2022 – Edition 9 – October 7

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

Our Platform

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

My father and NORDAM founder, the late Ray Siegfried, was an early and active supporter of ARSA and a former boxer. So in my first letter “from the desk of the president” in last October’s Hotline, I used a boxing metaphor he would have appreciated, writing “while ARSA’s team provides the punch, its members provide the weight.”

I spent the next year as your association president focused on beefing up that membership.

Each month, my “desk” became more packed with challenges to you and updates on our progress. I encouraged annual conference participation, explained the “return” on your dues investment, reported on the state of the association, pushed recruitment initiatives, connected to local politics, and even channeled Julie Andrews to help spread the impact of this association by adding to the weight behind its punch.

As my one-year term ends, I’m proud of the impact of this work. Thanks to the diligence of ARSA’s team and commitment of the industry, our membership renewal rate exceeded 90% last quarter. While some members left the aviation industry this year or moved to a position with a different member company: It is now practically a certainty that repair stations will maintain their association membership as long as they perform work on civil aviation products and articles.

This gives us an incredible platform to build on. I encourage you to continue sharing the good work of this association and bringing in new members. As you do, ARSA’s next president will be able to channel that enthusiasm into another important focus area.

At the board’s annual meeting next week, ARSA Vice President Josh Krotec will be elected as my successor. In his ARSA role and in his day job as senior vice president of First Aviation Services, Inc., he is heavily engaged in multiple long-term efforts to improve aviation policy. When we spoke about Josh’s priorities for the coming year, engaging with the government was at the top of his list. Our most active members recognize we have what it takes to succeed there, thanks to ARSA’s existing training and tools for professionally and productively engaging lawmakers and regulators.

Once again, we have a great platform from which to build. As I continue on as an ARSA director and president emeritus after my presidential term, I look forward to supporting Josh, the rest of the board – and you, our valued members – as we move the industry and this association into the future. Thank you for your support and investment in our collective work.

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

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ARSA Works

EASA Briefs on SMS for Non-Bilateral Foreign Repair Stations

On Sept. 19, EASA hosted a webinar to explain its new safety management system (SMS) requirements for EASA-approved Part-145 organizations outside the European Union in countries without a bilateral agreement.

Organizations in the United States, Canada and Brazil will continue to comply with the current bilateral aviation safety agreements and their corresponding maintenance implementation or guidance procedures. While repair stations in the EU must also comply with the new regulation, the presentation focused on how EASA will handle the transition phase to the new rules for maintenance organizations outside the EU that it oversees directly.

Commission Implementing Regulation (EU) 2021/1963, issued in November 2021, introduced the new SMS requirements in Part 145; it is effective Dec. 2, 2022. Section A of the regulation’s Annex II contains the new SMS rules for maintenance organizations; Section B describes how EASA and aviation authorities in European Union (EU) member States (“competent authorities”) will implement the requirements. The regulation establishes a two-year transition phase (Dec. 2, 2022 to Dec. 2, 2024) during which affected repair stations must develop an SMS transition plan.

Organizations with valid Part-145 approvals (i.e., an approval that has not been suspended or revoked) will receive a generic “transition finding” on or after Dec. 2, 2022 indicating the organization is not yet compliant with SMS requirements. According to EASA, the transition finding will allow approvals for as-yet noncompliant organizations to maintain their approved maintenance organization (AMO) approval during the transition period. The finding may be sent on its own or be made during an audit, during the renewal of the EASA surveillance cycle, or when the organization sends its SMS package to EASA for review. The finding’s due date will be June 2, 2024; while it will not be assigned a level, the finding will be elevated to a Level One if not closed by the end of the transition phase.

Organizations are required to prepare and submit an SMS application package by Dec. 2, 2023 that includes:

• EASA Form 2 with block 6.3 application type indicated as “change for SMS implementation i.a.w. Regulation (EU) 2021/1963”.
• An implementation plan with timelines for compliance with the new requirements, including staff training, roll out of new processes, and reorganization.
• A revised maintenance organization exposition (MOE) that meets the requirements of EASA User Guide (CAO.00024-009 MOE is currently in draft form).
• The name and qualifications of compliance monitoring and safety managers (EASA will decide on case-by-case basis whether the two roles may be performed by the same person).

After receiving the SMS application package, EASA will plan an “SMS Change Audit” to include a review of procedures, interviews with staff, evaluation of processes, etc. Based on the evaluation, the inspector will determine whether the SMS system is appropriately documented and suitable based on the size, nature, and complexity of the organization and the inherent risk associated with the organization’s work.

Timely compliance matters. EASA will not process any changes to approvals of organizations that do not submit their SMS applications by the Dec. 2, 2023 deadline. EASA also warns that organizations which do not close their SMS findings by June 2, 2024 risk not having their SMS changes approved by the Dec. 2, 2024 compliance deadline, which could lead to certificate action. If an organization’s approval is suspended or partially suspended on or after Dec. 2, 2022, it can only be reinstated if the organization is compliant with the new SMS requirements (as verified during the reinstatement audit). If an approval application is pending as of Dec. 2, 2022, an approval will only be issued if EASA finds the organization in compliance with the SMS requirements. Finally, organizations that applied for Part-145 approval after June 23, 2022 should prioritize SMS compliance given that the EASA approval process can take more than six months making it is unlikely the application will be approved before the Dec. 2, 2022 effective date of the new regulation.

In response to a question submitted prior to the webinar, EASA said that while the EU regulation is based on the International Civil Aviation Organization’s (ICAO) SMS framework, there are specific requirements unique to EASA. As such, an organization’s SMS program must comport with the new EU regulation, regardless of whether the organization’s SMS has already been developed in accordance with ICAO guidelines and approved by its home authority.

During the webinar, EASA also referenced the fact that it is introducing a series of new approval numbers for approvals in the United Kingdom. The approval number format will change from EASA.145.UK.#### to EASA.145.3###. EASA requests that organizations in the U.K. use the new approval number when providing new draft MOE with SMS changes. Once their SMS programs are approved, U.K. organizations will receive a new Form 3 certificate with its new approval number.

While EASA’s new SMS rule does not apply to U.S. repair stations with EASA approval, the writing is on the wall, and it is highly likely that the next Maintenance Annex Guidance between the FAA and EASA will include SMS requirements. Familiarizing yourself with the EASA rule now will put you ahead of the game when the new MAG is adopted.

More resources regarding SMS may be found on the EASA website, including:

• SMS transition letter sent to Foreign EASA Part-145 Organizations
• Draft of UG.CAO.00024-009 (“Foreign Part-145 Approvals – User Guide for Maintenance Organisation Exposition”)
• SMS Transition Guide
• Management System Assessment Tool

FAA Opens its Virtual Doors to Students

On Sept. 29, the FAA hosted its 6th Aviation Safety STEM Career Symposium. The online event allowed middle school, high school, and college students to navigate around a virtual convention center, visiting exhibit booths, asking questions, collecting resources, participating in a scavenger hunt and attending sessions encouraging careers in aerospace.

The virtual delivery of the event provided an important opportunity to dramatically increase its reach (see the 2019 at arsa.org/hidden-gems about “hidden gems”). Any ARSA members that were able – after late notice – to stimulate participation among local partners or who viewed the sessions independently are encouraged to share feedback. The event focused considerable effort on FAA careers, but is meant to stimulate general industry interest and is instructive on how the government is “selling” aviation opportunities.

Take a stroll around the event by checking out some images taken by an ARSA team member during the experience…

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Youth Task Force Wraps with ‘Can’t Wait’ Message

On Sept. 22, the FAA-managed Youth Access to American Jobs in Aviation Task Force held its final public meeting. The body closed its two-year run by delivering its congressionally mandated report and handing government and industry a checklist for improving aviation career opportunities.

After a kick-off address by Acting FAA Administrator Billy Nolen and a recorded speech by Secretary of Transportation Pete Buttigieg, Task Force Chair Sharon DeVivo walked through the group’s recommendations. Those proposals align into four categories:

(1) Early awareness and engagement. Though the task force’s charter targets high school students, DeVivo noted: “We can’t wait until they’re in high school until we get them, we have to feed that pathway so they’re ready.”

(2) Information access. The “connective tissue” of the report’s findings is communication and resource management.

(3) Collaboration. All aerospace stakeholders must follow and build on current models (e.g., the aviation workforce grant programs) that stimulate connection among and between employers, schools, community organizations, labor groups, and every level of government.

(4) Addressing financial hurdles. Not only is cost a barrier to entry for many careers requiring specific training and/or certification, but there are also structural limitations – including restrictive regulatory practices – that hold back innovation and limit career growth compared to other industries.

After the presentation, task force members – including ARSA Vice President of Operations Brett Levanto – discussed key lessons learned across their years of research together. Notably, the representatives highlighted the importance of reaching previous under-represented groups in order to expand the quality and size of the talent pool available to aerospace employers.

What’s next?

The task force’s report has been published on the FAA’s committee website (and is linked below). ARSA encourages all members to review its contents and consider individual actions that can be taken while the association presses larger policy objectives (like overhauling FAA training acceptance).

To access the agency’s committee webpage, click here.

To download the report, click here.

To view a recording of the meeting, click here or use the viewer below.

Partner for the Pipeline

In June, the White House issued its “Talent Pipeline Challenge” to stimulate workforce development programs in transportation infrastructure. The program builds on investments made by Congress through laws like the Infrastructure Investment and Jobs Act and the American Rescue Plan by pushing employers, educational institutions, government entities and philanthropic organizations to build career opportunities for underrepresented groups.

According to the program pledge, it encourages employers to partner with schools and community organizations, utilize apprenticeship programs and invest in recruitment incentives like tuition assistance or child care. With support from state and local governments using federal funds, these partnerships should provide new or bolster existing opportunities to expand workforce pathways.

ARSA has lent its support to the pipeline challenge through the National Skills Coalition’s Business Leaders United (BLU) program. The association has signed on to an effort encouraging the Biden Administration to continue pushing for local strategies to effectively train workers for in-demand jobs. This community-focused model is key to the ongoing success of the aviation workforce grant programs created during the most-recent FAA reauthorization and will remain a central driver of good workforce policy at the U.S. federal level.

The association encourages members to get involved in the initiative in one of three ways:

(1) Take the pledge. Though the White House specifically identifies the construction, broadband and electric vehicle sectors, the partnerships encouraged by the Talent Pipeline Challenge can serve all of the technical trades. By standing up for robust, equitable career opportunities, repair stations send a clear message about the vitality of the industry. Click here to get started.

(2) Broadly support local collaboration. The National Skills Coalition is collecting signatures in support for the Talent Pipeline Challenge. Separate from pledging to participate, companies can show the importance of focused workforce development policy from the executive branch: Advocating for effective use of existing federal funding. Email BLU Manager Jeran Culina to include your company (supporting organizations will not be listed publicly).

(3) Get ideas. The White House fact sheet includes multiple examples of programs stimulated by the challenge. Review them, look for potential partners or ideas for your own community-based collaboration.

As always, include ARSA in your communications and planning. The association always celebrates good investment in aviation professionals of the future and will help amplify your work to serve all.

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.

Layman Lawyer – The Picture of Innocence

By Brett Levanto, Vice President of Operations

Last month, this “Layman Lawyer” wrapped up (so we said) a series exploring the real-world implications of the FAA’s compliance program. Since January, we’d overviewed the program, checked agency guidance implementing it, covered the rights of the certificate holder to show compliance, and explained the FAA’s freedom to enforce its own rules.

Looking all the way back to that overview in January, an important problem justifies un-wrapping the series. Here’s the offensive paragraph:

“[Just culture] purports to have ‘an expectation of, and an appreciation for, self-disclosure of errors.’ According to the underlying ‘philosophy’ introduced in 2016, by diverting from an enforcement-first perspective, inspectors can help to foster greater safety through openness to recognizing inadvertent or quickly correctable non-compliance.”

Can you see it? The italicizations have been added to this writing to catch your attention. Here’s the problem: What if you ARE compliant?

The FAA is rife with unpredictable interpretations and tribal knowledge driving demands made of certificate holders and applicants. In September, I attended an industry event during which attendees chronicled diverging demands not only from different district offices, but between personnel in the same office. An FAA representative acknowledged that inconsistency in enforcement as a “black eye” on the Flight Standards Service…one it has apparently been wearing for decades.

In this environment, it’s a near certainty that if you’re engaged in aviation, you will have a disagreement with the FAA. Remembering your entitlement to your certificate rests on the responsibility to show compliance for a regulator meant to find it, these disagreements are not on their face evidence of non-compliance. There’s nothing to self-disclose in the name of “justice” if the error is not yours.

The June edition of this series asked: “What happens when it is the inspector demonstrating a ‘gross disregard’ for – or at best distinct ignorance of – the statutory and regulatory standards?” The answer was chronicled by Christian Klein in the “real” Legal Brief that month. Klein showed how one ARSA member (also a client of the association’s management firm) had to “think like a lawyer,” which starts with never assuming the FAA is right and you’re wrong.

From there, you need to know the tools and programs are available to help address your disagreement. You also need to have done your due diligence, which means actively building and documenting your relationship with the agency. Here’s your starting checklist for figuring this all out:

(1) Review ARSA’s “tools for dealing with the government,” which include training sessions and templates for documenting communication well before a problem occurs.

(2) See Klein’s piece on that ARSA member who demanded their right to due process, solving a problem (that never should have occurred) before it became a disaster).

(3) Start learning about the Consistency and Standardization Initiative (CSI) and Regulatory Consistency Communications Board (RCCB) and look forward to more content from ARSA.

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

Non-Emergency Certificate Actions

By Christian A. Klein, Executive Vice President

This month’s “Legal Brief” continues a long series on FAA’s enforcement process. Last month we explored the final step before the “true” legal process begins; the month before we discussed the process leading up to and following a Letter of Investigation (LOI); and in July we walked through an example of a repair station refusing to walk into further violations when it had been compliant all along.

This month we will explore non-emergency certificate actions; in future columns we will discuss emergency actions and the civil penalty process.

The rules applicable to legal actions against certificates are found in part 13 of 14 C.F.R.; the guidance is in Order 2150.3C (“FAA Compliance and Enforcement Program”). The term “certificate action” means the agency 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 (repair station) certificate because of a reinspection, reexamination, or other investigation.

The agency is authorized by 13.19(a) to take certificate actions when it determines that the public interest or public safety in air commerce is at risk, when the certificate holder has violated aircraft noise standards or used an aircraft to hunt or harass animals, or when the owner of an aircraft knowingly permitted an aircraft to be used to violate state or federal controlled substances laws (other than simple possession). (Note: special procedures apply to controlled substance certificate actions, see, 13.19(b).)

FAA attorneys initiate the process by issuing a Notice of Proposed Certificate Action (NPCA), which can be done on a non-emergency (13.20(c)) or emergency (13.20(d)) basis. In the case of non-emergency orders, the certificate holder is served with an NPCA advising of the charges or other reasons upon which the proposed action is based and providing 30 days to respond.  The recipient may:

• Reply in writing.
• Agree to the issuance of the order and waive the right to appeal.
• Request an information conference with an FAA attorney. Or,
• Request a hearing in accordance with part 13, subpart D.

The most common course of action is to request a copy of the Enforcement Investigative Report (EIR) and an informal conference. The certificate holder’s response will stay a non-emergency NPCA so the privileges of the certificate can be exercised during the appellate process.

In the leadup to the informal conference, the EIR must be reviewed carefully to prepare a “smart letter” explaining the certificate holder’s position on each allegation. The letter would address the facts of the allegations, the applicable regulations, any mitigating circumstances or actions and explain and attach any favorable evidence of compliance.

During the informal conference with the FAA lawyer, each allegation would be discussed using the smart letter as a guide. After the conference ends, any additional information or updates to the letter based on the discussion can be made and sent to the FAA lawyer.  Once the informal conference has been held, the FAA will notify the certificate holder whether some or all of the proposed certificate action will be withdrawn or whether it is proceeding with the action.

If the NPCA is not withdrawn in its entirety, the certificate holder may request a hearing within ten days of receipt of the notice.  Hearings regarding non-emergency NPCAs are conducted pursuant to part 13, subpart D. Under 13.20(c)(4), failure to make the request within the ten-day period constitutes waiver of the right to a hearing and appeal and authorizes the agency to  make appropriate findings of fact and issue an order without further notice or hearings.

In next month’s column we will delve into the process for emergency certificate actions.

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ARSA on the Hill

Softening SAMSA

By Christian A. Klein, Executive Vice President

The U.S. House of Representatives passed the Global Aircraft Maintenance Safety Improvement Act (H.R. 7321) on Sept. 29 by a vote of 374 to 52. The bill is an amended version of the Safe Aircraft Maintenance Standards Act (SAMSA), which was first introduced and rushed through committee by House Transportation & Infrastructure Committee Peter DeFazio (D-Ore.) in late 2019. ARSA has led industry opposition to SAMSA.

During committee reconsideration in June 2022, the legislation was significantly amended to allay many of the concerns expressed by ARSA and its allies. In addition to changing the bill’s name, H.R. 7321 was improved as follows:

• Air carriers would be required to report to the FAA about where heavy maintenance (C and D checks) is performed, however, the reports would be annual (less frequent than under SAMSA) and the information submitted would be protected as confidential.
• SAMSA required direct certification under part 65 of certain foreign repair station personnel; while HR. 7321still requires personnel certification, it can occur under either part 65 or an equivalent foreign personnel certification system.
• Countries determined by the FAA not to comply with ICAO standards (“CAT 2 countries”) are still in the crosshairs; however, the implications of falling into CAT 2 status are now less disruptive for industry. H.R. 7321 only prohibits new repair station certificates in CAT 2 countries and new contracts for heavy maintenance work.
• R. 7321 still directs the FAA to finish the long-awaited drug and alcohol rulemaking within a year of the bill’s enactment, but rather than punishing industry with a new foreign repair station certification ban if the rulemaking is not complete, H.R. 7321 now bars FAA personnel from traveling internationally until the rulemaking is done (with exceptions for safety-related travel, travel in the national interest, etc.).
• R. 7321 still provides for unannounced inspections, but they are “unannounced” only to the repair station. The bill allows notification of foreign authorities, governments, etc. and those unannounced visits may be risked based and must take place in accordance with U.S. international agreements and diplomatic norms.
• R. 7321 now directs a joint authorities review to examine the question of foreign repair station oversight on a global basis. This would include an examination of how to better leverage the oversight resources of other authorities.

Despite the improvements, ARSA does not support H.R. 7321 and still considers it a solution in search of a problem that would unnecessarily divert scarce FAA oversight resources. The legislation ignores the maintenance industry’s outstanding safety issue and would introduce new complexities into the global aviation regulatory regime (which is already complicated enough!)

The House Democratic leadership presumably brought the bill up for a floor vote as a final beau geste to DeFazio, who is retiring at the end of the current Congress and has long taken a dim view of the maintenance industry. Most Republicans did not oppose the bill because it was the result of a good faith negotiation process with T&I Committee Democrats.

Despite House passage, it is unlikely the bill will become law this year. There is no Senate companion, and the Senate Commerce, Science and Transportation Committee has held no hearings on the issue. ARSA and its allies will be urging senators not to take up the bill.

What remains to be seen is how and whether foreign repair station issues are addressed during the upcoming FAA reauthorization process (which will begin next year). Although the labor unions lobbying for the bill are losing their strongest ally with DeFazio’s retirement, the legislation still enjoys support among most Democrats and some Republicans. As a result, even if Republicans regain the House and Republican leadership opposes H.R. 7321, its proponents can still cobble together a bipartisan coalition to add it as an amendment to the FAA bill.

ARSA members should review the updated text of the bill and contact ARSA to become more involved in the fight to prevent this unnecessary legislation from becoming law.

Workforce Bill Heads to Senate

Another bill passed by the House during the last week in September is one of ARSA’s top 2022 legislative priorities: the National Center for Advancement of Aviation (NCAA) Act (H.R. 3482/S. 1752.

The bill is motivated by the need for a national aviation workforce strategy. It would establish the NCAA to serve as a national independent forum to facilitate collaboration and cooperation between aviation and aerospace stakeholders to support and promote civil and military aviation and aerospace. NCAA’s purposes would be to:

• Support the development of aviation and aerospace education curricula.
• Support the professional development of educators using such curricula.
• Promote aviation and aerospace employment opportunities.
• Support Armed Forces personnel seeking to transition to a career in civil aviation or an aerospace-related field through outreach, training, apprenticeships, or other means.
• Serve as a central repository for publicly available economic data, safety data, and research efforts related to the aviation and aerospace sectors.
• Serve as a forum, through symposiums, conferences, and other means as appropriate, for cross-disciplinary collaboration among aviation and aerospace stakeholders.

The NCAA would also be authorized to issue grants to organizations that have experience in, and knowledge of, creating, developing, and delivering or updating (1) high school aviation curricula; or (2) aviation curricula used at institutions of higher education, secondary educations institutions, or by technical training and vocational schools.

While the bill enjoys broad support within the aviation industry and on Capitol Hill, its prospects in the current Congress are uncertain given the limited amount of time remaining in the 117^th Congress. ARSA and its allies hope to enact the bill this year to provide more structure to the conversation during the upcoming FAA reauthorization.

Please use ARSA’s online grassroots action tool (sponsored by Aircraft Electric Motors) to send a message to your representative and senators supporting the bill.

Musical Chairs

Last month’s column discussed looming leadership changes on the House Transportation & Infrastructure Committee. This month we examine the Senate Commerce, Science and Transportation Committee and its aviation subcommittee leaders.

With Democrats in control of the Senate, the committee’s current chair is Sen. Maria Cantwell (D-Wash.) and the senior Republican (“ranking member”) is Sen. Roger Wicker (D-Miss.). Sens. Krysten Sinema (D-Ariz.) and Ted Cruz (R-Texas) are respectively the chair and ranking member of the aviation subcommittee.

No matter which party is in control of the Senate next year, Wicker may relinquish his Commerce Committee leadership position to become chairman or ranking member of the Senate Armed Services Committee (the current ranking member – Sen. Jim Inhofe (R-Okla.) – is retiring). If that happens, Cruz could become the senior Commerce Committee Republican and Wicker, who will likely keep his Commerce seat, could become ranking on the aviation subcommittee. It is less likely that Cantwell or Sinema would give up their current roles.

Bottomline: While we expect some movement between the leadership positions and Republicans may hold the gavels, the leaders of the committee and subcommittee responsible for aviation policy will likely remain unchanged in the next Congress.

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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.

Part Marking

Instructors: Sarah MacLeod, Christian A. Klein & Brett Levanto
Description: This session outlines the basic rules for aviation part marking and identification and reviews applicable guidance as it pertains specifically to the re-identification of parts while performing maintenance. It introduces the key requirements of 14 CFR part 45, Identification and Registration Marking.

Click here to register and get access for 90 days.

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.

Sale, Purchase and Stocking of Aircraft Parts

Get immediate access to Executive Director Sarah MacLeod’s three-session series on the regulations and other requirements affecting the purchase, stocking and sale of aircraft parts.

Regulations Impacting the Purchase of Aircraft Parts
The course reviews the civil aviation regulations in 14 CFR that impact the purchase of civil aviation parts, as well as other requirements that should be considered when making such purchases.
Click here to register and get 90-days of access to the recording.

Regulations Impacting the Receiving, Inspection and Stocking of Aircraft Parts
The course reviews the civil aviation regulations in 14 CFR that impact the receiving, inspecting and stocking of civil aviation articles for maintenance purposes, as well as other requirements that should be considered.
Click here to register and get 90-days of access to the recording.

Regulations Impacting the Sale of Aircraft Parts
The course reviews the civil aviation regulations in 14 CFR that impact the sale of civil aviation articles, as well as other requirements that should be considered when selling parts.
Click here to register and get 90-days of access to the recording.

Interested in all three? 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 § 11.73, FAA disposition of rulemaking petitions.

Click here to download the training sheet.

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Membership

2023 Annual Conference – Save the Date

March 14-17, 2023

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 2022.

See what happened last March…

2022 Information | 2022 Sponsors

Simple Agenda

Unless otherwise noted, all Annual Conference activities take place at the Ritz-Carlton, Pentagon City in Arlington, Virginia. Stay tuned for agenda updates as the event gets closer.

Executive to Executive Briefings: Tuesday, March 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.

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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.

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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.

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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.

Attendance & Pricing

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

(1) See sponsorship opportunities for exclusive access to the Executive to Executive Briefings (E2E) on Tuesday, March 12 and other complimentary benefits.

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(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.

Sponsorship

For information about committing your organization to the Annual Conference, contact ARSA Vice President of Operations Brett Levanto. To download a sponsorship overview containing the information below, click here.

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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

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Platinum – $10,000

Notation in all publicity, marketing and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, specific thank you in ARSA periodicals, 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

* All sponsorship support selections are subject to availability. The ARSA events team will discuss alternative suggestions.

2024 Platinum Sponsors

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Gold – $7,500

Notation in all publicity, marketing and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, specific thank you in ARSA periodicals, 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

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Silver – $3,500

Notation in all publicity, marketing, and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, complimentary registrations for one (1) participant in the Executive-to-Executive Briefings as well as one (1) in Legislative Day. At the Silver Level, sponsors may select one of the following to specifically support (may not reflect current availability for 2024):

• Annual Repair Symposium – Coffee Break (5)
• General Sponsorship

2024 Silver Sponsors

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Supporter – $2,500

Notation in all publicity, marketing, and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, specific email alerts to association contacts), and recognition in event materials and from the podium.

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Contributor – $500 to $2,499 (or equivalent support)

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

2024 Contributors

Location & Accommodations (Book by Feb. 21)

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. 

Awards

The Leo Weston Award for Excellence in Government Service

First bestowed on Leo Weston himself in 2005, the Weston award honors an instrumental figure in ARSA's birth by recognizing individuals who embody his commitment to the industry's safety and success. The symposium provides a venue for association members and invited guests from around the world to network and discuss issues that matter to the aviation maintenance industry. It is the perfect time to respect the history of the repair station community and honor the good works of those who support it.

Click here to learn more about Leo, the award bearing his name, and those who have received it.

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The Legislative Leadership Award

The association regularly recognizes members of Congress who have provided outstanding support to the aviation maintenance community by supporting policies beneficial to the industry. Honorees have each been key in moving forward specific legislation advancing priorities championed by ARSA on behalf of its members.

Click here to see past updates regarding Legislative Leadership Award recipients.

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The "Golden Shovel" Award

From time to time, ARSA recognizes individuals – usually at the time of their retirement – who have spent their careers in steadfast devotion to good business, good safety, and good oversight. In the colorful illustration of Executive Director Sarah MacLeod, these professionals have spent their lives shoveling against the tide of government bureaucracy; their achievement in never giving up is acknowledged through the "Golden Shovel Award."

Click here to learn more about the "Shovel" and see who has received it.

Looking Back at 2024 (Photos & Recordings)

Considering attending in 2025 and want to get a sense of the experience? Feeling nostalgic for last year's event? A few ways to look back at 2024...

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.

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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.

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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.

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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.

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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.

Quick Question – Foreign Validations

Bilateral aviation safety agreements (BASAs) are meant to improve international regulatory coordination. Reaching that goal – elusive as it is – requires constant attention to the realities of how civil aviation authorities actually interact and what those interactions mean for certificate or approval holders.

In September, the U.S. Government Accountability Office (GAO) sought assistance from ARSA regarding the processes used by the FAA and foreign CAAs to validate imported aviation articles. The association now seeks input from membership via this month’s “quick question,” about broad experiences with foreign oversight of approvals and certificates.

Though ARSA represents international entities across the world, for the purposes of these questions “foreign” means outside the United States:

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/qq-foreignvalidations.

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

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
AirMed International, Inc., R01
Evans Composites, Inc., R03
Hayes Aviation, LLC dba Hayes Aviation RS, R01
Intermountain Helicopter, Inc., Assoc

Renewed Members
Aero Instruments & Avionics, Inc., R04, 1991
Aerospace Turbine Rotables, Inc., R04, 2011
AerSale Goodyear Aircraft Operations Center, R04, 2015
Air Cargo Equipment, Inc., R01, 2010
Air Technology Engines, Inc., R03, 2006
Aircraft Ducting Repair, Inc., R03, 2002
Aircraft Lighting International, Inc., R01, 2018
Airforce Turbine Service, Ltd., R02, 2010
Airfrance Industries-KLM Engineering & Maintenance, Assoc, 2010
Ameron Global Product Support, R02, 2004
Aviation Blade Services Inc., R02, 2018
The Boeing Company, Corp, 1996
Citadel Completions LLC, R04, 2018
Curtiss-Wright Actuation Systems, R03, 2003
Empire Airlines, Inc. dba  Empire Aerospace, R03, 2002
Engine Disassembly Services, Inc. dba Engine Overhaul Services, R01, 2018
First Aviation Services, Inc., Assoc, 2018
Gateway Alliance Co. dba Affinity Aeronautical Solutions, LLC, R02, 2018
JET Aircraft Maintenance, Inc., R04, 2010
Mach II Maintenance Corp., R04, 2018
Midway Aircraft Instrument Corporation dba Midway Aerospace, R02, 2004
Offshore Helicopter Support Services, Inc. dba DART Aerospace, R02, 2019
Pearl River Community College, Edu, 2020
PPG Industries Inc.-dba PPG Aerospace Transparencies, R02, 2005
PT. Wira Jasa Angkasa , R03, 2021
Raytheon Technologies Corporation, Corp, 1997
Schaeffler Aerospace USA Corporation, R02, 2012
Sherwood Avionics & Accessories, Inc. dba Sherwood Aviation, R04, 2021
Tech-Aire Instruments, Inc., R01, 2012
Thomas Global Systems, LLC, R02, 2012
Turbine Weld Industries, LLC, R03, 2020
Turbines, Inc., R02, 2017

A Member Asked…

Q: In reviewing § 120.215 of covered employees. It is not clear to me if someone performing the receiving inspection function must be tested under the D&A program.

Does the person performing this function need to be in the D&A program? These individuals work for our parent company in a similar role; however, it is for distribution only. We are training and adding them to our inspection roster for this function only.

A: In 2017, ARSA requested and received a legal interpretation confirming persons that merely receive parts to be stocked or installed are not performing maintenance or preventive maintenance, and therefore should not (indeed, cannot) be in the safety-sensitive pool.

As you can see, the interpretation is limited to those persons that are NOT performing other tasks that would place them in the safety-sensitive category. Maintenance tasks are normally performed on articles received for maintenance, not on articles that will be used in maintenance activities. Similarly, persons that only perform calibration of equipment used in maintenance are not to be in the D&A pool because they are not performing maintenance as that term is defined in section 1.1 of the regulations and applied under 14 CFR part 43.

A thorough review can also be found in the following training (which is part of ARSA’s online series on drug and alcohol testing):

D&A Testing – Safety Sensitive Functions

This session covers “performance” of “safety-sensitive functions” in a repair station that is subject to 14 CFR part 120, Drug and Alcohol Testing Program. It focuses on the regulatory definitions of those activities and how they should be integrated into the repair station’s quality system and business practices. It also provides guidance on when tested employees should be removed or remain in the random testing pool.

Click here to register and get access for 90 days.

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.

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 News Roundup

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

Industry Calendar

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

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