2022 – Edition 5 – June 3

Table of Contents

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

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

The President’s Desk

Going Local

By Terrell Siegfried, NORDAM Assistant General Counsel and Corporate Secretary & 2022 ARSA President

“All politics is local.”

You’ve likely said and certainly heard those four words. First written in the 1930s, the mantra was made famous by Tip O’Neill in his 1982 campaign against an opponent bolstered by out-of-state donors. The long-time speaker of the U.S. House of Representatives made local-focus one of his “rules of the game” through an incredibly successful elected career.

What does it really mean?

I live and work in Oklahoma, which has long boasted one of aviation’s greatest supporters: Senator Jim Inhofe. Sen. Inhofe famously flew his own aircraft to and from campaign events – he once had ARSA Executive Director Sarah MacLeod contacted for regulatory compliance help – and remained an industry champion on Capitol Hill. It was Inhofe’s office that asked the association in 2018 for the help that begat the workforce grant programs signed into law as part of that year’s FAA reauthorization.

Inhofe was professionally invested in aviation because he had personally experienced the inequities of the system. His office helped authorize funds for training because he recognized the importance of maintaining a skilled aviation workforce and he honored the people that kept his aircraft flying. His retirement plan includes (hopefully) pushing through creation of the National Center for the Advancement of Aviation because so much of his work has been to advance our shared interests.

Who will follow in his footsteps?

Answering that question is less about the candidates for Oklahoma senator and more about how we develop, nurture, and engage our next champion on Capitol Hill. This is work ARSA performs constantly: educating lawmakers and providing resources for members to put a human face (and an economic value) on the aviation sector. From Legislative Day meetings in March to town halls, meet-and-greet sessions and facility visits leading up to election day, ARSA gives maintenance a voice in the industry’s story.

All politics being local means bringing big issues home. When a global shortage of skilled technicians, supply chain hang-ups, regulatory complexity, and bureaucratic impasse become real and present issues in states, counties, and towns, voters and officeholders can take action to serve the constituency.

How do you do it?

Follow the instructions in this edition of the hotline and join ARSA between now and November. Become an engaged constituent. Make yourself and your company an interested corporate citizen. Include ARSA in your advocacy.

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

Return to Top of Page

ARSA Works

FAA Capitulates on E100

The ride is over. Despite best efforts to convince the FAA it could stand behind its own regulations allowing a repair station to perform maintenance to identify an article and its condition and issue an approval for return to service for that work, the agency capitulated to EASA and removed its support of the ARSA-developed E-100 form.

The form was created in 2016 when EASA demanded new parts be accompanied by the proper “form” (i.e., EASA Form 1 or FAA Form 8130-3) from a production approval holder (PAH) (see updates on arsa.org/mag) even though an FAA Form 8130-3 is not required by the U.S. regulations.

The “requirement” for a PAH to issue the proper form is contained in the Technical Implementation Procedures (TIP) between EASA and the FAA. That document makes the transfer of a part from one national aviation authority to another an “export” under 14 CFR § 21.331. That fact has not penetrated the U.S. PAH to the extent necessary to ensure every part shipped to a repair station with EASA approval is accompanied by an FAA Form 8130-3.

While the FAA encouraged repair stations to continue including ARSA-recommended language (see 9/28/15 update on arsa.org/mag) in purchase orders to the effect that new parts ordered would be installed in articles subject to the FAA-EASA Maintenance Annex Guidance (MAG), the agency stated that an export occurs when the dual release is signed. This suggests that the agency will not enforce the requirement that the PAH issue an FAA Form 8130-3 when it ships a new part to an EASA-approved repair station, even if the repair station includes export language in its purchase order. The latest FAA letter contradicts the 2016 letter from the manager of the Aircraft Maintenance Division as well as an earlier letter issued by the Executive Director of the Aircraft Certification Service.

To read the FAA’s letter rescinding the acceptability of Form E100 to meet the requirements for use in work that will be issued a dual release, click here.

ARSA is reviewing its manual compilation and tools for member use – including the E100 – and will update members regarding new versions. The association will also continue to press the FAA to implement the requirements of the TIP through 14 CFR § 21.331 or to remove the requirement if it cannot be enforced.

AMT Day 2022 – Celebrating Charlie

Charles Taylor

Charles Taylor, the Wright Brothers’ mechanic and father of aviation maintenance, was born on May 24, 1868. Now – 154 years later – we celebrate him with every safe arrival and continued commitment to good work (regardless of the state of the world).

In 2008, a congressional resolution dedicated the date in honor of Taylor, establishing National Aviation Maintenance Technician Day. While the “holiday” doesn’t get anyone out of work (there are no days off from aviation safety), it’s important to celebrate the commitment, integrity and skill of every aircraft mechanic and all those who support them – this is Taylor’s legacy and our shared responsibility.

Hopefully all ARSA members recognized May 24, 2022 and will (if they haven’t already) share with ARSA (contact Brett Levanto at brett.levanto@arsa.org). The association often highlights member celebrations via its various communications and is always looking for great examples.

No matter how you celebrate AMT Day, it’s a small bit of well-deserved recognition. Thank you for your hard work, dedication and support.

The world can’t fly without you.

FAA Issues WebOPSS Access Workaround

The FAA will miss the June 15 deadline for updating its WebOPSS system to operate in the Microsoft Edge browser. Microsoft will decommission Internet Explorer, which was required for accessing the system, so the agency has distributed guidance providing an access workaround to allow time to update to the new standard. 

This action must be taken before June 15: Industry users who access WebOPSS from outside the FAA network must configure their Microsoft Edge browser to “Internet Explorer Compatibility View.” Internet Explore must remain installed for this view to function; do not uninstall it (or allow your IT department to uninstall it).

Instructions for configuring a Windows 10 PC for WebOPSS from outside the FAA network are found on the AFS-260 Technical Programs Section website. Industry users needing assistance should contact AFS-WebOPSS@faa.gov.

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.

 Return to Top of Page

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.

Giving Campaign Contributions

By Christian A. Klein, Executive Vice President

There’s a lot at stake in this year’s mid-term congressional elections. Republicans smell blood in the water and are bullish about their chances of retaking both the House and Senate. Democrats aren’t going to give up control of Congress without a fight and the leaked Supreme Court decision has activated the party’s liberal base.

The outcome is uncertain, but this year’s elections will certainly be among the most expensive. At some point in the next few months, it’s likely you’ll be asked by a congressional candidate or a political action committee (PAC) for a campaign contribution. Making campaign contributions is a way to make your voice heard in the process. Talking to candidates when they’re “dialing for dollars,” attending fundraisers, or meeting to deliver a check is an excellent way to build visibility and an opportunity to discuss important issues.

A candidate won’t do what you ask just because you give them a check (that’s called bribery and is a crime); but it’ll put you, your company, your industry, and your issues on their radar screen. Because ARSA wants its members to be politically active and exercise their rights, this month’s “Legal Brief” provides some basic guidelines for providing campaign-related financial support.

The Federal Election Campaign Act (FECA), which is administered by the Federal Election Commission (FEC), establishes limits and prohibitions on who can get involved in campaigns. Corporations (including nonprofits), banks, and labor unions are prohibited from using general treasury money to make direct contributions to candidates (independent expenditures by these entities – advertising in support or opposition to a candidate – are beyond the scope of this article). Partnerships and limited liability companies (LLC) can make contributions if it is attributed as income for tax purposes to one or more of the partners or owners.

The primary sources of congressional campaign funds are individuals and PACs. A PAC is a separate segregated fund set up by a corporation, bank, or union to receive contributions from individuals. The PAC can then use those resources to make bigger contributions to candidates. (By law, trade association PACs can’t ask you for a contribution unless you’ve consented to be contacted, so be sure to provide ARSA PAC with prior approval.)

Even though all contributions (directly to candidates or indirectly via PACs) must come from individuals, not all individuals are eligible to contribute. By law, foreign nationals are not allowed to make contributions in conjunction with U.S. elections; the contributor must be a U.S. citizen or permanent resident (green card holder). Federal contractors are also prohibited from making contributions; however, the ban applies to “persons” who have entered or who are bidding on a federal contract. In most cases, the contractor is likely to be a corporation (which is already prohibited from contributing); however, contributions from partnerships and limited liability companies with federal contracts are also banned, as are contributions from individuals under contract to the federal government and sole proprietors of businesses with federal contracts.

In addition to sources of campaign funds, the FECA also puts limits on how much individuals and PACs can contribute to candidates for each election. Keep in mind that in a normal cycle, a congressional candidate will have two elections: the primary (where the party chooses its candidates) and the general (which happens in November). However, the contribution limits also apply separately to runoffs and special elections.

In the 2021-2022 election cycle, an individual may contribute:

• $2,900 per candidate per election.
• $5,000 to a PAC.
• $10,000 to a state, district or local party committee.
• $36,5000 to a national party committee.

In 2014, the Supreme Court struck down limits on the total or aggregate than an individual can contribute, so you can give maximum contributions to as many candidates as you want. Also, an individual cannot make cash contributions that exceed $100 (because cash is harder to track) and anonymous contributions are limited to $50.

For FEC purposes, the term “contribution” means more than just money; the term is defined broadly as anything of value give, loaned or advanced to influence a federal election. In-kind contributions are goods or services offered for free or less than the usual charge; paying for something on a candidate’s behalf is also considered an in-kind contribution. Campaigns must report in-kind contributions and they count against contribution limits.

As part of our 2022 campaign strategy, ARSA strongly encourages its members to host candidates at company facilities. The meetings are an excellent opportunity for a candidate to gain knowledge about your business and industry and meet employees (i.e., voters). Hosting a standard facility visit (meeting with company execs/owners and a tour) shouldn’t raise campaign issues. However, if you want to host an event at your facility (i.e., a rally or fundraiser for a candidate), but sure to familiarize yourself with the applicable rules.

Supporting candidates and industry PACs is just one way to impact America’s political process. ARSA is standing by to support your engagement.

Return to Top of Page

ARSA on the Hill

District Offices – The One Stop Engagement Shop

By Christian A. Klein, Executive Vice President

Constituent engagement and service is one of the secrets to reelection. Even senior members of Congress (MC) with strong name recognition can find their jobs in jeopardy when they don’t make themselves available to voters “back home”.

One of the ways lawmakers stay connected with constituents is through state and district offices. While congressional staff on the Hill tend to focus on national policy issues, state and district staff are in the business of helping constituents solve problems with government. While they won’t force a specific outcome, congressional staff can get their executive branch colleagues focused on your problem.

Local office staff – the state or district director and outreach coordinator(s) in particular – play an important role in building ties between the MC, their Capitol Hill staff, and constituent businesses. While not as conversant as their Hill colleagues on specific issues, they can put you in touch with the right person in the Washington, D.C. office. Local offices also can coordinate the MC’s schedule when they come home. If you want to host a facility visit this summer, contacting the district office is a great place to start.

There are several resources to help you connect. Congressional office websites usually have “Contact” button near the top that will take you to general Hill and local office information. A better tool is ARSA’s Legislative Action Center (sponsored by Aircraft Electric Motors). Go to https://arsa.org/congress/, scroll towards the bottom of the page to “Find Officials”, enter your address when indicated, and click the forward arrow button. On the next page, you’ll see a list of all your federal officials (president, vice president, senators, and representative). Clicking on the name of one of the MCs will bring up contact information for their Capitol Hill and local offices (the number of offices will generally depend on the size of the state or district).

To find out who’s who, click on “Staff” under the MC’s picture. You’ll then see a list of Capitol Hill and local office staff. The local office is generally run by a state or district director. You’ll also likely see one or more outreach coordinators (who are responsible for building and maintaining relations with constituents) and case workers. You may also see a district scheduler. Sometimes members of Congress even put their staff director in the local office to show that constituent service is a priority.

Once you have the name of the district director or other staff member, you can call the local office to introduce yourself or obtain their email address so you can reach out in writing. You can also try to figure out the email address on your own. House staff email addresses are generally FIRSTNAME.LASTNAME@mail.house.gov; Senate staff addresses are FIRSTNAME_LASTNAME@SENATORSNAME.senate.gov. But be aware that sometimes staff email addresses will include middle initials or use nicknames (“Rob” instead of “Robert”), so that system won’t always work.

The good news is that ARSA has access to a comprehensive staff database that allows us to look up email addresses, so don’t hesitate to “Ask ARSA First!” if you’re having trouble getting contact information.

When you reach out – whether about policy issues, an invitation to visit or something else – please copy ARSA Executive Vice President Christian A. Klein (the association’s lobbyist) (christian.klein@arsa.org).

The maintenance industry is in the cross hairs on Capitol Hill now, with unions champing at the bit to pass anti-repair station legislation. ARSA is also working to get Congress to address the technician shortage and maintenance data availability. Whether you use the action center to send quick emails to the Hill in support of association positions or invest a bit more time to host a facility visit, you are key to success. Thanks in advance for your activism.

The hotline will continue over the summer providing guidance for being an active constituent, covering town hall meetings (going to them) and facility visits (hosting them). You can get a jump start on your own by asking your state/district office about these activities and going from there.

ARSA, Allies Object to Anti-Repair Station Bill

In a letter sent May 27, ARSA and nine other leading aviation trade associations told the bipartisan leadership of the U.S. House Transportation & Infrastructure (T&I) Committee to “just say no” to the Safe Aircraft Maintenance Standards Act (SAMSA) (H.R. 7321). The letter was also send to all members of the House T&I Committee.

The SAMSA bill, which was introduced by T&I Chairman Peter DeFazio (D-Ore.) on March 31, would impose new rules and restrictions on FAA-certificated repair stations located outside the United States, make it more difficult for U.S. air carriers to use them, violate bilateral aviation safety agreement obligations, and invite retaliation against American industry. The letter said the legislation would also “add to the Federal Aviation Administration’s workload without providing additional resources, thereby distracting the agency from more pressing safety matters.”

“This bill is a brazen attempt by unions representing airline mechanics to undermine contract maintenance and force more maintenance work ‘in house’,” ARSA Executive Vice President Christian Klein said. “Given the maintenance industry’s outstanding safety record, the unprecedent workforce challenges we’re facing, and decades long efforts to make global aviation regulatory compliance more efficient, it simply makes no sense.”

The following organizations joined ARSA on the May 27 letter:
Aerospace Industries Association
Aircraft Electronics Association
Airlines for America
Aviation Supplies Association
General Aviation Manufacturers Association
International Air Transport Association
Modification and Replacement Parts Association
National Air Carrier Association
Regional Airline Association

To read the full letter, click here.

ARSA is concerned that with Chairman DeFazio’s looming retirement at the end of the current Congress, he and his union allies will attempt to rush the bill through committee. While it’s unlikely that the legislation would be enacted this year (there is no Senate companion), a strong bipartisan vote in favor of the bill in committee could cause it to be included in next year’s FAA reauthorization bill.

“Very few members of Congress understand the maintenance industry and the legislation’s potential impact,” Klein said. “The national organizations have made it clear oppose SAMSA. Now is the time for aviation professionals to get active, reach out to congressional offices and express their opposition.”

ARSA makes engagement easy. The association has set up a resource page with more information about SAMSA. U.S. maintenance industry professionals are urged to contact Congress in opposition using ARSA’s legislative action center (sponsored by Aircraft Electric Motors); foreign repair stations should contact their embassies in Washington, D.C.

Return to Top of Page

Training

Make ARSA Training Work

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

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

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

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

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

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

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

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

What training do you need? Contact ARSA to let the association know and help get it developed.

Make a Difference in Washington

The Constitution’s First Amendment protects the right “to petition the government for a redress of grievances.” Unfortunately, the average citizen never directly engages their lawmakers on issues important to their personal, professional or community needs. The session will overview basic strategies for communicating with key lawmakers and their staff to become an effective advocate for their interests.

Click here to register and get unlimited access for 90 days.

Registration for an ARSA-provided training session includes:

• Unlimited access for 90 days to the recording made available after the live session is complete.
• A copy of the presentation and all reference material with links to relevant resources and citations.
• A certificate upon completion of the class, as well as any test material.

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

A Chicken Runs for Office

From the TED archives, view a “lesson on turning adversaries into allies.” Regardless of the subject matter or situation, understanding the needs of each party will help maintain a professional relationship. As ARSA’s Christian Klein often reminds first timers at Legislative Day: There are no enemies in policy, just opponents (a definition that shifts every day).

View the session – about efforts to curtail chicken factory farming – in the embedded window below or by going to www.ted.com.

Regulatory Compliance Training

Test your knowledge of 14 CFR § 11.47, requesting more time to comment.

Click here to download the training sheet.

Return to Top of Page

Membership

ARSA Survey – Workforce Remains Top Concern

ARSA’s 2022 member survey paints a picture of an industry slowly recovering from the pandemic but still suffering a severe labor shortage. In total, 108 member companies from around the world responded to the survey.

Members are generally optimistic about business conditions: 78 percent believe revenues and markets will grow, nine percent expect no change, eight percent expect contraction and five percent don’t know. Repair stations plan to hire: 70 percent intend to add workers in 2022, 21 percent expect no change in workforce, two percent plan to eliminate positions, and six percent do not know their company plans.

Hiring will be a challenge because the industry workforce still has not recovered from the pandemic. U.S. survey respondents reported having a total of 20,527 employees on Jan. 1, 2020 (before the pandemic), 16,181 as of Jan. 1, 2021 (a 21 percent year-over-year drop) and 18,059 on Jan. 1, 2022. Taken together, those numbers validate ARSA’s earlier findings about job losses during the pandemic and suggest the industry’s workforce is still 12 percent smaller than it was pre-COVID.

U.S. companies reported 1,992 vacant technical positions, representing 11 percent of the survey respondent workforce. Projected across the entire U.S. repair station industry (which employs182,000 Americans), there may be as many as 20,000 vacant technician jobs nationwide.

Not surprisingly “difficulty finding/retaining technical talent” was identified as the most significant threat to the industry and their companies (cited by 72 percent of respondents). Other issues of concern include overall economic uncertainty (52 percent), maintenance information availability (42 percent), regulatory costs/burdens (28 percent) and inconsistent enforcement/interpretation of aviation rules (27 percent).

The survey found the average hourly entry-level wage for technical personnel at U.S. repair stations was $19.16 per hour. Technicians with five years’ experience earn $26.50 per hour on average and more experienced technicians at “the top end” earn an average of $36.72 per hour.

Sixty-two percent of U.S. respondents have at least one foreign civil aviation authority (CAA) approval and, on average, 34 percent of gross revenues are associated with foreign certificates. This underscores the risk to U.S. companies should foreign CAA’s retaliate against potential congressional action limiting the use of foreign repair stations.

Repair stations don’t operate in a vacuum; they’re an important part of the fabric of the U.S. economy. Respondents reported having an average of 25 certificated vendors (the median was 13); 25 uncertificated vendors supporting maintenance (median: 5) and 54 vendors supporting general business operations (median: 9).

Respondents also reported a high level of satisfaction with the association. On a five-point scale (with five being “very satisfied”) the average score was 4.55. Here are some of the open-ended comments we received about the association and the value of membership:

• “A voice to speak on behalf of all repair stations is priceless.”
• “Always very helpful when I have regulatory questions.”
• “ARSA is consistent. There is a lot of inconsistency elsewhere these days.
• “ARSA was very helpful with the pandemic explanation detail with money and working with the US to get funds.”
• “ARSA works on issues that benefit us as well as the entire industry. They understand (and communicate) that the things we need will take years to achieve. It’s all about keeping the pressure on and engaging the system on topics that can generate results for the membership.”
• “Gives us confidence and peace of mind to have ARSA’s knowledge and history of backing small business’s especially regarding regulatory guidance and enforcement.”
• “Good support when needed, a positive organization for the industry with training and advocacy.”
• “Great resource.”
• “ARSA has a dynamic group that keeps it entertaining.”
• “ARSA’s impact over the years has been excellent. The expertise on the regulations has been unparalleled.”
• “You guys are awesome!”

Respondents said the most valuable member benefits were access to ARSA’s expertise (regulatory/legislative questions): 4.59/5 (5 = very important), regulatory compliance support (4.57), congressional advocacy (4.34), free regulatory compliance resources (4.32); and the Dispatch and hotline newsletters (4.19).

The data provided supports ARSA advocacy on the industry’s behalf and ensures that association resources are properly allocated. Thanks to all members who took the time to participate.

Quick Question – Engaging Elected Officials

ARSA’s legislative team works hard for the industry every day (with great success); the maintenance community can support its association by engaging directly with elected leaders. By investing personally in the political process at the local, state and national level, aviation professionals can help drive home important messages and put a human face on the general arguments made by the association.

With midterm elections fast-approaching, the association will be presenting instructive content on how to be an “active constituent” and get facetime with elected officials (see the first installment in the “ARSA on the Hill” section of this edition edition of the hotline).

To help ARSA enhance the industry’s engagement, take a moment to share your experience with activities that bring you and your company closer to those who represent your interests in government.

The survey is best viewed in its own browser window. To open it, click the following link or past the URL into your browser: https://www.surveymonkey.com/r/maintenance-advocacy.

For more information about this or any other question, contact Brett Levanto (brett.levanto@arsa.org).

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

Quick Question Answered – The Dynamic Regulatory System

It’s been more than six months since the FAA unveiled its Dynamic Regulatory System and the agency is preparing to decommission the Flight Systems Information Management System (FSIMS). As is already the case for certification-related guidance, the contents of Order 8900.1 must be accessed via the DRS. The agency asked the association for assistance gathering feedback on DRS use.

In May, ARSA asked and 59 respondents answered:

Click the image to see the breakdown of respondents’ experiences with the DRS.

Of those members, responses regarding DRS use were broken into rough thirds. Evenly sized groups reported (1) using the system regularly, (2) knowing of it but rarely or never using it or (3) never having heard of it before answering the question. Most respondents shared initial thoughts or feedback, reflecting the steep learning curve for understanding the DRS search functions, particularly considering the quantity of data returned by any query.

ARSA will share this feedback with the agency. In the meantime, members should invest time in building familiarity with the DRS as the FAA builds more legacy systems into it:

(1) Make sure drs.faa.gov is bookmarked on every computer in your facility and a regular stop for regulatory compliance questions. (EDITOR’S NOTE: The authors encourage you to make the DRS your first stop for questions, but graciously accepted the association’s reminder that members should “Ask ARSA First.”)

(2) Carefully review instructions available at drs.faa.gov/help.

(3) Every time you use the system, consider the experience. How could it be better? Submit thoughts by clicking on “DRS Feedback” on the top banner of the site and submitting the form.

Welcome Back – Renewing Members

ARSA’s members give the association life – its work on behalf of the maintenance community depends on the commitment of these organizations. Here’s to the companies that renewed in May:

Renewing Members

AeroKool Aviation Corporation, R03, 2017
ATP USA, Inc., R01, 2017
Aviation Safety Products, Inc., R01, 2013
Business Jet Services, LTD. dba Business Jet Access, R02, 2021
Ford Instruments & Accessories, LLC, R01, 2018
Jet Center MFR dba Southern Oregon Skyways, R02, 2006
Ozark Aeroworks, LLC , R02, 2015
Pennsylvania State University, R01, 2016
Performance Repair Group, LLC, R02, 2013
Quality Aviation Instruments, Inc. dba QAI Aerospace, R03, 2012
Southwest Airlines, R06, 2005
TAE Aerospace, Inc., R01, 2019
Turbine Aircraft Logistics, LLC, R01, 2021
WGI, Inc. dba Westfield Gage Company Overhaul and Repair, R03, 2018

A Member Asked…

Q: We have an issue with parts from a UK manufacturer that will not issue Form 1, only a CoC with an ominous message regarding the part only being eligible for installation by the TC holder.

I believe we can use these parts for FAA single release, as we have trace to the production approval holder and purchased them from an authorized source. Is there any concern about using these parts for FAA work?

A: The issue is a potential violation of 14 CFR § 21.9(a) which requires production approval for parts that are known to be installed on type certificated products. The non-compliance attaches at the time of production, not at the time of sale. If the manufacturer is producing parts without the appropriate approval, it is in violation of the referenced regulation.

That does not mean that a repair station cannot determine the article is eligible for installation.

The ominous “scare statement” is misleading: Once an article is produced, the only persons authorized to replace the article and therefore to determine if it is eligible for installation are maintenance providers with the certificates referenced in 14 CFR § 43.3. Manufacturers (i.e., design an/or. production certificate holders) cannot perform maintenance, only alterations and certain inspections (see, 14 CFR § 43.3(j)). The TC holder cannot even produce articles, manufacturing takes a PC or some other production approval.

The statement is also “proof” the manufacturer knew or should have known it was producing for installation on type certificated aircraft. And, another example of the failure to enforce regulations by Aircraft Certification.

As to whether the repair station can make the determination that this article meets an approved design and is in a condition for safe operation, FAA’s guidance material (AC 20-62) and 14 CFR part 3 both indicate that part marking is an important element for determining eligibility for installation. Therefore, yes, under 14 CFR parts 43 and 145, a maintenance provider can determine eligibility for installation with information provided by the seller of an aeronautical article.

ARSA’s E100 Form is still valid for part 43 purposes (despite the FAA’s backtracking on the form’s acceptability for compliance with the U.S./EU MAG). When completed in accordance with its instructions, the form establishes the article meets an approved design and is in a condition for safe operation.

Of course, there is “concern” and no doubt there can be questions. However, the questions should be asked of the manufacturer and the seller, not the installer!

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).

Return to Top of Page

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.

Contract Maintenance Under Legislative Attack (Again)

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

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.

Industry News Roundup

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

Industry Calendar

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

© 2022 Aeronautical Repair Station Association