2025 – Edition 4 – May 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

Legal Brief

Layman Lawyer

ARSA on the Hill

Training & Career Development

Membership

Resources

Industry Meetings & Events

The President’s Desk

Efficiency Pays

The smooth transition of association’s leadership should surprise none of the hotline’s loyal readers, who have experienced the association’s efficient management of its members’ resources. Regular reports regarding membership terms, training resources, essential regulatory compliance information and publications, legislative engagement, and countless other ways it serves industry are constantly flowing. Directors are well served by these efficiencies: Our yearly ARSA commitment is predictable between sets of elections held during the October annual meeting.

That predictability allows for quick adjustment to unexpected developments. When my immediate predecessor and fellow director Bob Mabe announced a career change requiring him to step down as the association’s president, a simple email referencing the relevant bylaw informed me of my promotion.

A couple weeks after that efficient transition, I was able to report on the “state of the association” at the Annual Membership Meeting by simply highlighting the support ARSA needs to ensure we all thrive. Chromalloy, my employer and an enterprise member, provides that support through advertising, Conference sponsorship and meeting participation, membership on government committees formed because of the association’s legislative activities, and in many other ways. All expenditures result in a return on investment for the company and the international community. The cost of supporting every aspect of ARSA’s work eliminates the expense of “doing it alone”.

Being president is a means for me to express direct appreciation for the association’s efficiencies and to ensure all members receive a return on their investment. The rest of my term will give me a “bully pulpit” to push for members to increase their return on investment in this association’s efficient and effective work. As the adage attributed to Ben Franklin goes, “We must all hang together, or assuredly we shall all hang separately.”

When hanging together saves resources in time and money, and is efficiently managed to obtain the most impact for the least investment, how can one go wrong?

John Riggs 2025 ARSA president | Director of Airworthiness, Chromalloy

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ARSA Works

What ARSA Has Done Lately – First Quarter 2025

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 aerospace safety for the first quarter of 2025.

Board Composition

The board elected Bryan Scott, HAECO Americas vice president of safety and quality, to complete the term of departed director Bob Mabe. It also elected sitting director Jon Silva, AeroKool president and CEO, as ARSA 2025 Treasurer.

Fiscal Health

Strong Annual Conference revenues powered association income in the first quarter.

Membership

The association welcomed 19 new members in the first quarter and recovered an additional five that had lapsed in the final quarter of last year. Complete data for 2024 shows ARSA member renewal was better than 90 percent.

Regulatory Advocacy

• Participated in Instructions for Continued Airworthiness Aviation Rulemaking Committee.
• Joined industry coalition requesting more time to comment on Draft FAA Order 8130.21J.
• Reported BOB decision updating Special Conditions between United States and European Union to require Safety Management Systems.
• Circulated OFMK survey regarding industry experience with certification and operation of restricted category aircraft.
• Reported updated FAA guidance for aviation safety inspectors overseeing domestic repair stations holding foreign approvals.
• Began developing foreign repair station drug and alcohol toolkit.

Membership of TSA Aviation Security Advisory Committee “eliminated” by new administration.

Legislative and Lobbying

• Advocated for improved address maintenance data access in FY 2026 National Defense Authorization Act.
• Supported reintroduction of Aviation Workforce Development Act (H.R. 1818/S. 1561) by Rep. Mike Collins (R-GA) and Sen. Tim Scott (R-GA).
• Supported coalition efforts to increase funding for air traffic control technology, infrastructure, and staffing.
• Updated ARSA Legislative Action Center to support 2025 Legislative Day outreach and member engagement with new Congress.

Communications and Surveys

ARSA in the News – Selected Industry Coverage

Tariffs Pose Big Challenges for Industry

Aviation Maintenance Magazine | Q1 2025

Christian Klein of ARSA and Jason Dickstein of MARPA share insights with the magazine on how international supply chain issues will impact the maintenance community.

Weston Award Recognizes Crowley’s Commitment to Learning

AviationPros | March 31, 2025

Before commencing the regulatory discussion of ARSA’s Annual Repair Symposium, Managing Director and General Counsel Marshall Filler called the assembly to order for the special award presentation.

US aviation coalition appeals to Trump for aerospace exception from tariffs

Aerotime | March 13, 2025

“The aviation supply chain involves tens of thousands of suppliers from all over the globe which provide parts, platforms, and systems that require safety approval for use and installation, all of which may not be easily replaced or substituted,” the coalition wrote.

ARSA-placed Industry Editorials and Content

Advertising

Next phase of outreach will engage past advertisers; follow up with ARSA Conference and other industry event sponsors. Team reviewing variable term options (i.e., shorter than 12 months).

Surveys

Annual Member Survey

• 109 Responses
• Membership Satisfaction Score: 4.58 (out of 5)
• Value of Association Benefits (out of 5):
  • Access to Expertise (4.62)
  • Regulatory Compliance Support (4.58)
  • Regulatory Compliance Resources (4.46)
  • Periodicals (4.16)
  • Congressional Advocacy (4.05)
  • Online Training (4.01)
  • RSQM Compilation (3.96)
  • Events (3.88)
  • Advertisements (3.56)
• Most Pressing Risks Facing Industry (Percent of Responses; Multiple Selection):
  • Difficulty Finding Technical Talent (62%)
  • Regulatory Costs (40%)
  • Availability of Maintenance Information (37%)
  • Overall Economic Uncertainty (36%)
  • International Inconsistency/Duplicative Oversight (28%)
  • Inconsistency of National Regulatory Enforcement (26%)
  • Restrictions on International Trade (22%)

Workforce Development

ARSA Helps CNBC Illustrate Career Development “Challenge”

On Feb. 14, CNBC published a 12 minute special addressing the workforce and career development challenges facing the maintenance industry. ARSA Executive Director Sarah MacLeod participated, lending a voice to the data and analysis provided behind the scenes by the association to producers constructing the video.

ARSA Joins Workforce Grant Application

On Feb. 5, the aviation non-profit Choose Aerospace, which administers ARSA’s annual scholarship in addition to providing a maintenance-focused curriculum for student and employee development programs, included the association on its application for an FAA Technical Workforce Development Grant.

Events & Meetings

Annual Conference Feedback (1 to 5)

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.
• Sarah had recurring meetings with Ric Peri of AEA.
• Sarah and Christian participated in multiple meetings supporting working groups associated with the Instructions for Continued Airworthiness Aviation Rulemaking Committee.
• Christian and Brett held monthly collaboration calls with Oliver Wyman Vector.
• The ARSA management team had lunch with Aron Ludovic of EASA (Jan. 15).
• Brett met with a new member regarding tools and training (Jan. 27.).
• Christian met with a member regarding the FAA/EASA MAG. (Jan. 29).
• Christian met with Alex Burstein of Citrus Television regarding ASAC (Jan. 30).
• Christian spoke with a member regarding multiple association initiatives (Feb. 4).
• Brett spoke with John Estes of Goodwin Recruiting regarding workforce issues (Feb. 4).
• Christian met with a member regarding Schedule A opportunities for recruitment and career development (Feb. 5).
• Brett met with a non-member regarding Human Factors training (Feb. 5).
• Christian met with Andrew Langer of the Inst. For Liberty/CPAC regarding regulatory issues (Feb. 18).
• Sarah, Marshall, Brett and Christian attended VAI VERTICON (Mar. 9-12).
• Brett spoke with Georgia Halliday of Aviation Week regarding panel participation at MRO Atlanta (Mar. 25).
• Christian and Josh Krotec met with Alex Thymmons of Rep. Harrigan’s office regarding NDAA (Mar. 28).

Championing the Industry at MRO Americas

On stage and behind the scenes at the Georgia World Congress Center, ARSA leaned into the 2025 MRO Americas convention theme: Shaping the future of aviation maintenance.

Brett Levanto, association vice president of operations, participated in multiple panels at both the main event and the co-located Systems Integration Summit. He also supported colleagues administering the Aerospace Maintenance Competition where 87 teams competed across 27 events – with ARSA members among the thousands watching the livestream from across more than 50 countries.

During his mainstage presentation on April 8, Levanto moderated a discussion between four developing aviation maintenance professionals. The group included a student (and Competition team member) from Embry Riddle, a recent Aviation Institute of Maintenance graduate (and valedictorian), a technician-turned-new-manager at Wheels Up, and a mechanic apprentice from United Airlines. Collectively they illustrated their different pathways into aerospace careers and instructed industry attendees as to how to best support aviation opportunities for their peers.

AMC teams are judged across each event – from safety wire to fan blade removal to electrical troubleshooting – according to the time required to complete the task in addition to penalties and bonuses specific to the task. Teams lose points for improper tool use, recordkeeping errors, and safety violations among other potential penalties while gaining bonuses for task-specific actions like FOD clearance or blade installation.

Southwest Airlines – Team Herb (as opposed to “Team Colleen”) took the William F. “Bill” O’Brien award as the top overall team. Tarrant County College took first place in the school category.

Sandra Acree (front row, to the right of the Taylor bust) poses with her AMC teammates from Embry Riddle Aeronautical University. Just 20 minutes before, Acree had been onstage discussing maintenance careers with MRO Americas industry attendees.

The AMC has grown into a worldwide event since its founding by John Goglia, who was announced in October 2024 to be the first mechanic nominated to the Aviation Hall of Fame since Charlie Taylor. The event has grown thanks to support by the aerospace community, which hosts and judges, provides prizes, and sponsors to offset the cost of bringing more than a thousand competitors together each year. Competitions are now hosted annually at both MRO Americas and VAI VERTICON.

ARSA encourages members to consider fielding teams for either event as well as supporting the AMC. Click here to learn more.

A Simple Opportunity

In April, ARSA participated in a roundtable hosted by the U.S. Small Business Administration’s Office of Advocacy that focused on the Department of Transportation’s Request for Information supporting regulatory reform (see this month’s “Layman Lawyer” for information on the RFI and how to participate). The association used the discussion and follow up to highlight a simple opportunity to address the FAA’s tendency to enforce requirements not supported by the rules: Review Operations Specifications paragraphs to address those not required by 14 CFR.

Here is the overview provided by ARSA using the SBA rubric:

DOT agency:

FAA

Name and citation of regulation:

14 CFR parts 119, 145, and 147 among others that require the issuance of Operations Specifications paragraphs.

A very brief summary of the issue (no more that 3-5 sentences):

The development of mandates on applicants and certificate holders through policy rather than the Administrative Procedure Act. The agency adds requirements through “Operations Specifications” paragraphs issued under 14 CFR parts 119, 145, and 147 (among others) that (a) are not contained in the regulation and in some cases have been specifically rejected during informal rulemaking, and (b) create unnecessary expenditures of time and money by the agency, applicants, certificate holders, and the public.

How does this issue burden small business?

It adds to the financial and time burdens associated with obtaining and maintaining certificates issued by the FAA. Since policy can change at the discretion of the agency, without notice or comment from the public, new or differing “requirements” can result in requests for “corrective actions,” issuance of letters of investigation, and notices of proposed civil penalty and/or certificate action that unnecessarily burden the agency and industry, particularly small businesses.

What would you like the agency to do?

Follow the advice of the industry contained in numerous solicited and unsolicited recommendations and create a method of developing Operations Specifications paragraphs that clearly distinguish among those (a) required by regulation, (b) requested by a certificate holder that can and should be issued in the interest of safety, and (c) developed for the convenience of the agency.

How would this change benefit small business?

It would remove unnecessary burdens from all applicants and certificate holders subject to 14 CFR requirements AND it will reduce the work for the agency to issue and keep the operations specifications paragraphs current.

The letters and recommendations associated with operations specifications paragraphs include:

• November 21, 2007 request for Chief Counsel to review unilateral changes to repair station operations specifications without due process.
• January 17, 2013 recommendation from the FAA appointed Consistency of Regulatory Interpretation Aviation Rulemaking Committee (CRI-ARC), followed by October 19, 2015 industry letter supporting creation of guidance based solely on regulations and a November 22, 2019 letter from ARSA to the new chief counsel on the same subject.
• April 13, 2018 industry letter supporting the congressional mandate that without “a written finding of necessity, based on objective and historical evidence of imminent threat to safety, the Administrator shall not promulgate any operations specification, policy, or guidance document that is more restrictive than, or requires procedures that are not expressly stated in, the regulations.”
• December 8, 2022 Aviation Rulemaking Advisory Committee final report on part 145 Repair Stations recommending changes to operations specifications paragraphs “automatically” issued to repair stations that are NOT limitations.
• A December 2024 FAA letter to ARSA stating: “We are also in the process of revising the requirements for part 145 Operations Specification paragraph A025, Electronic/Digital Recordkeeping System, Electronic/Digital Signature, and Electronic Media, which is not grounded in a regulatory mandate or safety limitation.” (Emphasis added.)

By focusing on something like Operations Specifications that are directed at applicants and certificate holders, the agency can eliminate any and all guidance that requires action from the public (applicant or certificate holder) unsupported by the plain language of a regulation.

Current FAA bureaucracy functions through “requirements” placed in the agency’s own “orders/policies” to its own workforce that require action by an applicant or certificate holder. Without the action being taken, the FAA employee cannot do its job, but there is no requirement in the regulation to obtain the information or action from an applicant or certificate holder. To “deviate” from the order or policy, the FAA employee must ask permission; if the employee does not “wish” to ask permission, the applicant or certificate holder is forced to request a deviation for the order which is not required to be followed by the applicant or certificate holder in the first place.

The association encourages members to connect with the Office of Advocacy, utilizing resources (including the “Red Tape Hotline” described in this month’s “Layman Lawyer”) and participating in industry outreach. Stay tuned for more on ARSA’s engagement and go to arsa.org/about/contact-us or use arsa@arsa.org to share updates on your own advocacy.

Final Documents/Your Two Cents

This list includes Federal Register publications, such as final rules, Advisory Circulars and policy statements, as well as proposed rules and policies of interest to ARSA members.

To view the list, click here.

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Regulatory Update

Shallow Dish – ICA ARC Update

At ARSA’s request, sec. 349 of last year’s FAA reauthorization law directed the FAA to form an Aviation Rulemaking Committee (ARC) to confront longstanding issues involving Instructions for Continued Airworthiness (ICA). Recognizing the ICA provision would be included in the final bill and in light of the fact that ARSA and 14 other organizations requested action in 2021, the agency initiated the ARC several months before the legislation became law.

The ARC was chartered on Jan. 22, 2024, with former ARSA president (and current board member) Josh Krotec (First Aviation) as its industry co-chair. ARSA Executive Director Sarah MacLeod and Executive Vice President Christian Klein are leading and participating in various ARC working group, as are other ARSA members, representatives from the FAA, the design/production approval holder, and operator communities.

The ARC has been tasked to make recommendations regarding FAA ICA regulations, policy, and guidance. This includes recommending a clear definition for ICA and performance-based requirements for ICA applicability, content, and availability. The ARC is also considering how other authorities handle ICA and identifying opportunities for further international harmonization.

In addition to weekly working group meetings and monthly plenary sessions, the ARC meets in person twice per year. A casual dinner after the first day’s session provides opportunities to sample the local cuisine and discuss things other than regulations.

ARSA can’t “dish” on specific discussions, but it’s fair to say that gaps in FAA’s rules and guidance have been identified and ARC members from across the industry are working in good faith to develop consensus solutions. Working groups addressing individual parts of the ARC charter are preparing recommendations for full ARC consideration.

The progress is encouraging but given the diversity and large number of participants, whether the group will be able to arrive at an actionable consensus is still to be seen.

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Legal Brief

Editor’s note: This material is provided as a service to association members for educational and informational purposes only. It does not constitute legal or professional advice and is not privileged or confidential.

Not So Secret Agent

By Christian Klein, Executive Vice President

Last October, the FAA issued its U.S. Agents for Service rule. Codified at 14 CFR part 3, subchapter C, it requires certain individuals without a physical U.S. address that hold or apply for FAA certificates, ratings, or authorizations to designate a U.S. agent for service of FAA documents.

Who’s Impacted?

Per sec. 3.301, the rule applies to individuals who:

• Do not have a S. physical address of record (defined at sec. 3.302; see below),
• Have a foreign address of record on file with the FAA, and
• Hold or apply for certificates, ratings, or authorizations under 14 CFR parts 47 (Aircraft Registration), 61 (Pilots, Flight Instructors, and Ground Instructors), 63 (Flight Crewmembers Other Than Pilots), 65 (Airmen Other Than Flight Crewmembers), 67 (Medical Standards and Certification), or 107 (Small Unmanned Aircraft Systems).

In other words, the rule does not apply to part 145 foreign repair stations, but it does apply to mechanics and repairmen certificated under part 65 and to certain other individual holders of FAA certificates, ratings, and authorizations employed at a foreign facility.

What’s Required?

Sec. 3.303 requires covered individuals to designate an agent for service (“U.S. agent”) within the United States. The designation must include the U.S. agent’s full name, address, and email address, and certification that the U.S. agent has accepted responsibility for receiving FAA service on behalf of the individual. Any change in contact information must be reported to the agency within 30 days.

Affected individuals have until July 7, 2025 to comply with the new rule. Those failing to do so may not exercise the privileges of their certificates, ratings, or authorizations under parts 47, 61, 63, 65, 67, or 107 and an individual aircraft owner’s aircraft registration will be considered ineffective. Individuals applying for certificates, ratings, or authorizations under the referenced 14 CFR parts must designate a U.S. agent during the application process.

What is a U.S. Agent?

Sec. 3.302 defines U.S. agent as:

• An adult (individual who is 18 or older),
• With a U.S. address,
• Who a certificate, rating, or authorization holder or applicant,
• Designates to receive FAA service on their behalf.

That section also defines the terms “U.S. agent address” and “U.S. physical address”. The U.S. agent address may not be a post office box, military post office box, or mail drop box and must be in the States of the United States, the District of Columbia, or any U.S. territory or possession. If the U.S. agent is an entity, the U.S. agent address is its office address; if an individual, the address must be the U.S. agent’s usual place of residence or U.S. military office address.

The FAA is taking an expansive approach to who may serve as an agent. FAA Advisory Circular 3-1 (“U.S. Agents for Service on Individuals with Foreign Addresses Who Hold or Apply for Certain Certificates, Ratings, or Authorizations”) explains that:

Individuals can hire any entity, including registered agent service companies, with a U.S. address to be their designated U.S. agent for service. Alternatively, individuals can hire or designate any adult who is 18 or older with a U.S. address, including a relative, friend, or associate, to be their U.S. agent for service.

What Must a U.S. Agent Do?

Part 3, subpart C applicability flowchart. Source: FAA Advisory Circular 3-1.

As explained by the AC, U.S. agents receive FAA documents on behalf of the certificate holder, including enforcement action letters, notices, and orders, letters of investigation, reexamination letters, and letters requesting additional information or denying a medical certificate, and, for aircraft owners, notices of ineffective or invalid registration.

The AC underscores the importance of ensuring the U.S. agent accepts and understands their responsibilities and can perform them. The responsibilities include being available to receive FAA documents, immediately transmitting them to the individual who designated the U.S. agent, and advising that individual of contact information changes.

Significantly, the FAA considers service on the U.S. agent as the equivalent of serving the individual who appointed the agent. Thus, it is the individual, not the U.S. agent, who is legally responsible for responding to or complying with the requirements of any FAA documents that are served.

The AC recommends that the U.S. agent and individual who appointed them agree in advance on the best method of transmission (e.g., scanning and emailing, faxing, sending via expedited mail).

What is the Process for Designating a U.S. Agent or Making Changes?

The FAA requires U.S. agent designation to occur via the agency’s U.S. Agent for Service (USAS) system. The AC provides more information about the process. U.S. agents may be changed at any time for any reason using USAS.

Why did the FAA Make This Change?

The rule preamble states there are approximately 115,000 individuals outside the United States who hold certificates, ratings, or authorizations under the referenced parts of 14 CFR. International service requirements can lead to delivery delays and additional costs and cannot be waived by document recipients, or circumvented by sending documents electronically (e.g., service via email). As such, the agency believes the new requirements will “conserve agency resources, ensure that lengthy delays in service of process do not compromise aviation safety, and provide individuals abroad with timely notice of FAA actions and the opportunity for more expedient due process.”

We don’t doubt the rule will save the agency money and time; whether it results in more timely communication and more “expedient” due process remains to be seen.

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Layman Lawyer

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.

The Real Red Tape

By Brett Levanto, Vice President of Operations

In an episode of the political drama “The West Wing,” the president explains a dubious origin for the term “red tape.” The Oxford English Dictionary dates the term far earlier, citing its use in 1658.

Origins aside, aerospace stakeholders are familiar with “official routine or procedure marked by excessive complexity which results in delay or inaction.” ARSA’s role has been to eliminate unnecessary bureaucracy by focusing on compliance with the plain language of the regulations. It has pointed out that the “guidance” associated with those rules has grown exponentially since the FAA “recodified” the regulations in the 1960s.

Eliminating the red tape of “guidance” and internal agency orders and policies that add “silent” requirements, time, submissions, and meetings beyond the plain language of the regulations takes public involvement. The U.S. Small Business Administration’s Office of Advocacy has established the “Red Tape Hotline”. The Department of Transportation also has an active opportunity for direct engagement. In April, it solicited comments via the Federal Register on how to “ensure lawful regulation” consistent with executive orders directing the government to reduce its regulatory footprint. Those orders targeted rules [orders, policy, or guidance] with shaky statutory authority and/or imposing costs on the public without sufficient benefits; the Layman Lawyer has already walked through one, which provided a chance to attack “regulation by guidance” via its one-in-ten-out directive.

Submissions require focus and discipline. Current comments read like social media posts and not government petitions. Observations unsupported by data and not tied to the criteria established by the laws or the agency aren’t “substantive” and do not need to be considered.

The SBA provides help with submitting comments directly to agencies (which it also encourages, as does ARSA) to use for any governmental communication. In sum:

Every letter, regardless of the rule [order, policy, or guidance] you are commenting on, should contain the following items.

• An introduction specifying who you are, the name of the rule [order, policy, or guidance] you are commenting on, a brief overview of your business and/or experience relevant to the rule [order, policy, or guidance], and a summary paragraph briefly describing the parts of the rule [order, policy, or guidance] you are concerned about.
• A section that describes the parts of the rule [order, policy, or guidance] you support or oppose, with explanations as to why each provision helps or hurts your small business. Be specific and offer any data that will support your position. Small businesses are often understandably reluctant to offer propriety information in their comment letter, but you must provide any information that will allow the government to understand your argument without disclosing any confidential information.
• A conclusion. The conclusion should summarize your main points, in about a sentence or two each. You should also thank the agency for considering your comment.

To see SBA’s complete guidance, click here. For ARSA training on “effective comments,” click here.

While comment periods may “close” observations (following the same instructions) can always be submitted to transportation.regulatoryinfo@dot.gov.

Share your submission (and any other government engagement) with ARSA, which will both amplify your voice through the association’s regular engagement with the executive branch.

Cutting red tape demands asking and answering the right questions. Taking the time to do so is demanded not just of every aerospace certificate holder, but of each citizen living under a nation of laws.

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ARSA on the Hill

ATC High on the Radar

The Trump administration, Congress, and aviation industry are responding aggressively to recent accidents and incidents highlighting the U.S. air traffic control (ATC) system.

Transportation Secretary Sean Duffy emphasized ATC in an op-ed highlighting the Trump Administration’s first 100 days in office. “We have supercharged the air traffic controller pipeline to fast-track the best and brightest. Our mission is to deliver a brand new, state-of-the-art air traffic control system to replace the World War II-era technology managing 21st century air travel,” Duffy said. “It’s time we propel our aviation system out of the stone age and into the golden age, where drones and supersonic travel are on the cusp of revolutionizing the airspace industry.”

With the House of Representatives poised to take up budget reconciliation, the House Transportation & Infrastructure (T&I) Committee unveiled its portion of the reconciliation bill on April 29. The initial proposal authorized $15 billion for ATC modernization; however, the amount was cut back to $12.5 billion during T&I Committee deliberations given GOP objections to non-aviation user fees proposed to offset new spending.

ARSA’s allies have also made ATC an advocacy priority and ARSA Legislative Day attendees raised it during their March 19 congressional meetings, and the association is supporting the Modern Skies Coalition efforts. Additionally, ARSA sent a letter to the leadership of the House T&I Committee on April 29 expressing strong support for the historic levels of ATC investment in the House T&I proposal. “The nation’s ATC system has long suffered from a lack of investment and prioritization,” ARSA said. “Modernizing ATC, as the T&I Committee is proposing, will improve both the safety and efficiency of the National Air Space (NAS) to the benefit of all Americans.”

While the focused attention on ATC is encouraging, the budget process still has a long way to go before any additional resources are available. The House and Senate passed the required budget resolution in early April, but it’s unlikely the reconciliation process will be completed before the summer.

It Only Takes One

The association advocates on the legislative and regulatory fronts to ensure legislation is implemented both efficiently and as intended. Even when the president signs a new FAA authorization bill into law (as President Biden did last spring), the ARSA’s work doesn’t end.

Given that the 2024 FAA bill included several workforce and regulatory improvement provisions requested by ARSA, the association is focusing resources on the bill’s implementation. A few examples:

• ARSA Executive Director Sarah MacLeod, Executive Vice President Christian Klein, and several ARSA members are participating in the Instructions for Airworthiness (ICA) Aviation Rulemaking Advisory Committee (ARAC) mandated by Congress at ARSA’s request in the FAA bill. The ARC, which also includes representatives of design and production approval holders and aircraft operators, has been in operation since last year and is aiming to deliver its report by the end of 2025.
• ARSA’s team is engaging with the U.S. Department of Transportation (DOT) Inspector General’s office to support its audit of the FAA’s Flight Standards (AFS) and Aircraft Certification (AIR) Services for consistency between regulations and guidance, policy, and orders.
• ARSA is collaborating with the Aviation Technician Education Counsel (ATEC) in support of bill language directing an FAA rulemaking to facilitate the transition of military aviation technicians into civil aviation by making part 65 mechanic certificates easier to obtain.
• The FAA has engaged industry stakeholders to review rulemaking policies and procedures while it plans to follow through on a new legislative mandate to add an Assistant Administrator for Rulemaking and Regulatory Improvement.

We all know the policy process can move frustratingly slowly, but sometimes all it takes is one or two successfully implemented FAA bill provisions to remind us that there’s light at the end of the tunnel. For example, ARSA’s proposed solution to the FAA issuing a letter of investigation (LOI) to a certificate holder but never closing the case is now contained in Sec. 805 of last year’s reauthorization bill. ARSA’s suggested language requiring the FAA, within two years of issuance of an LOI, to either pursue subsequent action or close the investigation is already in the U.S. Code as a note to 49 U.S.C. 44703.

Another example of success, of course, is the aviation technician workforce grant program proposed by ARSA and included in the FAA Reauthorization Act of 2018. Since the FAA began implementing it in 2021, the grant program has been so successful that Congress quadrupled funding to $20 million annually in the recent FAA bill and used it as the model to create a new grant program for the aviation manufacturing workforce.

The bottom line: The wheels of government grind slowly. Persistence and Solomonic patience are the keys to success.

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Training & Career Development

Make ARSA Training Work

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

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

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

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

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

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

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

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

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

White House Directs Technical Career Strategy Development

On April 23, the White House issued an executive order supporting efforts to boost the U.S.’s skilled employee pipeline. The order directs government agencies to examine current federal programs and integrate them into a new workforce development roadmap.

The president gave the secretaries of Labor, Commerce, and Education departments 90 days to develop a report “setting forth strategies to help the American worker.” Those reports must examine “alternative credentials and assessments to the four-year college degree that can be mapped to the specific skill needs of prospective employers.” Each agency’s strategy should examine ways to “integrate systems and realign resources to address critical workforce needs and in-demand skills of emerging industries,” based in part on input from prospective employers.

Specifically, the order directs the agencies to submit plans to surpass one million ne active apprenticeships in the United States. Those plans must include:

(a)  Avenues to expand Registered Apprenticeships to new industries and occupations, including high-growth and emerging sectors.

(b)  Measures to scale this proven model across the country, improve its efficiency, and provide consistent support to program participants.

(c)  Opportunities, including through the Carl D. Perkins Career and Technical Education (Perkins V) Act and Federal student aid, to enhance connections between the education system and Registered Apprenticeships.

“It is the policy of the United States to optimize and target federal investments in workforce development to align with our country’s re-industrialization needs and equip American workers to fill the growing demand for skilled trades and other occupations,” the order said.

ARSA is coordinating with its industry and trade association allies regarding the order and resulting opportunities for industry career development. To review the order, “Preparing Americans For High-Paying Skilled Trade Jobs Of The Future,” click here.

Lynden Helps Alaskan Students Excel

On April 1, ARSA associate member Lynden Air Cargo hosted 24 students from Alaska EXCEL at Ted Stephens Alaska International Airport.

Alaska EXCEL is a non-profit providing supplemental academic, career, and technical education incentives for rural youth and young adults across Alaska. The program coordinates individualized, real-life academic and career-oriented experiences allowing students to receive high school credit toward graduation and dual college credit in a specific program. The organization’s purpose is to prepare students for transitions into the workforce or post-secondary training.

During the well-planned visit, the Lynden team kept the participants busy. The itinerary ensured visits to each of the company’s operations:

Students participating in the Alaska EXCEL program tour the flight deck of a Lynden Air Cargo aircraft during their visit with the company in April.

Lynden’s management of the day’s visit provides a perfect example of how an aviation facility can engage public groups. The model can be scaled to any size operation: Meet people, see cool equipment, eat some pizza. The impact was positive; the Alaska EXCEL representative followed up after the event that “…[W]e truly enjoyed the pizza and the stickers. The students came back very jazzed about aircraft careers after their time with you at Lynden. We truly appreciate your continued support and look forward to bringing more students in the near future!”

ARSA applauds Lynden for its engagement with new generations of talent and for getting them “jazzed” about aerospace careers. The association encourages all its members to follow this example and share the results via the “Ask ARSA” portal.

Regulatory Compliance Training

Test your knowledge of 14 CFR § 21.27, type certificates for military surplus aircraft.

Click here to download the training sheet.

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Membership

Renewal and Reinvestment

ARSA members show continual support by renewing their membership, and they do so at a consistent 90 percent rate.

The member type breakdown from 2024 can show you where your company falls and in the areas you can help ARSA grow by saving money on your dues.

Working to Be Free

The Members Getting Members member benefit not only supports ARSA but can drop a year’s dues to $0.

Join these members that are earning the credit to be free!

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 April:

New Members
AOG Aviation Spares LLC, R03
Alliance Aeronautical Composites, LLC, R01
Audacity Aviation, R01
Corporate Air Parts, Inc., R03
DRJ Technologies, R02
Global Engine Maintenance, LLC, R04
LF Avionics, Corp, R01
Servotronics, Inc., R01
Turbo Technologies, L.L.C., R02
Tym’s LLC, Affil

Returning Members
AEE-EMF, Inc. d.b.a. Aircraft Electrical Electronics, R01, 2009
Aeroneuf Instruments Ltd., R02, 2022
Aircraft Electric Motors, Inc., R04, 1984
All Nippon Airways Co., LTD, Assoc, 2001
AOG Reaction, Inc., R02, 1993
Apex Heli-Support, LLC, R01, 2024
ATP USA, Inc, R01, 2017
Component Repair Technologies, Inc., R05, 1995
Chromalloy, Corp, 1993
Drayton Aerospace (Xiamen) Landing Systems LTD dba Drayton Aerospace, R04, 2024
Ford Instruments & Accessories, LLC, R01, 2018
Helicopter Express, LLC, Assoc, 2024
Metro Aviation, Inc., Assoc, 2003
Pac West Helicopters, Inc., R01, 2009
Piedmont Propulsion Systems, LLC, R04, 2011
Quality Aviation Instruments, Inc. dba QAI Aerospace, R03, 2012
SAFETECH USA, INC., R02, 2002
Southwest Aerospace Technologies, LLC, R01, 2019
Tarrant County College, EDU, 2017
Toledo Jet Center, LLC, R03, 2010

Advertising – What Do You Think?

ARSA’s expertise is regulatory compliance, we are not salesmen or experts in advertising.

Don Draper doesn’t stalk ARSA headquarters (or take us out to martini lunches). Recognizing our weakness in this area, we are asking members to share what they’d like to see in our advertisements.

This is your chance. We’re listening and suggestions will be given credit. Intrigued? Send your ideas to arsa@arsa.org and put “I have an idea” in the subject.

A Member Asked…Contracting or not?

Q: We are getting mixed information from different FAA offices regarding § 145.217. One FSDO says that since the provider we are outsourcing work to is certificated, trained per the customer’s requirements, and issues its own FAA Form 8130, then we don’t have to have the function approved and on a Maintenance Function List. Another FSDO (overseeing a different facility but addressing the same question) directed that all contractors must be on the function list regardless of certification.

How do we get some clarity?

A: Let’s first put the term “outsourcing” to bed forever. For both cultural and practical purposes, “contracting” is the best term and the one approved (no pun intended) by ARSA.

As a privilege of your repair station certificate, § 145.201(a)(2) allows you to “arrange for another person to perform the maintenance, preventive maintenance, or alterations of any article for which [your repair station] is rated.” That arrangement is made under § 145.217, which you correctly read to require the FAA approval of all functions – and the repair station listing of all functions – contracted to an outside source regardless of the certification of the contractor.

The nuance here is that the “arrangement” described above is for work performed by the repair station, i.e., when the contracting repair station (you) will issue an approval for return to service that includes the work performed by the outside source and (as required by § 43.9) listing that contractor in the maintenance record. In the situation you described, the certificated contractor issues approval for return to service for the work it performs and delivers to you a maintained article with a maintenance release.

In this case, the contracting repair station is not exercising the privileges of its certificate with regard to the work performed by the certificated contractor (the second “condition” described in paragraph 5.7.2.1 of AC 145-9A); you are not contracting this work under § 145.217 but instead receiving a maintained article for installation.

That being said, ARSA recommends listing all maintenance functions that either could be or must be contracted to outside sources, regardless of certificate status of the specific contractor or who will issue a return to service for the work performed. Practically speaking, listing all such functions protects you from a violation or delay in the case that a contractor changes. In the case of such a change, you would still have to evaluate a new vendor and update your vendor list, but the vendor list doesn’t have to be approved by the FAA (only the functions do) and you’ve removed a bureaucratic layer from the process.

However you choose to manage the list, you must be clear about what you’re actually doing under the rules.

Have questions about aviation regulatory compliance, legislative policy, or ARSA resources? Ask ARSA first!

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Resources

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

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.)

ARSA Member Benefits

From access to industry expertise to growing your own through education and training, ensure your company gets the most out of its investment in ARSA.

U.S. Legislative Action Center

ARSA requests its members’ assistance to keep FAA reauthorization front and center on the congressional agenda and ensure our workforce priorities are included. Please use ARSA’s grassroots action center (sponsored by Aircraft Electric Motors) to send a quick note to your elected representatives in support of our efforts.

Industry Meetings & Events

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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