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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  The draft guidance attempts to more narrowly address the FAA’s concerns about full engine test for type certificate applicants.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.

When Exporting PMAs to Europe, Be Sure to Use the Right Words on Your 8130-3 Tag

Do your export 8130-3 tags have the right language on them?  If they don’t then you run the risk that they may be rejected in Europe.

The Bilateral Aviation Safety Agreement (BASA) between the United States and the European Union specifies that the documentation that accompanies a PMA part bound for the European Union must include specific language in order to be acceptable to the European Union’s airworthiness authority, EASA.

Critical Parts Language on the 8130-3 Tag

The BASA Technical Implementation Procedures (TIP) direct that PMA parts being exported from the United States to the European Union bear appropriate language in block 12 (the remarks block) of the export 8130-3 tag. In order to meet this requirement properly, the export 8130-3 tag must identify the part as falling into one of these three categories (by using the authorized language):

1. For a PMA part which is not a critical component, the remarks block of the 8130-3 should state:

“This PMA part is not a critical component.”

But if the PMA part is a critical component, then there are two options for the language in the remarks block.

2. In the first option for critical components, if the PMA holder also holds an EASA STC design approval which incorporates the PMA part into an EASA certified or validated product, then the language should say:

“Produced by the holder of the EASA STC number [INSERT THE FULL REFERENCE OF THE EASA STC INCORPORATING THE PMA].”

3. In the second option, if the PMA holder holds a licensing agreement from the TC or STC holder (giving the PMA holder the rights to use the TC/STC design for the PMA parts), then the following statement should be written in the remarks block:

“Produced under licensing agreement from the holder of [INSERT TC or STC NUMBER].”

These options 2 and 3 are the only two options for exporting FAA-PMA critical components from the US to the EU.

Critical Components and the EU Bilateral

The PMA “criticality statement” is something that is requested under the technical implementation procedures (TIPs) that accompany the US-EU bilateral aviation safety agreement (BASA).

Under the US-EU TIP, a “Critical Component” is defined as:

“a part identified as critical by the design approval holder during the product type validation process, or otherwise by the exporting authority. Typically, such components include parts for which a replacement time, inspection interval, or related procedure is specified in the Airworthiness Limitations section or certification maintenance requirements of the manufacturer’s maintenance manual or Instructions for Continued Airworthiness.”

The determination of whether a PMA part is critical is made by the design approval holder (the FAA-PMA holder) and confirmed as part of the FAA approval. Section 4.4(c) of Order 8130.21H states that “The determination of a PMA article’s criticality, as required to be entered in Block 12 when exported, can only be determined by the actual design approval holder (that is, the FAA-PMA holder).” This is important language because certain parties (foreign governments and competitors) have attempted to gainsay the FAA-approved “critical part” decisions of the FAA-PMA holders.

we have heard of DARs who thought that this language meant that only the PMA holder could obtain the export 8130-3 tag.  This is not so.  This language is not meant to prevent a designee issuing an export 8130-3 tag from making a PMA “criticality statement” on the 8130-3 tag that is consistent with the determination of the design approval holder.  Thus, any designee issuing an export 8130-3 tag for any FAA-PMA part may rely on the (PMA) design approval holder’s determination as to whether the PMA part is a critical component.

This critical parts language generally does not appear to apply to most bilateral airworthiness agreements – it is a special nuance of the US-EU Agreement.  Adding the “criticality” language does not hurt the 8130-3 tag (and may be useful if the end-user is not yet known), but the criticality language generally remains unnecessary unless  the part is destined for Europe.

New FAA Policy Concerning § 33.83 Engine Surveys

The FAA has released a new draft Policy Statement concerning the vibration surveys and engine surveys required by § 33.83.  The new guidance clarifies that this regulation is intended to require a full engine test (for type certificate applicants).  The draft guidance, known as “PS‑ANE‑33.83‑01,” is currently available for public comment.

Members will recall that MARPA successfully opposed a final rule that would have applied the “full engine test” standard to PMA and STC applications.  At the time, our discussions with FAA representatives revealed that their real concern was applying the full engine test standard to engine type certificate applications, and not to PMAs.  The reference to PMAs and STCs, they explained, was an unfortunate mistake.

This draft guidance attempts to more narrowly address the FAA’s concerns about full engine test for type certificate applicants.

In order to ensure that the FAA’s intent is clear, MARPA plans to offer some additional language designed to clarify that this Policy Statement does not supersede the discussion laid out in FAA Advisory Circular 33-8 (Guidance for Parts Manufacturer Approval of Turbine Engine and Auxiliary Power Unit Parts under Test and Computation).  We will also look for opportunities to help the FAA meet their policy goals.

Comments are due to the FAA by November 21, 2014.  They can be emailed to dorina.mihail@faa.gov or mailed to her at:

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

Please share your comments with MARPA, too, so we can make sure our comments are consistent with the concerns of our members.

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.

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 Guidance for PMA Via Tests and Computations or Identicality: Forthcoming

Today, the FAA announced the issue of AC 21.3o3-4.  The title of this AC will be “Application for Parts Manufacturer Approval Via Tests and Computations or Identicality.”

As of this time, the AC is not yet available to the public.  When it is available to the public, it is expected to be posted online at this location:

http://www.faa.gov/regulations_policies/advisory_circulars/index.cfm/go/document.information/documentID/1024227

Note: the issue date published on the FAA’s website is March 21, 2014; however the AC is not yet available through the FAA’s online advisory circulars, nor through the Regulatory and Guidance Library (RGL).  The note on the FAA’s website states “This document‘s content is not currently available.”

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/.

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