2024 – Edition 1 – February 2
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
Conference Corner
Legal Briefs
ARSA on the Hill
Aviation Life Calendar
Training & Career Development
Membership
Resources
Industry Calendar
The President’s Desk
Becoming Generational
In 2016, ARSA participated in an aircraft maintenance technician career forum hosted by Airlines for America. The meeting boasted the hallmarks of that period in aviation workforce policy: The current crisis was still a “gathering storm,” with the FAA’s focused attention and ARSA-inspired grant programs years away, rather participants were driven to consider the future of the industry by looking at their own pasts.
A generation ago personal relationships drove a dedication to aviation. The group’s experience was that having family or friends with maintenance experience was key to driving people into an aviation-centric career.
Even then, ARSA was trying to change the mind-set: “While this is a great advantage when it works – recruits brought in through personal contacts are often deeply committed to aviation – these networks alone cannot provide the expanding pools of talent needed to support the maintenance community,” ARSA Vice President of Operations Brett Levanto observed after the meeting.
I’m a product of this history in so many ways. I’ve used my engineering skills and training to serve a company bearing my family name, one that has been an ARSA member since the association’s founding. My father Bill taught my brother and me the importance of leading both our businesses and the industry through bodies like this association. After a series of acquisitions, the company is now part of the HEICO Corporation.
On the other hand, Fortner Accessory Service Corp. remains a small-independent family-owned repair station with its own ARSA membership. The family roots of the company and my own career will always run deep
However, seeing the current state of the maintenance market and realities facing all aviation maintenance companies reinforce how much has changed. ARSA’s thinking expansively for recruitment holds true from generation to generation and can take many forms.
For the sake of engaged ARSA members, it means spreading interest in the association to new personnel. Whether they’ve come from the “family” or elsewhere, making new (and old) team members part of the collective work requires basic steps and commitment to the future:
(1) Involve them in events. I encourage every ARSA member to send new and younger personnel to the association’s Annual Conference in March. While attending in-person is best, and truly most rewarding, you can follow our example of giving the whole company “Conference Ambassador” access to the livestream of the event.
(2) Train them in regulatory compliance. Embracing new personnel means recognizing they may not become aviation lifers. Regardless of where they come from or where they are going professionally, every employee needs to understand what is special about their time in aerospace. That “specialness” is in the rules, and ARSA’s training on regulatory compliance is required knowledge for anyone working in aviation.
(3) Hook them up to the industry. Getting each member organization to identify as many internal contacts for ARSA’s database as possible is an ongoing challenge. Vice President of Membership Kimberly Dimmick works to update our profiles every year, help her out by clicking here and using the “Ask ARSA” form to submit your company’s entire contact list; this will ensure that all of your staff has access to expertise and resources.
It’s easy to be thankful for our past and the connections that brought us into aviation. Turning that past into a healthy future means thinking about new generations…and how they will evolve beyond our time.
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Gary Fortner 2024 ARSA president | Fortner Engineering & Manufacturing, Inc. vice president of engineering |
ARSA Works
What Has ARSA Done Lately – Fourth 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 through the end of 2023.
Fiscal Health
Full year revenue exceeded 2023 budget. Cashflow review demonstrates particularly strong periods – used for 2024 planning – in first and fourth quarters.
Membership
| Q4 Membership Renewal Rate | YTD Membership Renewal Rate | ||
| Total Renewed | 74 | Total Renewed | 281 |
| Total Recovered | 12 | Total Recovered | 40 |
| Total Paid Memberships | 86 | Total Paid Memberships | 321 |
| Total Cancelled/Lapsed | 6 | Total Cancelled/Lapsed | 23 |
| *Total Memberships Invoiced | 91 | Total Memberships invoiced | 344 |
| Renewal Rate | 94.5% | Renewal Rate | 93.3% |
| *Total invoiced does not include new memberships. | |||
Regulatory Advocacy
- Received 90-day extension to comment period for FAA Modernization of Special Airworthiness Certification (MOSAIC) proposal.
- Publicized EASA survey seeking feedback on Easy Access Rules.
- Pushed FAA and educated industry on issues related to repair station directory.
- Published notification about release of Revision 7 of Technical Implementation Procedures related to the U.S./EU bilateral agreement (with updated contacts for FAA AIR offices overseeing bilateral issues).
- Released cross-reference matrices for compliance with U.S./UK Maintenance Annex Guidance.
- Prevailed in request to FAA to cancel guidance and operations specification concerning Coordinating Agency for Supplier Evaluation (C.A.S.E.) approval.
- Delivered results of international digitalization survey during Maintenance Management Team meeting.
- JoinedS. Department of Transportation Aerospace Supply Chain Resiliency Task Force.
Legislative and Lobbying
- FAA reauthorization:
- Urged enactment of short-term FAA extension.
- Maintained pressure on Congress to pass long-term FAA law with ARSA priorities.
- National Defense Authorization Act:
- Stood up NDAA Steering Committee (First Aviation, AeroKool, Chromalloy, HEICO).
- Revised and updated lobbying collateral on DOD acceptance of FAA approvals and access to technical data.
- Identified target congressional offices.
- Identified date (Jan. 22) for NDAA visits.
Communications and Surveys
ARSA in the News – Selected Industry Coverage
FAA Extends MOSAIC Comment Period
Oct. 4, 2023 | Flying Magazine
ARSA and its allies jointly submitted the request on August 29, expressing the need for additional time to thoroughly review and assess the extensive amendments proposed by MOSAIC.
MCCCD’s workforce programs help Arizona soar in aerospace manufacturing
Nov. 13, 2023 | Phoenix Business Journal
In 2022, the Aeronautical Repair Station Association ranked Arizona among the top two for aviation maintenance economic activity.
ARSA-placed Industry Editorials and Content
| AMT Magazine | Playing with Definitions September/October | Brett Levanto |
| Passing the Test November/December | Brett Levanto |
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| Aviation Week | Regulators Should Not Be Able to Shape The AAM Market October | Sarah MacLeod |
| China’s Growth Could Drive Regulatory Collaboration with U.S. November | Christian Klein |
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| Technician Experience Trumps Paperwork in Parts Scandal December | Christian Klein |
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| DOM Magazine | A DOM By Any Other Name October | Christian Klein & Brett Levanto |
| People Over Paperwork November | Christian Klein & Brett Levanto |
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| Walking the SMS Walk December | Brett Levanto |
Bringing Advertising In-house
- Sales & Renewal: Multiple members submitting payments on renewals, ARSA team engaging with a returned member who has been an advertiser about total value proposition of association.
- Creative: Creation/placement of ARSA Conference ad on Website (along with supporting periodical content).
- Administrative: Adjustment to contract posted on web.
Surveys
- Quick Questions:
- Age Yourself (and Your People) (11 Responses)
- Conference Planning (35 Responses)
- Annual Member Survey Administration planned for Q1.
Events, Meetings and Training
Events
- Hosted Leadership Roundtables 12 at Helicopter Association International.
- Planning for 2024 Annual Conference (March 12-15)
- Registration Opened December First
- Speaker invitations underway – Opening Salvo panel to include in-person participation from FAA, EASA, ANAC Brazil, TCCA, and UK CAA.
- Sponsor recruitment ongoing, initial list unveiled in January.
Training
- “Magic Form” Series
- FAA Form 8130-3 – Overview and History – Sept. 27
- FAA Form 8130-3 – Completion Instructions & Multiple Releases – Oct.18
- “Appliance” Why Do You Care? – Nov. 21
- Public Aircraft Decision Tree – Dec. 14
External Meetings
- Sarah held recurring meetings regarding the Part 145 Working Group (and AMC development), the Repairman Portability Working Group, the ODA Expert Panel, MOSAIC, and engagement with both FAA Flight Standards and Aircraft Certification Services.
- Christian had multiple meetings regarding the MMT Digitization Working Group.
- Christian attended multiple TSA Aviation Security Advisory Committee meetings.
- Christian had multiple meetings with NDAA Steering Committee.
- Christian and Brett held monthly collaboration calls with Oliver Wyman.
- Christian attended multiple meetings of the ASAC Airport & Insider Threat Subcommittee.
- Brett and Sarah held multiple meetings in support of a full customization model manual.
- Christian met with member regarding apprenticeships (Nov 2).
- Christian briefing AEA’s Board of Directors on FAA Reauthorization (Nov 3).
- Christian and Brett held a quarterly meeting with ATEC regarding FAA workforce issues (Nov 16).
- Christian traveled to Cologne, Germany and presented at the MMT meetings (Nov 27-Dec 2).
- Brett met with a member to discuss worker drug use in Ohio (Nov 29).
- Brett met with purchaser of model compilation development (Dec 6).
- Christian participated in the semiannual meeting of EASA’s Maintenance Activity Group (AG012) (Dec. 6).
- Christian met with member and congressional staff regarding the FAA ICA issue (Dec 8).
- Sarah and Christian met with DOT re: ASCR Task Force (Dec 18).
- Christian held an introductory phone call with potential member (Dec 20).
Strategic Work Plan
- 2023 Q4 Objectives:
- Maintain pressure on FAA and EASA to resolve parts documentation issue. ONGOING
- Update RSQM Compilation materials for release of revision. ONGOING
- Execute management agreement. AGREEMENT COMPLETE, FINALIZING SIGNATURES
- Initiate 2024 Conference registration, sponsorship drive, and speaker invitations. COMPLETE
- Continue database development to support membership and benefits. ONGOING
- Expand advertisement sales targeting. ONGOING
- 2024 Q1 Objectives:
- Participate in HAI Heli-Expo.
- Host successful 2024 Annual Conference.
- Conduct 2024 annual member survey.
- Enact long-term FAA reauthorization legislation.
- Market initial 2024 training schedule.
- Continue database development to support membership and benefits.
- Update RSQM Compilation materials for release of revision.
- Gather and analyze data on membership participation.
ARSA, AEA Point to History with Joint MOSAIC Comments
On Jan. 22, ARSA and the Aircraft Electronics Association jointly submitted comments on the FAA’s Modernization of Special Airworthiness Certification (MOSAIC) proposal. The associations referenced multiple past rulemaking efforts as well as the history of continued airworthiness regulation in critiquing the technical specifics of the proposal while generally supporting the FAA’s effort to revise sport pilot privileges and limitations.
As reported by AEA, the joint comments focused in the following areas:
(1) Decoupling sport pilot privileges from the design and certification of light-sport aircraft as a viable option that should increase pilot recruitment, certification and operations. Recommending a 10 percent increase over the proposed stall speed of 54 knots CAS as supported by the FAA in a 30 year-old rulemaking.
(2) Enhancing the safety, performance and increased privileges for light general aviation aircraft. Providing research demonstrating the current regulations already support the FAA’s goal, without additional rulemaking. Beginning in 1989, the FAA proposed and succeeded in three separate rulemakings designed to create “simplified procedures for type, production, and airworthiness certification, and associated maintenance procedures.” Each of these three regulations allows for “the development of certification standards by the private sector and represents the most productive and cost-effective manner of streamlining the certification process.” (i.e., consensus standards)
(3) Leveraging the agency’s 30-year development of a safety continuum for the design, manufacturing and certification of viable general aviation aircraft, which is represented in the current regulations.
To read the complete comments, click here.
FAA Extends Comment Period on D&A Testing Proposal
On Jan. 19, the FAA notified ARSA that the agency would extend the comment period on its proposed rule to impose drug and alcohol testing requirements on maintenance personnel located outside the United States. The new deadline to submit substantive comments is April 5. The association and and 14 other industry organizations had requested the extension just three days before it was granted. The group, larger than the “Industry Coalition” organized by ARSA for the advanced notice of proposed rulemaking in 2014 and referenced in the NPRM, had explained the additional time was necessary for collective coordination.
“The rulemaking was issued during the holiday season, which represents ‘down time’ for may companies and individuals but is actually a critically busy period for the very air carrier personnel – and their contractors – most closely impacted by the proposal,” the group’s request explained. “Allowing ample time for review and comment, particularly considering the 11 years already invested by the government and industry in the process, is in the public interest.”
ARSA will now coordinate with those same allies on substantive comments to the FAA’s proposal. Association members are encouraged to engage in two ways:
(1) Plan to submit substantive comments representing your company, particularly related to the costs of compliance for repair stations located outside the United States. Contact ARSA to share your insights and for guidance related to commenting (resulting discussion may impact the association’s analysis for its own commentary).
(2) As with the extension request, be ready to comment in support of the industry coalition’s eventual submission of substantive comments.
(3) Respond to the “quick question” collecting data about D&A testing practices at repair stations located outside the United States.
For more information about the rulemaking, contact ARSA after reviewing the content at arsa.org/drugandalcohol.
ARSA was joined by the following organizations on the extension request:
Aerospace Industries Association
Air Transport Association of Canada
Aircraft Electronics Association
Airlines for America
Aviation Suppliers Association
Aviation Technician Education Council
Cargo Airline Association
Helicopter Association International
International Air Transport Association
Modification and Replacement Parts Association
National Air Carrier Association
National Air Transportation Association
National Business Aviation Association
Regional Airline Association
Managing CAAC Extensions
In December, ARSA received numerous queries from members related to a notice from the Civil Aviation Administration of China (CAAC) that it would return to on-site audits for repair station approvals in 2024. According to a letter and related guidance circulated to U.S. holders of CAAC approval, the agency would cancel extensions to existing certification pending the new audits.
ARSA has been in touch with multiple members who requested special approval prior to the Dec. 24th deadline set by CAAC to continue ongoing work and has learned they were all granted limited extensions through the remainder of 2024; after completing a new certification audit their Maintenance Organization Approvals will be reinstated in full.
The CAAC has also offered instructions for Chinese Operators to request special approval for use of a repair station as an “unlicensed repair unit” for new work. ARSA is working on ways for members to assist their customers in submitting these requests and is communicating with Chinese regulators on the matter.
Stay tuned for more updates. If your repair station has input regarding CAAC approval, contact ARSA to share experiences and ask questions.
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.
Conference Corner
Register Now
March 12-15, 2024
Sponsors | Information | Registration | Hotel (Book by Feb 16.)
Arlington, Virginia and Washington, D.C. with Livestream Options for Conference Ambassadors
Experience the maintenance community’s premier event. Join ARSA members and invited guests from around the world to engage governments, network with peers and improve the state of the aviation world.
Registration
Sponsor Salute
Sponsors | Information | Registration | Hotel (Book by Feb 16.)
Thank you to the 18 organizations that have committed (so far) to sponsor ARSA’s 2024 Annual Conference. There’s still time to join them…check the event page to see how.
Platinum
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Gold
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Silver
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Contributors
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Five CAAs
Sponsors | Information | Registration | Hotel (Book by Feb 16.)
The 2024 Annual Conference agenda is shaping into familiar form: four days of executive branch briefings, grassroots legislative advocacy, and discussions focused on international regulatory compliance.
ARSA is particularly looking forward to in person participation from the FAA, EASA, Transport Canada, ANAC Brazil, and the UK CAA for the “Opening Salvo” conversation with regulators on Thursday, March 14. This extended panel is the centerpiece of the regulatory content presented during the Symposium portion of the Conference and the perfect opportunity for maintenance professionals to deliver questions directly to representatives of these key civil aviation authorities.
Thursday, March 14 at 9:15 a.m. | Session 2: Opening Salvo – Conversations with the Regulators
International aviation safety agencies will provide updates on the regulations, policies, and procedures of importance to the global aerospace sector.
Lawrence Josuá Fernandes Costa, Continuing Airworthiness Certification Manager, Department of Flight Standards, ANAC Brazil [In person]
Ludovic Aron, Washington Representative, EASA [In person]
Karl Specht, Principal Coordinator Organisation Approvals, EASA [Online]
Lirio Liu, Executive Director, Aircraft Certification Service, FAA [Invited]
Larry Fields, Executive Director, Flight Standards Service, FAA [Invited]
Jeffrey Phipps, Chief, Operational Airworthiness (AARTN), Transport Canada Civil Aviation [In person]
Neil Williams, Head of Airworthiness, Policy & Rulemaking, United Kingdom Civil Aviation Authority [In person]
Click here for to register (and have your regulatory questions ready).
Event Information
Executive to Executive Briefings: Tuesday, March 12, 2024
Participation by industry executives with senior executive branch officials is limited to annual conference sponsors.8:30 a.m. | Coffee & Light Breakfast
9:00 a.m. | Introductory Briefing
10:00 a.m. | U.S. Department of Transportation
Elliott Black, Facilitator, Aerospace Supply Chain Resiliency Task Force, Office of the Under Secretary for Transportation Policy, U.S. Department of Transportation
ARSA is a member of the congressional-mandated task force examining the resiliency of the aerospace supply chain. Black will facilitate a group discussion about issues impacting the maintenance sector supply chain, including workforce, government policy, access to materials, geopolitical challenges, etc.11:00 a.m. | Break
11:15 a.m. | U.S. Department of State
Heidi Gomez, Deputy Assistant Secretary for Transportation Affairs, Bureau of Economic and Business Affairs
12:00 p.m. | Access to Maintenance Data: The ICA ARC
Josh Krotec, Senior Vice President, First Aviation and Member, ARSA Board of Directors
Krotec has been named industry co-chair of the newly established Instructions for Continued Airworthiness Aviation Rulemaking Committee, which was created at ARSA’s request to address the availability of maintenance data. He will discuss the ARC’s mandate and objectives, and opportunities to influence the ARC’s work.12:45 p.m. | Lunch & Midday Break
2:00 p.m. | U.S. Department of Commerce
Scott Kennedy, Director, Office of Transportation & Machinery, International Trade Administration
3:00 p.m. | Break
3:00 p.m. | Economic Impacts
Livia Hayes, Director, Market Intelligence Team, Transportation and Services Practice, Oliver Wyman
Hayes will review the findings of the most recent Oliver Wyman MRO industry forecast and lead a roundtable discussion of factors and trends impacting demand for maintenance services.4:00 p.m. | Wrap Up Discussion
Legislative Day: Wednesday, March 13, 2024
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.7:30 a.m. | Registration & Breakfast
8:00 a.m. | Welcome & Introductions
8:15 a.m. | It's All About Your Industry and Your Company
Find out what’s at stake in Washington for your company and your industry, where things stand, and what you can do to impact the process.
9:00 a.m. | National Defense Authorization Act Opportunities
ARSA is pursuing legislation as part of the annual Pentagon budget and policy bill to enhance competition and opportunities for small businesses in Department of Defense aircraft maintenance contracting.
Josh Krotec, Senior Vice President, First Aviation and ARSA Immediate Past President
Alex de Gunten, Senior Vice President for Government & Industry Affairs, HEICO and 2024 ARSA Government Affairs Chairman
9:45 a.m. | Break
10:00 a.m. | FAA Reauthorization: Industry Perspectives
Representatives of ARSA ally organizations discuss their priorities in the current FAA reauthorization and share insights about the likelihood of an FAA bill being enacted in 2024.
Karen Huggard, Vice President of Government Affairs, National Air Transportation Association
Jarrod Thompson, Vice President for Legislative and Regulatory Policy, Airlines for America
Sterling Wiggins, Senior Director, Transportation, Infrastructure, and Supply Chains, U.S. Chamber of Commerce
Adam Weiss, Counsel (Minority), U.S. House Transportation & Infrastructure Committee Subcommittee on Aviation
11:00 a.m. | Release of 2024 Global Fleet & MRO Market Report
Livia Hayes, Director, Market Intelligence Team, Transportation and Services Practice, Oliver Wyman
Uktarsh Mishra, Market Intelligence Specialist, Oliver Wyman CAVOK
11:30 p.m. | Wrap Up Discussion & Presentation of 2024 Legislative Leadership Award to Garret Graves (R-La.)
12:00 p.m. | Lunch
1:00 p.m. | Congressional Meetings Begin
Participants head to Capitol Hill for scheduled meetings with members of Congress and staffers covering subject matter or geographic jurisdictions impacting participant home/facility locations. NOTE: participants schedule their meetings directly with the relevant offices; instructions are provided in advance of the event.
TBD | Presentation of ARSA Legislative Leadership Award (Special Invitation Only)
4:00 p.m. | Symposium Registration Open (for non-Legislative Day attendees)
5:30 p.m. | Ice Breaker Reception
7:00 p.m. | Special Invitation Dinner
Annual Repair Symposium: Thursday, March 14, 2024
The centerpiece of Conference week, ARSA convenes a full day of substantive panel discussions covering key regulatory compliance and business issues.7:30 a.m. | Registration & Breakfast
8:00 a.m. | Welcome & Introductory Remarks
ARSA is the voice of the global aviation maintenance industry. How the association advocates your interests with legislators, regulators, and the media sets the stage for corporate growth. Information on how advancement of the industry’s collective interests enables individual companies to shine more brightly.
8:30 a.m. | Session 1: Fireside Chat with AVS-1
David Boulter, Associate Administrator for Aviation Safety, FAA
9:00 a.m. | Break
9:15 a.m. | Session 2: Opening Salvo – Conversations with the Regulators
International aviation safety agencies will provide updates on the regulations, policies, and procedures of importance to the global aerospace sector.
Lawrence Josuá Fernandes Costa, Continuing Airworthiness Certification Manager, Department of Flight Standards, ANAC Brazil [In person]
Ludovic Aron, Washington Representative, EASA [In person]
Karl Specht, Principal Coordinator Organisation Approvals, EASA [Online]
Dan Elgas, Director, Policy and Standards Division (AIR-600), Aircraft Certification Service, FAA [In person]
Tim Adams, Deputy Director, Office of Safety Standards, Flight Standards Service, FAA [in person]
Jackie Black, Manager, Aircraft Maintenance Division, Flight Standards Service, FAA [in person]
Jeffrey Phipps, Chief, Operational Airworthiness (AARTN), Transport Canada Civil Aviation [In person]
Neil Williams, Head of Airworthiness, Policy & Rulemaking, United Kingdom Civil Aviation Authority [In person]
12:30 p.m. | Lunch with Special Guest
Billy Nolen, Chief Safety Officer, Archer Aviation
2:00 p.m. | Session 3: Defining the Career
Using known pathways and the current regulations, panelists lay out templates for international maintenance technician recruitment, training, and retention.
Ryan Goertzen, Vice President of Workforce Development, AAR
Barrington Irving, Founder & CEO, The Flying Classroom and Founder of the Barrington Irving Technical Training School
Crystal Maguire, Executive Director, Aviation Technician Education Council
3:00 p.m. | ARSA Quiz Show
3:30 p.m. | Break
4:00 p.m. | Session 4: Training First
Based on recommendations from SOCAC’s Workforce Development and Training (WDAT) Working Group and the ongoing work of the ARAC Repairman Working Group, panelists will explain how industry can push the government to accept standards for competency and skill development.
5:00 p.m. | The Club Lounge Happy Hour
Member Day: Friday, March 15, 2024
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 choosing from one of several concurrent breakout sessions.8:00 a.m. | Annual Membership Meeting & Breakfast
9:30 a.m. | Break
10:00 a.m. | Training: Regulations for Supervisors & Inspectors
This session reviews the cardinal regulatory knowledge necessary for repair station personnel to be “thoroughly familiar with the applicable regulations in this chapter.” ARSA’s training team is rolling out the course for the benefit of Conference attendees.
12:00 p.m. | Conference Ends
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. Access to the livestream in 2024 will be available only to "Conference Ambassadors." These "Ambassadors" are contacts identified by in-person participants to bring the event back to their home facilities.
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, sponsorship rights and 10 registrations to an ARSA training session, 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 2024):- Online Conference Experience
- Executive to Executive Briefings
- Legislative Day – All Day
- Annual Repair Symposium – Ice Breaker Reception
- Annual Repair Symposium – Club Lounge Happy Hour
- Congressional Directories/Resources
2023 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, 5 registrations to an ARSA training session, 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 2024):- 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
2023 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):- Nametag Lanyards
- Hotel Room Keys
- Annual Repair Symposium – Coffee Break (5)
2023 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.2023 Supporter
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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.2023 Contributors
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ARSA's block of rooms for Conference participants at the Ritz-Carlton, Pentagon City in Arlington, Virginia is now closed. 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). To try and book a room independently, go to the hotel's website or call 703.415.5000.
Those seeking other options may consider these hotels (there are no ARSA-related specials or promotions at these locations):
Embassy Suites by Hilton Crystal City National Airport 1393 S Eads St. Arlington, Virginia, 22202
Residence Inn Arlington Capital View 2850 South Potomac Avenue Arlington, Virginia, 22202
DoubleTree by Hilton Hotel Washington DC – Crystal City 300 Army Navy Drive Arlington, Virginia, 22202
Crowne Plaza Washington National Airport 1480 Crystal Drive Arlington, Virginia, 22202
Hampton Inn & Suites Reagan National Airport 2000 Richmond Highway Arlington, Virginia, 22202
Radisson Hotel Reagan National Airport 2020 Richmond Hwy Arlington, VA 22202
Holiday Inn National Airport/Crystal City 2650 Richmond Highway Arlington, Virginia, 22202
The Leo Weston Award for Excellence in Government Service
First bestowed on Leo Weston himself in 2005, the Weston award honors an instrumental figure in ARSA's birth by recognizing individuals who embody his commitment to the industry's safety and success. The symposium provides a venue for association members and invited guests from around the world to network and discuss issues that matter to the aviation maintenance industry. It is the perfect time to respect the history of the repair station community and honor the good works of those who support it.
Click here to learn more about Leo, the award bearing his name, and those who have received it.The Legislative Leadership Award
The association regularly recognizes members of Congress who have provided outstanding support to the aviation maintenance community by supporting policies beneficial to the industry. Honorees have each been key in moving forward specific legislation advancing priorities championed by ARSA on behalf of its members.
Click here to see past updates regarding Legislative Leadership Award recipients.The "Golden Shovel" Award
From time to time, ARSA recognizes individuals – usually at the time of their retirement – who have spent their careers in steadfast devotion to good business, good safety, and good oversight. In the colorful illustration of Executive Director Sarah MacLeod, these professionals have spent their lives shoveling against the tide of government bureaucracy; their achievement in never giving up is acknowledged through the "Golden Shovel Award."
Click here to learn more about the "Shovel" and see who has received it.The Ritz-Carlton
The site of all substantive and social gatherings related to the ARSA Conference. The Ritz-Carlton, Pentagon City follows the Marriott International "Commitment to Clean." The guidance includes protocols and elevated practices and can be found at whattoexpect.marriott.com/waspc.
Virginia
With the exception of any Legislative Day meetings held on Capitol Hill (scheduled individually by participants), the entirety of the Annual Conference takes place in the Commonwealth of Virginia. Guidance related coronavirus protocols can be found at www.vdh.virginia.gov/coronavirus/protect-yourself.
Washington, D.C.
No Annual Conference activities open to general participation take place in Washington, D.C. Conference attendees going into the city for business or personal reasons should consult coronavirus.dc.gov for policy and guidance related to the pandemic.
U.S. CDC
According to the Centers for Disease Control and Prevention, both Arlington County (the location of the Ritz-Carlton, Pentagon City) and Washington, D.C. are classified as "medium" for community transmission. See county-by-county assessments and guidance at www.cdc.gov/coronavirus.
Going Livestream
If any in-person registrant wishes to opt out of participation because of personal health concerns (including illness) they may switch to livestream access at any time. Access to the livestream is available to all participants via the Digital Companion, a password-protected webpage for participants to access the agenda, speaker information and presentation resources.
Materials and Recordings
The Digital Companion (the much discussed online resource for event materials and resources, to which access information is sent to attendees via email and provided from the lectern on each day) is the location for PDFs of all presentations as well as links to additional resources discussed during the event. It also includes an attendee directory (in the “General Resources” area) and information about accessing the livestream sessions and raw recordings.
Don’t Sleep in the Cold
Sponsors | Information | Registration | Hotel (Book by Feb 16.)
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).
Rooms must be booked by Friday, Feb. 16, so get yours today and don’t sleep in the cold (or have ride the Metro to get to breakfast each morning). To make your reservation, visit:
book.passkey.com/go/ARSA2024AnnualConference
Annual Meeting Notice
The ARSA Annual Member Meeting is held in conjunction with the Annual Conference; this year it will take place during the Breakfast and Annual Report on Friday, March 15 at 8:00 a.m.
ARSA leadership will address members regarding the state of the association. Attendees are welcomed and encouraged to raise matters relevant to ARSA and the industry it represents.
If you are unable to attend – conference registration is open – but would like to submit comments/questions to ARSA’s board, please do so via the mechanisms available on arsa.org/contact.
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.
One Year and Waiting
By Christian A. Klein, Executive Vice President
Exactly one year ago, ARSA and 14 allied organizations sent a letter to the FAA and European Union Aviation Safety Agency (EASA) certification and flight standards directors urging resolution to the ongoing parts documentation dispute between the two authorities. Maybe 2024 finally brings a solution.
Following a change in the U.S.-E.U. Bilateral Aviation Safety Agreement (BASA) Maintenance Annex Guidance (MAG) in 2015, EASA demanded every new replacement part installed by a U.S. repair station during maintenance under the BASA be accompanied by an FAA Form 8130-3 form (or EASA Form 1) traceable to the production approval holder (PAH).
In 2022, the FAA and EASA formally withdrew acceptance of an ARSA-designed process to inspect an article under part 43, document the inspection, and issue an FAA Form 8130-3 with a right-side signature. Ever since, U.S. repair stations and parts distributors have since been stuck with large and expensive parts inventories that are not usable in a dual release work scope because they lack proper paperwork.
The parts documentation issue stems from differences in the FAA and EASA systems. EASA generally requires a production approval holder (PAH) to provide an EASA Form 1 with each new product or article attesting that it was manufactured in accordance with approved design data. In the United States, PAHs may provide an FAA Form 8130-3 with a new part being shipped domestically but aren’t required to do so. Those paperwork differences shouldn’t matter given that the BASA, MAG, and Technical Implementation Procedures (TIP) are based on the recognition of equivalent safety outcomes in the FAA and EASA systems.
Other countries certainly see it that way. Last year ARSA reviewed the special requirements for exporting articles from the United States to Australia, Brazil, Japan, Saudi Arabia, and South Korea. Some require an FAA Form 8130-3 or equivalent issued under subpart L. In other cases, all that is required is an FAA Form 8130-3 issued as an approval for return to service under part 43. None of the countries require FAA Form 8130-3s for the new articles installed during maintenance. The focus – as it should be – is on the top-level assembly’s conformity to an approved design and condition for safe operation.
The ARSA-led letter sent last January argued the agencies are misreading the BASA and using it to improperly justify EASA’s paperwork demand. The FAA and EASA have since convened a working group to address the issue – likely via upcoming revisions to the FAA-EASA MAG and TIP. However, the timing of a solution remains unclear.
ARSA’s Annual Conference is one of the few places the FAA, EASA, United Kingdom Civil Aviation Authority, Transport Canada Civil Aviation, and Brazil’s Agência Nacional de Aviação Civil come together annually on a single stage to publicly discuss regulatory issues. In the past, authorities have used the venue to make announcements about important developments. Will EASA and FAA use their presence at the ARSA Conference to unveil a solution to this longstanding issue? If they do, we hope you’re there to hear it; if they don’t, be there to help us hold the regulators’ feet to the fire.
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 – Deferential Treatment
By Brett Levanto, Vice President of Operations
In mid-January, the Daily Intelligence newsletter contained an article about fish. The periodical, compiled by ARSA’s management firm and sent on the association’s behalf to the primary contact at each member company to provide a news and regulatory round up useful to aviation professionals, included a Washington Post update that had nothing to do with aviation but everything to do with good government.
“This humble fish may help the Supreme Court weaken the ‘administrative state,’” proclaimed the headline of Ann Marimow’s review of a pair of cases challenging the authority of federal agencies. The cases concern requirements for commercial fisherman to pay for the presence of individuals monitoring their work at sea, but the key implication in the cases is the high court’s opportunity to reconsider long-standing judicial precedent set in 1984.
That year, in Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., the court determined the Environmental Protection Agency had reasonably interpreted Congress’ ambiguous use of a term impacting the regulation of air pollution-emitting devices. Justice John Paul Stevens’ opinion created “Chevron Deference,” which has provided lower courts a test through which to defer to the decision making of executive agencies in administering law where Congress’ intent was unclear or incomplete regarding the specifics at issue.
From Stevens’ opinion:
When a court reviews an agency’s construction of the statute which it administers, it is confronted with two questions. First, always, is the question whether Congress has directly spoken to the precise question at issue. If the intent of Congress is clear, that is the end of the matter; for the court, as well as the agency, must give effect to the unambiguously expressed intent of Congress. If, however, the court determines Congress has not directly addressed the precise question at issue, the court does not simply impose its own construction on the statute, as would be necessary in the absence of an administrative interpretation. Rather, if the statute is silent or ambiguous with respect to the specific issue, the question for the court is whether the agency’s answer is based on a permissible construction of the statute… When a challenge to an agency construction of a statutory provision, fairly conceptualized, really centers on the wisdom of the agency’s policy, rather than whether it is a reasonable choice within a gap left open by Congress, the challenge must fail. In such a case, federal judges – who have no constituency – have a duty to respect legitimate policy choices made by those who do.
Put simply, under Chevron Deference the court asks whether Congress directly instructed the agency on whatever question is being considered. If yes, then whatever the lawmakers said goes. If no, then the court generally defers to the agency’s interpretation.
As a result, executive branch agencies hold considerable authority in interpreting and enforcing the will of Congress. The courts avoid an onslaught of cases challenging “the wisdom of the agency’s policy,” but the system remains bogged down by plaintiffs unable to pursue due process in the face of government overreach or misinterpretation.
“When statutes aren’t clear, courts consider whether the agency interpretation is sensible, well-reasoned, and aligns with the statute’s design,” said Jody Freeman, Harvard University Archibald Cox Professor of Law in a review of the issue. “If so, the agency wins.”
A “win” for the agency can often be a loss for reasonable oversight. In 2017, a US court ruling determined the FAA was not obligated to force a manufacturer to supply maintenance instructions to a repair station, noting that it is the agency’s discretion if and how it enforces its own rules – in this case related to § 21.50’s ICA requirements – even though the agency had already determined the design approval holder to be in violation of the “make available” provision of that very section (see the case’s exhibits along with other ICA enforcement challenges on ARSA’s issue page).
The political history of Chevron Deference is complicated. In the 1984 case through which it was created, the decision gave President Reagan’s EPA leeway to administer clean air regulations in a way that liberal environmentalists decried. The Court’s attention to it in 2024 is generally considered the result of conservative justices’ willingness to undo a judicial mechanism that has enabled the overreach of the regulatory state. Regardless of placement on the ideological spectrum, the final decision will impact how the executive branch oversees the public and potentially facilitate pushback against overreach or misdirection.
ARSA will continue to monitor the case and report to its membership. In the meantime, this “layman lawyer” reminds his industry colleagues that regardless of judicial principle it will never be the association’s position to defer to a government agency. Certificate and approval holders show compliance with the rules and must demand their inspectors know how to find it.
ARSA on the Hill
FAA, NDAA, and Legislative Day
By Christian A. Klein, Executive Vice President
With a new year well underway, ARSA is back at work on Capitol Hill promoting repair station interests. FAA reauthorization and the FY 2025 National Defense Authorization Act (NDAA) are priorities. The best way to support these efforts, make your voice heard, and impact the process is to attend ARSA’s 2024 Legislative Day in Washington, D.C. on March 13.
FAA Reauthorization Languishes
In December, Congress extended the FAA’s operating and revenue collection authority through March 8, the second extension since the agency’s authorization law lapsed on Sept. 30. The House passed a multi-year FAA budget and policy bill (H.R. 3935) last summer, but Senate Commerce, Science & Transportation Committee (Commerce) action on its bill (S. 1939) has been delayed by disagreements about pilot training. Airlines want more flexibility; pilot unions are opposed.
There are rumblings the Senate Commerce Committee may markup its FAA bill in February, but as the hotline went to press, no hearing information had been posted to the Commerce Committee website.
The chart below details the issues ARSA is tracking (many of which the association itself proposed).
| Status of ARSA Reauthorization Priorities | ||||
| Issue | House Bill (H.R. 3935) |
Senate Bill (S. 1939) |
Notes | ARSA Position |
| Regulatory | ||||
| FAA Management Board | Sec. 122 | No provision | Among other things, 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. | Add to Senate bill; retain in conference. |
| Ending open-ended investigations | Sec. 208 | No provision | Requires FAA investigations to be completed within two years of issuance of a letter of investigation | Add to Senate bill, retain in conference. |
| Enforcement consistency; aligning regulations and guidance | Secs. 252 and 253 | No provision | Sec. 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. Sec. 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 | Include both provisions in Senate bill, retain in conference report. |
| Foreign repair stations | Sec. 505 | Secs. 311 and 312 | Prescribes new and unnecessary regulatory and oversight requirements for foreign repair stations that will divert FAA resources from higher priorities with no safety benefit. | Do not included in conference report. |
| Maintenance data availability | Sec. 516 | Sec. 333 | Both House and Senate bills direct FAA Administrator to assign an instructions for continued airworthiness task to FAA Aviation Rulemaking Advisory Committee to resolve longstanding questions about maintenance data availability. | Merge and retain in conference. |
| Major alterations vs. supplemental type certificates | Sec. 517 | No provision | To resolve uncertainty for maintainers and operators, requires the agency to issue or update guidance to clarify the conditions under which a major alteration requires a supplemental type certificate. | Add to Senate bill, retain in conference. |
| Workforce | ||||
| Aviation workforce grant programs | Secs. 301 and 302 | Sec. 501 | To address persistent shortages of aviation technical personnel, House bill reauthorizes, triples funding, increases maximum grant from $500k to $750k, expands program eligibility to include 501(c)(3) nonprofits, and creates a similar new grant program for the aviation manufacturing workforce. Senate bill reauthorizes, doubles funding, creates new program for manufacturing, increases maximum grant to $1 million from $500k). | Merge and retain in conference. |
| National Center for the Advancement of Aerospace | Sec. 303 | No provision | Creates a new National Center for the Advancement of Aerospace to coordinate workforce development activities among industry, academia, and other stakeholders. | Add to Senate bill, retain in conference. |
| Military technician transition to civilian careers | Sec. 311 | Sec. 504 | House establishes an interagency working group to improve the transition from military to aviation technician careers. Senate bill directs rulemaking to create new military mechanic test and adjust airman certification standards. | Retain Senate language in conference. |
| Early airframe and powerplant mechanic general knowledge testing for students who have completed high school coursework | Sec. 312 | Sec. 503 | House establishes a working group to examine airman knowledge testing to create new opportunities for high school graduates in the maintenance industry; Senate directs GAO study.
|
Retain House language in conference. |
| Adding aviation maintenance representation to stakeholder bodies | No provision. | Secs. 202(d) (Airspace Innovation Office integrated plan development stakeholders) and 502(b) (Women in Aviation Council composition). | Creates panels addressing issues impacting aviation maintenance. Representation from the maintenance industry should be added. | Add “aviation maintenance” to indicated stakeholder bodies. |
Even though the year is still young, chances of getting the FAA bill done this year are only about 50/50. Four months into the new fiscal year, Congress still hasn’t finalized the FY 2024 spending bills necessary to keep the government open. The president’s budget will be released soon, which will start the annual budgeting and NDAA processes. Bills addressing aid to Ukraine, border security, and tax cuts are all on the front burner. And the multiyear reauthorization of agricultural programs via the Farm Bill is competing for political attention and floor time.
The looming November elections are also a factor. During election years members of Congress spend less time in Washington, D.C. legislating and more time “back home” campaigning. There’s also less incentive to compromise, either to deny political opponents a victory or because the political landscape may allow for a better deal next year.
All that said, ARSA is still hopeful Congress will complete FAA reauthorization this year. The House bill has broad, bipartisan support from lawmakers and industry. Recent aviation incidents have put new pressure on lawmakers to get the FAA bill done. The agency has a new administrator who needs direction and more resources to be successful. And a series of short-term extensions would be a disaster because it would keep the agency lurching from one potential shutdown (and all the related distraction) to another.
NDAA Gets Underway
While FAA reauthorization generally takes place every five years, Congress reauthorizes Department of Defense (DOD) programs annually.
ARSA is proposing two provisions for the FY 2025 NDAA. The first directs the DOD to accept FAA approvals more readily in conjunction with maintenance on DOD’s fleet of commercial derivative aircraft. The second provision would clarify government rights to the technical data repair stations need to perform work for the DOD. Both provisions would enhance competition for DOD aircraft maintenance services, reduce costs for taxpayers, enhance readiness, broaden the defense industrial base, and strengthen the defense supply chain.
The NDAA process starts early each year as congressional offices begin accepting requests for issues to address in the bill. The release of the president’s budget in February – which articulates administration defense priorities – is another important milestone. After that, the process can move very quickly; last year, the House NDAA was introduced in April, reported by committee in late June, and passed by the House in mid-July.
Given the quick timeline, ARSA Executive Vice President Christian Klein and leading association members held a series of meetings on Capitol Hill this past month to discuss ARSA’s proposals. If you want more information or to become involved in the association’s NDAA efforts, contact us.
ARSA Legislative Day: Make a Difference
FAA and NDAA reauthorization will be front and center when industry leaders descend on the nation’s capital for ARSA’s annual Legislative Day on Wednesday, March 13.
The day begins at the Ritz-Carlton Pentagon City with breakfast, briefings by ARSA team members, representatives from allied organizations, and congressional staff, and the release of the ARSA/Oliver Wyman annual MRO market forecast. After lunch at the hotel, attendees travel to Capitol Hill for individual meetings with their congressional offices. The day ends with the ARSA Icebreaker Reception for all conference attendees on Wednesday evening.
Please seize this important opportunity to join like-minded colleagues and help advance maintenance industry interests in Washington, D.C. Register for Legislative Day now.
|
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. |
Aviation Life Calendar
February Through MaySomething 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.
Training & Career Development
Multidisciplinary Training at HELI-EXPO 2024
In February 2024, in the lead up to the 2024 ARSA Annual Conference, ARSA’s training team will offer a
multidisciplinary slate of options during HAI HELI-EXPO 2024 in Anaheim, California.
Sarah MacLeod, Marshall S. Filler, Christian Klein, and Brett Levanto executive team members of the association (and managing members of Obadal, Filler, MacLeod & Klein, P.L.C.) will lead a number of professional education courses as well as “Rotor Safety Challenge” presentation and multiple activities in support of growing regulatory knowledge.
Any participant who completes one of their professional education courses (which are provided on behalf of OFMK) and submits his or her completion certificate to (brett.levanto@arsa.org) will be given a code to access one free hour of ARSA online training.
Click here to register for the event and visit heliexpo.com/education for course information.
Professional Education Courses
Note: These sessions are provided on behalf of OFM&K and are listed in schedule order.
Prophylactic Procedures: Managing Audits, Investigations, and Penalties
Feb. 24 | 1:00 pm – 5:00 pm
This course reviews the regulations, policies, and procedures that generate letters of investigation (LOIs) and the best methods for responding to governmental questions. It describes objectives and performance standards for FAA inspectors, details the circumstances that may lead to an LOI, and provides an overview of administrative and enforcement actions that may result from an LOI.
Know the Rules Like You Know Your Tools
Feb. 24 | 1:00 pm – 5:00 pm
This session covers the FAA’s organization, authority and process for promulgating rules, then walks through the general requirements in 14 CFR to explain how its various components link together in a “regulatory chain” that must be comprehended by aviation businesses. Topics specific to maintenance include part 43 maintenance, preventive maintenance, rebuilding and alteration; part 65, subpart D mechanics (certification); part 65, subpart E repairmen (certification); and part 145 repair stations.
Going Global: Business under International Regulations and Law
Feb. 25 | 8:00 am – 12:00 pm
This course summarizes the framework for international safety regulation, discusses how the International Civil Aviation Organization (ICAO) allocates regulatory responsibilities among contracting states, and explains the important role of bilateral aviation safety agreements, which dictate what US companies must do to operate business aircraft or conduct operations in a foreign country for compensation or hire.
Drug and Alcohol Testing: From Regulatory Basics to Business Needs
Feb. 25 | 1:00 pm – 5:00 pm
This course reviews the drug and alcohol testing requirements in Titles 14 (Aeronautics and Space) and 49 (Transportation) of the US Code of Federal Regulations (CFR). It also provides guidance on setting up these programs, including instruction on how safety-sensitive functions are defined as well as how to avoid many common testing program mistakes that can subject companies to enforcement action.
Regulations Affecting Aircraft Part Purchase and Sale
Feb. 26 | 8:00 am – 12:00 pm
This course reviews the civil aviation regulations in 14 CFR that impact the purchase, sale, receiving, stocking, inspection and installation of civil aviation articles for maintenance purposes. It also overviews other guidance as well as regulatory and contractual requirements that should be considered.
Public Aircraft Operations
Feb. 26 | 1:00 pm – 5:00 pm
This course provides instruction on the statutory provisions and FAA guidance governing public aircraft operations. It covers the basic requirements for an aircraft to be operated as a public aircraft, what constitutes an eligible governmental function, and the practical implications of using the same aircraft to conduct both civil and public operations. It also discusses the FAA policy regarding operations conducted under contract for a government entity.
Rotor Safety Challenge Sessions
Note: This session is are provided on behalf of ARSA.
Building a Professional Relationship with the Government
Feb. 27 | 11:45 am – 12:45 pm
This session provides a road map for building a positive relationship with civil aviation authorities. It begins by describing the rules that should always be considered when engaging with aviation safety regulators, then provides instruction on how to introduce your company and maintain consistent contact — not just when there’s a problem. The session concludes by providing strategies for maintaining a professional relationship with regulators.
Best Practices in Maintenance Recordkeeping
March 7 – 9:15 a.m. to 10:15 a.m. EST
This session explores the regulatory responsibilities of creating and maintaining maintenance records. It will help participants to define:
- Regulatory responsibilities of the operator versus the maintenance provider in creating and maintaining maintenance records
- How obligations can be shifted by contract but not under aviation safety regulations
- Maintenance recordkeeping regulations, the documents essential to making airworthiness determinations.
Whether you are able to participate in Anaheim or not, much of the material presented ARSA’s team members at HELI-EXPO is available through the association’s online training program. To review the library of available courses and register for immediate access to on-demand sessions, click here.
From 2019
ARSA’s Sarah MacLeod really does have a good time at @HeliAssoc @HELIEXPO. Thanks to Advanced Composites Florida for providing proof. #AVMRO pic.twitter.com/Fw9hBBr47z
— ARSA (@ARSAWorks) March 6, 2019
Live From the Conference – Regulations for Supervisors & Inspectors
On March 15, the final day of the 2024 ARSA Annual Conference, the association will present attendees with the first installment of its newest training series: Regulations for Supervisors & Inspectors. The training team is working with the provider of the online platform to make this session available individually for live training registrants to view and participate as it is livestreamed from the Ritz-Carlton, Pentagon City in Arlington, Virginia.
Part 145 requires key personnel to be “familiar with the regulations in this chapter” and ARSA’s training team is developing content to help ensure none of its members falls short of this standard (beginning with knowing what “this chapter” is). This session reviews the cardinal regulatory knowledge necessary for repair station personnel.
Attendance Options:
(1) Register to attend the Annual Conference in person (click here), benefit from the event’s full agenda from content and wrap up your week with this fundamental training.
(2) Stand by for training registration to open via the InReach platform. Regular training registration rates will apply.
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 § 21.4(b), ETOPS reporting requirements.
Click here to download the training sheet.
Note: § 21.4‘s content is broken across multiple training sheets.
Membership
Take Action – Old ARSA Bank Account Closing!
ARSA opened a new bank account in June of 2023, yet despite repeated notifications, members are still using the old account to make ACH and wire payments.
Every invoice since June 2023 has contained a special note in the billing message regarding the account change – and invoices will continue to provide the correct bank account information – but as of February 15, 2024, the old account will be closed, and any payments made to the old account will fail.
Any invoice due or received in the future will have the correct bank account information in red so please update the information with your accounting department or bank.
For questions or to receive the new information before you are invoiced, please contact kimberly.dimmck@arsa.org.
Advertising – How Jobs Make Careers
Members may have noticed other members using association periodicals to attract job seekers. Since almost all members are seeking candidates for open positions, these advertisers can be viewed as employee stealers instead of job seekers.
That view is not only incorrect, but shortsighted and unnecessarily paranoid. Attracting and maintaining talent for all aspects of aviation and aeronautics includes recognizing when your company’s requirements do not match an individual’s capabilities.
ARSA welcomes talent seeking advertisements because there are no better places to find, encourage, educate, and exchange talent than other repair stations and maintenance support organizations.
Every company is different because every employee is different, some want a job, some have talent but no direction, some are seeking knowledge, or money, and some want a career. Whatever the expectations, there is an aerospace position waiting—let each other know about those positions so talent can be attracted to and maintained in aeronautic and aerospace.
Learn how to share your company’s story…and add to it…through ARSA advertising.
Quick Question – Foreign Drug and Alcohol Testing
The FAA has followed a congressional mandate to issue a proposed rule requiring safety sensitive employees in foreign repair stations to be tested for drug and alcohol use under the United States regulations. While ARSA coordinates with its industry association allies to comment on the proposal, member companies can help by providing data through 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/d_and_a_nprm.
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 January:
New Members
GAR-MRO Services, Inc, R02
NAS MRO Services , R03
Returning Members
Aero Accessories & Repair, Inc., R04, 2023
Aircraft & Component Technical Services, LLC, R02, 2009
ATP USA, Inc, R01, 2017
Aviation Avionics & Instruments, Inc., R03, 2012
Barfield Precision Electronics, LLC, R04, 1996
Central Cylinder Service, Inc., R01, 1985
Colorado Northwestern Community College, EDU, 2021
Consolidated Turbine Specialists, LLC, R03, 2018
Delta TechOps Services Group, Corp, 2002
First Class Air Repair, Inc., R02, 2016
Gables Engineering, Inc., Assoc, 1995
Genesis Aviation, Inc., R04, 1994
Helicopter Services, Inc., R01, 2019
Linear Motion LLC, R02, 2017
MTU Maintenance Dallas, Inc., R04, 2020
Sky Aircraft Maintenance, LLC, R01, 2021
Southwest Turbine, Inc., R02, 2018
ST Engineering Aerospace America, Inc., Corp, 2006
Tinker Airforce Base-Sustainment Center Flight Standards Management Office, Military, 2022
World Class Accessory, Inc., R01, 2007
A Member Asked and Answered…Satellite Capability Lists
Q: Can you help clarify the regulation for a satellite repair station capabilities list? I want to add an item to the satellite’s list that is NOT on the managerial repair station’s list.
I interpret the regulation (§ 145.107) as the prohibiting the satellite repair station from holding a RATING the managerial repair station doesn’t have. The rule says nothing about the capability list:
(a) A certificated repair station under the managerial control of another certificated repair station may operate as a satellite repair station with its own certificate issued by the FAA. A satellite repair station—
(1) May not hold a rating not held by the certificated repair station with managerial control… [Emphasis added.]
This unit falls under an accessory rating which both repair stations have. The test equipment is at the satellite facility, and the units will be overhauled there.
So, does the part number need to be on BOTH capabilities lists or are we fine with just listing it on our satellite capability list as it falls under a rating that both facilities have?
A: You are correct; a capability list update is not a change to a rating. Additionally, a capability list need not be by part number unless you have dictated it will be kept that way in your manual. The regulations require a capability list to be kept by make and model or other nomenclature (see, § 145.215(b)), so you might want to look at why you are using part numbers. Also, please make sure that neither RSQM indicates that the capabilities lists have to be the same, the manual should merely dictate how the list(s) are kept…not that they have to change simultaneously.
Good work!
Have questions about aviation regulatory compliance or legislative policy? Ask ARSA first! (…and enjoy this playing of “Satellite” by the Dave Matthews Band.)
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).
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
| Event | Date | Location |
| MRO Southeast Asia | Spring 2024 | TBD |
| HAI HELI-EXPO | 2/26-29/2024 | Anaheim, California |
| ARSA Annual Conference | 3/12-15/2024 | Arlington, Virginia |
| ATEC Annual Conference | 3/17-20/2024 | Tucson, Arizona |
| AEA International Convention & Trade Show | 3/19-22/2024 | Dallas, Texas |
| MRO Americas | 4/9-11/2024 | Chicago, Illinois |
| NBAA Maintenance Conference | 4/30/-5/2/2024 | Portland, Oregon |
| Farnborough Air Show | 7/22-26/2024 | Farnborough, United Kingdom |
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