MARPA recently filed comments on the FAA Engine and Propeller Directorate’s draft Advisory Circular 33-Geometry, discussing geometry and dimensional considerations for comparative test and analysis for turbine engine and APU replacement parts. In a previous blog post we observed that AC identified a number dimensional and geometric factors that the FAA expects to be assessed in ensuring the integrity of dimensional characteristics for the purposes of showing similarity.
We requested feedback from our members describing to what extent the FAA’s expectations were reasonable and practicable, and identifying any issues with the proposed guidance on which MARPA should comment. We received several very helpful responses from our members that helped us shape our comments to the proposed AC. Among the issues members identified were:
Feedback from our members is both helpful and valuable to our comments, as it helps us to identify issues that directly affect members’ businesses, and helps us to better focus our resources on those matters that are important to the PMA community. The result is more detailed and on-point responses to the FAA to better help shape the guidance material that will ultimately be issued.
We greatly appreciate the feedback we received from our members on this Advisory Circular, and we hope that our members will continue to answers our requests for responses as additional guidance and rulemaking documents are issued. Together we can work with the FAA to develop the best possible guidance for our industry.
The FAA is currently seeking comments on its Draft Advisory Circular Engine Overtorque Test, Calibration Test, Endurance Test, and Teardown Inspection for Turbine Engine Certification (§§ 33.84, 33.85, 33.87, 33.93).
As the title suggests, the AC offers guidance on compliance with the engine overtorque, calibration, and endurance tests, and teardown inspection called out in Part 33 of the Federal Aviation Regulations. Although the guidance is directed at engine manufacturers, foreign regulatory authorities, applicants for engine type design approval, and FAA designees, it also notes that parts manufacturer approvals “may require running certain endurance testing for compliance with § 33.87″ and refers to AC 33.87-2 for guidance on showing compliance by comparative test methods.
MARPA would like to know to what extent members anticipate this AC might effect them, and whether we should submit comments. If you plan on submitting comments, or have already done so, we would would like your feedback so that we can incorporate member concerns into our comments.
Comments on the Draft AC are due next week, so if you have feedback for us please submit them to email@example.com soon!
The FAA Engine and Propeller Directorate has issued a new draft Advisory Circular that could have a significant effect on companies seeking PMAs, STCs, or approval of repair or alteration of turbine engine and APU parts. Draft AC 33-Geometry: Geometry and Dimensional Considerations for Comparative Test and Analysis for Turbine Engine and Auxiliary Power Unit (APU) Replacement, Redesign, and Repaired Parts is directed at applicants who use comparative techniques to reproduce dimensional characteristics of parts during the reverse engineering process.
The AC is intended to provide guidance to help PMA (and other) applicants assess their reverse engineering methods to identify possible causes of dimensional inaccuracies, as well as helping applicants develop adequate criteria for determining dimensional similarity between the PMA design and the sample. To that end, the draft AC identifies several dimensional and geometric factors that the FAA expects should be assessed in seeking to ensure the integrity of dimensional characteristics for the purposes of showing similarity. These factors range from geometric relationships to precision and accuracy to influence on critical parts.
The background section of the draft AC states that because reverse engineering methods vary in their measurement techniques, interpretation and combination of data, and in dimensioning systems, they do not typically produce a design with the exact same dimensional properties as the type design part. It further explains that because dimensional differences may exist, functional assessments–which may include both test and supplemental analytical data–will be necessary to safeguard type design functional properties, as well as capabilities of interfacing and higher level assemblies. Such explanations help to illuminate the FAA’s expectations of an applicant in making showings of dimensional similarity. MARPA would like feedback from our members describing to what extent such test data is currently available and practical within the industry.
Although this AC, like all Advisory Circulars, is neither mandatory nor regulatory, such guidance documents do sometimes become ingrained and relied upon in considering applications. It is therefore important to review the draft and offer comments to the FAA to ensure the guidance reflects the realities of our industry. MARPA will be closely reviewing the guidance and offering comments on behalf of the PMA community. If you identify any particular issues within the guidance, please bring them to our attention so we can incorporate them into our comments. Email your concerns to firstname.lastname@example.org. We also recommend that members who identify concerns file their own comments on the guidance. Comments are due July 3, 2014 and should be submitted to Mark Bouyer of the Engine and Propeller Directorate, at email@example.com
In recent weeks the FAA has released final versions of two important pieces of guidance. FAA Order 8110.42D – Parts Manufacturer Approval Procedures, which cancels revision C, was published on April 10, and FAA AC 21.303-2 – Application For Parts Manufacturer Approval Via Tests and Computations Or Identicality, was published on April 7. Both of these documents have a direct effect on PMA producers.
MARPA submitted comments addressing issues in these guidance documents in September, 2013. Among the issues MARPA noted was the intended use in Order 8110.42D of the FAA’s Risk Based Resource Targeting Tool (RBRT tool) to prioritize PMA projects. MARPA observed that the RBRT tool as intended relied on subjective assessments of project risk that could result in unfair treatment of certain PMA projects. The FAA agreed that the RBRT tool was not quite ready for prime time and has removed it from the Order. MARPA will remain vigilant, however, as guidance for use of the RBRT tool will be addressed in a future Order.
MARPA also worked with its members to offer comments and feedback to the FAA regarding AC 21.303-2. This new AC consists primarily of guidance to PMA applicants that formerly appeared in the now-cancelled Order 8110.42C. MARPA offered comments addressing the expected sample sizes needed for PMA applications based on test and computation, origins of samples, and discretion for establishing sample sizes. The FAA’s adoption of these comments should better help square the advisory guidance with the realities of industry sampling.
MARPA also commented that references to Order 8110.119 - Streamline Process for Parts Manufacturer Approval (PMA) should be included in both documents to encourage use of the Streamlined PMA process when applicable. We are pleased that the FAA agreed and adopted references to the Order in both guidance documents. We are hopeful that the inclusion of references to Order 8110.119 in both Order 8110.42D and AC 21.303-2 will further promote ACO acceptance and PMA applicant use of the Streamlined PMA process.
Both of these guidance documents are now active. Members should familiarize themselves with the guidance, as it will inform the nature of the application process and the relationship with the FAA and your ACOs. In reviewing the two documents, if you notice anything troubling or that seems out of place, please bring it to our attention so that we can work with the FAA to find a solution. Send your thoughts on Order 8110.42 revision D and AC 21.303-2 to firstname.lastname@example.org.
In January, we wrote in this space about two new FAA Policy Statement proposals aimed at increasing coordination between FAA offices in the cases of certain engine PMA and propeller PMA applications. MARPA is always on the lookout for those potential regulations and policies–whether large or small–that could effect our members. In an effort to best support the industry, MARPA solicits feedback from members and files comments addressing the concerns of the PMA community with the FAA. MARPA also works to support the FAA in order to provide industry’s perspective and needs in order to help develop the best rules, policy, and guidance possible.
Last week we filed comments on draft policy statements PS-ANE-33.3-05 and PS-ANE-35.15-02. These two statements were substantially similar in content, and therefore raised similar concerns. The policy statements are intended to create a uniform policy describing the engine and propeller PMA projects for which an ACO is required to use the national certification project notification (CPN) database to alert the Certification Management ACO (CMACO) and Engine and Propeller Directorate (EPD) about the project. The purpose is to enable the CMACO and EPD to provide relevant input when the PMA application is for a project the failure of which may result in a loss of thrust or power.
MARPA noted several possible issues with the proposed Policy Statements. First, our comments noted that the policy as proposed could run the risk of burdening PMA applicants by delaying response time, as each FAA office took the opportunity to review the project. MARPA also noted the risk that differences of opinion between offices could be hashed out using an individual PMA application as the mechanism. This could also result in undue burden to the applicant. Finally, MARPA noted that inquiries by FAA offices about certain PMA projects could inadvertently alert TC holders of possible competition in a particular part market, and give that TC holder the opportunity to lock up the market before the PMA package is ever approved; a clear unfair competitive advantage.
Finally, MARPA noted that a certain provision uniquely included in PS-ANE-33.3-05 (the engine-PMA Policy Statement) was needlessly critical of PMAs and potentially harmful to the PMA industry. The sentence in question reads “[f]ailure of some of these engine PMA parts has resulted in unsafe conditions and the issuance of airworthiness directives.” MARPA explained that this sentence was inappropriate for two reasons. First, it incorrectly implies that PMA parts are abnormally unsafe and that TC products do not have a history of resulting in ADs. Second, the sentence in no way advances the purpose of the Policy Statement, which is to establish uniform standards for use of the CPN database. For these reasons, MARPA recommended the deletion of the sentence.
MARPA will continue to work for its members to advise and cooperate with the FAA in crafting fair and effective policy. Members comments on these issues are always welcome.
You can read MARPA’s comments in their entirety on the MARPA website under the Government Affairs tab at http://www.pmaparts.org/government/.
Last month, MARPA joined with a broad coalition of U.S. industry associations and representatives who together signed on to a letter to the U.S. House of Representatives in support of current legislative efforts to enact reform of the regulatory process. The multi-industry letter emphasized the importance of creating a level playing field for citizens regulated by federal agencies, holding agencies accountable to the public, and improving the transparency of agency actions.
Transparency and participation between federal agencies and the citizens they regulate is an important part of the regulatory process. Rulemaking processes that are opaque or secret can result in regulations that are not only unduly burdensome, but which also may ignore important advances in industry practices and techniques, due to an absence of industry participation and information. Such regulations also undermine industry confidence in the regulatory agencies and can lead to unjust or unreasonable penalties as a result poorly drafted rules or rules that are unworkable in practice.
The legislation before the House of Representatives, H.R. 2804 Achieving Less Excess in Regulation and Requiring Transparency (ALERRT) Act, draws upon concepts described in a number of other bills. Several key elements are included in the ALERRT Act:
By enacting the above mentioned reforms, Congress can help to create a level playing field for its citizens, better hold agencies accountable to the public, and improve the transparency of agency actions. Improved access and confidence in the regulatory process should result in fewer unduly burdensome or unworkable regulations and encourage increased stakeholder participation in the rulemaking process.
In mid-December the Commodity Classification Standards Board (CCSB) issued a Notice of Proposed Amendment to the National Motor Freight Classification. Specifically, the proposed amendment seeks to make certain reclassifications relating to helicopter rotor blades and leading edge coverings, and make clarifications regarding aircraft propeller blades. Those companies that manufacture and ship rotorcraft blades and leading edge coverings may wish to review the proposed amendment to determine the potential cost effects of the proposed reclassifications.
The National Motor Freight Classification is a voluntary standard that assigns classes based on a product’s transportation characteristics, and provides a comparison of those products when they are shipped via motor carrier. The transportation characteristics of a product are determined based on its dimensions, density, ease of handling, and potential liability due to damage or other factors. Products once classified are assigned a class name (e.g., Class 50; Class 100; Class 300) with higher class names generally having a greater cost to ship.
The provisions pertaining to leading edge coverings and rotor blades were initially developed in the 1950s. Leading edges were assigned item number 12110 and rotor blades 12130, and freight classes 70 and 100, respectively. In the intervening years, technological advances in manufacturing and materials have resulted in leading edges and blades becoming longer and less dense. The effect of these advances is that the original freight classes assigned to the item numbers no longer accurately reflect the shipping characteristics of leading edges and blades of increasing length.
The proposed amendment suggests that as edges and blades grow longer and less dense, the costs of handling, practicalities of stowing, and potential liability due to damage increases, and therefore items of increasing length should be assigned differing freight classes to reflect the varying transportation characteristics. The amendment therefore makes two proposals: First, it would cancel item number 12110 pertaining to leading edges and redefine item 12130 to include both rotor blades and leading edges. This is due to the understanding that leading edges and rotor blades have similar transport characteristics.
Second, the amendment would assign different freight classes to blades of increased lengths as follows:
|Greatest Dimension||Proposed Class|
|Exceeding 288 inches||300|
|Exceeding 192 inches but not exceeding 288 inches||175|
|Exceeding 96 inches but not exceeding 192 inches||100|
|Not exceeding 96 inches||92.5|
These proposed classes greatly exceed the current freight classes assigned to leading edges and blades, and as such have the potential to substantially increase transportation costs. It should also be noted that the proposed classes exceed the class suggested by CCSB’s own density guidelines.
A final element of the proposal would also specifically exclude rotor blades and edges from category 12280 pertaining to aircraft propeller blades to avoid confusion or ambiguity.
Persons with information regarding the transportation characteristics of rotor blades and leading edge coverings are invited to submit a written statement to CCSB prior to their meeting on Tuesday, January 28, 2014. Information regarding this proposal may be found at CCSB Docket 2014-1. Manufacturers should take the opportunity to review the docket and data therein to determine what potential effects such reclassifications would have on their shipping and transportation costs, as well as to determine if the proposed classes are reasonable based on the transport characteristics of the articles.
Last week MARPA filed comments with the FAA in response to two policy documents that directly affect PMA manufacturers. As we previously explained on this blog, both of these documents speak directly to the PMA approval process.
Draft revision D to FAA Order 8110.42 Parts Manufacturer Approval Procedures. Two notable changes made in the revision was the removal of guidance to PMA applicants (released as a stand-alone document as draft AC 21.303-PMA) and the inclusion of a section directing ACOs to apply the FAA Risk Based Resource Targeting (RBRT) tool. It also made certain technical changes to the Order to update citations and keep up with rule changes.
MARPA observed that the inclusion of RBRT in the Order creates the risk of unequal treatment across—or even within—different offices. This is because the RBRT tool attempts to create the appearance of objectivity by assigning numerical values to what are essentially subjective evaluations by FAA personnel. Because the tool offers no metric, rubric, or guidance to aid FAA personnel in assigning values, it is possible for even identical projects to be assigned different risk values based on the subjective assessments of personnel. The ultimate result is that highly similar projects could be allocated markedly different resources.
Draft Advisory Circular 21.303-PMA updates the FAA guidance to applicants for PMA of articles submitted on the basis of test and computation or identicality without a license agreement. This guidance is for the most part a recast of the guidance that formerly appeared in Order 8110.42C. MARPA offered suggestions for improving the guidance related to sample sizes required for test and computation analysis, as well as general comments seeking to clarify the guidance.
In both documents, MARPA commented that the FAA should include a section describing use of the Streamlined PMA application process.
We plan to meet with representatives from the FAA in person to further discuss these comments. FAA personnel will also be at the MARPA Conference in Las Vegas, October 23-25, and available to discuss PMA guidance and other initiatives. MARPA will continue to work with the FAA to ensure that the guidance enhances safety while limiting burden to our members and the industry.
We previously wrote in this space that MARPA will be attending the 2013 Aerospace Industry Exhibition Tokyo (ASET). As a benefit to our members, MARPA plans to feature member-company literature in our booth to allow you to make connections with the Japanese aerospace manufacturing market. This is just one of the benefits of MARPA membership. ASET offers an excellent opportunity get in front of a substantial segment of the Japanese aerospace manufacturing community; at the last conference over 23,000 people attended!
In order to help us feature member companies in the MARPA booth, members must ship their literature to us in Tokyo. To ensure we are able to showcase your literature, you must follow these steps:
1. Act quickly! ASET runs October 2-4. You should plan to have your literature arrive absolutely no later than Monday, September 23. This will allow adequate time to ensure your package clears customs.
2. Ship your package to:MARPA (Booth No. G-01) c/o AEROSPACE INDUSTRY EXHIBITION TOKYO 2013 2013 Management office Tokyo Big Site 3-11-1 Ariake, Koto-ku, Tokyo 135-0063, Japan
3. Email Katt Brigham at MARPA with your package tracking information. This should include the date the package was shipped and the estimated date of arrival. You should also include the contents of your package so we know what to look for.
4. Confirm your package arrives in Tokyo. When you have confirmed arrival email Katt to let us know as well.
Remember it will take about a week for your shipment to clear customs upon arrival in Japan. It is therefore vital that you ship your literature in time to ensure arrival by September 23.
MARPA is excited to be able to offer this opportunity to its members. If you have any questions about shipping, please contact Katt at (202) 628-6777 or by email at email@example.com.
MARPA continues to work diligently in support of the FAA’s Part 21 ARC. One of the ARC working groups is focused specifically on performing a cost benefit analysis of the ARCs proposals. We previously posted on the blog a request for our members’ input on what data we should be tracking in order to best estimate costs. Although we have received a handful of responses to date, we still need your feedback to ensure we have an accurate cost assessment as possible!
Our members have reported the following measurable data points
The data your company is able to measure may be similar, or may be different. In either case, we want to hear from you to provide a useful and usable data survey. Remember, at this time we are NOT collecting actual numbers, but merely attempting to determine what data we can reasonably expect to collect in the future to help with our cost benefit analysis. Future data will be collect anonymously to protect our members’ competitive interests while also guarding against costly regulation.
This information will help us to develop metrics for measuring industry costs of regulatory compliance. We will then have a baseline to which we will compare the costs and benefits of the ARC’s proposals. This is industry’s opportunity to provide detailed feedback regarding the costs of FAA regulations. The FAA will be joining us at the MARPA Conference in October, so it is important that we have investigated and reviewed this data prior to that time.
If you have not yet taken the opportunity to respond with what sort of cost data your company tracks, please take a few minutes and let us know. This will go a long way to helping us ensure the Part 21 ARC develops sound and cost effective proposals to deliver to the FAA. Email responses to MARPA Associate Counsel Ryan Aggergaard at firstname.lastname@example.org.