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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/.

New FAA Policy on Coordination of Engine and Propeller PMAs

The FAA has issued two new PMA guidance documents for comment.  One of these is a document affecting engine PMA applications (PS-ANE-33.3-05) and the other is a document affecting propeller PMA applications (PS-ANE-35.15-02).  Each of them would require additional internal FAA coordination for certain engine and propeller PMA projects.

Under the new policy, when an Aircraft Certification Office (ACO) accepts an application for a PMA for an engine part or a propeller part, where a failure of that part could result in the total loss of thrust or power, the ACO is required to coordinate the project with the office that manages the type certificate and the Engine and Propeller Directorate.  Coordination is accomplished by entering the project into the national certification project notification (CPN) database.

While better management of coordination should be a good thing, the reason for such coordination is to obtain more input from the other offices.  There are two possible concerns associated with that additional input that should be addressed but that are not raised in this guidance: (1) decreased FAA efficiency in turning projects, and (2) increased potential for release of sensitive business data.

The guidance asserts that the CPN process should not add burden to the PMA applicant.  This does not consider, however, whether the process may add additional lag time in processing the PMA applications. If the certificate management office and the Directorate request additional time to study the project and add their comments, then this could slow down the turn-around-time for reviewing packages.  We have been made aware of instances where local offices disagreed with a directorate about a technical matter, and the PMA applicant was the real victim, as the two FAA offices brought the application to a stand-still while they hashed out their differences.

In addition, PMA applications are often considered to reflect sensitive company data, because they reveal the company’s business plan.  If a certificate management office starts asking questions about a part, even without revealing which company has filed the PMA application, it could still alert a type certificate holder to the potential for competition and the type certificate holder may take action to protect their market in that part before the PMA part is approved (which would be unfair).

But one positive aspect of such coordination is that the certificate management office or the Directorate may have useful information not readily available elsewhere.  For example, they may have service information that helps to show where the original type certificated part was not performing as expected.  This information could give the PMA applicant an opportunity to improve the part so that it meets customer expectations.

The FAA has opened these two policies up for comment through March.  MARPA members who want MARPA to comment on either of these draft policies should let us know by the end of February.

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.

MARPA Comments on FAA PMA Policy Guidance Revisions

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.

You can review MARPA’s comments on draft Order 8110.42D and draft AC 21.303-PMA in their entirety on our website at www.pmaparts.org.

Planning on Having Your Company Literature Featured in MARPA’s Booth in Tokyo? Here’s How:

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 katt@marpa.aero.

MARPA Co-Founder George Powell Passes

George Powell at the 2005 MARPA Meeting

George Powell at the 2005 MARPA Meeting

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 Powell, Gloria Nations and Jason Dickstein at the 2009 MARPA Conference

George Powell, Gloria Nations and Jason Dickstein at the 2009 MARPA Conference

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.

MARPA Appoints a New Chair of the Air Carrier Committee: Ed Pozzi of United Airlines

Ed PozziEd 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.

Opportunity for MARPA Members to Have Their Company Literature Presented Japan

MARPA is pleased to announce that we will be at the 2013 Aerospace Industry Exhibition Tokyo, and you can be there too!

While this is a fantastic opportunity for making connections in the Japanese aerospace manufacturing market, we recognize that not ever member can afford to add this to their trade show agenda, so MARPA will be featuring literature from members at their booth.  That’s right – you can have your company literature included in the MARPA literature rack at ASET 2013 in Tokyo!

COST: Free to MARPA members (it is a membership benefit).

HOW BIG IS THIS CONFERENCE: The last conference was in 2011 (it is held every two years) and there were 23,373 visitors for the aerospace trade floor.

YOUR REQUIREMENTS: YOU are responsible for producing your company materials.  YOU are responsible for shipping the materials to the convention center and for alerting us to look for it.

WHAT WE WILL DO: We will keep your literature in our literature rack or on our display table (depending on factors like size and volume of member response) and hand it out to interested conference-attendees.

HOW DO I GET STARTED: Contact Katt Brigham by calling or emailing the Association

OTHER CONFERENCE DETAILS:

The Aerospace Industry Exhibition Tokyo (ASET) is the only exhibition held in Tokyo dedicated to specialized aerospace technologies.  In addition to the unique business opportunity, ASET also features programs and lectures from key industry figures, as well as business and social networking events.

MARPA will have an exhibit booth for the three day event, October 2-4, 2013, and MARPA President Jason Dickstein will give a keynote address discussing PMA and the advantages that it represents.  This is an excellent opportunity to further raise industry awareness about the value and benefits of PMA and about MARPA itself.

DO YOU PLAN TO ATTEND?

ASET has asked for our help in getting the word out about this opportunity, as ASET is seeking PMA companies to join their PMA session.  The PMA companies would be asked to introduce their business to the attendees and participate in a PMA panel.  As inducement for participation, ASET is offering to provide exhibition booth space (three-day exhibition required) and potentially other inducements to PMA companies who are willing to present at the exhibition.

The city of Tokyo’s event planning subsidiary specifically requested the presence of PMA manufacturers at ASET 2013.  This is a great opportunity for our members to exhibit their products in front of a large audience in one of Asia’s key business hubs.  It is also a chance to further educate the aerospace community on the advantages of PMA.

If your company is interested in taking advantage of this opportunity, please contact ASET advisor Jay Kato via email at  jktechci@jcom.home.ne.jp.  ASET 2013 runs October 2-4, so it is important to act quickly.  MARPA hopes to see you there!

Help MARPA Understand Your Costs of Regulatory Compliance

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

  • Time for FAA review and approval of applications
  • Time of DER review
  • Data package development costs
  • ODA costs
  • Personnel costs to supplement decreased FAA involvement

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 ryan@washingtonaviaition.com.

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