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LOBBYING REPORT |
Lobbying Disclosure Act of 1995 (Section 5) - All Filers Are Required to Complete This Page
2. Address
| Address1 | 117 NORTH HENRY STREET |
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| City | ALEXANDRIA |
State | VA |
Zip Code | 22314 |
Country | USA |
3. Principal place of business (if different than line 2)
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5. Senate ID# 81351-12
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6. House ID# 363090000
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| TYPE OF REPORT | 8. Year | 2023 |
Q1 (1/1 - 3/31) | Q2 (4/1 - 6/30) | Q3 (7/1 - 9/30) | Q4 (10/1 - 12/31) |
9. Check if this filing amends a previously filed version of this report
| 10. Check if this is a Termination Report | Termination Date |
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11. No Lobbying Issue Activity |
| INCOME OR EXPENSES - YOU MUST complete either Line 12 or Line 13 | |||||||||
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| 12. Lobbying | 13. Organizations | ||||||||
| INCOME relating to lobbying activities for this reporting period was: | EXPENSE relating to lobbying activities for this reporting period were: | ||||||||
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| Provide a good faith estimate, rounded to the nearest $10,000, of all lobbying related income for the client (including all payments to the registrant by any other entity for lobbying activities on behalf of the client). | 14. REPORTING Check box to indicate expense accounting method. See instructions for description of options. | ||||||||
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Method A.
Reporting amounts using LDA definitions only
Method B. Reporting amounts under section 6033(b)(8) of the Internal Revenue Code Method C. Reporting amounts under section 162(e) of the Internal Revenue Code |
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| Signature | Digitally Signed By: Christian Klein |
Date | 7/14/2023 4:12:35 PM |
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code AVI
16. Specific lobbying issues
Reauthorization of the Federal Aviation Administration (Securing Growth and Robust Leadership in American Aviation Act (H.R. 3935) and FAA Reauthorization Act of 2023 (S. 1939). Specific issues:
1. Enhance Aviation Rulemaking and Exemption Due Process by improving agency responsiveness to industry stakeholder petitions for rule changes and exemptions.
2. Require timely resolution of FAA investigations so stale letters of investigation sent to certificate holders do not hang as a cloud over their companies and careers for years.
3. Restore the right of repair stations to unilaterally surrender their certificates (as proposed in the PLANE Act 601) when businesses close, merge, etc. to improve due process given the lack of FAA procedures for accepting surrendered certificates.
4. Enhance international cooperation between the FAA and other CAAs by directing FAA to amend 14 CFR part 43 to allow the FAA to accept certificates/approvals issued by other CAAs if those CAAs accept FAA certificates pursuant to a bilateral aviation safety agreement.
5. Enhance access to maintenance data by directing FAA to task the Aviation Rulemaking Advisory Committee (ARAC) to review current rules and policy related to instructions of continued airworthiness (ICA, aka maintenance manuals) and recommend guidance and/or regulatory changes to enhance ICA access for aircraft owners, maintainers, and others.
6. End misapplication of FAA guidance by confirming that unless a course of conduct is specifically prohibited by the regulations, the agency must allow it and by prohibiting the agency from enforcing guidance not supported by a specific law or regulation.
7. Limit reversal of agency approvals issued to a certificate holder without the express written consent of the executive director of FAAs Flight Standards Service and/or Aircraft Certification Service, as applicable, or their delegees.
8. Clarify supplemental type certificate requirements by tasking the agency to explain the differences between a major alteration that introduces a major change in type design under 14 CFR 21.113(b) and a major alteration that does not require an Supplemental Type Certificate.
9. Maintain current foreign repair station oversight regime by rejecting legislation to impose unnecessary, new mandates on U.S. aircraft operators and FAA certificated repair stations outside the United States, divert scarce FAA resources, and potentially subject U.S. facilities to foreign retaliation.
10. Expand and enhance the maintenance technician and pilot workforce development grant programs created by Sec. 625 of the 2018 FAA law by increasing funding to at least $20 million for each grant program and making changes to expand eligibility and improve implementation.
11. Improve the transition of military maintenance professionals to civil aviation by directing FAA to create a military competency examination similar to that for military pilots and to fast-track repairman certificate applications for individuals with military technical experience applicable to aviation maintenance (even those from non-aviation specialties) but insufficient to qualify for full mechanic certification.
12. Create a National Center for the Advancement of Aviation (as proposed in the 117th Congress in H.R. 3482) to facilitate collaboration and cooperation between aviation and aerospace stakeholders to support and promote civil and military aviation and aerospace careers.
13. Improve federal coordination and data collection by creating an interagency aviation workforce working group comprised of representatives from the FAA and Departments of Transportation, Labor, and Education to identify data gaps and ways to improve government data collection and analysis, including expanding FAA U.S. Civil Airmen Statistics as recommended by the Women in Aviation Advisory Board.
14. Reduce barriers to entry by directing a rulemaking to amend part 65 to allow mechanic certificate applicants to sit for the general knowledge test prior to meeting those experience requirements if they have completed the appropriate curriculum in conjunction with a high school program.
15. Improve the repair station certification process by better prioritizing applications.
16. Enhance use of 529 educational savings accounts for aviation technical education (H.R. 1818).
17. House(s) of Congress and Federal agencies Check if None
U.S. HOUSE OF REPRESENTATIVES, U.S. SENATE, Federal Aviation Administration (FAA)
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Christian |
Klein |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
LOBBYING ACTIVITY. Select as many codes as necessary to reflect the general issue areas in which the registrant engaged in lobbying on behalf of the client during the reporting period. Using a separate page for each code, provide information as requested. Add additional page(s) as needed.
15. General issue area code DEF
16. Specific lobbying issues
Urge inclusion of language in the FY 2024 National Defense Authorization Act (NDAA) (H.R. 2760 and S. 2226) to compel DOD to improve competition for maintenance on civilian derivative aircraft by more-readily accepting FAA approvals (e.g., Parts Manufacturer Approval (PMA) parts and Designated Engineering Representative (DER) repairs) and by improving access to the technical data required to maintain aircraft purchased by DOD.
17. House(s) of Congress and Federal agencies Check if None
U.S. SENATE, U.S. HOUSE OF REPRESENTATIVES
18. Name of each individual who acted as a lobbyist in this issue area
| First Name | Last Name | Suffix | Covered Official Position (if applicable) | New |
Christian |
Klein |
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19. Interest of each foreign entity in the specific issues listed on line 16 above Check if None
Information Update Page - Complete ONLY where registration information has changed.
20. Client new address
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21. Client new principal place of business (if different than line 20)
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22. New General description of client’s business or activities
LOBBYIST UPDATE
23. Name of each previously reported individual who is no longer expected to act as a lobbyist for the client
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ISSUE UPDATE
24. General lobbying issue that no longer pertains
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AFFILIATED ORGANIZATIONS
25. Add the following affiliated organization(s)
Internet Address:
| Name | Address |
Principal Place of Business (city and state or country) |
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26. Name of each previously reported organization that is no longer affiliated with the registrant or client
| 1 | 2 | 3 |
FOREIGN ENTITIES
27. Add the following foreign entities:
| Name | Address |
Principal place of business (city and state or country) |
Amount of contribution for lobbying activities | Ownership percentage in client | ||||||||||
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28. Name of each previously reported foreign entity that no longer owns, or controls, or is affiliated with the registrant, client or affiliated organization
| 1 | 3 | 5 |
| 2 | 4 | 6 |
CONVICTIONS DISCLOSURE
29. Have any of the lobbyists listed on this report been convicted in a Federal or State Court of an offense involving bribery,
extortion, embezzlement, an illegal kickback, tax evasion, fraud, a conflict of interest, making a false statement, perjury, or money laundering?
| Lobbyist Name | Description of Offense(s) |