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2023 – Edition 7 – August 4

the hotline 1984


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 Briefs
ARSA on the Hill

Aviation Life Calendar
Training & Career Development 
Membership
Resources
Industry Calendar


The President’s Desk

Nothing New

While the U.S. House of Representatives’ bill to reauthorize the FAA is a major step towards advancing policy fostered by ARSA, there’s a long way to go until the “Securing Growth and Robust Leadership in American Aviation Act” becomes law. The Senate is yet to act on its version, and there are considerable differences between the policymaking perspectives of the two chambers. The law eventually signed by the president will likely have a new tongue twisting name.

None of this is new. Big authorization laws require a lot of haggling between the chambers before they are ready for enactment.

What is also old news is ARSA’s outsized impact on the process. As reported by Executive Vice President Christian Klein, the House Bill directs the FAA to improve consistency in regulatory application, handle petitions with more transparency, establish time limits for investigations, and increase funding for marquee workforce grant programs, among the many things ARSA’s work provides its membership.

One of the provisions in the House bill has been a central focus of ARSA’s advocacy for decades: a directive to the FAA to task the Aviation Rulemaking Advisory Committee with identifying ways to improve access to instructions for continued airworthiness (ICA). It’s imperative to find practical ways of ensuring the best maintenance information is available when needed by those given the responsibly for continued airworthiness.

What Congress is asking the FAA to do is also nothing new. It is the same reason ARAC is investigating the value of repairman certificates. The body is a venue for all stakeholders to investigate and recommend regulatory actions that have a minimum impact on commercial issues, like the protection of intellectual property.

The inclusion of these priorities is a direct result of the years ARSA’s team and engaged members spent educating elected officials. By participating in Legislative Day, responding to calls to action, hosting facility visits, and being proactive local constituents, ARSA has given the international maintenance industry a real voice in American lawmaking.

While nothing may be new, the players are, so there is work to be done. Whether Congress completes its work before the Sept. 30 expiration of the FAA law or needs short term extensions, ARSA will bird-dog the process to the end (and beyond).

Become part of the work through arsa.org/legislative.

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

 


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ARSA Works

What ARSA Has Done Lately – Second Quarter 2023

Each quarter the board of directors receives reports on the association’s activities and fiscal health. Step into a board member’s shoes with this overview of the financial, operations, legislative and regulatory reports highlighting advocacy on behalf of aviation safety 2023’s second quarter.

Fiscal Health

Revenues and expenses are on target. New methods for tracking cash against budget are helping team bolster non-member revenue and accurately project income for member renewals on a monthly basis.

Membership

New member applications outpaced lapsed memberships and retention for the quarter was 91 percent. The association’s retention procedures engage lapsed member contacts for three months after the membership term. One lapsed member has already been continued in good standing.

Regulatory Advocacy

Reported on—

  • The Government Accountability Office (GAO) report on “Current and Future Availability of Airline Pilots and Aircraft Mechanics.”
  • Presenting at FAA/EASA International Safety Conference.
  • Attending EASA Engineering & Maintenance Technical Committee (EM.TEC) meeting.
  • Leading effort through Maintenance Management Team (MMT) Industry Group to coordinate digitization issues.
  • Presenting at the FAA Office of International Affairs International Knowledge Exchange meeting.
  • Serving – through management firm – on Organization Designation Authorizations (ODA) for Transport Airplanes Expert Review Panel.
  • Continuing alignment of regulations in part 145 with associated guidance through previously-convened working group.

Legislative and Lobbying

  • House FAA reauthorization bill (Securing Growth and Robust Leadership in American Aviation Act (H.R. 3935) includes the following provisions based on ARSA’s regulatory and workforce recommendations:
    • 516 requires the FAA administrator to task the Aviation Rulemaking Advisory Committee (ARAC) to identify ways to improve access to instructions for continued airworthiness (ICA).
    • 252 directs the U.S. Department of Transportation’s Inspector General to audit the Flight Standards and Certification Services regarding the consistency and application of guidance and regulations, a persistent industry concern.
    • 253 directs the FAA administrator to ensure consistency in oversight through audits, more frequent updates to guidance and rules, and better documentation of findings and decisions.
    • 122 creates the new position of FAA assistant administrator for rulemaking and regulatory improvement, who is charged with, among other things, improving transparency and responsiveness relating to the agency’s handling of petitions for rulemaking and exemptions.
    • 517 requires the agency to issue or update guidance to clarify the conditions under which a major alteration requires a supplemental type certificate.
    • 208 requires FAA investigations to be completed within two years of issuance of a letter of investigation (LOI).
    • 502 encourages the agency to pursue cooperation more aggressively with other civil aviation authorities.
    • 301 reauthorizes, triples funding for, and improves the aviation workforce grant programs created by ARSA’s efforts in 2018 (and creates a similar new grant program for the aviation manufacturing workforce).
    • 303 creates a new National Center for the Advancement of Aerospace to coordinate workforce development activities among industry, academia, and other stakeholders.
    • 311 establishes an interagency working group to improve transition from military to aviation technician careers.
    • 312 establishes a working group to examine airman knowledge testing to create new opportunities for high school graduates in the maintenance industry.
  • 505 incorporates language that passed the House in a standalone bill last fall targeting foreign repair stations. The legislation is less disruptive than legislation introduced in the last Congress.
  • Worked with office of Senator James Lankford (R-Ok.) to develop repair station certification process improvement bill.

Communications and Surveys

ARSA in the News – Selected Industry Coverage

FAA Seeks Input On Repair Station Safety Management System Mandate

April 3, 2023 | Aviation Week

The FAA’s SMS rollout has come with voluntary programs that many companies adopted in advance of mandates. According to the agency, 72 repair stations have SMS, and 19 are recognized by the FAA as being “fully functioning,” Acting Administrator Billy Nolen said at the Aeronautical Repair Station Association (ARSA) annual conference in March.

New Bill Could Curtail Offshoring U.S. Aircraft Maintenance

May 8, 2023 | Aviation Week

Christian Klein, executive vice president of the Aeronautical Repair Station Association (ARSA), sees the bill as an expensive and wasteful “solution in search of a problem.” Klein believes the bill would unnecessarily divert resources from an already stretched FAA and could create additional problems.

3 Ways to Jump-start Networking in Aircraft Maintenance

June 1, 2023 | Flying Magazine

Although technically for MRO businesses, the Aeronautical Repair Station Association is an excellent resource for anyone in the aviation business, maintenance or otherwise.

ARSA-placed Industry Editorials and Content

AMT Magazine Unbreakable Optimism
May/June | Brett Levanto
Varied Perspectives Needed to Solve MRO Workforce Shortages
April | Brett Levanto
Aviation Week Regulatory Compliance Is a Matter of Reading Comprehension
May | Brett Levanto
EASA’s Paperwork Obstinacy Amplifies Supply Chain Woes
June | Marshall Filler, Sarah MacLeod, & Christian Klein
Choosing our Words and Our People
April | Brett Levanto
DOM Magazine Bilateral Disorder
May | Brett Levanto
Primary Responsibility
June | Josh Krotec

Bringing Advertising In-house

  • Sales – Two renewals of existing advertisers
  • Working with one active lead & one upcoming renewal (see ARSA’s advertising options).
  • Creative – ARSA-produced placements in both Newsletter Leaderboard and Web Box.
  • Administration – Exploring expanded/unique value ARSA can offer advertisers, e.g., training sponsorships. See June hotline.

Surveys

Quick Questions:

Events, Meetings and Training

Events

  • Planning Fall Leadership Roundtables and Annual Board Meeting.
  • Contracts signed with Ritz-Carlton for 2025-2027 ARSA Annual Conference. Scheduled dates:
    • March 12-15, 2024
    • March 18-21, 2025
    • March 17-20, 2026
    • March 9-12, 2027

External Meetings

  • Sarah held recurring meetings regarding the Part 145 Working Group (and AMC development), the Repairman Portability Working Group, and engagement with both FAA Flight Standards and Aircraft Certification Services.
  • Christian had multiple meetings regarding the MMT Digitization Working Group.
  • Christian attended multiple meetings related to TSA Aviation Security Advisory Committee service.
  • Christian and Brett held monthly collaboration calls with Oliver Wyman.
  • Christian met with James Longley and JR Jezierski of Senator Capito’s office regarding foreign repair stations (Apr 12).
  • Christian spoke with Henry Canaday of Aviation Week regarding foreign repair stations and the FAA reauthorization (Apr 13).
  • Christian had a call to discuss workforce-related legislative policy with Drew Jacoby Lemos from RAA (Apr 13).
  • Brett met with Aaron Ward of AEA to review the exchange agreement between ARSA and AEA and discuss issues related to rollout of SMS program access for ARSA members (Apr 14).
  • Christian and Marshall had lunch with Ludovic Aron of EASA (Apr 19).
  • Christian and Brett met with Caitlin Davis regarding industry opportunities for developing apprenticeship programs (Apr 19).
  • Brett listened in on the House Aviation Subcommittee hearing related to aviation workforce and career development challenges (Apr 20).
  • Christian had an update call regarding workforce development policy with allied organizations including ATEC and AMFA (Apr 24).
  • Christian spoke with Tracee Sutton of Rep. Stanton office regarding FAA reauthorization issues (Apr 27).
  • Christian met with Andrew Giacini from the House Aviation Subcommittee regarding STC language (May 1).
  • Christian spoke with GAMA and AIA-Aerospace regarding foreign repair station bills (May 9)
  • Christian and Marshall met with Patrick Ky, Luc Tytgat and Ludovic Aron of EASA (May 10).
  • Christian met with Kenneth Coleman of Sen. Tim Scott’s office regarding aviation workforce legislation (May 10).
  • Christian met with Rep. Garrett Graves regarding aviation workforce legislation (May 11).
  • Brett attended the Women in Aviation Capital Region Outreach Summit (May 12).
  • Christian had a Military Transition Coordinating call with AMFA and AAR (May 16).
  • Christian met with Crystal Maguire of ATEC regarding aviation career interest for high school girls (May 17).
  • Christian and Brett participated in a quarterly meeting of close allies including ATEC to discuss workforce policy updates with the FAA (May 18).
  • Christian held an FAA Workforce Reauthorization meeting with AAR, AMFA, ATEC and AIA (May 25).
  • Christian met with EASA to plan for his presentation at the FAA/EASA International Safety Conference (Jun 7).
  • Brett traveled to Miami to present at a luncheon of the Greater Miami Aviation Association (Jun 8).
  • Brett visited FEAM Aero in Miami (Jun 8).
  • Christian traveled to Cologne to present at the FAA/EASA International Safety Conference and EASA EM.TEC meeting (Jun 9-17).
  • Sarah and Brett met with Curt Devine of CNN to provide background on service difficulty reports and other issues (Jun 13).
  • Christian and Brett met with Caitlin Davis of Virginia Manufacturing and Chris Pierson of AJAC regarding sponsored apprenticeships (Jun 13).
  • Brett attended a reception hosted by Lufthansa Group Executive Board (Jun 13).
  • Sarah and Brett met with multiple contacts from Boeing Global Services about repair station service on military derivative aircraft (Jun 20).
  • Christian met with Theresa Jeffrey of Sen. Lankford’s office regarding the repair station bill (Jun 21).
  • Brett, and Christian attended the HAI reception in Alexandria, VA (Jun 27).
  • Christian had an introductory meeting with Bobby Weitzel of the Airline Service Providers Association (Jun 30) to discuss SIDA enhancement opportunities.

Strategic Work Plan

  • 2023 Q2 Objectives:
  • 2023 Q3 Objectives:
    • Continue releasing live training classes.
    • Support enactment of FAA reauthorization legislation.
    • Complete updated management agreement.
    • Host executive team leadership retreat.
    • Begin 2024 Conference planning.
    • Manage 2023-24 officer recruitment and nomination process for directors with expiring terms and to replace Warner Calvo’s who retired from Coopesa after 38 years necessitating his resignation from ARSA’s board where he had represented international interests since 2013.

 


A4A Invites ARSA Members to NDT Forum

On Sept. 18, Airlines for America will convene its 2023 Non-Destructive Testing Forum in Denver Colorado. A4A is specifically focused on boosting repair station participation in the four-day event.

The A4A NDT Forum is a venue for airline professionals and service providers to discuss current issues related to NDT methodologies and advancements. The forum draws participants from a wide variety of sources, including equipment designers, technicians, vendors, regulatory authorities, and maintenance personnel in addition to airline leaders. The event features:

  • Technical presentations by leading NDT researchers and users.
  • Exhibition space showcasing new NDT technology.
  • Opportunity to earn ASNT Level III credit.

The forum will feature a panel discussion on maintenance issues. Presenters will explore topics including OEM/operator support, regulatory issues, standards, training, and emerging trends in the repair station environment.

For information and registration, visit a4andtforum.com.

 

 


FAA Workforce Grant Applications Open

On July 17, the FAA opened applications for its next round of funding available through two aviation workforce grant programs championed by ARSA during the 2018 reauthorization of the agency by Congress. The association has remained an ardent supporter of the programs it helped create; boosting available funds is a key priority for this year’s reauthorization cycle. While lawmakers consider ways to expand grant resources, members should investigate application options for currently available funds.

The Aircraft Pilots Workforce Development Grants fund programs that educate students to become pilots, aerospace engineers or unmanned aircraft systems operators. The Aviation Maintenance Technical Workers Workforce Development Grants fund programs that prepare people to be aviation maintenance technicians. Representatives of eligible organizations can submit applications at www.grants.gov through August 16. 
 
Eligible organizations can apply for grants of up to $500,000 for each grant per fiscal year. Last year the FAA awarded $10 million in grants to more than 20 schools and organizations. 
 
The Notice of Funding Opportunity for each grant provides detailed information on eligibility, deadlines, evaluation criteria and application procedures. To ensure fair and open competition for the grants, answers to frequently asked questions will be posted on the FAA website.  
 
Potential applicants should visit the site to review answers to frequently asked questions, eligibility requirements, and guidelines that may assist them in completing their grant application. 

To see ARSA’s previous efforts related to the grant programs, visit arsa.org/grant-program. See the program’s future by reviewing the current status of legislative effort to reauthorize the FAA in this month’s “ARSA on the Hill“.

 


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.

Click here to access a PDF copy of the list.

 


 

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Legal Briefs

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.

Creating ICAO

By Christian A. Klein, Executive Vice President 

Last month’s “Legal Brief” reviewed the adoption of the Convention on International Civil Aviation (“the Chicago Convention” or “Convention”), which provides the legal framework for international air navigation and government oversight. This month we describe how the treaty gave birth to the International Civil Aviation Organization (ICAO) and its constituent bodies.

Part II of the Chicago Convention declares ICAO to be made up of an Assembly, a Council, and “such other bodies as may be necessary.” ICAO’s aims and objectives (set forth in Article 44) are to:

  • Ensure the safe and orderly growth of international civil aviation throughout the world.
  • Encourage the arts of aircraft design and operation for peaceful purposes.
  • Encourage the development of airways, airports, and air navigation facilities for international civil aviation.
  • Prevent economic waste caused by unreasonable competition.
  • Ensure that the rights of contracting states are fully respected and that every state that is a party to the convention has a fair opportunity to operate international airlines.
  • Avoid discrimination between contracting states.
  • Promote safety of flight in international air navigation.
  • Promote generally the development of all aspects of international civil aeronautics.

Chapter VIII defines the operations of the ICAO Assembly, in which all “contracting states” (i.e., those countries that have ratified the Chicago Convention) are entitled to one vote and in which the decisions are made by majority vote. Among other things, the Assembly is empowered to:

  • Elect its president and other officers.
  • Elect the contracting states to be represented on the ICAO Council (see below).
  • Examine and take action on reports from the Council and decide matters referred by the Council.
  • Establish rules of procedure and subsidiary commissions it deems necessary.
  • Approve ICAO’s annual budget.
  • Refer matters to the Council and other ICAO bodies,
  • Enter into agreements with international organizations committed to world peace (e.g., the United Nations (UN)).
  • Consider and make amendments to the Chicago Convention by a two-thirds vote.

Article 48 originally provided that the Assembly would meet every year; however, in 1962 the Convention was amended to require meetings “not less than once in three years”, driving today’s triennial schedule.

Chapter IX creates the Council, a permanent body composed of representatives from 21 contracting states elected by the Assembly every three years. The Convention requires the Assembly to ensure the Council represents:

  • States of chief importance in air transportation.
  • States that make the largest contribution to the provision of international air navigation facilities (if they are not otherwise represented).
  • The world’s major geographic regions.

The Council elects a president, who serves for three years, as well as one or more vice presidents. The president convenes Council meetings, represents the Council on ICAO’s Air Transport Committee and Air Navigation Commission and to carries out duties the Council assigns.

While only Council members elected by the Assembly may vote, any contracting state may participate in meetings of the Council and those of its committees.

The Council is charged to:

  • Submit annual reports to the Assembly.
  • Carry out directions of the Assembly and discharge the duties and obligations in the Convention.
  • Appoint and define the duties of the Air Transport Committee.
  • Establish the Air Navigation Committee.
  • Administer ICAO’s finances.
  • Appoint a Secretary General to serve as ICAO’s CEO.
  • Report on infractions by contracting states and failure to carry out Council recommendations and determinations.

Aside from these and other administrative functions, the Council is also responsible for:

  • Requesting, collecting, examining, and publishing “information relating to the advancement of air navigation and the operation of international air services, including information about the costs of operation and particulars of subsidies paid to airlines from public funds.”
  • Adopt international standards and recommended practices via Convention annexes.
  • Consider Air Navigation Commission recommendations for amendments to those annexes.

The Council is also empowered to:

  • Create subordinate transportation commissions on a regional or other basis to facilitate the aims of the Convention.
  • Delegate duties to the Air Navigation Commission.
  • Conduct and communicate the results of research and facilitate information exchanges.
  • Study issues affecting the organization and operation of international air commerce.
  • Investigate and report, at the request of any contracting state, on situations that present avoidable obstacles to the development of international air navigation.

Article 56 creates the Air Navigation Commission, which is composed of 12 members appointed by the Council based on nominations from contracting states. Reflecting the technical nature of the Commission’s work, its members must have “suitable qualifications and experience in the science and practice of aeronautics.” The Commission’s president is also appointed by the Council.

The Commission’s duties are to:

  • Consider, and recommend to the Council, modifications to the Chicago Convention annexes.
  • Establish technical subcommittees.
  • Advise the Council on the gathering and dissemination of information the Commission deems “necessary and useful for the advancement of air navigation.”

In the interest of creating an organization of independent, international public servants, the Convention prohibits the Council President, Secretary General, and other ICAO personnel from seeking or receiving instructions on discharging their duties from any authority external to ICAO (e.g., the governments of their home countries). Each contracting state is bound by the treaty to respect this independence and to not seek to influence its nationals in the performance of their duties as ICAO employees.

Finally, Part Two of the Convention allows ICAO to enter into agreements with “any general organization set up by the nations of the world to preserve world peace” and empowers the Council to enter into agreements with other international bodies for the “maintenance of common services and for common arrangements concerning personnel”. It is via these Convention provisions that ICAO operates as a specialized agency of the United Nations.

Next month “Legal Briefs” will take a closer look at ICAO’s adoption and promotion of common international safety standards and the organization’s other activities.

 



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 – Drowning in ADs

By Brett Levanto, Vice President of Operations

In 2021 and 2022, this layman lawyer exercised his research skills – and ability to use puns in editorial titles – to investigate the FAA’s authority to issue an airworthiness directive against a parachute. This month, the agency re-energized the matter by issuing an AD against a life preserver. 

We’ll get to that, but first some regulatory background. 

The FAA issues ADs under the authority described in 14 CFR part 39. The a “plain language rule” uses a question and answer format to explain the legal framework under which the government issues legally binding rules requiring action to address perceived unsafe conditions in aviation. The scope of this framework is defined in § 39.3:

39.3 Definition of airworthiness directives.

FAA’s airworthiness directives are legally enforceable rules that apply to the following products: aircraft, aircraft engines, propellers, and appliances.

In the exchange regarding parachutes, the question of the FAA’s authority centered on the definitions of each “product” (used in this section separately from…but similarly to…the definition familiar to most aviation maintenance personnel, which applies only to part 21). Could a personally-worn parachute fit the standards of any of those four terms? 

You can review the analysis at arsa.org/parachutead. A parachute could not be included under the regulatory definitions of an aircraft, aircraft engine, propeller, or appliance. The agency pushed back, citing sloppy statutory language in 49 U.S.C. § 40102(11) including “parachute” as an example of an appliance. ARSA’s contention that while some parachute systems could meet each of the three criteria necessary for an item to be an appliance, a personally worn “device used or intended to be used to retard the fall of a body…through the air” (see § 1.1) could not. 

(Can you define “appliance”? ARSA has training for that.) 

The search for clarity in the parachute matter met resistance and eventually disregard from the FAA and Department of Transportation. In July, the agency produced another AD demanding questions over the applicability of part 39, this one against Survitec Group Limited (RFD Beaufort Ltd.) Life Jackets. 

Quickly analyzing “commercial airline lifejackets [providing] passengers and crew with emergency flotation during an aircraft ditching” against the relevant terms in § 39.3, such a device is obviously not an aircraft, aircraft engine, or propeller. This brings us back to the criteria for determining an appliance – such an item must: 

(1) Be used or intended to be used in operating or controlling aircraft in flight. 

(2) Be installed in or attached to aircraft during flight. 

(3) Not be a part of an aircraft, aircraft engine, or propeller. (see § 1.1) 

Clearly a life jacket is not “used or intended to be used in operating or controlling an aircraft in flight.” Also, in the spirit of “fool me once…”, ARSA’s team was sure to check the statutory definition…which includes no examples or references to personal flotation devices. 

As the team prepares to question the agency on the July AD, there are key lessons for members – particularly the many layman lawyers practicing aviation regulatory compliance every day: 

(1) Words matter. ARSA constantly pushes back against the whims of the government and coaches its members to resist the preferences of inspectors when they contradict or are not found in the plain language of the rules. The regulations in 14 CFR define the scope of the FAA’s authority. Even understandable excess – the safety of a parachute or life jacket is important, but importance doesn’t beget regulatory authority – must be curtailed. The duty of a regulated industry is to provide a check against the incursions of its regulator. 

(2) There are no days off from compliance. The FAA issued the NPRM AD in question on April 10 and it first appeared in ARSA’s Daily Intelligence newsletter when posted for public inspection on April 7. This is a painful admission: I missed it – still returning from a family trip to Europe and not attentive to email. Ignorant of the proposal and unable to comment (seeing the AD’s preamble proclaim that no comments of any kind were received is particularly frustrating), ARSA missed an opportunity to press the FAA for official justification of its authority as required by § 11.9’s requirement that: “When preceded by an NPRM, a final rule will also identify significant substantive issues raised by commenters in response to the NPRM and will give the agency’s response.” 

Despite the April oversight, ARSA will engage the FAA on the subject (stay tuned). While it does, follow the lessons above. In particular, ensure your company’s primary contact receives and reads the Daily Intelligence and shares updates from it. 

And…if you ever see an AD issued against anything other than an aircraft, aircraft engine, propeller, or appliance, please email me.

 


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ARSA on the Hill

Authorization Expiration?

The FAA’s operating authority expires on Sept. 30.

The House passed its FAA bill in mid-July, the Senate Commerce, Science, and Transportation (“Commerce”) Committee cancelled a markup earlier this summer amid bipartisan disagreement over modifying pilot training requirements. There’s been no further action on the Senate bill.

Congress is set to return from recess on Sept. 5, giving it four weeks for the Senate to approve a bill, House and Senate committee leaders to negotiate a deal, and the two chambers to approve the conference report. As with past reauthorization cycles, it’s likely Congress will pass one or more short-term extensions to keep the FAA operating.

What can you do?

This month, ARSA President Josh Krotec extolled ARSA’s “outsized impact” on the process so far. By reading the brief overview of the House bill (and viewing the list of provisions provided to the board in “What ARSA Has Done Lately“, you’ll see it includes a number of industry priorities; two staffers even commented on the inclusion of certain language as a result of their attendance at the association’s Legislative Day in March.

As Josh explained, that impact is primarily the result of the persistent work by engaged ARSA members to the maintenance community a voice with American lawmakers. To continue that impact, follow Mr. Krotec’s lead:

(1) Participate in Legislative Day, where association members spend time personally engaging their members of Congress.

(2) Respond to calls for action, which requires reading your ARSA newsletters, visiting the website (particularly the congressional action center, provided by Aircraft Electric Motors, at arsa.org/congress).

(3) Host facility visits and be a proactive local constituent.

(4) Communicate with ARSA about what’s going on in your local district.

 


Want to Learn More About ARSA PAC?

ARSA’s Political Action Committee helps elect congressional candidates who share ARSA’s commitment to better regulation and a strong aviation maintenance sector.   In this critical election year, ARSA PAC has never been more important.  But ARSA is prohibited from sending PAC information to members who haven’t opted in to receive it.

Please take a second to give us prior approval to talk to you about ARSA PAC.  Doing so in no way obligates you to support PAC.  It just opens the lines of communication.

Click here to give ARSA your consent today.


ARSA-Supported FAA Bill Passes House

On July 20, the U.S. House of Representatives overwhelmingly passed the chamber’s bill to reauthorize the FAA: the Securing Growth and Robust Leadership in American Aviation Act (H.R. 3935).

In a letter to House leadership on July 14, ARSA Executive Vice President Christian Klein praised the bill and offered the association’s strong support for its passage. Klein noted H.R. 3935 would continue to build on key priorities for the maintenance community and address challenges facing both the FAA and the industry it regulates. As outlined in the letter, if passed into law the bill would:

  • Improve FAA personnel training, professionalism, and management.
  • Enhance regulatory oversight transparency and consistency.
  • Empower the agency to adjust more rapidly to changing circumstances.
  • Strengthen the agency’s hand in its relationships with other global aviation authorities.
  • Expand efforts already underway to attract a new generation of the technicians to maintain the airworthiness of America’s fleet.

“ARSA is also particularly grateful that the bill addresses the longest standing challenge facing the U.S. maintenance sector: access to Instructions for Continued Airworthiness (i.e., maintenance data),” the letter said.

Despite its general enthusiasm for the bill, ARSA remains on guard against language targeting foreign repair stations. That language has been greatly improved since it was first introduced as a standalone bill by then-T&I Chairman Pete DeFazio in 2019. That previous effort, common to the Oregon Democrat whose policies were generally antagonistic to repair stations, would have imposed considerable burdens on the industry and threatened to punish maintenance providers for FAA inaction on key rulemakings. The provision included in the House bill is much less disruptive, given the maintenance industry’s safety record and the scrutiny foreign repair stations already receive from the FAA, airline customers, and third-party auditors. ARSA continues to believe that the foreign repair station language is a solution in search of a problem.

The legislation had been unanimously approved by the House Transportation & Infrastructure committee on June 14. It now heads to the Senate, which is considering its own FAA reauthorization bill.

To read the bill, click here.

To read ARSA’s letter in support of the bill, click here.

To see a list of key provisions advancing ARSA priorities, read “What ARSA Has Done Lately” in this month’s edition.

 


The Summer Calendar

In June, ARSA President Josh Krotec reminded members the summer is time for engaging with lawmakers their home states and districts. To make good on their presence, it’s important to know how to find your member of Congress. While specifics can be gathered from official websites or by calling the district or state office (using arsa.org/congress, thanks to generous support from ARSA member Aircraft Electric Motors), businesses can plan longer term by looking at the House and Senate calendars.

These plans show when each chamber expects to be in session. While emergencies may require additional time in the capital, Americans can focus on planned recess periods for opportunities to meet their lawmaker (or host them for a facility visit). According to the calendars, these are the weeks designated for homework for the remainder of 2023:

Note: The dates below capture workdays and do not include weeks where only one or two days has been identified for district/state work. For specifics, refer to the House and Senate calendars.

House Senate
Aug. 7-11 Aug. 7-11
Aug. 14-18 Aug. 14-18
Aug. 21-25 Aug. 21-25
Aug. 28-Sept. 1 Aug. 28-Sept. 1
Sept. 5-8 Oct. 10-13
Oct. 2-6 Nov. 20-24
Oct. 10-13 Dec. 18-22
Oct. 30-Nov. 3 Dec. 26-29
Nov. 6-9  
Nov. 20-24  
Dec. 18-22  
Dec. 26-29  

 



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Aviation Life Calendar

August Through November

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.

Month Day Event or Celebration
All All This Day in Aviation
August All This Day in Aviation History – August
August 16 National Airborne Day
August 19 National Aviation Day
August 19 National Aviation Week
August 19 Orville Wright’s Birthday
August 25 Amelia Earhart Flies Coast to Coast – Nonstop
August 30 First African American in Space
September All This Day in Aviation History – September
September 6 Global Talent Acquisition Day
September 15 Hispanic Heritage Month
October All This Day in Aviation History – October
October 4 World Space Week
October 20 International Air Traffic Controller Day
November All This Day in Aviation History – November
November All National Native American Heritage Month
November All National Aviation History Month
November 8 National STEM/STEAM Day

 


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Training & Career Development

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).

Price: One-hour sessions are $75 for ARSA Members and $150 Non-Members. Classes with special pricing are indicated on this page. (Member prices provided to certain associations through reciprocal arrangements. Sessions will often be available at lower prices through bundles, coupons and other special opportunities.)
Government employees: Contact ARSA directly for auditing opportunities.
Registration: Registration and payment may be processed directly through the training platform/course catalog (free account creation required).
Technical questions and assistance: Click here for FAQ and technical support from training platform vendor.
Refunds: No refunds are granted for ARSA training sessions. When classes are canceled, registrants can choose from future courses of equal value. If a registrant is unable to attend a live session, their registration allows access to the on-demand, recorded version of the webinar.
IA Approval: A number of ARSA training sessions have been accepted for Inspection Authorization (IA) renewal credit. These sessions are denoted on their registration page with their FAA course acceptance number (in red).
Benefits: Registration for an ARSA-provided training session includes:
  • Access to the live class session on the scheduled date (if applicable).
  • Unlimited access to the on-demand, recorded version of the webinar to be made available after the live session is complete (or at time of purchase, for on-demand classes).
  • A copy of the presentation and all reference material with links to relevant resources and citations.
  • A certificate* upon completion of the session as well as any required test material.
*Only registered participants are eligible to receive a completion certificate for each session. Certificates are delivered automatically via email after the completion criteria – usually viewing the session and submitting an associated test – are met.
OFM&K Training Portal: All of ARSA's training sessions are provided through OFM&K's training portal. As the training provider of choice for ARSA and a trusted resource for the aviation community, the firm's training materials represent a vital tool for entities pursuing regulatory compliance and business success. All of the courses are administered via PotomacLaw.InreachCE.com, which is not part of ARSA's website.

Complying with Part 145 – “Soup to Nuts” (Four Hours) Instructor: Sarah MacLeod Description: Specially recorded with a hand-picked audience for interactive discussion, this session thoroughly reviews 14 CFR part 145, discusses the application of the rule and overviews some practical implications of obtaining and maintaining a repair station certificate. Pricing Note: This is a four-hour session and is $300 for members and $600 for non-members. Click here to register and get access for 90 days.

Sessions Accepted for IA Renewal Credit Eight of ARSA's on-demand training sessions have been accepted by the FAA for Inspection Authorization renewal credit under 14 CFR § 65.93. Each session is currently available for registration and immediate access:Click here to purchase all eight sessions (plus one required prerequisite) at a “bundled” discount – let ARSA take care of your IA renewal requirements this year. Click here to purchase all eight sessions (plus one required prerequisite) at a “bundled” discount.

The following general subject areas are covered by sessions currently available in ARSA's training library. Search these and other topics directly via the online training portal (click here to get started).

Aircraft Parts


Audit Activism & Prophylactic Lawyering


Drug & Alcohol Testing


Human Factors


Instructions for Continued Airworthiness


Parts 21, 43, 65, 145 (and others)


Public Aircraft"Going Global" - International Regulatory Law


Grassroots Advocacy


Recordkeeping – "Finishing the Job with Proper Paperwork"


The Fourth Branch of Government (Administrative Agencies and Procedures)


Self Disclosure Programs and Practices

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

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


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


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

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

The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFMK’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.

 


Still on Sale – Part 91 Subpart Walkthrough

On Aug. 30, ARSA Executive Vice President Christian Klein will continue his exploration of 14 CFR part 91 (three sessions already on demand, see below). The series provides useful overview for anyone in aviation and basic competency in the general operating rules for aircraft under the FAA’s jurisdiction.

Flash Sale – ARSA is offering 50 percent off registration for each session in the series. The discount will be automatically applied at checkout and is available until the beginning of the next live session on Aug. 30.

Live Training Session in August

Part 91 – Subpart B

August 30 @ 11:00 a.m.

This session reviews the rules in 14 CFR part 91 subpart B, which define basic procedures and requirements related to flight of aircraft subject to the jurisdiction of the U.S. aviation safety rules.

Click here for more information and to register.

Training Sessions Available On Demand

Registration allows for unlimited viewing of the recorded session for 90 days.

Part 91 Overview

This session overviews the general operating rules of 14 CFR part 91. It reviews the structure of the part and its subparts and describes their applicability to persons operating aircraft within the U.S. national airspace system.

Click here for more information and to register.

Part 91 – Compensation or Hire

This session explores the details of the general operating rules in 14 CFR part 91 impacting operations performed for compensation or hire. It highlights the elements of the rule governing such operations and identifies relevant other areas in 14 CFR.

Click here for more information and to register.

Part 91 – Subpart A

This session reviews the rules in 14 CFR part 91 subpart A, which set general standards for operations and flight of aircraft subject to the jurisdiction of the U.S. aviation safety rules. It discusses part 91’s applicability, pilot in command responsibilities, and rules and restrictions applicable to the operation of U.S. registered civil aircraft.

Click here for more information and to register.

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.

 


Part 43 “In Depth” Short Training Series

ARSA Vice President of Operations Brett Levanto (with support from Executive Director Sarah MacLeod) is building on ARSA’s existing training covering 14 CFR part 43 by running an “in depth” series exploring specific elements of the maintenance rule. The first two 15 minute sessions are available on demand, with live sessions resuming in August.

Click here to see bundled pricing options for the currently available sessions covering part 43 (tiered savings up to 50% off the total registration cost for all sessions).

Part 43 In Depth: Non-applicability (§ 43.1(b)) (15 Minutes)

August 15, 2023 @ 11:00 a.m.

This session focuses on the applicability of 14 CFR part 43, Maintenance, Preventive Maintenance, Rebuilding and Alteration. It highlights the points of “non-applicability” explained in § 43.1(b).

Click here for more information and to register.

Part 43 In Depth: Life Limited Parts (§§ 43.1(c) & 43.10)

August 16, 2023 @ 11:00 a.m.

This session focuses on the applicability of 14 CFR part 43, Maintenance, Preventive Maintenance, Rebuilding and Alteration. It highlights the responsibilities related to life limited parts created by § 43.1(c).

Click here for more information and to register.

Part 43 In Depth: Performance Rules

On Demand

This session focuses on the performance rules of 14 CFR part 43, Maintenance, Preventive Maintenance, Rebuilding and Alteration. It reviews each paragraph of § 43.13 and describes the reading process maintenance providers should follow when meeting the minimum standards of the rule.

Click here for more information and to register for on-demand viewing.

Part 43 In Depth: Applicability

On Demand

This session focuses on the applicability of 14 CFR part 43, Maintenance, Preventive Maintenance, Rebuilding and Alteration. It reviews each paragraph of § 43.1 and highlights the related regulations and definitions impacting its meaning.

Click here for more information and to register for on-demand viewing.

ARSA will continue its series exploring elements related to part 43, including both 15 minute and hour-long sessions and varying levels of instruction. Stay tuned for additional sessions.

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.

 


Going Global Again – International History & Context

Note: Schedule changes made since initial hotline distribution.

Going Global – International Obligations

Wednesday, August 30 @ 11am

This session provides history and context for international aviation safety regulations. It explains the background to the Chicago Convention, the establishment and authority of the International Civil Aviation Organization (ICAO) to set the standards and responsibilities of civil aviation authorities.

Click here for more information and to register.

Going Global – European Enlightenment

Tuesday, September 12 @ 11am

This session provides the history behind the bilateral airworthiness agreements (BAA) and bilateral aviation safety agreements (BASAs) between the United States and European nations. Provides the background to the development of the European Union Aviation Safety Agency (EASA) through the Joint Aviation Authorities (JAA). It explains how implementation procedures for design and production are negotiated separately from implementation procedures for maintenance.

Click here for more information and to register.

To view ARSA’s two existing “global” sessions, visit arsa.org/goingglobal.

Bundle pricing available, click here to learn more.

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.

 


The Magic Form – Exploring the 8130-3

Note: Schedule changes made since initial hotline distribution.

FAA Form 8130-3 – Overview & History

Wednesday, September 27 @ 11am

This session reviews the history of the FAA Form 8130-3, Authorized Release Certificate, to its beginning as an export airworthiness approval, putting into context its evolution from an export document to its current usage.

Click here for more information and to register.

FAA Form 8130-3 – Completion Instructions & Multiple Releases

Wednesday, October 18 @ 11am

This session walks through the steps for completing the FAA Form 8130-3, Authorized Release Certificate, Airworthiness Approval Tag. The training uses instructions developed as part of ARSA’s RSQM Compilation and focuses on language used for work to be issued a release under the regulations of multiple civil aviation authorities including a “dual release” under the U.S./EU bilateral agreement.

Click here for more information and to register.

Bundle pricing available, click here to learn more.

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 § 21.2, Falsification of applications, reports, or records.

Click here to download the training sheet.

 


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Membership

Advertising Update – Getting Technical

Since taking over control of its periodical distribution and advertising sales last November, ARSA’s communications team has been slowly building procedures and capabilities. New newsletter templates are in place, contact lists are clean, ad content options and contract details are available, new sales are being made, and the team is having fun developing its own content and enticements to advertise.

A key focus of July was enhancing the association’s technical capabilities related to add click-through tracking. Providing useful feedback regarding ad performance is a supplement to the value already inherent in a company’s support for ARSA.

Each ad – image and text – on ARSA.org and in all three periodicals (the Daily Intelligence, Dispatch, and the hotline) now provides performance metrics back to the ARSA team. Advertisers receive simplified updates regarding the performance of their ads as part of the total viewership produced each month.

This technical functionality is useful in demonstrating value of advertising through the association. However, the system does not gather information about the users clicking on the ads, nor does it utilize cookies; it just provides useful feedback for advertisers (and the association) without impacting the privacy of readers.

Learn more about the advertising program at arsa.org/advertising.

Not interested in advertising? Don’t forget to send your news releases and other media information to arsa@arsa.org and share some useful feedback in this month’s “quick question.”

 


Live Free (of Membership Dues)

Using your voice to further ARSA’s reach can earn you discounted…even free…dues for the following year.

“Member Getting Member” Program rules:

  • For each paid membership referral, the referring member will receive on its forthcoming membership renewal a credit equal to 10 percent of the new member’s dues. For example, if an $1,800 member is referred, you will receive a credit of $180 towards your company’s next membership renewal.
  • The maximum benefit is 100% of a referring member’s annual membership dues.
  • The applicant must clearly indicate on its application or in its submission for membership, the name of the member company that referred it for membership (it doesn’t hurt for you to give the membership team a heads up ahead of time, email arsa@arsa.org).
ARSA-FlyingLogo-20140910

Click here to download a draft message you can use to begin recruiting new ARSA members.

Use the Members Getting Members Toolkit to become free of membership dues.

Become a Champion

A great way to recruit members is to promote the association actively at industry meetings and trade shows. Champions display ARSA-provided materials at their company exhibit booths.

Interested? Contact ARSA.

 


Quick Question – Advertising

ARSA continues its successful rollout of new advertising opportunities. In the first year since the board of directors approved the “big takeover” of the association’s periodical distribution and advertising sales, the team has stood up new procedures and has signed its first cadre of new contracts.

“Advertising with ARSA is about more than just selling; it demonstrates belief in quality and safety, a commitment to commonsense compliance, and intelligent business acumen,” Association President Josh Krotec said in the June 2023 hotline newsletter. “When you see a company in the pages of a periodical like the hotline or on ARSA.org, you know more than just what they sell…you see who they are.”

All members should review the options available by visiting arsa.org/advertising. Even those who don’t think the association is the right venue for their ads can help by providing feedback via this month’s “quick question”:

Note: The question is displayed in its own, embedded window. If the “Submit” button is not visible on the screen, you must scroll within the survey window to submit your response.

If the embedded survey does not appear/load, open the survey independently by visiting: https://www.surveymonkey.com/r/ARSAAdvertising.

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 July:

New Members
Airborne Aviation Hawaii, R01
Alpha-Tech Aviation Services, Inc., R02
Little Wolf Consulting, LLC, Affil
Marana Aerospace Solutions, Inc. dba Ascent Aviation Services, R06
Thrust Tech Accessories Inc., R03

Renewed Members
Aero Design Services, Inc., Affil, 2000
Aerospace Engineering Group, S.L., R03, 2014
Aerotron AirPower, Inc. dba Fokker Services Americas, R04, 1990
Airbus Americas, Inc., Assoc, 1995
Air Cargo Equipment, Inc., R01, 2010
Aircraft Ducting Repair, Inc., R03, 2002
Aircraft Specialties, Inc., R03, 2019
AllFlight Corporation, R03, 2011
Ametek Ameron, LLC dba Ameron Global Product Support, R01, 1989
Atlantic Cape Community College, Edu, 2022
Aviation Repair Resources, Inc. (ARR), R02, 2009
Bemidji Aviation Services, Inc., R03, 2017
Boeing Company, Corp., 1996
Cosgrove Aircraft Services, Inc., R01, 2021
Eagle Creek Aviation Services, Inc., R04, 2016
E.U.A. Air Support, Inc., R01, 2003
EXTEX Engineered Products, Inc., Assoc, 2002
F&E Aircraft Maintenance (Miami) L.L.C , R06, 2012
General MRO Aerospace, Inc., R03, 2015
Jet Center MFR dba Southern Oregon Skyways, R02, 2006
MTI Aviation, Inc., R02, 2011
Nampa Valley Helicopters, Inc., R02, 1993
Paz Aviation, Inc., R02, 2016
R.W. Raddatz, Inc., R03, 2004
Raytheon Technologies Corporation, Corp., 1997
Southern Air Repair, Corp., R01, 2016
Southwest Airmotive Corp., R01, 2012
Tennessee Aircraft Company, Inc., R01, 2012
Texas Air Services, Inc., R02, 2003
Zee Company, Inc., R02, 2019
Warner Propeller and Governor Co., LLC, R02, 2010

 


A Member Asked…

Q: Can you create an article or memo in plain language that explains the RS-DER and their approval of major repair specifications for the benefit of the aerospace community and promote it worldwide? Every now and then we are asked and must explain to a foreign company what DER-approved repairs are and that they are FAA approved.

A: Under the United States aviation safety regulations, when a repair or restoration action results in or will result in a major repair, the “technical data” supporting the action must be approved by the FAA. The FAA has the authority to delegate a “finding of compliance” to another “person,” such as an individual engineer or a company. The FAA administers its delegations under 14 CFR part 183, and internal directives, such as Orders 8100.8, 8100.15, 8110.37.

Order 8110.37 is “a handbook of procedures, technical guidelines, limitations of authority, and tools and resources for designated engineering representatives (DERs). It was written for all DERs and the FAA staff who manage them.” Delegations to engineers and to engineering companies are based upon knowledge, experience, continued education, and other information required by the agency to establish the authority delegated.

With respect to actions that will result in major repairs, Order 8110.37, revision F makes it clear that an approval issued by a duly authorized designated engineering representative is an FAA approval.

4. DER Authorities.

a. DER approval. It is the applicant’s responsibility to show that engineering data will demonstrate their design complies with applicable airworthiness requirements. When a DER finds the engineering data shows compliance to those requirements it is referred to as a DER approval. * * * For repairs and alterations a specially delegated DER can approve some or all of the technical data intended to be used for a major repair or major alteration.

b. DERs may approve or recommend approval of engineering technical data within the limits of their authority by means of FAA Form 8110-3 where delegated. (Revision F, page 2-2, August 31, 2017.)

7. DER Special Delegations/Special Authorizations/Specific Functions.

a. Special Delegations. A DER may be appointed to approve technical data not specifically listed in the charts of appendix A. Each engineering delegation has an authorized area of “special”, with authorized functions to cover this contingency. When the FAA authorizes a special delegation, the FAA lists the “special” authorized area and specifically defines the function. A DER must have significant experience in the appropriate area in order to be given a special delegation. The following “Special” delegations may be granted:

* * *

(2) Major Repairs and/or Major Alterations.

(a) A DER requires a special delegation to examine and approve data for major alterations and/or major repairs. The FAA may assign a DER the special delegation of Special – Major Repairs and/or Special – Major Alterations. A DER with these delegations may only make findings of compliance within their existing delegation. DER’s need this delegation only if their FAA Form 8110-3 will be referenced as the approval of the engineering data for a specific major repair or major alteration. The three (3) special delegations for major repairs and/or major alterations are:

1. Special – Major Repairs.

2. Special – Major Alterations.

3. Special – Major Repairs and Major Alterations.

Note 1: Service documents and overhaul manuals produced by the original design/Production Approval Holder (PAH) are not considered major repair or major alteration data requiring this special delegation.

Note 2: Before the DER may be granted a special delegation for Major Repairs and/or Major Alterations, the on-line training course must be satisfactorily completed. The course can be found at https://av-info.faa.gov/DsgReg.

Note 3: DERs granted a special delegation for major repairs may also be specifically authorized for multiple-use, non-serial number specific repair data in support of repair specification approval.

Note 4: DERs exercising their authority for major alterations may only approve data consistent with the category of alterations according to FAA Order 8300.16(). The DER does not require the special delegation for alterations in order to approve data in support of a Supplemental Type Certificate (STC) or TC amendment that will result in an alteration.

(b) Special Delegation for Major Repairs and/or Major Alterations for Vintage Airplanes and Engines. A DER may be appointed with a special delegation for major repairs and/or major alterations for vintage airplanes and/or engines. This delegation allows a DER to approve data for only the types of repairs and/or alterations to vintage airplanes and/or engines that would be eligible for FAA field approvals according to FAA Order 8300.16(). A DER with this special delegation may have their authority defined by multiple technical specialty areas with specific limitations noted. The specific delegations are:

1. Special vintage airplane (or engine) major repairs,

2. Special vintage airplane (or engine) major alterations, and

3. Special vintage airplane (or engine) major repairs and major alterations.

Note 1: DERs with the special delegation for vintage airplanes are limited to examination of data and findings of compliance within their specialty in support of field approvals according to FAA Order 8300.16().

Note 2: The intent of this special delegation is to allow individuals who do not meet the conventional DER appointment criteria to become DERs with limited approval authority in multiple technical specialties for repairs and/or alterations of specific makes of vintage airplanes and/or engines. This will facilitate complete approvals by a single DER when practical. Requirements for appointment of DERs with this authority are found in FAA Order 8100.8().

Note 3: DERs who already hold a special delegation for major repairs and major alterations need not be granted an additional special delegation for vintage airplanes.

(c) Special Delegation for Repair Specification DER (RS-DER). DERs granted specific authority to manage and approve technical data in repair specifications are called RS-DERs. An “RS-DER” is a shortened name for a DER with the special delegation to approve non-serial number-specific major repair data and manage repair specification approvals. Although RS-DERs may only make data approvals within their technical discipline, the project management function of this special delegation is not discipline specific. (More information about the functions and responsibilities of an RS-DER can be found in chapter 3, paragraph 4 and chapter 4, paragraph 13 of this order.)

The Order also explains that DERs with major repair or alteration special authority, and RS-DERs issue the FAA approval on an FAA Form 8110-3.

We are hopeful this information will make it “worldwide” and help members and other civil aviation authorities and customers understand that DER approval is FAA approval.

 


 


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/advertising.

 


Stand Up for ARSA

In order to provide world-class resources for its members, the association depends on the commitment of the aviation community. By sponsoring events and activities, supporters can help ARSA’s work on behalf of repair stations to endure.

Need a place to start? For information about opportunities, contact Vice President of Operations Brett Levanto (brett.levanto@arsa.org).

 


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Resources

ARSA strives to provide resources to educate the general public about the work of the association’s member organizations; should you need to provide a quick reference or introductory overview to the global MRO industry, please utilize AVMRO.ARSA.org.

About ARSA PAC

ARSA’s Political Action Committee helps elect congressional candidates who share ARSA’s commitment to better regulation and a strong aviation maintenance sector. But ARSA is prohibited from sending PAC information to members who haven’t opted in to receive it.

Careers in Aviation Maintenance

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

U.S./EU Maintenance Annex Guidance

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

 


Industry Calendar

Conference Dates Location
LBACE 8/8-10/2023 Sao Paulo, Brazil
MRO Asia-Pacific 9/26-28/2023 Singapore
Dubai Airshow 11/12-16/2023 DWC, Dubai Airshow Site
MRO Southeast Asia Spring 2023 TBD
ARSA Annual Conference 3/12-15/2024 Arlington, Virginia
AEA International Convention & Trade Show 3/19-22/2024 Dallas, Texas
NBAA Maintenance Conference 4/30/-5/2/2024 Portland, Oregon

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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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