Will we see you in London this January?
The agenda for the January 22-23, 2014 London PMA Summit is set and is available on-line.
This Conference is managed by Aviation Maintenance Magazine and is a wonderful opportunity to meet with companies from the European and Middle-Eastern sectors of the aerospace industry. MARPA supports the Conference because it is a chance to continue to educate people about PMA in a positive and business-friendly setting.
Both Jason Dickstein and Ryan Aggergaard from MARPA plan to be there. We hope to see you too!
Congress has endorsed the concept of Part 23 aircraft relying on consensus standards as the basis for updates to airworthiness standards.
This was a key part of the Pat 23 ARC (an Industry-FAA rulemaking committee) recommendations, in which the reliance on consensus standards was meant to permit the FAA to update airworthiness standards more rapidly to reflect changing technical standards. It is hoped that this will permit companies to more readily develop safety improvements for the general aviation fleet.
For companies manufacturing Part 23 aircraft or parts for such aircraft, it will be important for them to identify the consensus-standards-setting bodies and to track or participate in their efforts to the extent that they affect the company’s projects.
Yesterday, the House agreed to the Senate version of the bill (H.R. 1848), which clears the bill for the President’s signature. The bill recognizes that the FAA shall issue new regulations by December 15, 2015 that will permit the establishment of broad, outcome-driven safety objectives in the hopes that they will spur innovation and technology adoption.
As of October 15, a significant change to the export regulations removed many articles from the ITARs and move them to the Commerce Department’s export jurisdiction.This movement reflects the fact that lower-risk parts do not need to have the same export controls as high-risk parts.
This change means that most dual use items (article used on both civil and defense aircraft) are transferred to the export jurisdiction of the Commerce Department’s Bureau of Industry and Security (BIS) where they will be regulated under the Export Administration Regulations (EARs).
Note that the rule change was largely aimed at aircraft parts, and non-aviation items may not be affected by this change.
So after the change, which aircraft parts remain subject to Directorate of Defense Trade Control (DDTC) export jurisdiction? Here is a partial list:
These above-referenced parts remain on the United States Munition List (USML), which is part of the International Trade in Arms Regulations (ITARs). So their exports will continue to be subject to ITAR control. But what is important is what is no longer on this list!
Parts that were previously described on the USML and were thus subject to DDTC/ITAR export jurisdiction but that are now moved to BIS/EAR jurisdiction have mostly been moved to the 600 series Export Commodity Classification Numbers (ECCNs). These are ECCNs with the number “6″ in the middle spot of the five-character ECCN. The 600-series is designated for Wassenaar Arrangement Munitions List (WAML) articles and for former USML articles.
As of today, the Commerce Control List (CCLs) on the Commerce Department website did not include the 600-series ECCNs, and the fact that the government was shut down suggests that they might not be updated soon. But you can still see the new ECCNs by looking at the Federal Register publication of the final rule.
Many aircraft parts that are no longer regulated under the DDTC ITARs are moved to ECCN 9A610. If an article remains on the USML, like an Attitude and Heading Reference Systems (AHRS), then its unclassified software may have moved to a BIS/EAR 600 series ECCN; the unclassified software and technology indirectly related to such USML articles move to new ECCNs 9D610/9E610 (aircraft software/technology) or 9D619/9E619 (engine software/technology). There is also a new ECCN for military commodities outside the US that are derived from “600 series” controlled content (ECCN 0A919 – Category 0 includes miscellaneous items).
In some cases, the precise placement of an article may depend on whether it is “specially designed” for 600-series articles or for non-600 series articles. BIS has provided an online decision tree-based tool to help with the “specially designed” determination and it is available at http://www.bis.doc.gov/index.php/specially-designed-tool.
Licenses from BIS will still be required to export and reexport most 600 series items worldwide (except to Canada), unless an EAR license exception is available. If you have an article that was subject to the DDTC/ITAR jurisdiction and has been moved to BIS/EAR jurisdiction, then your existing ITAR licenses may remain valid. Details on how this works and when your license may remain valid are available in last week’s post about grandfathering existing export licenses.
Got questions? We will be talking about export at the MARPA Conference. The Washington Aviation Group continues to provide export legal advice. So if you need to get really creative, please give the Washington Aviation Group a call and let them work with you to find a solution.
MARPA is pleased to announce that two more speakers have been confirmed for the 2013 agenda at the Annual Conference.
Peter Requa, the Director of Supply Chain Operations for Southwest Airlines will discuss How PMA Affects the Air Carrier. Eduardo J. Iglesias is the Executive Director of ALTA (Latin American and Caribbean Air Transport Association) and he will join us to discuss Latin America and The Caribbean: Growth and PMA Opportunities.
You can see the latest version of the Conference Agenda on our website at http://pmaparts.org/annualconference/2013ConferenceAgenda.shtml
Also, we have just returned from a very successful trip to Japan, and we are looking forward to welcoming several Japanese Conference attendees who will be looking for US business partners; so the Conference should be full of new business opportunities!
This week, MARPA is in Japan at the 2013 Aerospace Industry Exhibition Tokyo (ASET 2013). MARPA has an exhibit booth featuring information about the PMA marketplace and about our membership.
MARPA is not alone! Both Heico and Jet Parts Engineering sent staff to participate in the PMA panel during the conference. The panel featured two hours of presentations about PMA and questions and answers about PMA. It was attended by over a hundred aerospace professionals interested in learning more abut PMA.
In addition, though, several of our members sent literature to the conference, and MARPA has been handing their information to interested conference attendees. Those members were:
So far, we’ve seen a lot of interest from Japanese manufacturing companies in partnering with PMA companies from the United States, so the literature from member companies has been very helpful in educating the Japanese marketplace about potential US partners.
Many Japanese companies seem able to bring novel production technologies and novel solutions to the table as potential partners/suppliers. But that has not been the sole focus of this trip. We also had an opportunity to spend time with representatives from both ANA and JAL during our trip. Both air carriers remain keenly interested in the potential posed by PMA.
We were fortunate to be invited to deliver training sessions to both ANA Trading and ANA’s Materials Management Department. Both organizations were very gracious hosts. PMA was an important topic in each of those training sessions, and there were lots of insightful questions.
As many of you know, MARPA has been an active participant in the FAA’s efforts to develop both Design Organization and SMS regulations that would apply to the manufacturing community. This gives our members an exceptional opportunity to influence the regulations so that they will make sense and preserve safety.
The FAA is working on regulations that would require most design approval holders to be Design Organizations, which would be similar to EASA DOAs (under EASA subpart J in Europe). FAA Engineering Division Manager Dave Hempe will be at the MARPA Annual Conference to talk to companies about the costs and benefits of such a requirement.
The smallest companies (including many PMA companies) could be excepted from those design organization rules. But even those excepted companies will likely have to met some standard; the lower risk posed by excepted companies would mean that the standards applied to them could be lower.
This raises the question “how much of an organization SHOULD a small company be required to have as a minimum FAA standard?” We will be looking to the PMA community to help answer this question!
Soon, we will be soliciting volunteers for a limited engagement subcommittee that will be tasked with recommending those minimum standards. We anticipate that volunteers will be expected to commit to participate in between one and three one-hour-long telephone conferences – there will be no live meetings and no travel required. The purpose of those calls will be to solicit input about minimum standards that could apply to all design approval applicants and holders (even the smallest ones).
We really are going to need your help on this so please consider donating your time in order to register your opinion about what is reasonable for your business to do.
We will be publishing more details soon, but please contact us if you think you would like to participate!
George Powell’s family has set a date for a celebration of George’s life. This will be a cocktail reception to remember George and his impact on aviation. The reception has been set for the day after the MARPA Conference so that people from out of town can easily travel from the MARPA Conference in Las Vegas to Arizona to attend the reception and pay their respects to the family.
Please RSVP to email@example.com.
We hope to see all of the MARPA community at this very special event.
George’s children will be establishing an aerospace engineering scholarship in George’s name to honor his love of aviation and learning. More details should be available at the reception.
MARPA co-founder George Powell died on Friday, September 6 after a battle with cancer.
George’s aviation career began as an aircraft pilot during World War II. He then spent a career as an engineer and customer support manager for Bell Helicopter (highlighted by a daring escape from Iran when the Shah’s government fell).
By the 1980s, society felt George was ready to retire but George had different
plans. He became active as a PMA manufacturer and as an independent DER. He was passionate about small business and he helped many of today’s PMA companies get on their feet.
The idea of MARPA was born during the late 1990s, when George, Jim Reum and I sketched out our ideas for a trade association on the back of a cocktail napkin during the lunch break at an Aviation Rulemaking Advisory Committee meeting.
George served as the first President for the Association, and after he stepped down he remained an active guiding voice for MARPA. He was important mentor who helped to guide me and many others within the PMA community. He frequently communicated his ideas to the FAA, helping to shape the policies and regulations that affect the aerospace community.
George was never the sort who could rest – he always wanted to be active and involved. He was one of the leading voices on the MARPA Leasing Committee during the last year of his life. Despite the cancer, he also was active in supporting aerospace businesses right up until days before he passed.
George’s family is planning a celebration of life ceremony in October. They are trying to plan the celebration in Arizona just after the MARPA Conference in order to permit more of George’s friends and business associates from the aerospace industry to conveniently attend (more details are coming soon, and final details will depend on availability).
His family is working on a scholarship fund for aerospace engineering at George’s alma mater (RPI). We hope to have more details on this effort to share with the industry by the time of the MARPA Conference.
MARPA and the industry will be forever indebted to George for his leadership and guidance.
I am looking forward to seeing everyone at the 2013 MARPA Conference on October 23-25 in Las Vegas.
This year’s conference will review some of the new FAA programs that affect PMAs, and also offer a glimpse into the new policies and regulations that will affect the PMA community in the near future. A special highlight will be an opportunity to speak with FAA Engineering Division Manager Dave Hempe about Safety Management Systems (SMS). He is particularly interested in knowing what SMS will cost small businesses, This is an opportunity to ask questions, express your concerns, and provide information about potential costs.
And as always, we have A LOT of customers registered for the conference so there are tremendous sales opportunities waiting for PMA-company attendees as well!
We continue to add more information to the agenda about speakers and events, so be sure to check out the online Conference Agenda.
Not yet registered? The Conference Registration form is available online. Just fill it out and email or fax it. Questions? Call Katt Brigham at (202) 628-6777 and she will provide answers!
Make sure your registration reaches MARPA before the next deadline to get the current registration discount! The next deadline is Sept 21, 2013 and meeting that deadline will save MARPA members $200 (for the first-registrant from a company) to $300 (for each additional registrant from a company) over the cost of on-site registration.
You don’t have to be a member to come – non-members are also welcome to attend the Conference for the non-member rate.
Ed Pozzi of United Airlines has agreed to accept the position of Chair of the MARPA Air Carrier Committee.
Ed began his aviation career with United Airlines as a Customer Service Representative at Long Island MacArthur Airport in 1984 handling all aspects of airport operations. In 1990 he was promoted to engineering as an engineer in the 757/767 Fleet Technical Service group providing technical support for aircraft systems and interiors.
Ed has nearly 30 years of experience in the industry, all with United Airlines, holding a variety of managerial positions within engineering as well as representing United Airlines as the first airline employee to accept an internship with a Presidential-appointed Member of the NTSB in Washington, DC
Ed has demonstrated exemplary leadership as a change agent reinventing the PMA process by applying LEAN principles to many aspects of PMA development and approvals. This has resulted in PMA cost savings for United’s Technical Operations. He has also developed and implemented data mining methods to identify problematic, high cost, high usage parts for new PMA opportunities.
Please join me in welcoming Ed as the new Chair!!
Ed has some exciting plans for the Committee. I hope all of our air carrier members will all be able to join him at the Air Carrier Committee Meeting on October 23 (part of the MARPA Annual Conference) as well as the brainstorming session he is planning to examine a lobbying effort aimed at producing an air carrier PMA-approval-checklist that would be published as an FAA Advisory Circular. Information on these events can be found at the MARPA Conference Agenda, and the details will be updated as more information becomes known.