ARSA Action – 2009

Regulatory Advocacy

• Presented a comprehensive proposal to both the FAA and the Department of Transportation Office of the Inspector General (DOT-IG) for restructuring the air carrier operations specifications paragraph dealing with contract maintenance providers. The plan also included refinement of selection criteria for required inspection items, and moves away from extra-regulatory terms such as “substantial” and “essential” maintenance.
•  Sought acceptance of a single document as a “multiple release” record; a letter explaining the stumbling blocks that exist was sent to the national authorities of the United States, Canada, Australia, New Zealand and the European Union.
• Received clarification from the FAA to the Association’s request regarding 14 CFR §§ 121.709(b) and 135.443(b). ARSA questioned whether a certificated part 145 repair station may issue an airworthiness release or log entry approving the work it performs on an aircraft for return to service on behalf of a certificate holder operating under part 121 or 135.
•  Hosted 2009 Annual Repair Symposium, bringing together representatives of industry and regulatory bodies including the FAA, EASA, Transport Canada, and others. Held regulatory compliance workshops for membership.
•  Represented member interests at the 2009 EASA/FAA International Aviation Safety Conference; attended regulatory compliance panels and updated membership on new efforts at trans-Atlantic harmonization of standards.
•  Conducted survey of members regarding Airworthiness Directives (ADs) that have been issued as a result of SFAR-88 reviews by design approval holders. The review had resulted in the methods, techniques and practices contained in certain component maintenance manuals being mandated by AD.
•  Received accolades from FAA Interim Administrator Robert Sturgell for the Association’s continued commitment to safety and regulatory compliance.
•  Recommended the FAA issue guidance to end confusion surrounding the new definition of “current” for 91.409(f)(3) that “a current inspection program recommended by the manufacturer” means one that the registered owner chose at a point in time, not current as of “today”. In response the FAA issued an Information for Operators which clarifies that an operator must properly adopt a program under 14 CFR section 91.409(e) that is “current” at that time (the time of the adoption).
•  Submitted a request for interpretation to the FAA’s Office of Chief Counsel regarding maintenance manuals or instructions referenced in the Airworthiness Limitations Section of Instructions for Continued Airworthiness.
•  Continued efforts to have FAA correct the language in Order 8900.1, volume 5, chapter 5, section 4 prohibiting issuance of a repairman certificate to “circumvent” a mechanic’s certificate.
•  Sent letters to the FAA to dispel the agency’s notion that a repair station could not use a manufacturer’s component maintenance manual to perform an overhaul. The agency had opined that a facility must either use a manufacturer’s “overhaul manual” or develop its own FAA-approved manual to accomplish the described work. See the FAA’s response
•  Continued to serve as a voting member of the Aviation Rule Committee (ARC) for Safety Management Systems (SMS) and as the Chair for the Maintenance Working Group.

General Legislative Advocacy and Public Relations

• Initiated a Positive Publicity Campaign (PPC) to educate key audiences about the critical role the aviation maintenance industry plays in the economy and the negative impact of pending legislation that would restrict the use of foreign repair stations. ARSA has thus far conducted extensive public opinion research to help support campaign planning and messaging and completed economic research to help quantify the aviation maintenance industry’s economic footprint.
• Made presentations to the Small Business Administration, Department of Commerce, and House Aviation Subcommittee staff on economic impact of maintenance industry utilizing data from the PPC.
•  Facilitated visits by members of Congress to repair stations to elevate the industry’s profile.
•  Enhanced grassroots tools for ARSA members.
•  Hosted a fundraising event for House Aviation Subcommittee Ranking Member Tom Petri (R-WI) in conjunction with ARSA’s 2009 Legislative Day.

Congressional Lobbying

• Led two major grassroots efforts, in addition to ongoing initiatives, aimed at educating Congress on the detrimental effect of trade prohibitive language in the House FAA reauthorization bill.
•  Worked to add signatories to a letter penned by Rep. John Barrow (D-GA) calling for amendment to the trade prohibitive language in the House FAA reauthorization bill; also worked to gather support for the amendment, which did not pass.
•  Met with members of the New Democrat Coalition and Blue Dog Coalition to educate on trade prohibitive measures in House FAA reauthorization bill and urge support for removing language.
•  Met with Senate staff prior to and after release of Senate FAA reauthorization bill to urge rejection of trade prohibitive language similar to that found in the House bill.
•  Joined the Coalition for a Democratic Workplace, an alliance of associations and business urging defeat of “card check” legislation in any form.
•  Maintained dialogue with staff on the House Small Business Committee on issues impacting small businesses in the aviation industry.

Enhancing ARSA Member Benefits

• Continued to support the creation of the Aviation Alliance Insurance Risk Retention Group (AAIRRG) to provide a new product liability insurance option exclusively for ARSA members.
•  Initiated a new program with Bluestone Payments to help ARSA members reduce credit card transaction fees.