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ARSA Test Site > ARSA Action > ARSA Action – 2011

ARSA Action – 2011

Regulatory Advocacy

  • Responded to misleading statements made by the Department of Transportation’s World-class Workforce Subcommittee.
  • Joined the Coalition for a Democratic Workplace (CDW) in an amicus curiae (friend of the court) brief toRoundy’s v. Milwaukee Building & Construction Trades opposing unfair non-employee union access to the workplace.
  • Served on the Federal Aviation Administration’s (FAA) Airworthiness Directive (AD) Advisory Rulemaking Committee, which submitted its final report in August 2011.
  • Challenged the Pipeline and Hazardous Materials Safety Administration’s sole jurisdiction over maintaining high-pressure cylinders and requested that the Federal Aviation Administration FAA change its guidance accordingly.
  • Requested and received FAA affirmation that fabrication of a part is not considered maintenance.
  • Submitted comments to the National Transportation Safety Board’s advance notice of proposed rulemaking suggesting changes that would bring justice to the adjudication process regarding FAA certificate actions.
  • Advised industry on the implementation and regulatory impact of the US-EU Bilateral Aviation Safety Agreement (BASA).
  • Commented on the FAA’s proposed interpretation of duty and rest provisions for maintenance personnel, pointing out that the interpretation impermissibly creates a de facto new duty time regulation and therefore circumvents the rulemaking process.
  • Filed comments to the FAA’s proposed Airworthiness Directive (AD) legal interpretation, arguing that it overlooks the existing relationship among and between the design, production, operating, and maintenance rules in 14 CFR and that agency rules must be clearly understood by the person performing the required action.
  • Stressed the need for consistent public policy regarding pre-employment background screenings in a letter to the Equal Employment Opportunity Commission.
  • Opposed a National Labor Relations Board (NLRB) proposal to speed up the unionization process which threatens an employer’s ability to communicate with employees, making a mockery of the election process.
  • Joined the CDW in rejecting a Department of Labor rule change that would significantly broaden reportable activities under the Labor Management Reporting & Disclosures Act.
  • Recommended that the FAA issue guidance to reflect current practices relating to the identification referenced in maintenance records when more than one number is applied to a part at production. Received a response from the agency indicating that it shares ARSA’s concerns and plans to review and revise the affected guidance.
  • Questioned the FAA’s issuing Parts Manufacturer Approvals for “materials,” asking the agency to issue guidance establishing the definitions for “material,” “part,” “component,” “appliance,” and “process.”
  • Urged the Joint Maintenance Coordination Board to consider revisions to the Maintenance Annex Guidance of the U.S./EU bilateral aviation safety agreement.
  • Requested Transportation Security Agency (TSA) Administrator John Pistole and Homeland Security Secretary Janet Napolitano rapidly issue the TSA repair station security rule to facilitate the certification of new foreign repair stations.
  • Asked the FAA to issue a legal interpretation to resolve existing confusion and reverse misunderstandings regarding the applicability of “automatic” major repairs.

Legislative Advocacy

  • Signed a Small Business Coalition for Affordable Healthcare letter encouraging repealing the 2010 Patient Protection and Affordable Care Act (H.R. 2).
  • Secured language in the House-passed FAA reauthorization bill (H.R. 658) that ensures effective repair station oversight; subsequently, ARSA endorsed the House bill over the Senate’s language.
  • Held numerous meetings with House and Senate staffers directly involved in crafting FAA reauthorization legislation.
  • Joined successful lobbying efforts to repeal the 1099 IRS reporting mandate.
  • Joined the Coalition to Save our GPS, an ad hoc group working to prevent disruptions to the GPS satellite spectrum.
  • Sent a letter to all House members requesting protection of the maintenance provisions in the FAA Reauthorization and Reform Act of 2011 (H.R. 658).
  • Testified before the House Small Business Committee on the importance of the Regulatory Flexibility Act’s small business protections.
  • Supported the Job Protection Act (S.964) and joined efforts to advance the Protecting Jobs from Government Interference Act (H.R. 2587), measures preventing the National Labor Relations Board from telling an employer where it can create jobs.
  • Opposed politicization of the federal procurement process by joining allies supporting the Keeping Politics Out of Federal Contracting Act (H.R. 2008/S. 1100).
  • Signed a letter opposing an NLRB push to decrease the timeframe for union organizing elections.
  • Coordinated letters to Senators Patty Murray and Aviation Subcommittee Chair Maria Cantwell from repair stations in Washington state urging adoption of the ARSA-endorsed language in the House-passed FAA bill.
  • Issued a statement criticizing Congress for political gamesmanship that put politics ahead of aviation safety during the 21st FAA authorization extension debate.
  • Launched the “Keep it Clean” campaign, encouraging lawmakers to keep must-pass FAA reauthorizations clean of policy.
  • Started a lobbying campaign to “Lift the Ban” on the FAA’s ability to issue new foreign repair station certificates and surveyed ARSA members on the prohibition’s impact, using the data to bolster campaign efforts.
  • Secured repeal of the three percent government contractor withholding tax (H.R. 674) through close collaboration with allies in the business community.
  • Advocated for House passage of measures to reduce regulatory burdens facing employers (H.R. 10, H.R. 3010) and improve the protections of the Regulatory Flexibility Act (H.R. 527).
  • Decried the negative impacts of the congressional ban on certification of new foreign repair stations in a letter to the Senate Homeland & Government Affairs Committee.
  • Coordinated the collection of anecdotes about the negative impact of the ban on certification of new foreign repair stations.
  • Called on Congress to pass a multiyear FAA reauthorization bill to allow aviation maintenance companies to grow and prosper.

Media Advocacy and Public Relations

  • Appeared on PBS’s Frontline to defend the safety record of aviation maintenance and contract repair stations.
  • Monitored news and developments in trade, industry, local and national press outlets.
  • Provided reporters with information and background about aviation maintenance and Positive Publicity Campaign (PPC) data on the national and localized economic footprint of repair stations.
  • Established a Public Relations Committee of leading aviation maintenance company representatives to direct PPC actions and expenditures.
  • Sent letters to the editor and reporters in opposition to a Transport Workers Union (TWU) report about repair station safety.
  • Responded to Washington Examiner biased TWU coverage.
  • Released a report detailing the benefits of Bilateral Aviation Safety Agreements (BASAs) for certificated repair stations.
  • Blasted biased reporting from a local Seattle television affiliate that paints a distorted picture of the contract repair industry.

Other Activities

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