall and Christian met with senior FAA staff regarding parts documentation issues (Aug. 16).
• Christian gave a briefing to Gulfstream’s government affairs team (Sep. 7).
• Christian and Kimberly attended EASA’s Safety Management Systems webinar (Sep. 15).
• Brett attended the Aviation Technician Education Council (ATEC) Fly-in (Sep. 21).
• Brett participated in the final FAA Youth Access to American Jobs in Aviation Task Force public meeting (Sep. 22).
• Brett attended an FAA STEM careers event (Sep. 29)
• Sarah, Christian and Brett met with the Government Accountability Office (GAO) regarding international certification issues (Sep. 29).

ARSA Talks Workforce at IATA

Finding, and retaining talent has been a major concern for all sectors of industry. ARSA Executive Vice President Christian Klein traveled to Dubai this month for the International Air Transport Association’s (IATA) 2022 Safety Conference, where workforce featured heavily on the program.

Klein participated in an Oct. 26 panel entitled, “Safety Critical Workers Recruitment and Retention Strategies”. Moderated by IATA Director of Flight and Technical Operations Stuart Fox, the panel also featured Captain Robert Thomas, United Airlines managing director for aviation safety and Michelle Bishop, director of programs at CANSO, the international air traffic control (ATC) association. Panelists focused on three key areas: reasons for the global aviation industry’s workforce challenges, opportunities to build the talent pipeline, and recruitment and retention strategies.

The conversation was informed by the results of a recent IATA member survey that found a global shortage of a wide variety of workers critical to airline operations. IATA estimates the percentage of staff currently in place at airlines over the next 18 months is just 72 percent for pilots, 70 percent for maintenance and technical operations personnel, 63 percent for ground handling and 61 percent was cabin staff. Much of the concern, however, was focused on maintenance personnel given the relatively long lead times to competence versus other types of personnel.

Klein discussed the range of challenges facing repair stations seeking to recruit talent, including the sector’s lower visibility versus operators and manufacturers, misconceptions about repair station jobs, regulatory requirements, decreased technical proficiency among high school graduates, and an aging workforce. He provided ARSA’s regulatory, legislative, and public relations efforts to address the problem, including improving repairman certification, updating 14 CFR part 147, lobbying Congress to create the new maintenance grant program, and supporting industry initiatives such as Choose Aerospace.

Klein also highlighted the recent report of the FAA’s Youth in Aviation Taskforce, which provides a playbook for improving awareness about industry careers, enhancing collaboration between industry, schools and government, and addressing financial and regulatory hurdles.

As part of his remarks, United’s Thomas said that with 500 aircraft on order, the airline is forecasting the need for 25,000 new employees and 8,000 new pilots over the next five years. He discussed the airline’s approach to recruitment, including the United Aviate Academy for pilot candidates, and technician apprenticeship program. Bishop discussed challenges unique to the ATC world, including recruiting candidates for a career in which they will be doing the same job from the day they start to the day they retire. A separate panel highlighted unique efforts to build interest in aviation careers on a regional basis.

“The key takeaway for the IATA program is that workforce development is a global problem,” Klein said. “There may be different local or national reasons for the talent shortage, but we share the same goal of recruiting and retaining the best workers for our safety-critical industry. There’s enormous value in coming together to share strategies and leverage resources.”

Measuring Progress at Fall Roundtables

ARSA Leadership Roundtable Participants listen as ATEC Executive Director Crystal Maguire (on screen) briefs the group on rollout of the new AMTS rule. The association’s board of directors was joined (online and in-person) by representatives from ten allied organizations before the arrival of FAA and EASA personnel.

On Oct. 13, ARSA hosted its annual Leadership Roundtable sessions in Washington, D.C. Each year, the association focuses the attention of its board of directors – in town for its annual meeting the following day – on the issues most important to aviation stakeholders from across the regulatory chain.

The event began with at Old Ebbitt Grille, where the board was joined by corporate member representatives and special guest Michael Reynolds of Baker, Donelson, Bearman, Caldwell & Berkowitz, PC. Reynolds shared his experience from years working in aviation policy as a congressional staffer and shared his expectations for the upcoming FAA reauthorization cycle.

After lunch, the day shifted to the offices of the General Aviation Manufacturers Association, which hosted the group while ARSA administered roundtable discussions with allied organizations and FAA officials. Representatives from ten trade associations that regularly collaborate with ARSA each shared updates on recent activity, points of focus and needs for improving policy in the coming year.

After welcoming the group, GAMA President & CEO Pete Bunce opened discussion by highlighting the need to produce more data – and improved insight – related to regulatory issues facing the industry. Heading into the FAA reauthorization process, Bunce explained, demands that the aerospace community effectively illustrate the challenges it faces every day.

“You can’t fix something you can’t measure,” Bunce said.

In the spirit of measuring progress – or at least establishing baselines – the group highlighted a series of challenges faced by their members at the hands of FAA oversight. Based on those issues, discussion centered on the importance of government personnel development and training in order to ensure regulators have the competency to support the critical thinking demanded by aviation safety.

Here’s a basic rundown of the updates provided by each organization:

General Aviation Manufacturers Association – Focused on how the industry can help the FAA through policy, noting especially the need to improve training, restructure pay and benefits, and overhaul the government procurement process.

Aerospace Industries Association – Highlighted the importance of “predictability” as cousin of “consistency” in regulatory enforcement. Noted the challenge of re-thinking how aviation careers will progress for new entrants into the industry.

Aircraft Electronics Association – Chronicled experience co-leading Part 145 Working Group with ARSA and focus on the history of the rule in order to inform how to fix myriad points of contention between the rule, guidance and inspector tribal knowledge.

Aircraft Owners and Pilots Association – Continued attention on legislation to create a National Center for the Advancement of Aviation, a public-private partnership that would act as a clearinghouse for all actions related to bolstering the industry and its workforce.

Airlines for America – Brought up the importance of the Air Traffic Control workforce to air carrier operations and recounted ongoing challenges related to 5G rollout.

Aviation Technician Education Council – Celebrated success in promulgation of new Aviation Maintenance Technician Schools rule (14 CFR part 147), sharing experience in “educating FAA’ and benefitting from agency’s collaboration on rollout.

International Air Transport Association – Reminded about importance of protecting open skies and maintaining stable resources for industry to continue to emerge from pandemic disruptions.

Modification and Replacement Parts Association – Discussed how inspectors’ incentives (and the metrics tied to them) impact behaviors in ways that slow down certification and surveillance.

National Air Transportation Association – Described challenges related to slow movement on certification projects and manual reviews.

Regional Airline Association – Underscored importance of growing (and protecting) service to airports outside of major hubs and metropolitan areas.

After the discussion ended – though it could have continued – the group was joined by the executive directors of the FAA’s Aircraft Certification (AIR) and Flights Standards (AFS) Services, Lirio Liu and Larry Fields, and EASA Washington Representative Ludovic Aron.

Liu and Fields focused considerable attention on agency internal management issues, including plans for further reorganization of certification personnel and the need to improve training for government personnel. The two described opposite challenges in workforce readiness: AIR tends to employ early career engineers, while AFS inspectors are generally late career and out of industry. The former needs seasoning in industry while the later needs detoxification from year’s spent building personal experience that may not jive with the actual language of the rules. Aron noted that EASA’s organization is fairly stable, but faces dilemmas related to harmonizing oversight across international borders.

As highlighted for members in the August edition of the hotline by 2022 President Terrell Siegfried, the annual roundtable sessions are a microcosm of the engagement available to all members:

“This level of access and its resulting productivity is not exclusively for board members. Each March, the Annual Conference allows you to interact with agency leaders, association allies, and professional colleagues – in person or from behind a computer screen. We offer so many opportunities to expand your network, connect with key industry players, stay in the know, share your knowledge, and get things done.”

Save the dates for the 2023 Conference: March 14-17 in and around the nation’s capital.

Seeking Simplicity and Flexibility in D&A Recordkeeping

On Oct. 4, ARSA commented on the Department of Transportation’s Advanced Notice of Proposed Rulemaking (ANPRM) “Electronic Signatures, Forms and Storage for Drug and Alcohol Testing Records.” DOT sought information – through a series of 11 questions – on how best to amend current regulations in 49 CFR part 40 to authorize electronic recordkeeping. As it often does, the association provided the agency with a regulatory-based rationale for minimizing changes to existing rules while allowing the broadest possible range of options for those seeking to comply.

“ARSA urges the government to minimize or eliminate any limitations on methods for handling required records,” the association said. “Instead, the regulations should continue to focus on the information that must be documented and set standards for confidentiality in handling that data while remaining agnostic about technical specifics.”

The comments referenced the sections of part 40 covering content and delivery of required reports as well as the subpart on confidentiality. Based on a plain reading of the current rule, ARSA encouraged DOT that “allowing” electronic recordkeeping is less about changing the regulations than it is about understanding what’s possible under them. In its specific responses to the agency’s questions, the association repeatedly explained how the government should stay out of the details of each service agent or employer’s recordkeeping system.

“Providing flexibility to both service agents and employers ensures each entity may best serve its own business and operational needs. Providing choice in selecting recordkeeping methods…limits the cost burden of compliance by allowing companies to fulfill regulatory obligations in whatever manner is most efficient for their business,” ARSA said while repeatedly pushing back on DOT’s interest in specific system elements like confidentiality, authentication, non-repudiation, and file access. “The rules should maintain [substantive] focus and not add unnecessary heft for the sake of addressing logistical matters.”

DOT has begun the rulemaking process under congressional mandate that includes a February 2025 deadline. The executive branch often allows such timelines to lag and regulatory review can be an incredibly deliberate process. With at least a notice of proposed rulemaking (NPRM) and subsequent final rule publication still ahead, the agency has considerable work ahead of it.

Stay tuned to ARSA for updates.

To read the association’s complete comments, click here.

To review previous actions related to D&A rulemakings, review the content below and click here to search the website for all updates.

To see ARSA’s training sessions on D&A programs for repair stations, click here.

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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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.

Emergency Certificate Actions

By Christian A. Klein, Executive Vice President

This month’s “Legal Brief” continues the long series on FAA’s enforcement process. Past columns have explored non-emergency certificate actions, the process leading up to and following issuance of a Letter of Investigation (LOI), and self-advocacy in FAA investigations. This month we examine emergency certificate actions; in future columns we will discuss the civil penalty process. 

The term “certificate action” means the FAA is proposing to amend, modify, suspend, or revoke all or part of a type, production, airworthiness, airman, air carrier operating, air navigation facility, or air agency certificate because of a reinspection, reexamination, or other investigation. The FAA is authorized under 49 U.S.C. § 44709 to take such action against a certificate if it determines that safety in air commerce or air transportation and the public interest require such action. 

The rules applicable to legal actions against certificates are found in part 13 of 14 C.F.R.; the applicable guidance document is Order 2150.3C (“FAA Compliance and Enforcement Program”).  

Under 49 U.S.C. § 46105 certificate actions may be effective immediately if, in addition to the safety determination mentioned above, an emergency exists. The agency will deem an emergency exists if it can establish that the certificate holder lacks qualifications, or there is a reasonable basis to question whether the certificate should be held by the person, or the holder does not comply with regulatory or statutory requirements. The Administrator must also find that the holder is reasonably able to exercise the privileges of the certificate (in other words, that the holder is actually operating). 

The Administrator’s determination that the holder lacks qualifications may be based on a lack of technical proficiency, the failure to meeting airman medical standards, or a lack of the required care, judgment, or responsibility. A revoked certificate cannot be reinstated; however, the holder may be issued a new certificate at some point in the future if they meet the certification requirements. 

In the alternative, the Administrator may choose to suspend a certificate on an emergency basis, rather than revoking it. Emergency suspensions may be punitive (for a specific period of time as a punishment and deterrent to future bad behavior) or indefinite (until certain conditions related to compliance are met). The agency may also issue deferred punitive certificate suspensions to encourage the holder to take immediate corrective action. 

While the Administrator has discretion in determining which certificate action to pursue, there are certain instances where revocation or suspension are mandatory. For example, pursuant to 49 U.S.C. § 44726, the Administrator is required to revoke a certificate if the holder is convicted of violating a U.S. law relating to the installation, production, repair, or sale of a counterfeit or fraudulently-represented aviation part or material. Revocation is also mandatory in the absence of a conviction in such case if the certificate holder, knowingly and with the intent to defraud engaged in such prohibited conduct. 

Similarly, 49 U.S.C. § 44924 requires the Administrator to revoke the certificate of a foreign repair station determined by the Transportation Security Administration (TSA) to be an immediate security risk or suspend the foreign repair station’s certificate if TSA determines it does not maintain appropriate security measures. Unlike other certificate actions, security-based certificate actions are appealed to TSA, not the National Transportation Safety Board (see below). 

If you receive an emergency order, you are required to immediately cease using and to surrender the certificate at issue. One may, pursuant to 49 U.S.C. § 44709(e)(3), appeal the determination that an emergency exists to the NTSB. The request for review must be filed within 48 hours after the certificate holder receives the order. If the Board finds that an emergency does not exist, the emergency order shall be stayed, and the certificate holder may continue to exercise its privileges while the appeals process plays out. The Board is required to dispose of an emergency review request not later than five days after the date on which the request is filed and must make a final disposition of an appeal not later than 60 days after the date on which the appeal is filed. 

The NTSB has adopted rules applicable to air safety proceedings, which are found at 49 C.F.R. part 821. Given the stakes and knowledge of NTSB rules required to pursue an appeal, holders who wish to maintain their certificate are strongly advised to retain the assistance of legal counsel with experience handling NTSB case. 

Our series will continue next month with a discussion of the civil penalty process. 

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ARSA on the Hill

CALL TO ACTION: Repair Station Opponents Eye Must-Pass Bills

By Christian A. Klein, Executive Vice President

The end of a congressional session is always a frantic time. Lawmakers seek to add their priorities to whatever “must past” legislation will make it to the president’s desk before the year’s end. For Democrats, the sense of urgency is amplified by the looming loss of control of Congress.

Airline mechanic unions and their congressional allies are working to add the Global Aircraft Maintenance Safety Act (H.R. 7321) to the FY 2023 National Defense Authorization Act, one of the few pieces of must-pass-legislation.

H.R. 7321, which passed the House on Sept. 29, is an improved version of the Safe Aircraft Maintenance Standards Act proposed by House Transportation & Infrastructure Committee Chairman Peter DeFazio (D-Ore.). The legislation is just the most recent in a series of bills proposed by pro-labor members of Congress to discourage airlines from using contract maintenance and drive-up repair station costs.

ARSA is opposed to rushing it through the Senate by adding the bill to the NDAA and thinks that any discussion above repair station oversight should happen during next year’s FAA reauthorization, when all the FAA’s priorities and resources can be considered holistically.

The tension surrounding H.R. 7321 is enhanced by the fact that Chairman DeFazio is retiring at the end of the current Congress. As the mechanics unions’ strongest and most visible ally on Capitol Hill, he sees the legislation as an important part of his legacy and will likely fight hard to get it across the finish line. ARSA and our allies are fighting back, educating lawmakers and congressional staff about why enacting H.R. 7321 now is such a bad idea.

There is no Senate companion to H.R. 7321 and the Senate Commerce, Science and Transportation Committee has not considered maintenance issues in years, making it less likely that the Senate will accede to DeFazio’s wishes. But until the 117^th Congress is gaveled to a close, there will always be a risk.

Please take a minute to support our efforts and send a quick note to your elected representatives to let them know you’re opposed to H.R. 7321.

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Aviation Life Calendar

Something exciting happens every day in an aviation career.

If you want to keep aviation in the forefront of career choices, celebrate success every day with these resources. Every one provides a positive view of the industry’s ability to make the impossible an everyday event by individuals from every walk of life, socio-economic level, race, creed, color, religion, orientation, and physical capability.

Check back regularly for updates.

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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.

To review sample syllabi of training session options from the firm – many of which have similar sessions available generically through ARSA training – click here to download a combined PDF. The syllabi include “Regulatory Comprehension for Maintenance,” “Public Aircraft,” “AD Compliance” and more. 

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.

D&A Testing – Requirements of 14 CFR part 120

This session provides basic information on the Federal Aviation Administration’s drug and alcohol testing requirements contained in Title 14 CFR part 120, Drug and Alcohol Testing Program (full description available on registration page).

Instructor: Marshall S. Filler

Click here to register and get access for 90 days.

Interested in all five D&A sessions (you can see them all on the training platform)? Click here to purchase them together and save.

Registration for an ARSA-provided training session includes:

• 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.
• Upon completion of the class as well as any test material, a completion certificate.

The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit PotomacLaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.

D&A Testing – Traps for the Unwary

This session provides information on avoiding many of the common drug and alcohol-related mistakes that can subject companies to enforcement action, typically in the form of civil penalties (full description available on registration page).

Instructor: Marshall S. Filler

Click here to register and get access for 90 days.

Interested in all five D&A sessions (you can see them all on the training platform)? Click here to purchase them together and save.

Registration for an ARSA-provided training session includes:

• 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.
• Upon completion of the class as well as any test material, a completion certificate.

The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit PotomacLaw.inreachce.com. To learn more about the association’s training program and see course availability, visit arsa.org/training.

Regulatory Compliance Training

Test your knowledge of 14 CFR § 11.81, required content in petitions for exemption.

Click here to download the training sheet.

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Membership

Krotec Brings Cross-Disciplinary Experience to ARSA Leadership

2023 ARSA President Josh Krotec at First Aviation’s booth at NBAA-BACE in Orlando, Florida in October. Krotec is standing next to his “ARSA Champion” display. Photo courtesy First Aviation.

During its annual board meeting on Oct. 14, the ARSA board of directors elected Josh Krotec to serve as its 2023 president. Krotec is senior vice president of First Aviation Services and has been engaged in the association’s volunteer leadership for several years, serving as government affairs chairman before his election to the board in 2019.

ARSA’s board represents a broad range of international maintenance interests, ensuring attention is given to the entire aviation safety life cycle. Krotec represents the small business segment of the industry – most association members – and his professional network touches all elements of aviation. Since his initial election, he has helped recruit five of the board’s nine elected directors since 2020.

“Leaders must be proactive in dealing with governments,” Krotec said of his support for the association. “Everyone encounters inconsistencies and contradictions among rules, guidance, and personal interpretation. Easing the burden of these inevitabilities demands actively engaging at every possible level to make government oversight efficient and effective. ARSA enhances our individual and collective actions.”

ARSA’s immediate past president Terrell Siegfried, assistant general counsel, and corporate secretary of NORDAM, will remain on the board. Siegfried made member retention and recruitment the major themes of his presidency. By the end of his one-year term, Siegfried was able to celebrate record member renewal rates and a bevy of new ARSA members. In his final piece for the association’s monthly newsletter, Siegfried recognized ARSA’s healthy membership as a platform on which to build.

Krotec is bringing his own focus to the association’s top leadership position. Using his personal experience engaging the FAA, the Departments of Defense and Commerce, and other U.S. and international government agencies, he will emphasize building professional relationships with regulators and policymakers at every level.

“As long as I’ve known Josh, he’s worked to solve problems from the local to the federal level and at every lawmaking point in between,” said ARSA Executive Vice President Christian Klein. “He’s worked side by side with – sometimes in front of – the association’s team on Capitol Hill, in local jurisdictions, in the Pentagon, on Independence Avenue [at FAA headquarters], and on issues stretching around the world with the Department of Commerce. His experience and polite tenacity are – and will continue to be – an asset to this association and the industry it supports.”

Krotec’s engagement is not limited to ARSA. He is also a member of the U.S. Department of Commerce International Trade Advisory Committee and a board member for the Modification and Replacement Parts Association (MARPA). He also serves in executive roles for First Aviation’s subsidiary businesses: Aerospace Turbine Rotables; Aviation Blade Services; Evolution Aerospace; Heliblade International; and Piedmont Propulsion Systems.

“Josh is resolute,” said ARSA Executive Director Sarah MacLeod. “He moves himself, his business, and the industry steadily in the right direction. He makes certain there is a return on investment by engaging the ARSA team for the industry while ensuring business interests are considered. For the next year, ARSA and Josh will work to leverage those investments for the entire industry’s benefit.”

Gary Fortner, vice president of engineering for Fortner Engineering & Manufacturing, was elected for the third time to serve as ARSA vice president. Bob Mabe, director of regulatory compliance for HAECO Americas, joins Krotec and Fortner on the executive committee as the association’s treasurer. The association welcomed new directors Rob Roedts, Columbia Helicopters vice president of aircraft solutions, and Jon Silva, president and chief executive officer of AeroKool Aviation, who were elected to initial one-year terms.

Quick Question Returned – SMS Implementation

In 2019, ARSA submitted comments to EASA’s Notice of Proposed Amendment regarding Safety Management System requirements. The association collected feedback regarding industry progress towards implementing SMS. The FAA is expected to issue a proposed rule expanding SMS requirements to repair stations – the NPRM publication could happen any time – so the association is requesting new input regarding progress towards program implementation.

A February 2013 study from the Center for Aviation Safety Research (CASR) at Saint Louis University found the majority (52 percent) of repair stations had not yet started any SMS development activities. The report also found that larger repair stations were more familiar with SMS and further along in implementation than are smaller ones. The 2019 “quick question” run by ARSA collected input from 38 responding repair stations and reflecting this differentiation by size: Number of employees appeared to be reflective of institution of SMS.

Help ARSA update its data for 2022: 

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/sms-2019.

The last round of responses…

See the data gathered by ARSA in 2019, from the 38 responding repair stations:

Click here to access a downloadable version of this InfoGraphic.

There was a small but consistent number of respondents within each company size category, which were based on ARSA’s regular membership structure. Considering the portion of individuals in each category reporting their company’s establishment of an SMS, those in larger organizations – particularly those with more than 200 employees – were more likely to have have taken steps towards program establishment.

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 October:

New Members
AllClear Aerospace & Defense, Inc. dba AllClear Repair Services, Inc., R03
Construction Helicopters, Inc dba CHI Aviation, R02

Renewed Members
A Plus Avionics Corp. dba AvionTEq, R01, 2020
A.O.G Aircraft Services Inc., R01, 2018
AerSale Landing Gear Solutions, R03, 2009
Aircraft Inspection Services, Inc., R01, 2013
Arkwin Industries, Inc., R02, 1994
Aviation & Marketing International, Inc., R01, 2021
Calvin Taff Electronics, Inc., R01, 2003
Columbia Helicopters, Inc., R06, 1998
Commercial Jet, Inc., R04, 1999
Component Repair Technologies, Inc., R05, 1995
Dassault Falcon Jet do Brazil, R02, 2010
Dassault Falcon Jet – Wilmington Corp., R05, 2002
EuroTec Vertical Flight Solutions, LLC, R02, 2004
Federal Express Corporation, Assoc, 2000
Fortner Accessory Service Corp., R01, 2002
Global Parts Aero Services, R01, 2012
HAECO Americas, Corp, 2000
Ikhana Group, LLC dba Ikhana Aircraft Services, R04, 2003
MRO Holdings, Corp, 2017
Peter Stonefield, Affil, 2010
Rapco Fleet Support, Inc., R01, 2008
SDM Avionics LLC, R01, 2019
Soniq Aerospace, LP, R01, 2016
STS Aviation Group, Corp, 2020
Trace Aviation, R02, 2017
Turbine Standard, Ltd., R03, 2003
Yuba-Sutter Aviation, R01, 2018
Wavestream Corporation, R04, 2021

A Member Asked…

Q: Section 145.206(a) states: “Each repair station must acknowledge receipt of the part 121 or part 135 operator notification required under 121.1005(e) and 135.505(e)…”.

I can’t find in the rule a requirement the repair station must keep a record of this acknowledgement. Is there one?

A: This is an excellent example of the hidden cost of having a certificate from the government to conduct business in civil aviation.

Part 145 has no regulation on keeping a record of the acknowledgement of the carrier’s will-or-will-not carry hazmat notification and neither does § 121.1005(e). ARSA suggests keeping a copy of documents establishing compliance with the rules in general. With respect to the notification, the “compliant action” is signing, dating, and copying the letter and returning the original to the airline.

Filing your copy is a means to avoid having to defend against the accusation the airline’s notification was never acknowledged. The government loves to shift the burden of proof; in litigation, it would have to prove you did not acknowledge the notification. Since the government runs on paperwork, it is best to keep any documents that show compliance merely to avoid the necessity of proving your innocence or the expense of making the government fulfil its burden of proof.

In this situation, since neither the airline nor the repair station has a requirement to keep the notifications and acknowledgements, all parties would be at a draw unless “someone” keeps the records and that might as well be you.

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.

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.  But ARSA is prohibited from sending PAC information to members who haven’t opted in to receive it.

Careers in Aviation Maintenance

How do you share the industry’s story with the people who could be its future? Teach them about the great work done every day to keep the world in flight. (Even if we can’t recruit somebody, we sure can make them thankful for our work.) 

U.S./EU Maintenance Annex Guidance

See all of the association’s public updates since 2012 on the Maintenance Annex Guidance between the United States and European Union. The page focuses in particular on matters related to parts documentation issues arising since MAG Change 5 was issued in 2015.

The FAA Enforcement Process

There are several reasons the agency may open an enforcement investigative report (EIR). Complaints from former or current employees, routine surveillance of your operations or a problem from a customer are all examples of how an “investigation” starts.

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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