ARSA - Aeronautical Repair Station Association

FAA Responds to ARSA Request

Wed, 24 Feb 2010 11:54:44 -0500

On February 23, 2010, the Federal Aviation Administration (FAA) issued its final response to a Customer Service Initiative (CSI) request filed by ARSA on behalf of Erickson Air-Crane nearly six years ago. (The program is now known as the Consistency and Standardization Initiative.) The FAA’s CSI letter addresses the relationship between technical data (i.e., engineering information) on the one hand, and methods, techniques and practices for performing maintenance and alterations on the other.

Concurring with ARSA’s interpretation of the pertinent rules, the FAA concluded that the "how-to" instructions for performing maintenance and alterations contained in manufacturer’s manuals is already supported by approved technical data when such approval is required under sections 65.95(d)(1), 121.379(b), 135.437(b) and 145.201(c) (i.e., when performing major repairs and alterations). Because the technical data was approved under the design change procedures of part 21 there is no need to have the data re-approved via a field approval (block 3 of a Form 337), DER approval (Form 8110-3) or approval by another authorized designee. The FAA’s decision applies to thousands of existing manufacturers’ maintenance and overhaul manuals including Structural Repair Manuals, Aircraft Maintenance Manuals, Engine and Propeller Maintenance Manuals and Component Maintenance Manuals.

ARSA Questions TSA Authority

Thu, 18 Feb 2010 16:52:57 -0500

In its comments to the Transportation Security Administration’s (TSA) repair station security regulations, ARSA questioned whether the agency had jurisdiction over certificate action. In its proposed rule, the TSA attempted to follow the congressional mandate to establish procedures for appealing a revocation of a certificate when the repair station posed an "immediate security risk". However, that statute does not, in ARSA’s opinion, supersede the National Transportation Safety Board’s (NTSB) authority to review all certificate actions. The association requested the TSA to completely rewrite the compliance and enforcement subpart and to use the existing procedures in the Federal Aviation Administration regulations (14 CFR part 13) and NTSB rules (49 CFR part 831).

Dear Mr. President: We Know a Great Place to Start…

Thu, 11 Feb 2010 13:12:33 -0500

On Jan. 27, President Obama delivered his first State of the Union address. While touching on numerous initiatives from foreign relations to the waning healthcare legislation, the crux of the president’s message was simple—the nation needs jobs and an economic jolt. To spur economic growth, Obama said, "[W]e need to export more of our goods. Because the more products we make and sell to other countries, the more jobs we support right here in America."

The aviation maintenance industry certainly agrees that a greater emphasis on selling goods and services abroad benefits businesses in the U.S. Unfortunately, pending legislation on Capitol Hill could undermine one of our country’s greatest exports.

ARSA Contributes at EASA ICA Workshop

Wed, 27 Jan 2010 13:12:08 -0500

On Jan. 19, the European Aviation Safety Agency (EASA) hosted an “Instructions for Continued Airworthiness (ICA) Workshop” at the Agency’s headquarters in Cologne, Germany.

In addition to industry representation, the Federal Aviation Administration (FAA), Transport Canada (TCCA) and other National Aviation Authorities (NAA) were in attendance. In that regard, EASA will attempt to “harmonize as far as possible [the ICA requirements] with relevant FAA and TCCA rules, orders and guidance.” Due to the intense interest in ICAs, all 133 seats in the meeting room were occupied and approximately 50 people were turned away due to space constraints according to EASA.

SCOTUS Ruling Lifts Campaign Finance Restriction

Wed, 10 Feb 2010 21:19:17 -0500

On Jan. 21, a divided U.S. Supreme Court changed the landscape of campaign finance in a decision relaxing limitations placed on corporations, labor unions, and non-profit organizations.

The 5-4 decision in Citizens United v. Federal Election Commission negated a provision in the 2002 Bipartisan Campaign Reform Act (better known as the “McCain-Feingold Act”) prohibiting corporations, labor unions, and non-profit organizations from financing political advertisements in support or opposition to a political candidate within 30 days of a primary or 60 days of a general election. Justice Anthony Kennedy, who penned the majority opinion, stated that the restrictions in place under the McCain-Feingold Act were counter to First Amendment protections.

Part 21 Changes

Fri, 18 Dec 2009 11:59:17 -0500

Effective April 14, 2010, the FAA rules regarding the certification procedures and identification requirements for aeronautical products and articles will change. Sections of parts 1; 21; 43; and 45 are amended. In the preamble to the final rule (Published in the Federal Register: 74 FR 53368, October 16, 2009 the FAA’s stated aim is to update and standardize requirements for production approval holders, revise export airworthiness approval requirements to facilitate global manufacturing, move all part marking requirements from part 21 to part 45 and amend the identification requirements for products and articles. The FAA claims the changes will better reflect the current global aircraft and aircraft products and articles manufacturing environment.