A Glance Back
As we enter 2014, the association takes the opportunity to review the most visible contributions to its members’ continued viability during the past year.
Major regulatory victories for the industry included a Federal Aviation Administration (FAA) clarification that a maintenance provider may restore missing part information and the withdrawal of a maintenance duty time legal interpretation.
The association also obtained an FAA letter confirming that part-specific training is not required and secured the FAA’s concurrence with the association’s contention that the agency could not prohibit early compliance with Order 8130.21H (i.e., use of the revised Form 8130-3 before its Feb. 1, 2014 effective date).
The association’s most important purpose is to advocate for fair, clear, concise, and consistent rulemakings. To that end, ARSA submitted substantive comments to the proposed FAA air carrier contract maintenance requirements (see March 13 comments), a European Aviation Safety Agency (EASA) Notice of Proposed Amendment that would incorporate safety management system requirements into EASA part 145 (see May 22 comments), and FAA draft order 8300.X which provides guidance on the approval of technical data associated with major repairs or alterations (see June 9 comments).
ARSA continued its quest to ensure good governance when it requested objective evidence to support an FAA proposed airworthiness directive. The request, and its subsequent comments, pointed out that the proposal lacked elements for compliance with the most basic rulemaking requirements, the Small Business Regulatory Enforcement Fairness Act and the Regulatory Flexibility Act. The association also urged the Small Business Administration to weigh in.
ARSA furthered its mission to make maintenance manuals available to maintenance providers with a letter to European Parliament members commending recent inquiries to the European Commission. ARSA Vice President for Legislative Affairs Daniel Fisher detailed the fact that regulatory bodies weren’t enforcing their own regulations which require design approval holders make instructions for continuing airworthiness available, particularly when repair stations are required to follow them.
In March, ARSA held its Annual Repair Symposium and Legislative Day. Kicking off the event, industry representatives visited 32 congressional representatives including Senate Aviation Subcommittee Ranking Member Kelly Ayotte (R-N.H.). The Symposium ended on a high note with FAA Administrator Michael Huerta speaking on the important role ARSA plays and lauding the maintenance community for its contribution to aviation safety. (Register now for the 2014 ARSA Symposium, being held March 19-21.)
ARSA continued to exercise its legislative muscle by submitting a statement to the House Subcommittee on Aviation regarding inconsistent agency regulatory interpretation. ARSA highlighted its involvement with the Consistency of Regulatory Interpretation Aviation Rulemaking Committee and the lack of agency response to the committee’s recommendations.
The association was unrelenting in urging lawmakers to lift the FAA foreign repair station certification ban to stop the industry from being penalized by government inaction. Simultaneously, ARSA engaged Capitol Hill allies to pressure the Office of Management & Budget, Transportation Security Administration, and the Department of Homeland Security at every opportunity to finalize repair stations security rules. Additionally, ARSA secured repair station participation on the Aviation Security Advisory Committee, which has been proposed in the Aviation Stakeholders Participation Act. The bill passed the House and companion legislation was introduced in the Senate (also including repair stations as committee members).
Finally, ARSA made good on past promises to provide online training courses and webinars (more information at http://arsa.org/training-2/online-training/), expanded its affiliate programs to include drug and alcohol testing services, held member outreach meetings across the U.S., and introduced the ARSA Blog and avmro.arsa.org, a one-stop shop for information about the aviation maintenance industry.
As we press on in the New Year, the association will continue to fight the good fight. Indeed, we encourage members to review and comment on the recently released “ARSA 20/20”, a strategic plan that details future advocacy and program development. We look forward to working with industry and our membership to ensure continued industry growth and success in 2014.