121 north henry street alexandria, va 22314 tel. 703.739...

121 North Henry Street Alexandria, VA 22314

Tel. 703.739.9543 Fax 703.299.0254

www.arsa.org

ARSA Works Serving the Aviation Maintenance Industry

October 21, 2015 Marshall S. Filler

Managing Director and General Counsel

http://arsa.org/

ARSA is devoted to the worldwide civil aviation maintenance industry—from its global corporations to the small, independent businesses. ARSA members are located on five continents and in nearly 20 countries.

The association’s experts create the tools for members to navigate the maze of government mandates while enhancing safety, efficiency and productivity.

ARSA is managed by the law firm of Obadal, Filler, MacLeod & Klein, which provides management, government affairs, and legal services to trade associations and transportation-centric companies.

About the Aeronautical Repair Station Association

1 Copyright © 2015 Obadal, Filler, MacLeod & Klein, PLC

703 299 0784 • http://potomac-law.com October 21, 2015

http://arsa.org/

http://arsa.org/

http://arsa.org/

http://potomac-law.com/


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OFMK is a boutique law firm based in Alexandria, Virginia (across the river from Washington, D.C.). It provides management, government affairs and legal services to trade associations and transportation-centric companies with particular emphasis on international aviation safety regulations. It helps clients navigate the maze of government mandates while enhancing safety, efficiency and productivity.

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About Obadal, Filler, MacLeod & Klein, P.L.C.

October 21, 2015 Copyright © 2015 Obadal, Filler, MacLeod & Klein, PLC 703 299 0784 • http://potomac-law.com

http://www.potomac-law.com/


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Marshall S. Filler is managing member of OFMK and the managing director and general counsel of the Aeronautical Repair Station Association. He has advocated for individuals and companies on international aviation safety law, policy and compliance issues for over 40 years. Mr. Filler obtained his bachelor of arts and law degrees from The American University in Washington, D.C.

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About the Presenter – Marshall S. Filler

Copyright © 2015 Obadal, Filler, MacLeod & Klein, PLC 703 299 0784 • http://potomac-law.com

October 21, 2015


http://potomac-law.com/attorneys/marshall-s-filler/


http://arsa.org/

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The purpose of this presentation is to provide an overview of how ARSA works to serve members (and potential members) and demonstrate the association’s value to the maintenance industry. As the global maintenance industry’s leading regulatory compliance organization, it is also an opportunity to discuss and address key issues facing maintenance providers.

October 21, 2015 Copyright © 2015 Obadal, Filler, MacLeod & Klein, PLC 703 299 0784 • http://potomac-law.com 4

Why Are We Here?


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• Communications Program • Workforce Development • Advocacy Resources • Training Services • Legislative Advocacy • Regulatory Compliance

How ARSA Works



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• Introduction to aviation maintenance: • You Can’t Fly Without Us documentary. • AVMRO web portal.

• Tools for policy advocacy: • Global Fleet & MRO Market Assessment. • Policy Solutions for a Stronger Tech. Workforce. • “Illustrations of Industry Data” infographics.

• Voice in the Media: 211 pieces have highlighted ARSA products, activities or counsel in the last year.

Communications Program



http://www.arsa.org/documentary

http://avmro.arsa.org/

http://arsa.org/news-media/economic-data/

http://arsa.org/wp-content/uploads/2015/02/ARSA-ATEC-WMTechnicalWorkforceStudy-20150217.pdf

http://arsa.org/news-media/economic-data/

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• Joined ICAO’s Next Generation of Aviation Professionals (NGAP) Task Force.

• Joined the STEM Education Coalition Leadership Council.

• Jointly released an aviation workforce study by William & Mary policy researchers.

• Submitted rewrite of AC 65-30B, Overview of the Aviation Maintenance Profession.

Workforce Development



http://www.icao.int/safety/ngap/Pages/default.aspx

http://www.icao.int/safety/ngap/Pages/default.aspx

http://www.stemedcoalition.org/

http://www.stemedcoalition.org/

http://arsa.org/arsa-atec-rewrite-faas-aviation-maintenance-overview/

http://arsa.org/arsa-atec-rewrite-faas-aviation-maintenance-overview/

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• Requested revision to Standard Occupational Classification (SOC) aviation maintenance personnel definitions.

Workforce Development


• Launched AeroJobs.org, an aviation maintenance-focused online recruitment tool.


http://arsa.org/soc/

http://arsa.org/soc/

http://www.aerojobs.org/

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Advocacy & Business Resources



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• Industry experts providing training sessions and materials across a broad range of regulatory compliance, business development, legal and legislative topics.

• The ARSA training program includes: – Online sessions and webinars. – Live, On-site classes. – Tailored, company specific programs.

Training Services



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• Online Training – Regularly scheduled live sessions. – On-demand recordings. – 2015 Schedule (remaining):

• “Overhauling Overhaul” (Oct. 28). • MAG CHG 5 listening session (Nov. 3). • Three-part series on FAA enforcement (Nov-Dec). • Three-part series on parts (on-demand).

[The same classes you will be completing today –introduce colleagues to the topic.]

Online Sessions and Webinars



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• Usually in conjunction with outreach activities. • A means to bring value of direct engagement to

member facilities and areas with strong maintenance industries.

• Can be a venue for tailored, company-specific classes.

Live, On-Site Classes



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• Courses can be presented online or at company facilities.

• Materials are customized to the particular operation and are presented in 2, 4, 6 or 8-hour segments.

• Companies can “mix and match” content as desired.

• ARSA can seek IA-renewal credit for course material if desired.

Tailored Training Programs



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• Topics are responsive to member/customer needs.

• What training sessions would be valuable to you? Send a note to the teacher:

arsa.org/training

Developing Training



http://arsa.org/training

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• FAA Reauthorization – Current law extended through March 2016 (its 1st

extension). • Last reauthorization process required 23

extensions. – General advocacy goals:

• Educate about economic impact of aviation maintenance.

• Demonstrate the harm of burdensome mandates on aviation businesses.

Legislative Advocacy



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• FAA Reauthorization – Specific policy initiatives:

• Guarantee due process protections for all certificate holders.

• Move along part 147 rewrite (Aviation Maintenance Training Schools).

• Protect international agreements (e.g., BASAs), respect international sovereignty & business realities.

• Fund the FAA appropriately; give it the resources to do its job.




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• Technical Education Policies. – General advocacy goal:

• Sharpen focus of federal education programs to support life-long technical skill development from early/secondary education through advanced training.

– Specific policy initiative: • Include STEM and technical skills training in

reauthorization of all three major education bills awaiting action: – Early Secondary Education Act (ESEA). – Higher Education Act (HEA). – Carl D. Perkins Career & Technical Education Act.




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• Alternative Parts – Great example of association “defense” on

specific initiative. – Legislative team learned of effort to include language

in FAA reauthorization mandating new FAA rulemaking regarding alternative parts.

– In July, association led coalition of six other trade associations in letter to congressional leaders.

– As of now, effort to include mandate language has been abandoned.

arsa.org/alternative-parts




http://arsa.org/alternative-parts/

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• Legislative Day – March 16, 2016. • Facility visits. • Roundtables/community events. • Grassroots advocacy – ARSAaction.org. • ARSA PAC. • Engage the media.

arsa.org/legislative/get-involved

Legislative Advocacy – Member Involvement



http://arsaaction.org/

http://arsa.org/legislative/get-involved/



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• Work instructions. • Continue-in-service determinations. • The new part 145:

– The “serious” issue - § 145.221(a). – Voluntary Surrender - § 145.55(a). – “Or new” - § 145.57(b).

• FAA/EASA MAG Change 5

arsa.org/arsa-works

Regulatory Compliance – Agency Engagement



http://www.ecfr.gov/cgi-bin/text-idx?SID=354ce8df7429e01e02c2013c04c48363&mc=true&node=se14.3.145_1221&rgn=div8

http://www.ecfr.gov/cgi-bin/text-idx?SID=95ea9633399b2a52246d651f330712a1&mc=true&node=se14.3.145_155&rgn=div8

http://www.ecfr.gov/cgi-bin/text-idx?SID=ec5a50cd866c1af582ba5692777ea9ab&node=se14.3.145_157&rgn=div8

http://arsa.org/arsa-works

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• Aug. 12, 2014 – Federal Register publishes part 145 final rule, having removed the word “serious” from the service difficulty reporting section (§ 145.221(a)).

• Sept. 22, 2014 – ARSA leads industry coalition to petition FAA to immediately re-insert the word “serious.”

• Nov. 10, 2014 – FAA publishes direct final rule replacing “serious” on same day new part 145 becomes effective.

• In 88 days, association and its allies averted a serious problem. See the whole story:

arsa.org/serious

Regulatory Compliance - The “Serious” Issue



http://www.ecfr.gov/cgi-bin/text-idx?SID=354ce8df7429e01e02c2013c04c48363&mc=true&node=se14.3.145_1221&rgn=div8

http://arsa.org/serious

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• Sept. 9, FAA and EASA release change 5 to the Maintenance Annex Guidance (MAG).

• Compliance required beginning Dec. 8. • Replaced the word “should” with the word “must” in

provision addressing documentation of new components installed during maintenance.

• Clear requirement for FAA Form 8130-3 to accompany new parts received by U.S. repair stations on articles installed on EU-registered aircraft.

• Used parts installed in a top assembly also require Form 8130-3.

Regulatory Compliance – MAG Change 5



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• Under current FAA rules the agency must issue the 8130-3, usually through a designee.

• The FAA addressed that problem in a final rule published Oct. 1, effective March 29, 2016 (longer timelines will be required for agency review and approval of new processes).

• Certificate holders face gap of nearly four months (at least) before they can legally comply with the MAG change’s new 8130-3 requirement.




http://arsa.org/production-certificates/

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• On Oct. 7, ARSA led a coalition of 12 other industry groups on letter to FAA and EASA, requesting: 1) A delay in the implementation date of the specifically

referenced MAG provision for six months after the effective date of the FAA’s final rule published on Oct. 1.

2) That U.S. PAHs be given the opportunity to implement the provisions of the new rule prior to March 29, 2016.

3) That agencies issue a definitive statement that new, airworthy parts released by a U.S. PAH prior to the implementation date of MAG CHG 5 are not subject to the Form 8130-3 requirement.




http://arsa.org/wp-content/uploads/2015/10/Industry-letter-FAA-EASA_8130-3-MAG-CHG-5_20151007.pdf

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• What ARSA is doing: – Providing analysis and guidance for maintenance

providers. – Leading industry coalition effort to smooth

implementation process. – Hosting “listening session” stimulate discussion and

feedback from affected industry members (Nov. 3). • Stay current on association’s actions:

– arsa.org/mag-change-5




http://arsa.org/mag-change-5/

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• Working Away Draft Guidance. – arsa.org/working-away

• Contract Maintenance Rule References/Tools – arsa.org/contract-maintenance

• “Overhaul” Interpretation Content and Training – arsa.org/overhaul-training

• Conducting Audit Survey – arsa.org/audit-survey

http://arsa.org/regulatory

Regulatory Compliance - Industry Resources



http://arsa.org/working-away/

http://arsa.org/contract-maintenance/

http://arsa.org/overhaul-training/

http://arsa.org/audit-survey/

http://arsa.org/regulatory

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To access course materials, please visit:

http://potomac-law.com/orlando-2015


Course Materials







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Questions?


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121 North Henry Street Alexandria, VA 22314

Tel. 703-548-2030 Fax 703-299-0254

www.arsa.org [email protected]

Contact ARSA


http://www.arsa.org/

121 north henry street alexandria, va 22314 tel. 703.739...

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