Aeronautical Repair Station Association

The Good, the Bad, and the Ugly

SM-WebDecember 2012 – The Association’s capability to influence legislation as well as regulation depends upon its knowledge and ability to provide balance between the demands of government and industry. That means taking positions based upon law, logic and practical knowledge that may be unpopular with certain segments of the membership.

In January 2012, such a position was taken with respect to a new policy the Federal Aviation Administration (FAA) issued on Instructions for Continued Airworthiness (ICA). Availability of ICA has been a centerpiece of ARSA’s existence. It was the issue upon which the Association was founded and continues to be a core concern. However, the policy issued by the FAA will not stand the test of time and that fact was pointed out by the Association in its January comments to the draft. The policy has since been issued and used to the advantage of many members and non-members alike.

On a more positive note, the trade Association welcomed Component Control as a preferred provider for its members. Business management software is essential to efficiency and creating a source for preferred rates is a value of membership.

In that first month the Association also requested the FAA to change the description of how a repair station certificate must be amended on Form 8310-3, Application for Repair Station Certificate and/or Rating.

The second month of the year brought interesting results from the 2012 member survey—thankfully, the industry was optimistic about economic prospects and that positive indicator, surprisingly enough, bore out over the year. It was also the month I took the opportunity to talk about Regulation and Responsibility to a group of super mechanics in Wisconsin and visit members and non-members in Kansas.

The Association ran another successful symposium in March, with the Leo Weston Award going to Carol E. Giles, former policy maker and leader of the aircraft maintenance division in the FAA’s Flight Standards Service. The end of the first quarter and April gave me the opportunity to present the Association’s views to the FAA’s regional managers on “Collaboration with the FAA from an industry perspective; to join colleagues on panels at the MRO Americas for both the main arena and the Engine MRO Forum; chances I hope to have in the future.

Also in April, ARSA submitted comments to a notice of proposed rulemaking (NPRM) from the National Transportation Safety Board (NTSB) regarding the rules of practice in air safety proceedings. It also joined with several of its industry allies in a letter to the FAA requesting the agency’s assistance in resolving specific “tagging” requirements in the FAA-European Aviation Safety Agency (EASA) Maintenance Annex Guidance (MAG). At the end of the month, the Association’s then Senior Vice President Gary Fortner, vice president of Quality Control & Engineering at Fortner Engineering in Glendale, Calif., testified before the House Transportation & Infrastructure Committee’s Aviation Subcommittee about the excellent work repair stations across the country and around the world are doing to ensure aviation safety.

Continuing its battle for good government, ARSA responded to a petition filed by a coalition of law professors with the National Archives and Records Administration (NARA) requesting an update to guidelines permitting the incorporation of materials by reference in the federal rulemaking process. ARSA strongly supported improving the availability of documents incorporated by reference; this will help all businesses improve compliance and not be left in the dark when a final rule sets forth new mandates.

The middle of the year put the Association in hot water again when it filed an amicus curiae (friend of the court) brief with the United States Supreme Court asking for its intervention in an ICA availability matter. The case was not taken by the Court.

Aviation maintenance didn’t escape the heat of July; NPR ran an interview that disparaged the safety record of the airline industry while raising false and unproven safety concerns about the use of contract maintenance. ARSA responded promptly with facts to contravene the alarmist interview with Bill McGee, a consumer advocate who writes about the airline industry.

That month also provided ARSA Vice President of Regulatory Affairs Craig Fabian an opportunity to stress the maintenance industry’s unwavering commitment to safety on a New York television station focused on the delays and controversies surrounding the FAA’s mandated fuel tank explosion suppression systems. The story was part of the station’s annual anniversary coverage of TWA flight 800.

Members responding to a survey confirmed the fact that audits need to go on a diet; audits suck an enormous amount of resources from every repair station. The study will be used to convince the national aviation authorities that cooperation, validation and sharing of data will be more valuable than continued, numerous, contradictory audits from multiple sources.

As summer wound down, ARSA filed comments with the FAA supporting Blue Ridge Community College’s (BRCC) efforts to modernize the requirements for aviation maintenance training at schools certificated under 14 CFR part 147. It also requested and received an extension of the comment period for draft Advisory Circular (AC) 145-11 that provides guidance on how U.S.-based repair stations may obtain, renew or amend an EASA approval utilizing the MAG.

During the early fall, ARSA held its 2012 Strategic Leadership Conference in Hamburg, Germany in conjunction with celebrations surrounding the 50th anniversary of Lufthansa Technik’s FAA certificate. It was ARSA’s first time hosting an international event. The Association was able to make a valuable contact with Bruce Dickinson, Iron Maiden’s lead singer and aviation entrepreneur.

ARSA also received a response from the FAA to the Association’s request for clarification regarding the use of maintenance instructions modified according to EASA § 145.A.45(d). To match its international efforts, the Association released a prototypical EASA supplement based upon the MAG.

In middle and late fall, ARSA filed comments on the proposed repair station rule, elected leaders and updated its website significantly.

The Association has earned its reputation as a reliable source of information for industry and government. The ability to balance principles of good government with practical application of myriad regulations is based upon seeing, understanding and applying the good, the bad and the ugly.

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December 1st, 2012




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