2024 – Edition 8 – September 6
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.
President’s Desk
Conference Corner
Regulatory Updates
ARSA Works
Legal Briefs
ARSA on the Hill
Training
Membership
Resources
Industry Calendar
The President’s Desk
The Members Ask
It takes competence to succeed in the aviation industry. Both the rules and practical sense require repair stations to have “a sufficient number of employees with the training or knowledge and experience” to perform work. Though ARSA’s team would prefer to edit § 145.151(c) to read “knowledge gained through training and experience,” the requirement for competent persons in maintenance is foundational.
The association’s member companies support competence through ARSA’s primary member benefit: Access to industry expertise. When new companies (or individuals) join, they are provided access to this expertise from the association’s team. For current members, this is an important to get a reminder.
There are three ways you members can take advantage of this essential benefit every day (while booking your trip to join the Annual Conference in March).
(1) Ask ARSA first! You wouldn’t ask the IRS how to do your taxes, so don’t go to the FAA with regulatory questions before knowing the answer. The association offers regulatory analysis and practical advice and (most importantly) helps to figure out what the right question is in the first place.
(2) Online Training. Association members get discounts on live and on-demand training sessions to stay smart, current, and out of trouble. Registration includes 90 days of unlimited access, digital presentation materials, and one certificate of completion. The program is created and overseen by ARSA’s management firm, providing the same expertise available through Ask ARSA.
(3) Model Manuals and Other Tools for Members. Each of ARSA’s model manuals, programs and supplements is based on industry experience, agency guidance and plain-language interpretation of the rules. The publications page gives access to the “free tools for members,” which support a variety of company needs. If you’re considering a manual overhaul, the RSQM Compilation is a comprehensive set of documents compliant with U.S. repair station rules and compatible with certain bilateral partners.
Finally, each edition of the hotline shares a member question (reading it brings immediate benefit and provides inspiration to query the team yourself), lists useful training sessions, and includes new tools and updates. This periodical is your starting point to gaining your own knowledge through the association’s competence.
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Gary Fortner 2024 ARSA president | Fortner Engineering & Manufacturing, Inc. vice president of engineering |
Conference Corner
ARSA’s Eventful Year
Next Month, ARSA’s Board of Directors, key allies, and corporate member contacts will gather outside of Washington, DC for the association’s Leadership Roundtables. The event coincides each year with the board’s annual meeting, bringing regulators and industry together to discuss activities and concerns.
Bringing together government and business interests for aviation safety is ARSA’s everyday business. While tentpole events like the October Roundtables and the Annual Conference each March create visible opportunities for collaboration. The association’s team spends the rest of its year making way (and sometimes doubling back) on the topics garnering the most attention during the in-person meetings.
Regardless of whether you will join the board at the invitation-only Leadership Roundtables (stay tuned for after-event coverage in this periodical), all members should plan their participation at the 2025 Annual Conference. Save the dates for March 18-21 and review the event information from this year to prepare.
The details from the 2024 event are maintained here as a reference for attendees and to assist in preparation for 2025.
Executive to Executive Briefings: Tuesday, March 18, 2025
Participation by industry executives with senior executive branch officials is limited to annual conference sponsors at the Administratium, Platinum, Gold, or Silver levels. In past years, meeting participants included representatives from the U.S. Departments of Commerce, Defense, Labor, State, and Transportation as well as the fellow trade associations and industry interest groups.Legislative Day: Wednesday, March 19, 2025
The day dedicated to educating both the aviation maintenance industry and elected officials. Learn (or brush up) on what ARSA does and what you can do so you're ready for afternoon visits with targeted Capitol Hill legislators and staff.Annual Repair Symposium: Thursday, March 20, 2025
The centerpiece of Conference week, ARSA convenes a full day of substantive panel discussions covering key regulatory compliance and business issues. After the keynote address, regulators from across the world join the full-morning "Opening Salvo" conversation, followed by lunch and an afternoon of practical regulatory and business discussion.Member Day: Friday, March 21, 2025
ARSA's leadership briefs members on the state of the association as well as goals and priorities for the coming year. Participants then close out the event by participating in breakout and/or training sessions focused on key aerospace topics. The Conference ends by 12:00 p.m. EDT.In-Person
All substantive and social activities were hosted at the Ritz-Carlton, Pentagon City in Arlington, Virginia. Legislative Day participants will head to Capitol Hill for meetings with congressional offices as appropriate.
Livestream
The majority of Conference events will be available to livestream viewers via a Vimeo web-player embedded into a page on ARSA.org. All in-person registrants will be able to name a "Conference Ambassador" as a contact to access the livestream and bring the event back to their home facilities. Paying registrants for livestream access may share with multiple company contacts. Livestream participation will include a mechanism for submitting questions to onsite personnel.
Pricing
| Executive to Executive Briefings | ||||
| Open to Administratium, Platinum, Gold, and Silver-level sponsors. | ||||
| Legislative Day – Wednesday, March 19 | ||||
| Members | Non-Members | |||
| First | Additional | First | Additional | |
| In-person | $400 | $360 | $600 | $540 |
| Livestream Free with in-person registration. | $400 | $600 | ||
| Symposium – Thursday, March 20 | ||||
| In-person | $900 | $810 | $1,250 | $1,125 |
| Livestream Free with in-person registration. | $900 | $1,250 | ||
| Legislative Day & Symposium Bundle | ||||
| In-person | $1,100 | $990 | $1,500 | $1,350 |
| Livestream Free with in-person registration. | $1,100 | $1,500 | ||
| The Super Bundle (Silver Sponsorship, E2E, Legislative Day, & Symposium) | ||||
| In-person | $4,200 | $4,500 | ||
| Livestream Free with in-person registration. | ||||
| Member Meeting & Training/Breakouts – Friday, March 21 | ||||
| In-person | Free with Symposium registration. | |||
| Livestream | ||||
(2) Registration fees may be waived for government personnel, members of the media, speakers, and other support personnel or special guests upon approval by the ARSA event team.
Administratium – $20,000
What is Administratium? An element aerospace professionals see every day (click here to learn more). Notation in all publicity, marketing and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, specific thank you in ARSA periodicals, additional advertising placement via ARSA’s communications, complimentary registrations for three (3) participants in the Executive to Executive Briefings as well as three (3) in Legislative Day, and free livestream access for personnel unable to attend in person. At the Administratium Level, sponsors may select one of the following* to specifically support (please note the list in this document does not reflect current availability):- Annual Repair Symposium – Ice Breaker Reception
- Annual Repair Symposium – Thursday Happy Hour
- General Sponsorship
Platinum – $10,000
Notation in all publicity, marketing and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, specific thank you in ARSA periodicals, complimentary registrations for three (3) participants in the Executive to Executive Briefings as well as three (3) in Legislative Day, and free livestream access for personnel unable to attend in person. At the Platinum Level, sponsors may select one of the following to specifically support (may not reflect current availability for 2025):- Online Conference Experience
- Executive to Executive Briefings
- Legislative Day – All Day
- Congressional Directories/Resources
- General Sponsorship
2024 Platinum Sponsors
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Gold – $7,500
Notation in all publicity, marketing and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, specific thank you in ARSA periodicals, complimentary registrations for two (2) participants in the Executive to Executive Briefings as well as two (2) in Legislative Day, and free livestream access for personnel unable to attend in person. At the Gold Level, sponsors may select one of the following to specifically support (may not reflect current availability for 2025):- Legislative Priorities Brochures/Resources
- Digital Companion/Electronic Materials
- Legislative Day – Continental Breakfast
- Legislative Day – Congressional Briefing and Luncheon
- Annual Repair Symposium – Continental Breakfast
- Annual Repair Symposium – Luncheon with Special Guest
- Nametag Lanyards
- Hotel Room Keys
- General Sponsorship
2024 Gold Sponsors
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Silver – $3,500
Notation in all publicity, marketing, and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, conference attendee contact list, specific email alerts to association contacts), recognition in event materials and from the podium, complimentary registrations for one (1) participant in the Executive-to-Executive Briefings as well as one (1) in Legislative Day. At the Silver Level, sponsors may select one of the following to specifically support (may not reflect current availability for 2024):- Annual Repair Symposium – Coffee Break (5)
- General Sponsorship
2024 Silver Sponsors
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Supporter – $2,500
Notation in all publicity, marketing, and periodicals (e.g., the hotline, Dispatch, ARSA team email signatures, specific email alerts to association contacts), and recognition in event materials and from the podium.Contributor – $500 to $2,499 (or equivalent support)
Notation in some publicity, marketing, and periodicals (e.g., the hotline, Dispatch), and recognition in event materials and from the podium.2024 Contributors
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ARSA has reserved a block of rooms for Conference participants at the Ritz-Carlton, Pentagon City in Arlington, Virginia. The hotel hosts most of the activities related to the ARSA Conference and is convenient to the Metro as well as Washington Reagan National Airport (DCA). The deadline for reservations made in this block is Feb. 21, 2025.
To reserve your room(s), visit https://book.passkey.com/go/ARSAAnnualConf2025.
Attendees may also call the dedicated group desk +1.800.422.2410. Reference the ARSA Annual Conference when making reservations. 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.Event Photos
ARSA has created a Google Album including photos taken during the 2024 Annual Conference, which allows participants to share their own photos (Sharing event photos constitutes consenting to their use/distribution in association with Conference-related publicity for this or future events, at ARSA’s discretion). To see the album, click here.Select Recordings
The following selections were highlighted in ARSA's member newsletter, the hotline. Click the headline link to view the recording in the March edition.Legislative Day Briefing – Global Fleet & MRO Market Report
The team from Oliver Wyman CAVOK presented their findings to Legislative Day participants on March 13, illustrating the current and projected states of the North American and global aircraft fleets and related impacts on maintenance demand.
Legislative Day Briefing – Perspectives on Reauthorization
Attendees used these insights (and all the March 13 content) in their meetings on the Hill; all members can benefit from the cross-industry expertise of this lobbyist panel.
Symposium Briefing – What Has ARSA Done Lately
The brief session includes key updates from the association’s year as well as instruction for maximizing membership value.
Symposium Briefing – In the Fire with AVS-1
There were no real flames on stage, but an intense and engaged discussion of the state of the aviation industry. View a clip from the exchange where Sarah MacLeod and David Boulter discuss SMS, training, and more.
Symposium Briefing – Training First
The Symposium portion of the Annual Conference wrapped on March 14 with an hour-long session on how we learn and what we can learn about improving training and personnel development.
Regulatory Updates
FAA Releases Limited-function Repair Station Directory
In August, ARSA tested the FAA’s new searchable directory of certificated repair stations. The system, which has been integrated to include all part 141, 142, and 147 in addition to part 145 certificate-holding facilities, includes geographic search functions and rating filters. Search results are limited and do not allow for downloading a complete dataset: the available “crosstab” provides only basic company name and contact information.
ARSA has contacted the FAA regarding additional search and downloading functions. While it seeks full functionality, members may utilize the currently-available search functions at www.faa.gov/av-info/facility-dashboard.
FAA Reorganizing Guidance on Maintenance Records
ARSA and its allies have received extra time to comment on the FAA’s draft Advisory Circular (AC) 43-9D, “Maintenance Records.” Members should pay attention to the comment process (now due on Oct. 18) as part of an agency effort to reorganize what is contained in public vs. internal guidance.
The draft AC covers how to complete an FAA Form 8130-3 as a maintenance record. This information will be removed from the next draft of Order 8130-21H. The new order will only contain the information associated with completing the FAA Form 8130-3 by a production approval holder or a designee of the Administrator subject to part 21. A draft of Order 8130-21 will be released for comment soon so the two documents can be reviewed for redundant or conflicting information.
The content moving into the AC includes an overview of the form’s use and implications for digital or automated forms management systems. It then provides regulatory references for both U.S. and European use (under the FAA/EASA bilateral agreement) before providing block by block instruction for the form’s completion. After both guidance documents are updated, this information will only reside in the AC.
Agency guidance is not regulatory in nature and cannot create requirements outside those in the rules, which are not changing. The FAA’s planned edits simply rearrange its instruction to certificate holders for use of the form as a maintenance record. ARSA and its allies will use the comment period to push the agency to align the new AC with the regulatory realities of parts 43 and 91.
Auditing the Auditor
Congress’ May 2024 reauthorization of the FAA, requires the Department of Transportation’s Office of Inspector General (IG) to audit the FAA’s Flight Standards and Aircraft Certification Services (see P.L. 118-63, Sec. 821).
ARSA got things started during a meeting with the OIG personnel that will be conducting the audit. As a follow-on, we will be asking members to assist the IG identify issues and potential stakeholders to discuss consistency in interpretation and application of regulation, policy, orders, and guidance across agency offices and individuals.
The association will provide the DOT OIG with anonymous examples of inconsistencies but is seeking applicants and certificate holders willing to provide information directly to the OIG when the audit is announced (which may be as early as mid-2025).
The OIG is to audit consistency of the—
(A) Interpretation of policies, orders, guidance, and regulations; and
(B) Application of policies, orders, guidance, and regulations.
It will seek information from individuals or entities that hold a—
(1) Supplemental type certificate (STC), audit results are due by Nov. 15, 2025.
(2) Air agency certificate issued under part 145, audit results are due by March 15, 2027.
(3) Technical standard order authorization audit results are due July 15, 2028.
It will want to know the reporter’s—
(1) State(s)/region(s)
(2) The type of services it uses within the FAA’s Aviation Safety Office
(a) Aircraft Certification Service
(b) Flight Standards Service
(3) The divisions within the services with whom the reporter has communicated—
(a) Aircraft Certification Service Divisions
(i) Senior Technical Experts Office, AIR-20
(ii) International Office, AIR-40
(iii) Safety and Performance Integration Division, AIR-300
(iv) Integrated Certificate Management Division, AIR-500
(v) Policy and Standards Division, AIR-600
(vi) Compliance and Airworthiness Division, AIR-700
(vii) System Oversight Division, AIR-800
(viii) Enterprise Business Operations Division, AIR-900
(b) Flight Standards Service Divisions
(i) Office of Air Carrier Safety Assurance
(ii) Office of General Aviation Safety Assurance
(iii) Office of Safety Standards
(iv) Office of Foundational Business
(4) The branch(es) within the Service(s) responsible for oversight or with which the reporter communicates regularly—
(a) Aircraft Certification Service Branches
(i) Certification Branches–formerly Aircraft Certification Offices (ACO)—identify the branch as depicted in the link.
(ii) Certificate Management Branches–formerly Manufacturing Inspection Offices (MIO)—identify the branch as depicted in the link.
(iii) Certificate Management Sections–formerly Manufacturing Inspection District Offices (MIDO)—identify the branch as depicted in the link.
(b) Flight Standards Service Local Offices
(i) Certificate Management Offices—identify the office as depicted in the link.
(ii) Flight Standards District Offices—identify the office as depicted in the link.
(5) Whether the reporter hold a single or multiple—
(a) STCs
(b) 145 repair station certificates
(c) TSOA
All members should stay tuned for announcement of ARSA’s audit survey.
ARSA Works
Good Catch, Gary!
Change 9 to the Maintenance Annex Guidance (MAG) for the U.S.-EU bilateral aviation safety agreement was released on June 12, 2024. As the Oct. 8 compliance deadline nears, ARSA members on both sides of the Atlantic are digging into the details and updating manuals and procedures accordingly.
NOTE: ARSA has prepared cross-reference matrices for compliance with the special conditions and assistance with the supplement guidance in MAG change 9. The matrices include “red-lined” versions showing edits between changes 8 and 9. The matrices are available as part of ARSA’s free “tools for members.” To request your updated copy, which is delivered as a .zip file containing the “tools,” complete the order form at arsa.org/publications.
During his own MAG 9 review, ARSA President Gary Fortner (Fortner Engineering) spotted a change that had escaped the ARSA team. Item 1(d) on the Visit Report checklist for EASA Sampling Inspection System (SIS) visits to U.S. repair stations (Section A, Appendix 2) had been changed to read: “Does the repair station retain maintenance records for 3 years after the performance of work?” (Emphasis added.)
Where did three years come from? 14 CFR sec. 145.219(c) requires repair station records demonstrating compliance with part 43 to be retained for a least two years from the date the article was approved for return to service. The special conditions applicable to U.S. repair stations in Annex 2 of the FAA-EASA bilateral say nothing about record retention periods. Past MAGs have, however, referenced a 3 year record retention period for EU AMOs, which is consistent with EASA rules that generally prescribe a 36 month record retention period (see, e.g., Part-M M.A.305 Aircraft continuing airworthiness record system).
Based on Gary’s inquiry (and those of other members), ARSA contacted EASA for clarification. Karl Specht, EASA’s principal coordinator for organisation approvals, quickly confirmed our suspicions that the new MAG misstated the record retention period for U.S. repair stations. The checklist has since been corrected and now asks, “Does the repair station retain maintenance records after the performance of work?”
Thanks to Gary for bringing the issue to our attention. It’s a great example of ARSA and its members working together to keep the authorities honest. If you encounter similar issues, let ARSA know.
Up next month is a change in Section C for European AMOs seeking U.S. certification and working away from the fixed location. Stay tuned for more anomalies that may be discovered (or answered).
Experiencing FAA Misunderstanding of Rulemaking Communications
On Aug. 22, ARSA offered to help the Office of the FAA’s Chief Counsel correct misunderstanding of ex parte communications during active rulemaking. Such engagement is a method of ensuring government-public collaboration encouraged by Department of Transportation policy. The office responded within a week, citing language from the DOT’s guidance that was advantageous to its position that no problem exists.
The Latin term “ex parte” means that a “one sided” information exchange took place without the knowledge of all interested parties. The law (see 5 U.S.C. 533) requires the agency “give interested persons an opportunity to participate…through submission of written data, views, or arguments with or without opportunity for oral presentation.” Citing the statute, the U.S. Department of Transportation’s guidance agrees there are “no explicit prohibitions against ex parte communications in informal rulemaking.” (Emphasis in original.)
ARSA’s letter, signed by Executive Director Sarah MacLeod and delivered to the chief of staff for the chief counsel, continued a theme sounded in the association’s public communications: FAA leadership mistakes the ex-parte protection as a prohibition against rather than instructions for gathering useful information during informal rulemaking. It referenced a long history of this confusion punctuated by a recent public event where an agency attorney reprimanded another representative for violating supposed ex parte prohibitions.
Despite the government’s misgivings, FAA personnel can discuss active rulemaking procedures with the public. If those discussions include substantive regulatory negotiations, involved stakeholders need only include a memorandum in the related docket for public consumption.
“Attorneys in the Office of Chief Counsel must clearly understand, communicate, and support the standards contained in the… [DOT] Ex Parte Communications memorandum,” the letter said. “That document clearly encourages open and continued dialogue with the public throughout the informal rulemaking process.”
Rather than take the association’s letter to heart with an eye towards improving communications, the Office of Chief Counsel denied the issue exists.
“Although our office agrees DOT’s ex parte guidance encourages contact with the public during informal rulemaking, we note it does place guideposts on such contacts,
particularly when discussing deliberative, non-public information to the public after the initiation of a rulemaking,” Laura Megan-Posch, FAA assistant chief counsel for regulations, said in her response. “In sum, although the guidance encourages open and transparent public participation in the rulemaking process, the guidance limits Agency participation in such contacts regarding a petition for rulemaking or after the initiation of a rulemaking.”
Lawyers tend to create adversarial positions even when they aren’t in confrontational proceedings. Informal rulemaking is not an adversarial process; that is why there is no prohibition against ex parte communication if all interested parties are made aware of the exchange and have a chance to comment. An industry representative with extensive experience and knowledge in the administrative process brought an issue to the agency’s Chief Counsel for discussion and resolution. In response, the government also requested details on the meeting and individuals involved in one example of hiding behind ex parte, contrary to the “blame free” safety management system principles touted by the agency. The response contained typical adversarial tactics, which did not surprise the author of the association’s letter. The response is merely proof of the problem, failure to communicate with the industry in meaningful ways.
ARSA’s strategy for improving regulatory compliance depends on open engagement between the FAA and its public. Whenever the agency uses excuses to avoid communicating with its regulated parties – “ex parte” has become such an excuse – the industry’s ability to improve government oversight is weakened. The association is pushing to correct the agency’s error in order to improve the rulemaking process consistent with the law.
To review ARSA’s letter, click here.
To review the FAA’s response, click here.
Industry Gets Extra Time to Review Records AC
On Aug. 9, ARSA joined 11 other aviation trade associations requesting additional time to comment on the FAA’s Draft Advisory Circular (AC) 43-9D, “Maintenance Records.” The FAA subject matter expert in charge of the AC quickly responded with an additional 60 days – the new deadline is Oct. 18.
The draft would replace the current version of the guidance document in use since 1998. The AC provides acceptable means of showing compliance with general aviation record-making and recordkeeping requirements according to parts 43 and 91. Though not regulatory – it provides a method, not the only method for showing compliance – the industry continues to push the FAA to carefully align its guidance with the regulations.
“The document contains changes that must be reviewed carefully to ensure compliance with both parts 43 and 91, while accommodating the proper method for completing an FAA Form 8130-3,” the request said. “To use an FAA Form 8130-3 as a maintenance record, information on its completion must be reconciled with the elements required by § 43.9 and multiple bilateral agreements, maintenance implementation documents, and other advisory material.”
Note: Get background on the larger “reorganization” of maintenance records guidance in this month’s “Regulatory Update.”
To read the complete request, click here.
To view the coordinated copy of the draft AC, click here.
In addition to ARSA, the following organizations supported the request*:
Aircraft Electronics Association
Aircraft Owners and Pilots Association
Airlines for America
Aviation Suppliers Association
Aviation Technician Education Council
General Aviation Manufacturers Association
Modification and Replacement Parts Association
National Air Carrier Association
National Air Transportation Association
Professional Aviation Maintenance Association
Regional Airline Association
*The Aerospace Industries Association confirmed to ARSA its own separate request in support of the group’s need for more time to comment.
Draft Fabrication AC Needs to Wait on ICA ARC
On Aug. 1, 21 representatives of the Instructions for Continued Airworthiness Aviation Rulemaking Committee requested the FAA withdraw Draft Advisory Circular 43-18A.
The group’s letter to Associate Administrator for Aviation Safety David Boulter highlighted multiple policy issues in the draft guidance on fabrication by maintenance personnel that fell under FAA tasks given to the ARAC committee considering ICA compliance and enforcement. Those issues include ARC tasks to—
(1) Propose a clear baseline standard defining ICA, recommending performance-based requirements for applicability, content, and availability as necessary to address specific areas of controversy.
(2) Address the requirement that a design approval holder must furnish or make available ICA while a maintenance provided does not.
(3) Propose the role of repair source approval and criticality of parts and repairs.
“Since the ARC recommendations are to address the information in the draft AC, the members represented below ask the FAA to withdraw it from public comment and provide any comments received to the ARC, whose final report will provide direction to the agency as part of its complete review of the issue,” the group said.
In addition to ARSA, the following aviation trade associations and private businesses joined the letter:
Aerospace Industries Association
Aircraft Electronics Association
Aircraft Owners and Pilots Association
Airlines for America
Cargo Airline Association
Chromalloy
Collins Aerospace
First Aviation Services
HAECO Americas
HEICO Corporation
Honeywell Aerospace
International Air Transportation Association
Modification and Replacement Parts Association
National Air Carrier Association
National Air Transportation Association
National Business Aviation Association
Pratt & Whitney
Professional Aviation Maintenance Association
Regional Airline Association
Vertical Aviation International
To read the complete letter, click here.
Final Documents/Your Two Cents
This list includes Federal Register publications, such as final rules, Advisory Circulars and policy statements, as well as proposed rules and policies of interest to ARSA members.
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.
First, Kill All the Lawyers
By Sarah MacLeod, Executive Director
It will not surprise ARSA members that its executive director has taken on the issue of FAA’s use of ex parte communications as a shield to keep information at bay instead of a method for ensuring the best regulations are written. It recalls the misunderstood line uttered by Dick the Butcher in Act IV, Scene II from Shakespeare’s Henry VI, Part III. Dick is helping Jack Cade lead a rebellion against the King and to make it easier to take over a populace ignorant of its rights, Dick says, “The first thing we do, let’s kill all the lawyers.”
ARSA’s first attempt to ensure the agency understood the industry and Congress’ concerns over the use of ex parte to avoid communications with industry did not return a positive result. No doubt it is because the persons in the FAA’s Office of Chief Counsel responsible for regulations took umbrage at the tone and approach.
Unfortunately, the response proved the concerns are valid; failure to listen to the public is the reason ex parte communications are not prohibited during informal rulemaking. Despite the protestations of the Office of Chief Counsel, even if the contact is truly ex parte and influences the agency’s rulemaking, taint can be removed any number of ways. One is for the agency to actively reach out to other interested parties for information, or extend the comment period after docketing the substantive information so interested parties have an opportunity to provide opposing or supportive views, or if worse comes to worst, withdrawing the pending rulemaking or even a final rule, and issuing a supplemental notice of proposed rulemaking.
In fact, the agency has a readily available Federal Advisory Committee Act-compliant committee to vet any questions, gather needed information, and ensure the activity is public—that is, the Aviation Rulemaking Advisory Committee. ARAC’s Charter clearly recognizes it as a method of obtaining “information, advice, and recommendations…concerning rulemaking activities…”. Yet, the Office of Chief Counsel used ex parte as the reason for not meeting with it; a committee that was created to obtain information from all interested parties, including the general public, for resolving or clarifying rulemaking questions. ARAC meetings are public and the committee includes all directly and indirectly impacted parties.
So, when the agency needs to understand the impact of a potential rule, it should openly use its own forum to gather information, even during deliberations on a pending rule after the comment period closes. If the ARAC information creates a better regulation, a delay of 30 to 60 days to reopen the comment period would be well worth it.
Even more importantly, the public can play a role in removing any ex parte stigma by ensuring meetings always contain interested and directly affected parties and that any substantive information provided to the agency is submitted to the docket so the agency can add any information it wishes to ensure that a proper review can be made.
Using any other approach to ex parte communications during informal rulemaking merely invites industry suspicion, congressional concern, and public reprimand.
Editor’s note: This material is provided as a service to association members for educational and informational purposes only. It does not constitute legal or professional advice and is not privileged or confidential.
Layman Lawyer – The E in Pear
By Brett Levanto, Vice President of Operations
The layman lawyer is continuing an exploration of Safety Management Systems as a human factors practice by diving into each element of the PEAR Model.
| Who’s Driving? ARSA Executive Director Sarah MacLeod recently saw Pixar’s Inside Out, so the association’s team has been reflected on how its core emotions drive its actions. Responses so far show that most (but not all) ARSA members believe “Joy” is in control…share (anonymously) which of these five emotions drives you in the still-open quick question from July 2024. |
The primer in the June 2024 hotline introduced “people, environment, actions, and resources” as a safety assurance structure. Last month’s article looked at the “human” performance elements of the model, which exists within the working environment provided by a company and created by its people. Ssome examples from ARSA’s Human Factors training include:
- Physical: Location, Workspace, Lighting, Noise, Shift, Safety.
- Organizational:
- Direct: Supervision, Personnel, Employee-Management Relations, Pressures.
- Indirect: Crew Structure, Company Size, Profitability, Morale, Culture.
The FAA Safety Team’s “Human Factor’s Guide for Aviation Maintenance and Inspection,” explains human factors is a science of people’s interactions with the world around them. That world is formed by the working environment.
“The term ‘environment,’ in the context of human factors, refers to both the physical workplace and the overall organizational framework within which the aviation maintenance department exists,” the guide explains. Physical factors can be passing, like a bad storm in a line maintenance environment, or enduring like the constant threat of evening thunderstorms in a hot climate. The impacts of these factors are to be assessed and mitigated, particularly what is learned from exceptional events.
The “organizational” environment elements are more mercurial but perhaps more important. Mitigating these inter-personal and strategic issues requires personal ownership, not just for oneself but also in terms of impact on others.
This series continues the reference from ARSA’s overview training session references the Three Stooges performance as aviation professionals in “The Dizzy Pilots.” Larry, Curly, and Moe’s work is entertainingly inhibited by their poor choice of facilities. The “Wrong Brothers” can’t even fit their aircraft through the door, so the physical plant is clearly inappropriate.
From an organizational perspective, increasingly poor personal interaction and lax oversight prevent performance of their work. While funny in an old TV comedy, these kinds of problems must be avoided in aviation.
Awareness and ownership are first steps to mitigating environmental factors. A fully formed SMS translates that attention into a means of observing, assessing, and reporting on environmental risks to both personnel and aviation safety.
For tools that can help ARSA members with the translation to SMS, go to arsa.org/sms-program for resources available through a partnership with the Aircraft Electronics Association.
ARSA on the Hill
The Countdown
By Christian Klein, Executive Vice President
With both major party conventions behind us, the race for the presidency has begun in earnest. But more than the White House (and control over the entire executive branch) is at stake. Razor thin margins in both the House and Senate mean Congress is also up for grabs in November. Lawmakers will want to spend as much time as possible between now and election day campaigning back home, complicating efforts to finish remaining “must do” bills.
At the top of the list is appropriations. Bills like the recent FAA reauthorization authorize funding for federal agencies and departments for multiple years (“the FAA can spend this much money in FY 2025, 2026, 2027, and 2028 …”), but Congress still must appropriate funds annually (“…. and here’s the FAA’s money for FY 2025”). If the appropriations bills don’t get done, all or some of the federal government shuts down at the end of the fiscal year (Sept. 30). Not even one of the 13 FY 2025 appropriations bills has been enacted, so the likely path forward is a short-term appropriations omnibus bill to fund all of the federal government.
Neither party wants a government shutdown weeks before the election, but there will be partisan wrangling. Republicans want to pass a longer continuing resolution through March; Democrats are pushing a shorter bill to get us past the elections.
Uncertainty is bad for business and the last government shutdown was a disaster for industry and the FAA alike, so ARSA is encouraging swift action and compromise to make sure the agency can keep working. Additionally, ARSA wants to make sure money flows to the aviation workforce grant programs the association led the charge to create in the 2018 FAA bill.
Another must-do item is the National Defense Authorization Act (NDAA). ARSA has pressed Congress and the Department of Defense for years to enhance competition for DoD aviation maintenance contracts. Inflated costs and military readiness aside, geopolitical instability makes the deconsolidation of the defense industrial base even more important for the supply chain. We’re working to make 2024 the year we get the ball across the goal line.
What will ultimately happen is anybody’s guess, but recent history suggests we’ll get a short-term omnibus through mid-December and that Congress will then pass a bill funding the government into late winter that includes the NDAA.
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Learning to Fish
“Give a person a fish and they’ll eat for a day; teach them to fish and they’ll eat for life.” ARSA lives by that mantra. Our regulatory compliance assistance helps members understand the regulations better than regulators and empowers industry professionals to be zealous advocates. That philosophy also holds true when it comes to our congressional lobbying.
The best lobbyist for your company is you. No one understands better what you do, how you do it, and how your operations are affected (positively and negatively) by government. Through ARSA’s grassroots program, members build relationships with lawmakers so they can engage Congress effectively when crises arise, or important legislation is considered.
(From left) Bob Arnett, Greg Stanton, and Bill Grantham together in August. Photo courtesy Bob Arnett.
This summer, the association is leveraging ARSA Political Action Committee (PAC) funds to strengthen ties between our members and Congress. Activist members in key states are coordinating with ARSA to schedule meetings to (re)introduce the maintenance industry and deliver ARSA PAC support to candidates who share our commitment to fair, effective oversight and achieving the highest level of safety by the most efficient means possible.
The effort kicked off this month when members Bob Arnett (Earp Aviation Repairs) and Bill Grantham (International Air Response) met on ARSA’s behalf with Rep. Greg Stanton (D-Ariz.) on Aug. 19 to deliver ARSA’s contribution. Stanton, a former Phoenix mayor, has been representing Arizona’s 4th congressional district since 2019. Significantly, he’s been a member of the House aviation subcommittee that whole time, which is appropriate given that aviation maintenance is big in Arizona, employing close to 12,000 workers and generating $2.37 billion annually for the state’s economy.
Other efforts are underway between now and the election. If you’re interested in “learning to fish” and strengthening your (and ARSA’s relationship) with your congressional representatives let ARSA know.
Finding Your Member of Congress
In the summer of an election year, senators and congressmen want to meet constituents. ARSA members should take advantage of this interest to schedule facility visits, town halls, meet and greets, or any other excuse to spend time with the person representing your business in Congress.
As ARSA Legislative Day participants hear every year, building an ongoing relationship with your elected officials is really a matter of simple effort. The most successful constituents are patient and persistent…and they know how to use a few simple tools for finding their members of Congress.
Who represents you?
Using ARSA’s Legislative Advocacy Tools – provided all year by Conference sponsor Aircraft Electric Motors – find your elected officials by entering your zip code in the “Election Center.” (Remember to enter your personal zip code and also the one for all facilities associated with your company; there may be multiple officials/offices with an interest in your needs.) Get started at arsa.org/congress.
When will they be home?
Members of the U.S. Congress try to spend as much time in their states/districts as possible. Both the House and Senate leadership have published session calendars for 2024. By reviewing these calendars, you can determine when your senators and congressman are likely to be “back home” by looking for dates not in session. Review the schedule documents below and find updated information at www.congress.gov/calendars-and-schedules.
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What do you do now?
Contact use the contact resources available at arsa.org/congress to get in touch with the offices that represent you and invite them to visit your facility on one of the dates for “district work.” For talking points and other guidance, visit arsa.org/legislative or contact ARSA.
Aviation Life Calendar
September Through December
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 |
| September | All | This Day in Aviation History – September |
| September | 4 | 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 Aviation History Month |
| November | 8 | National STEM/STEAM Day |
| December | All | This Day in Aviation History – December |
| December | 7 | International Civil Aviation Day |
| December | 17 | Wright Brothers Day |
Training & Career Development
Part 65 Mechanic Certificates
This session reviews the requirements of 14 CFR part 65 subpart D, which concerns aviation mechanics. It walks through the requirements for an individual to apply for a mechanic’s certificate, then defines the privileges and limitations bestowed on that individual by his or her certificate. Finally, it covers the enhancements to a mechanic’s privileges produced by obtaining Inspection Authorization.
Instructor: Sarah MacLeod
Click here to register and get access for 90 days.
This is part of a three part series on part 65 the association has made available (see the other two sessions below). Want all three? Click here to purchase together and save.
Other Sessions on Part 65 (Click title to see more)...
Part 65 – Getting a Repairman's Certificate
This session reviews the requirements of 14 CFR part 65 subpart E, which concerns aviation repairmen. It presents the language of part 65 in the context of parts 121, 135 and 145 as well as agency guidance regarding the management of repairman applications. Throughout, the session connects and compares the repairman’s requirements to those of the mechanic’s certificate issued under part 65.
Instructors: Sarah MacLeod & Brett Levanto
Part 65 – Overview
Part 65 – Overview
This session overviews 14 CFR part 65, Certification: Airmen Other than Flight Crewmembers. It introduces the statutory authority through which the FAA administers certificates and outlines the rules for application, issuance, testing, disqualification and duration of agency-issued certificates. It then introduces the five different certifications issued under part 65 by reviewing the relevant eligibility requirements for each.
Instructor: Sarah MacLeod
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.
Recordkeeping for Mechanics
Proper maintenance demands proper documentation. Listen to ARSA Executive Director Sarah MacLeod and learn how to “finish the job with proper paperwork.”
This session defines the regulatory responsibilities of the operator versus the maintenance provider in creating and maintaining maintenance records, including how obligations can be shifted by contract, but not under aviation safety regulations. It also covers maintenance recordkeeping regulations; the documents essential to making airworthiness determinations.
Click here to register and get access for 90 days.
Registration for an ARSA training session includes:
- Access to the on-demand recording of each session for 90 days.
- Digital copies of the presentation and all reference material with links to relevant resources and citations.
- A certificate upon completion of each class.
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 145 – Friends in Certificated Places
This session* provides an overview of business and aviation safety requirements associated with repair station personnel requirements. Upon completion of this session, participants will have the tools to understand:
- What employees are required for a repair station certificate?
- What qualifications must those employees possess?
- What are the approved training program requirements?
Click here to register and get access for 90 days.
*The slides included in this session’s materials PDF have been corrected to update the description of repairman certificate eligibility on slides 18 and 20. Please ensure you are accessing the most recent version when utilizing these materials.
Registration for an ARSA training session includes:
- Access to the on-demand recording of each session for 90 days.
- Digital copies of the presentation and all reference material with links to relevant resources and citations.
- A certificate upon completion of each class.
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 §§ 21.16, 21.19, and 21.20, basic requirements related to applications for type certificates.
Click here to download the training sheet.
Membership
For Your Benefit
ARSA’s members give the association life and take business value out of the association’s work. Maximize your company’s use of its member benefits:
(1) Access to Industry Expertise. Got a question? Ask ARSA First!
(2) Periodicals. You’re reading one right now! Make sure you’re getting them all.
(3) Discounts on Online Training. Learn more about how ARSA turns its experience into your knowledge.
(4) Discounts from ARSA-Approved Preferred Providers. Click here to see deals on office supplies and payment processing.
(5) Discounts on Advertising Placements in ARSA Communications. Showcase your company, a product, or event while demonstrating commitment to the only association representing the international aviation maintenance industry.
(6) Discounted Legal Fees. Jump to the website of ARSA’s management firm.
(7) Reduced Rates on ARSA-produced Publications. See the tools and models developed by the team for industry use.
(8) Safety Management System Program Management by AEA. Click here to learn more and enroll.
(9) Special Rates for Event Attendance, particularly the Annual Conference held each spring.
(10) New benefit coming soon! Stay tuned.
Advertising – Going Beyond
“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. When you see a company in the pages of a periodical like the hotline or on ARSA.org, you can see more than just what they sell…you see who they are.”
Josh Krotec, 2023 ARSA President, “The President’s Desk,” June 2023.
First Aviation Services Vice President Josh Krotec reported often when he was ARSA’s president on the progress of the association’s “takeback” of its advertising and periodical distribution programs. Krotec always made one point clear: The value of ARSA.
Enhance that value by going beyond your membership dues and investing in your commitment to quality and commonsense compliance through an advertisement in ARSA’s publications, website, or training sessions.
Sell a product or service, celebrate an event, recruit fellow professionals, or simply take pride in seeing your company clearly associated with the voice of the aviation maintenance industry.
To learn more about ARSA’s advertising program, click here.
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 August:
New Members
Able Aerospace Services, Inc., R05
Aircraft Tooling, Inc., R01
Aviation Fabricators, Inc., R03
Koturov, Myrat, Affil
Setnix LLC, R01
Stein Seal Company, R01
Renewing Members
Aerotron AirPower, Inc. dba Fokker Services Americas, R04,
Aero Instruments & Avionics, Inc., R04, 1991
Aircraft Lighting International, Inc., R01, 2018
Airframe Components by Williams, Inc., R02, 2003
AllFlight Corporation, R03, 2011
Ameron Global Product Support, R02, 2004
Aviation Repair Solutions, Inc., R02, 2006
Eagle Creek Aviation Services, Inc., R04, 2016
Empire Airlines, Inc. dba Empire Aerospace, R04, 2002
Engine Disassembly Services, Inc. dba Engine Overhaul Services, R01, 2018
EXTEX Engineered Products, Inc., Assoc, 2002
IBM Flight Operations, Assoc, 1997
International Turbine Industries, LLC, R02, 2010
Millennium International, L.L.C., R02, 2013
MTI Aviation, Inc., R02, 2011
MTU Maintenance Hannover GmbH, R06, 2007
Nampa Valley Helicopters, Inc., R02, 1993
NFF Avionics Services, Inc. dba NFF Aviation Services, R02, 2010
Pearl River Community College, EDU, 2020
Precision Aero Technology, R03, 1993
Regional Avionics Repair, LLC, R03, 2006
Rotron, Inc. dba Ametek Rotron, R02, 2016
S & K Aerospace, LLC dba AE & C Services, LLC, R01, 2017
STS Aviation Group, Corp, 2020
Tennessee Aircraft Company, Inc., R01, 2012
The Zee Company, Inc., R02, 2019
Vanguard Aerospace, LLC, R01, 2022
Wavestream Corporation, R04, 2021
A Member Asked…Recent experience?
Q: I hold a mechanic’s certificate that I have not used (signed off on work under my own certificate) for more than 24 months. As the accountable manager of a repair station applicant (still waiting in queue), if I have technically supervised other mechanics performing non-certificated work, do I meet the recent experience requirements of § 65.83?
A: As always, it depends. Currency can be gained in three ways other than serving as a mechanic:
(1) Technically supervise others, i.e., oversee those unfamiliar with the tasks.
(2) Supervise, in an executive capacity, the work on aircraft.
(3) Any combination of (1) and (2).
The answer to technical supervision in a repair station is contained on the roster of supervisors, inspectors, and managers. It would not be a question of whether you “could” but whether you are listed as doing so, and in fact, perform that function as it is delineated in § 145.153.
With respect to executive supervision, the regulation uses the term aircraft, which has a definition in § 1.1. The agency may not necessarily take the term literally, using instead a broader definition for repair station management personnel – that any article is part of an aircraft – would no doubt depend upon, again, whether your name and management role is shown on a roster of the repair station.
For another walk-through of a similar question, refer to the November 2018 edition of the hotline. To help provide additional detail to ARSA and other members with questions related to recent experience, contact the association to share issues you’ve faced related to § 65.83.
Have questions about aviation regulatory compliance, legislative policy, or ARSA resources? Ask ARSA first!
Quick Question – Campaign for Yourself
ARSA’s legislative team works hard for the industry every day (with great success); the maintenance community can support its association by engaging directly with elected leaders. By investing personally in the political process at the local, state and national level, aviation professionals can help drive home important messages and put a human face on the general arguments made by the association.
With the U.S. national election fast approaching, now is the time for maintenance professionals to engage with their elected officials and candidates. To help ARSA enhance the industry’s engagement, take a moment to share your experience with activities that bring you and your company closer to those who represent your interests in government.
If the embedded survey does not appear below, use the following URL to access the questionnaire in your browser: https://www.surveymonkey.com/r/maintenance-advocacy.
Note: The question is displayed in its own, embedded window. If the “Done” button is not visible on the screen, you must scroll within the survey window in order to submit your response.
For more information about this or any other question, contact Brett Levanto (brett.levanto@arsa.org).
Click here to see what questions have been asked and answered…and keep a lookout for more.
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 |
| Aero-Engines Europe | 9/10-11/2024 | Amsterdam |
| World Remanufacturing Conference | 9/10-12/2024 | Chicago, Illinois |
| ATEC Fly-In | 9/17-19/2024 | Washington |
| World Sustainability Symposium | 9/24-25/2024 | Miami, Florida |
| MRO Asia-Pacific | 9/24-26/2024 | Singapore |
| IAQG Meeting Week & 56th General Assembly | 10/21-24/2024 | Tokyo |
| MRO Europe | 10/23-24/2024 | Barcelona |
| 2024 NBAA Business Aviation Convention & Exhibition | 10/22-24/2024 | Las Vegas, Nevada |
| MRO Australasia | 11/13-14/2024 | Brisbane, Australia |
| NATA Aviation Business Conference | 11/13/2024 | Nashville, Tennessee |
| AOPA High School Aviation Symposium | 11/17-19/2024 | Atlanta, Georgia |
| ARSA Annual Conference | 3/18-21/2025 | Arlington, Virginia |
| IAQG Meeting Week & 57th General Assembly | 4/7-10/2025 | Brussels |
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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