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MARPA to Discuss Policy with Engine and Propeller Directorate

Dear MARPA Members:

MARPA will be “meeting” with the Engine and Propeller Directorate via a telephone conference on August 7, 2014 at 13:00 Eastern Time. Association members are invited to participate.  If you are a MARPA member and would like to participate, please contact Katt Brigham by email or by phone!

We will be discussing the Engine and Propeller Directorate’s future work plan for policy guidance affecting PMAs, and will also receive status updates on current projects.  MARPA plans to share trends in the industry that could require FAA attention, as well as information on “lessons learned” in the realm of Continued Operational Safety (COS).

This informal working meeting is part of a series of meetings between MARPA and the FAA that are intended to promote communication in an effort to manage safety in a proactive, efficient, effective manner.  It is an excellent opportunity to let the Engine and Propeller Directorate know whether their existing policy is effective in supporting safety.  Nothing said by the FAA is intended to bind the FAA to any particular course of action.  Participants are asked to respect the FAA’s standards reflecting ex parte communication.

Ensure Your Manufacturing Designees Get Their New Designee Numbers

Do you have manufacturing designees in your facility?  If so then they should be going through the process of obtaining new designee numbers.

The FAA is switching all FAA-designees over to their new DMS system and all designees are being given new, unique, nine-digit identification numbers known as “designee numbers.”  The DMS was announced in Order 8000.95,which is the FAA’s Order on Designee Management Policy.

DMS will collect, store and process data and information associated with designees and the designee management processes in accordance with FAA recordkeeping requirements. See Designee Management Policy, FAA Order 8000.95 (April 11, 2014). Designees should note that there is an explicit disclaimer of privacy, so designees are surrendering any expectations of privacy that they may have with respect to information stored in this system.

Manufacturing DARs are first to go through this process and many of them have already received their new numbers. The deadline for completing this process is ten days after the notification (which should have been received in June or early July), so if your manufacturing DAR is not yet registered properly in the DMS system, then please make sure he or she gets registered appropriately, ASAP; failure to renew through the DMS system could mean that the DAR loses his or her designee privileges!

The FAA intends for ALL manufacturing designees to be converted over to the DMS system by September. To that end, all new manufacturing DAR and DMIR applications after May 7, 2014 are being processed through the DMS.

JCAB to Speak at the 2014 MARPA Conference

We are just over two months away from the 2014 MARPA Conference! MARPA is thrilled to see that PMA manufacturers, air carriers, and regulators from all over the world are joining us this year in Las Vegas.  Part of what makes the annual MARPA Conference an important event to attend is hearing from leaders in our industry first-hand.

This year, Daisuke Umezawa, Japan Civil Aviation Bureau (JCAB)’s Director, Airworthiness Standards and International Affairs Office Airworthiness Division, will be joining us to discuss Japan’s consideration of establishing a Japanese PMA framework, and the possibility of working with FAA regulators to accept JPMA articles.  This is a very exciting prospect for the future of PMA, and we think you’ll enjoy hearing his insights regarding possible developments.

At the invitation of MARPA member Jay Kato, MARPA visited Japan to attend the 2013 Aerospace Industry Exhibition Tokyo (ASET 2013).  This visit was an opportunity to introduce ASET 2013 attendees to information about the PMA marketplace and about our membership.  Many Japanese companies are very interested in the potential offered by PMA, and bring new opportunities as potential partners and suppliers.  Mr. Umezawa visiting our event is an excellent chance to continue to both learn about and to share with the JCAB.

We’ve got an exciting line-up of keynote and other speakers on the agenda, and you will hear more in the weeks ahead. You can find the Conference agenda and other information on our website.

We hope to see you in Las Vegas this October. Register today!

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!

MARPA Announces United Airlines’ Mike Arata as Day Two Keynote Speaker for 2014 MARPA Conference

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MARPA is proud to announce that Mike Arata, Managing Director of Engineering at United Airlines, will serve as day two keynote speaker for the 2014 MARPA Conference.

Mr. Arata has held various positions at United over his 22 year career.  He hired into United in San Francisco as a Liaison Engineer upon his graduation from college. He later transferred to Chicago, where he continued to work with Liaison Engineering in the lead engineer role.  He ventured out of engineering for a few years and worked with the Chicago Line Maintenance team as an Area Manager responsible for the day to day maintenance activities of running a large hub maintenance station.  Prior to his current role of Managing Director, he held the title of Senior Manager of Liaison Engineering. 

 In his current role, Mr. Arata is responsible for the compliance, configuration control, and modifications technical program requirements for the fleet.  Mr. Arata’s engineering team consists of over seventy engineers that work in the following four disciplines: Avionics, Systems, Powerplant Engineering and Cabin Systems

Beyond United, Mr. Arata holds the Chairman role on the A4A Engineering Maintenance and Material Council.  He also serves on the advisory board for Penn State University.

The MARPA Annual Conference will take place October 1-3, 2014 at the Renaissance Las Vegas Hotel. More Conference information is available online at: www.pmaparts.org/annualconference.

2014 MARPA Conference News! Members Can Take Advantage of Super Saver Discounts

MARPA Members wishing to take advantage of the Super Saver Discount to renew their membership and register to attend the Conference should send their information to MARPA by close of business tomorrow, April 30, 2014.  

The 2014 MARPA Conference will be held from October 1-3, 2014 at the Renaissance Las Vegas Hotel.  This year’s program will be an exciting three days featuring workshops, guest presenters, and panels that are sure to make your company both safe and successful!  Highlights include:

  • “PMA 101″ Workshop – Learn the how-tos of PMA!
  • Exporting Goods into the International Marketplace
  • Growth Opportunities for PMA Throughout Latin America
  • MRO Roundtable

You can find the most up-to-date information about the Conference on our website: http://pmaparts.org/annualconference

Not a MARPA member yet, but interested in savings?  Visit us for more information: http://pmaparts.org/membership

MARPA Announces Copa Airlines’ Ahmad Zamany as Keynote Speaker for 2014 MARPA Conference

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MARPA is proud to announce that Ahmad R. Zamany, Vice President of Technical Operations, Copa Airlines will serve as a keynote speaker for the 2014 MARPA Conference.

In Mr. Zamany’s role as Vice President of Technical Operations at Copa Airlines, he is ultimately responsible for the Maintenance, Engineering, and Technical Purchasing of the Company.  Mr. Zamany started his aviation career with Pan Am and has held several key roles with other carriers. He was previously with Atlas Air & Polar Air Cargo as Vice President of Technical Operations, and Gemini Air Cargo as Senior Vice President and Chief Operating Officer.

Copa Airlines Colombia provides service to 10 cities in Colombia as well as international connectivity with Copa Airlines’ Hub of the Americas through flights from Barranquilla, Bogota, Bucaramanga, Cali, Cartagena, Medellin and Pereira. Additionally, Copa Airlines Colombia has international flights from Colombia to Panama City, Caracas, Cancun, Mexico City, Guayaquil, and Quito.  Through its Panama City hub, the hub with the most destinations and international flights on the continent, Copa Airlines is able to consolidate passenger traffic from multiple points to serve each destination effectively.  As of November 1, 2013 Copa Holdings operates a fleet of 90 passenger aircraft: 64 Boeing 737-Next Generation aircraft, 26 Embraer 190 aircraft.

The MARPA Annual Conference will take place October 1-3, 2014 at the Renaissance Las Vegas Hotel. More Conference information is available online at: www.pmaparts.org/annualconference.

EASA Proposes Engine Vibration Testing Changes With the Potential to Undermine Trade

A seemingly innocent EASA rule could potentially undermine US-EU trade in aircraft engine parts.

EASA has issued a Notice of Proposed Amendment that would make changes to the EASA engine vibration rule for engine certification.  At first blush, this appears to inhibit the development of an independent turbine engine approved part industry in Europe.  The EASA rule and the FAA rule are currently harmonized, and the proposed change would also de-harmonize the rule from the FAA standards, which might provide a basis for an EASA refusal to accept PMA turbine engine parts from the United States, in the future.

One of the reasons that this could be used to undermine US-EU trade is because the current EASA acceptance of FAA-PMA parts is based upon the finding of substantial similarity between the systems, which in turn is based upon the harmonization of the regulations.  If the regulations are no longer harmonized, then EASA might choose to reject PMA parts on the grounds that they are not subject to the same sort of testing required by the EASA regulations.  It is likely that such an act would not be taken immediately, but the rule change would lay the ground work for a later decision to exclude FAA-PMA parts.

Such a decision to begin excluding FAA-PMA parts on technical grounds would likely violate international agreements, so it is important to prevent EASA from laying the groundwork for such a decision, The Agreement on Trade in Civil Aircraft references the Agreement on Technical Barriers to Trade for purposes of determining the acceptability of technical barriers.  That Agreement specifies that:

“Members shall ensure that technical regulations are not prepared, adopted or applied with a view to or with the effect of creating unnecessary obstacles to international trade.”

If the change would have the effect of creating an unnecessary obstacle to international trade in aircraft parts, then it could reflect a violation of the Agreement on Technical Barriers to Trade.

So what language are we talking about?  Here is an example of existing EASA language that is harmonized with the FAA regulations:

“The Engine surveys and their extent must be based upon an appropriate combination of experience, analysis and component test and must address, as a minimum, blades, vanes, rotor discs, spacers and rotor shafts.”

The correlative language in the proposed replacement text would say:

 “It must be established by test or a combination of test and validated analysis that the vibration characteristics of all components that may be subject to mechanically or aerodynamically induced vibratory responses are acceptable throughout the declared flight envelope.”

Some people might look at the term validated analysis and wonder what range of analysis that might permit.  The AMC language quoted in the NPA clarifies a definition of the term:

“A validated analysis is one with demonstrated predictive capability within a specified domain of applicability that encompasses one or more complementary baseline tests.”

Our first look at this regulatory change suggests that the change makes it far more difficult to create and approve a replacement engine part under the European system.  Replacing the option to use component tests with requirements for “test or test and validated analysis” could enforce the notion that an engine part cannot be developed in the European system without full engine testing of that part – no matter how insignificant the systems effect of the part may be (because of its economic effect, such a rule would be tantamount to banning the development of independent turbine aircraft engine parts).

Recently, we wrote about BAE’s efforts to nurture a true independent aircraft parts production industry in Europe.  Such efforts would infuse competition, and all of the price and quality advantages that competition traditionally tends to bring.  Certainly this independent aircraft parts production industry is in its infancy but it promises to provide jobs and revenues in Europe, while also moderating prices and stimulating safety and reliability advances.  But the proposed change could have the effect of strangling the nascent aircraft parts industry by preventing it from producing aircraft engine parts.

We are really curious to hear what the MARPA community has to say about this.

Parts Approval in Europe Becomes a Reality

For years, PMA parts were a uniquely American product. But recent European events may suggest that others will be following our lead. BAE has been focused on obtaining design approval and production approval to create approved independent replacement parts under the European system.

On January 22, Graham Smith and Phil Beard explained how BAE has been obtaining replacement parts approval user EASA standards. They explained that BAE has been able to get European approvals that are very similar to US PMA approvals.

As with FAA PMA, they start with a significant review of a part in order to determine whether it is feasible to reverse engineer and produce the part. They perform a full reverse engineering operation. They develop their own engineering drawings. Like most modern PMA companies, they take special pains to avoid using OEM data to support their analysis in order to make sure tat they are avoiding misuse of someone else’s intellectual property.

Beard feels that the substantiation of these engineering documents is a little different from the U.S. process. He explained that EASA does not allow BAE to use identicality. Instead they must use positive substantiation of compliance with the airworthiness standards. He said that this generally comes from analysis, understanding of the part’s function, and testing.

As with test and computation PMAs in the US, the substantiation process that BAE uses permits them to fully understand the part, which in turn permits them to remedy reliability problems with the original design or make other improvements desired by the customer. Beard offered an example during his discussion; he commented that if service history has shown evidence of unexpected corrosion, then BAE might change the coating in order to better protect against corrosion.

BAE has made good use of its Design Organisation Approval (DOA) system, which allows BAE to operate under a government-controlled system in order to make findings of compliance up which the government can rely (similar to the ODA system in the United States). Smith and Beard affirmed that this system has been invaluable to their parts approval efforts.

BAE’s initial efforts appear to be largely focused on parts for Regional Jet Aircraft; but they are approved and willing to undertake work on all fixed-wing aircraft types.  This an exciting development for international trade in civil aircraft parts.

Correct Your Foreign Intellectual Property Woes

Are you concerned about how a foreign nation is treating your intellectual property?  Are your trade secrets being stolen?  Patents being infringed?  Copyrights violated?  Trademarks being used in a confusing or deceitful manner?  If you feel that a foreign government has failed to enforce their intellectual property protection laws, or if you think that their laws are inadequate, then now is time to stand up and let the US government know your concerns.

The United States Trade Representative (USTR) is responsible for identifying countries that fail to adequately protect intellectual property rights.  This annual list of nations is known as the Special 301 Report.  The 2013 Special 301 Report details which countries are considered to be intellectual property problems: it identified a wide range of concerns, such as:

  • Deterioration in intellectual property protection, enforcement, and market access in the Ukraine
  • Misappropriation of trade secrets in China
  • Copyright piracy over the Internet in countries such as Brazil, Italy, and Russia

Countries that are identified in the Special 301 Report are the focus of increased U.S. attention concerning the problem areas, with the aim of helping the foreign trading partner to improve their laws, or the enforcement of their laws.

Written submissions from the public are an important source of information for the Special 301 review process, so the USTR has asked for public comments about intellectual property rights issues arising in other countries.

To facilitate the review, written comments should be as detailed as possible and provide all necessary information for identifying and assessing the effect of the foreign acts, policies, and practices. It helps if you are specific about what foreign laws or policies apply, how they affect you, what the dollar value of that effect is, and how you calculated the dollar value.

The deadline for submitting written comments is February 7, 2014. All written comments,must be submitted electronically to http://www.regulations.gov, docket number USTR–2013–0040. Please specify ‘‘2014 Special 301 Review’’ in the ‘‘Type Comment’’ field on http://www.regulations.gov.

If you need help with this process, please feel free to call us!

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