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Ryan Aggergaard

Ryan Aggergaard has written 24 posts for MARPA

Draft Policy Concerning § 33.83 Engine Surveys Due Next Week

We previously wrote in this space about a new Draft Policy Statement issued by the FAA concerning the vibration surveys and engine surveys required under section 33.83 of the Federal Aviation Regulations.  The draft guidance attempts to more narrowly address the FAA’s concerns about full engine test for type certificate applicants.

MARPA plans to provide comments on this Draft Policy Statement to the FAA and has sent a draft of our comments to the MARPA Technical Committee for review.  If any of our members wish to review our draft comments to provide their feedback we would love to hear from you.  Please email Ryan Aggergaard at ryan@washingtonaviation.com if there are particular issues in the draft statement you believe should be addressed so that we can incorporate our members’ concerns.

MARPA also encourages our members to file their own comments on the Draft Policy Statement.  Comments are due to the FAA by November 21, 2014.  Comments should be emailed to Dorina Mihail at dorina.mihail@faa.gov. Comments can also be mailed to her at:

Federal Aviation Administration
Engine and Propeller Directorate
Standards Staff, ANW-111
12 New England Executive Park
Burlington, MA 01803

MARPA looks forward to your comments.

MARPA Wins Department of Commerce Grant to Expand Export of PMA!

MARPA is proud to announce that it is the recipient of a $300,000 matching grant from the Department of Commerce International Trade Administration Market Development Cooperator Program!  MARPA was one of eight recipients of funding under the Market Development Cooperator Program (MDCP), which is intended to help organizations boost exports and create U.S. jobs.  With the receipt of this assistance, MARPA plans to implement a number of initiatives to help grow the international PMA market and most importantly help our members grow their businesses by exporting more PMA parts!

The first of these initiatives will be to establish a European MARPA Conference, similar to the MARPA Annual Conference held in Las Vegas. Our current target is for the inaugural MARPA Europe conference to occur in May 2015, in Istanbul, Turkey.  The primary goal of MARPA Europe will be to bring together PMA manufacturers (our members) and customers from both Europe and the Middle East.  Air carriers reliably account for 25% of our Las Vegas attendees, and we expect to meet or exceed that rate at MARPA Europe.

Another initiative will be to lead educational missions to regions that present an opportunity for expanded PMA penetration. These include Japan, China, Southeast Asia, and the Middle East.  MARPA will lead technical and regulatory seminars explaining the benefits of PMA and the way PMAs fit within the regulatory framework of the various countries we visit.  MARPA also plans to attend regional MRO shows and other trade shows to educate the global aviation industry about the benefits of PMA.

Finally, MARPA will work with our partners and air carrier contacts to continue to bring more air carriers to both the MARPA Annual Conference in Las Vegas as well as MARPA Europe.  The significant and growing attendance by air carriers at MARPA’s conferences make them the premiere events for PMA manufacturers to meet and network with air carriers in an intimate setting.

Of course nothing in life is free!  One very important element of MARPA’s participation is the MDCP program will be measuring the effects our efforts have on growing the export PMA market.  In a previous post we explained that MARPA would begin collecting export data from our members to get a better idea of the global PMA market share and identify to what market PMAs were being sold and where opportunities lay.  As a part of our commitment to the Commerce Department, MARPA will track and measure the increases in exports reported by our members.  This will be an important part of the next three years, as MARPA works closely with the Commerce Department to grow exports of PMA.  MARPA will also need the help of its members to collect and report accurate data to measure the effects of our initiatives.  We will be working with our members to help them increase their exposure to foreign markets and increase their exports in order to optimize the return on the Commerce Department’s investment as well as to develop accurate PMA export data.

Fred Elliot from the Department of Commerce and Ryan Aggergaard from MARPA will be on hand at the MARPA 2014 Annual Conference in Las Vegas to discuss some of MARPA’s planned initiatives and the requirements related to the award of the MDCP grant, as well as to answer member questions on how they can benefit from MARPA’s new programs.  We look forward to seeing you there!

PMA Export Data Needed

As the sole trade association representing the PMA industry, MARPA receives many inquiries from both industry and regulators regarding the economic effect of the PMA industry.  Among the most frequent question is to the extent PMA parts are exported to other countries.  Because the aerospace industry is such a large exporter, information regarding economic effect is useful in helping to shape policy and build support for the industry.

Unfortunately, MARPA does not have a significant pool of data from which to report or draw conclusions when approached with questions about economic effects and export statistics.  Although we have data from a handful of members and plenty of anecdotal evidence to support the PMA industry’s positive economic effect, we lack significant hard data from which to draw any statistical conclusions.  We would like to change this.

MARPA is therefore beginning an initiative to collect export data from our members to begin developing statistical data specific to the PMA industry.  Rather than relying on information from aerospace trade publications or industry forecasting groups, which tend to focus on the aerospace industry as a whole without distinguishing PMA, MARPA seeks to develop a PMA-specific industry analysis.

But to develop and perform such economic export analyses, we need the help of our members.  We will therefore be requesting that our members provide to us economic export data about their businesses.  Such data would include, for example, to which countries you export, revenue derived from export, and percentage of total revenue derived from exports.

Of course, there is nothing more important to MARPA than a robust and competitive PMA industry.  With that in mind, all information submitted to MARPA will be kept strictly confidential, and used only for overall statistical analysis.  No company names, data, or strategies will ever be disclosed, either to other members, regulators, or the public in general.  We understand and appreciate how important confidentiality is, and how much value is placed in keeping data about your business private.

The more data we obtain the better we will be able to promote the benefits of PMA, open new markets and expand existing markets, continue to build the trust of industry, and gain the support of regulators.  We cannot do any of this without the support of our members.

We will be discussing this initiative further at the MARPA Annual Conference in Las Vegas, just a little more than a month away.  But in the meantime, if you have data readily available, or have any questions about this initiative, you can email them to Ryan Aggergaard at MARPA at ryan@washingtonaviation.com.  We look forward to hearing from you, and continuing to build the future of PMA.

Revised MARPA COS Guidance is Now Available for Comment

One of the many ways MARPA supports the PMA industry is through the issuance of its Continued Operational Safety (COS) system guidance material.  In order to continue to improve safety and address industry and regulatory concerns, MARPA regularly revises its COS guidance and makes the revised guidance available to the public.

MARPA recently issued Revision 3 to MARPA’s Guidance Material for a PMA Continued Operational Safety (COS) System for review and comment.  The COS guidance is available on the MARPA website under the Government Affairs Continued Operational Safety menu, or by clicking the direct link in this post.

As with any guidance material it is important that we receive comments and feedback from our members to ensure that the revisions to the COS guidance are workable and make sense.  We are therefore asking our members and the PMA industry to review the revised COS guidance and provide us with feedback.

Comments are due to MARPA by September 19, 2014.  You can submit comments to MARPA by emailing them to Ryan Aggergaard at ryan@washingtonaviation.com.  We look forward to your feedback.

MARPA Files Comments on FAA Geometry AC

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:

    •  Possible confusion over availability of existing industry guidance;
    •  Apparent inconsistency with existing FAA guidance;
    •  Inaccurate implications that product testing is the only method available to collect data for lifing methods of life limited parts; and
    •  Issues regarding the specific practice of part selection for selective assembly components.

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.

Your Feedback Needed on Engine Endurance Test Draft AC

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 ryan@washingtonaviation.com soon!

New Draft AC Could Affect Engine PMA Manufacturers

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 ryan@washingtonaviation.com.  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 mark.bouyer@faa.gov

New FAA PMA Policy Documents have been Issued

In recent weeks the FAA has released final versions of two important pieces of guidance.  FAA Order 8110.42DParts Manufacturer Approval Procedures, which cancels revision C, was published on April 10, and FAA AC 21.303-2Application 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 ryan@washingtonaviation.com.

MARPA Comments on New FAA PMA Policy

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/.

MARPA Joins U.S. Industry in Demanding Regulatory Transparency

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:

  • Federal agencies will submit monthly or yearly reports describing planned or final rulemakings to the Office of Management and Budget (OMB).  OMB would then release information about those rulemakings, including cost and benefit, to the public.
  • The Administratve Procedure Act will be updated to provide greater transparency to the public during the rulemaking process.  This is particularly important in light of the recent increase in regulations creating million- or billion-dollar burdens on industry.
  • Bring more transparency to the “sue and settle” process under which outside advocacy groups often take control of an agencies agenda and regulatory priorities.
  • Expand the scope of required regulatory impact analyses under the Regulatory Flexibility 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.

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