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Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.
Jason Dickstein has written 304 posts for MARPA

Yes, You CAN Sell FAA-PMA Parts into China!

Yes, China accepts FAA-PMA parts.

The United States and China signed a Bilateral Airworthiness Agreement (BAA) in 1991.  That agreement recognized that each authority (FAA and CAAC) had a system for production and airworthiness approval of civil aeronautical products, and that each system was sufficiently equivalent to the other to permit the authorities to accept certain approval decisions of the other.

The BAA is implemented through a Schedule of Implementation Procedures.  This schedule explains how international aerospace transactions will work.  It is meant to facilitate certain transactions and relationships.
The schedule covers, inter alia, Chinese acceptance of FAA Export Certificates of Airworthiness appliances, parts, and materials for which the FAA is the exporting authority.  The schedule explains that China will accept US export certificates of airworthiness for parts and materials when the FAA certifies that each article:

(a) Conforms to approved design data;
(b) Is properly marked; and
(c) Meets the special requirements of the importing country.

This is typically done through the issue of an FAA 8130-3 tag.

The special import requirements of China must be formally presented to the United States, and then the United States publishes those special import requirements in Advisory Circular (AC) 21-2.  The Chinese special import requirements apply to airframes, engines, propellers, and TSOA articles, but the only special import requirement that applies to FAA-PMA parts is that the part must be accompanied by an 8130-3 tag.  Since the 8130-3 tag is the medium for communicating the compliance, the 8130-3 for a FAA-PMA part can be safely annotated as meeting the special import requirements of China.

The Chinese have clarified in several places that they really mean it when they say that they are accepting PMA parts.

In order to ensure that there is no confusion, appendix D of the Schedule of Implementation Procedures specifies that the term ‘part’ means replacement and modification parts manufactured under any FAA production approval.  The appendix goes on to say that this includes replacement and modification parts manufactured by an FAA-PMA holder!

Some additional provisions are listed in the Schedule of Implementation Procedures , but none of them actually impose any additional obligations on someone who exports a PMA part to China, so long as that part already complies with US regulatory standards.

  • Critical components must have a part number and a serial number (this is already required under FAA Part 45 for FAA-PMA parts); and
  • All PMA parts must be marked with the part number and the manufacturer’s name or trademark (this is also required of all PMA parts under FAA Part 45 marking requirements).

China has also published their own advisory circular on the acceptance of FAA-PMA parts.  The advisory circular clarifies that FAA-PMA parts are acceptable for use on Chinese aircraft and reiterates that the parts should marked according to the requirements of FAA Part 45.

MARPA and Other Trade Associations Fight to Prevent FAA From Being Assigned Needless Tasks

Some of you may have heard that there is legislative language that would force the FAA to promulgate unnecessary regulations related to marking of “influencing parts.”  These would be defined as parts that can affect an engine LLP; there is no further refinement that would limit the scope of the term “affect.”

The proposed legislation would require the FAA  to issue regulations for marking these “influencing parts.” Ordinarily, you mark a part because the part marking is perceived to be useful; but it appears that the proposed markings would not be used for anything.  No guidance for what should be marked on new parts is indicated, so one cannot even guess at the purpose that such markings might achieve.

Under the proposal, the FAA would also be required to issue regulations for “post repair marking or identification on an influencing part [to reflect] the drawings and specifications used to gain the repair design approval issued by the Federal Aviation Administration.” What is wrong with this picture:

  • Remember that the description of the work performed is required to be on the approval for return to service and is typically included in the work order as well, so this marking requirement is generally redundant.
  • The FAA has no uniform identification system for drawings and specifications, and drawings and specifications are typically proprietary, so the reference would also be meaningless to third parties in many cases, thus the specific requirment provides no value.
  • Given the fact that hot section parts generally will lose markings due to the conditions inside the engine it appears that this requirement is not calculated to achieve anything useful for such parts.
  • Finally, marking engine parts in a way that will not be rapidly eradicated may require physical marking (like vibra-peening); such marking practices need to be researched for individual parts because of the possibility that they may undermine the strength or integrity of the part (thus wasting resources better spent on protecting safety).  So such marking requirements may actually undermine the safety of aircraft engines!

Perhaps the most important issue here is that anything that seemed good about this proposal already exists in FAA regulations and/or guidance.  The FAA has been diligent on the issues surrounding this proposal, and legislation is not needed.  Legislation of this sort would only serve to divert important FAA resources away from issues that really do affect safety.

Several trade associations have banded together to write Congress about the impracticality of this proposal.  The letter is being transmitted to Congress today.

Special thanks go out to Daniel Fisher, the Vice President of Legislative Affairs for ARSA, who alerted us to this legislative issue and who led the effort to send a letter to Capitol Hill on this issue.

MARPA Efforts to Increase PMA Sales to Southeast Asia and China

MARPA is organizing the first-ever PMA Trade Mission to Singapore and China (Hong Kong, Guangzhou, Shanghai and Beijing) for November 3-13, 2015.

The purpose of this trade mission is to introduce air carriers and MROs in Southeast Asia and China to the concept of PMA, and to the significant advantages that they can recognize by doing business with PMA manufacturers from the United States.  We hope that this will help increase PMA sales into these regions.

The mission will begin for MARPA at MRO Asia in Singapore, November 3 through 5.  We are planning to set up a few pre-scheduled meetings as well as allowing members to interact with the MRO attendees.  After MRO, we will fly to Hong Kong to meet with air carriers on Friday.  We plan to transfer to Guangzhou over the weekend in order to meet with Gameco and China Southern on Monday.   Then we will spend Tuesday-Wednesday in Shanghai and Thursday-Friday in Beijing meeting with air carrier and MRO sales targets.

If you aren’t yet selling into Asia, then this is a wonderful way to start meeting potential customers.  If you already have business in Singapore, China and Hong Kong, then you won’t want to miss this exceptional opportunity to renew acquaintances and build more business.

Tails at Beijing Airport

Tails at Beijing Airport

MARPA has been planning this 2015 trade mission since late 2014, and we’ve enjoyed incredible support from our US government contacts.  This trade mission is undertaken in partnership with the US Department of Commerce, and we are being assisted by the International Trade Administration and the Commercial Foreign Service officers in the embassies and consulate offices.  This is a valuable membership benefit that is available to help MARPA members increase their export business so make sure you take advantage of it!

If you are interested in participating or want more information, then please contact the Association.  We’d love to hear from you.

We hope to soon be able to offer a specific itinerary and price for the mission.  Once this is announced, we will take firm commitments from members on a first-come-first-served basis until the program is full.

Wondering if you can sell PMA parts into China?  Tomorrow we will start addressing the legal standards for PMA acceptance in China!

New FAA Draft Policy: Structural Certification Criteria for Antennas, Radomes, and Other External Modifications

The FAA has published new draft guidance for public comment. The policy statement identifies acceptable means of compliance for certification of external modifications to Part 25 aircraft. Such modifications can include antennas, radomes, cameras, and external stores.

The draft policy explains that there has been a significant increase in the number of structural certification projects involving external modifications, especially large antenna installations. It provides guidance on selection of certification requirements within the context of the certification basis of the modification. The directions in the policy statement are each linked to existing regulations, so no new regulatory obligations are meant to be imposed.

Comments are due to the FAA by July 6, 2015.

You can email comments to:jan.thor@faa.gov

Comments can also be delivered by mail or hand to:
Federal Aviation Administration
Transport Airplane Directorate
Transport Standards Staff, ANM-110
1601 Lind Avenue SW
Renton, WA 98057

Please send a copy of your comments to MARPA, so that the Trade Association’s response can support your concerns. Please also let the Association know if this is guidance that is important to your business.

New Draft FAA Guidance: Non-TSO Functions in Seats

The FAA has published new draft guidance for public comment.  The policy statement clarifies the non-TSO function language in TSO C127B, which was added in 2014.  Non-TSO functions are those that go beyond the minimum standards of the seat TSO, like reading lights or in-flight-entertainment.

The draft policy explains that non-TSO functions in aircraft seats should be declared, in order to signal to the installer that the substantiation and design control for the added functionality may need to be addressed by a separate design approval, because it may not have been an FAA-approved design element in the TSO design approval.  It also provides additional guidance on what functions are non-TSO functions.

Comments are due to the FAA by July 20, 2015.

You can email comments to: robert.a.rouza@faa.gov

Comments can also be delivered by mail or hand to:
Federal Aviation Administration
Design, Manufacturing & Airworthiness Division
Systems & Equipment Standards Branch, AIR-130
470 L’Enfant Plaza, SW, Ste. 4102
Washington, DC 20024

Please send a copy of your comments to MARPA, so that the Trade Association’s response can support your concerns.  Please also let the Association know if this is guidance that is important to your business.

MARPA Founder Jim Reum; Dead at 83

It is with great sadness that we report that Jim Reum passed away on Sunday, June 14th due to complications resulting from an automobile accident. He was 83 years old.

Jim Reum

Jim Reum chaired the first MARPA Board meeting in 2000

Jim was one of the original three founders of MARPA.  The idea of MARPA started when he was a delegate on the FAA’s Part 21 ARAC Working Group (parts and production approvals).  As those meetings conrttinued, he and others recognized that there was a need for a permanent voice for PMA in Washington, DC.  Over lunch during a break from the working group meetings, he agreed to start MARPA with George Powell and Jason Dickstein.  As it is with many great foundational documents, the agreement to form the trade association was written on a placemat from a Washington DC Irish Bar.

Jim served as the original Chairman of the Board of Directors of MARPA and he established a tradition of strong support for MARPA among the Heico family of companies.  He introduced other companies to the MARPA community.  He helped to set the pattern of strong MARPA support for safety and for FAA compliance programs.  He believed that MARPA should always stand for the highest ideals of safety and compliance, and he was always generous with his time in these pursuits.  Even after leaving the Board, he continued to serve  as a mentor to the MARPA community.

I will always remember Jim for his patience in teaching me how things really work.  He would take me through the Jet Avion facility and explain how things were built, and would unselfishly detail the innovations in production and testing of which he was most proud.  He understood that a lawyer needs to understand the technical side of PMA, if that lawyer is going to adequately represent the industry.

In those days, we fought shoulder-to-shoulder just to convince the industry that PMA parts were safe and acceptable.  Jim was always happy to share the industry’s safety data; and he was always willing to give anyone a tour of the Jet Avion/Heico facilities.  After a tour of those facilities with Jim,  it was easy to understand how much effort went into compliance and safety, and to trust PMA.

Heico’s President Eric Mendelson eloquently eulogized Jim in an address to the Heico staff:

Jim was an incredible friend to HEICO and mentor to our team members for the last 25 1/2 years. We will miss him greatly. Our values and quality focus exist as a result of Jim’s efforts and beliefs and HEICO has lost a truly incredible human being. HEICO wouldn’t be the company it is today without Jim Reum.

After a long and distinguished career in the aviation industry with General Electric, United Airlines, Aviall, and Chromalloy, Jim joined HEICO as a consultant in 1990. His initial project was to recommend where HEICO should focus its efforts, after successfully saving the worldwide narrow-body fleet from grounding after an OEM-redesign of the JT8D Combustion Chamber.

Jim recommended that HEICO “become the NAPA of the Aerospace Parts Industry” and then came out of retirement to become EVP-COO of our Flight Support Group in order to help HEICO achieve his vision. Along the way, Jim created the quality technical focus for which HEICO is known, and helped to instill our values which have permitted HEICO to become the company that it is today.

Those who were lucky enough to work with Jim until he retired from full-time service on his 70th birthday in 2001, and then again as an EVP until his passing, remember his kind and patient temperament combined with his incredible judgement, knowledge, passion, dedication, loyalty, humility, and respect for people. He gave so much of himself and so many of us at HEICO received opportunities to grow as a result of his unwavering confidence and support.

Jim’s passing has created a permanent void in our hearts, but his spirit lives on in all of us, and for that we can be very proud. Jim frequently commented that “HEICO is the highlight of my career.” Words can’t express the love that Jim felt for HEICO and our Team Members.

Our thoughts and prayers are with his wife Ann and son Rex and their entire family. The Reum Family can take great comfort in knowing the outpouring of gratitude and collective appreciation for sharing Jim with us and for letting us learn so much from such a fine human being.

There will be a Memorial Service for Jim at 11am on Saturday, June 20th:

2005-10 Powell Dickstein Reum

MARPA Founders in 2005. From Left to Right, George Powell, Jason Dickstein, Jim Reum.

Covenant Village
9215 West Broward Blvd
Plantation, FL 33324

Flowers and Cards may be sent to:

Reum Family
c/o Jim Reum Memorial Service
Attn: Chaplin Rocky Cook
9215 West Broward Blvd
Plantation, FL 33324-2404

New Draft FAA Guidance: replacing vacuum-driven attitude instruments with electronically-driven replacement indicators

The FAA has published new draft guidance for public comment.  The guidance is meant for instruments and indicators designed for small (Part 23 or CAR 3) aircraft.  It is a policy statement that describes acceptable compliance methods for replacing vacuum-driven attitude instruments with electronically-driven replacement indicators. Electronically-driven attitude indicators include indicators that use electrical power to (1) excite an internal gyro, or (2) replace the operation of the gyro with microelectronics.

The policy notes that electronically-driven attitude indicators may replace the existing attitude indicators used in VFR or IFR airplanes.

Comments are due to the FAA by August 21, 2015.

You can email comments to: leslie.lyne@faa.gov

Comments can also be delivered by mail or hand to:
Federal Aviation Administration
901 Locust St
Room 301, ACE-114
Kansas City, MO, 64106

Please send a copy of your comments to MARPA, so that the Trade Association’s response can support your concerns.  Please also let the Association know if this is guidance that is important to your business.

FAA Seeks Experts to Develop Airframe Crashworthiness and Ditching Standards

Do you want to serve on a FAA working group that will help the FAA shape regulations affecting safety?  Do you have expertise in composite and other nonmetallic airframe materials?  Can you add to a discussion about airframe crashworthiness?

The FAA has asked the Aviation Rulemaking Advisory Committee (ARAC) to provide recommendations regarding airframe-level crashworthiness and ditching standards that would be incorporated into the FAA’s regulations.  TYhe group would also prepare advisory materials.

During the development of current airworthiness standards and regulatory guidance, the FAA assumed that airframe structure for transport airplanes would be constructed predominantly of metal, using skin-stringer-frame architecture. Therefore, current regulatory requirements either do not address all of the issues associated with nonmetallic materials, or have criteria that are based on experience with traditionally-configured large metallic airplanes.

With respect to crashworthiness, there is no airframe-level standard for crashworthiness.  Many of the factors that influence airframe performance under crash conditions on terrain also influence airframe performance under ditching conditions. Past studies and investigations have included recommendations for review of certain regulatory requirements and guidance material to identify opportunities for improving survivability during a ditching event; consideration of these recommendations is included in this tasking.

You can find a full discussion of the working group’s task, online.

If you wish to become a member of the Transport Airplane Crashworthiness and Ditching Working Group, you can express that desire by contacting:

Ian Won
Federal Aviation Administration
1601 Lind Avenue SW.
Renton, WA 98055,
ian.y.won@faa.gov
phone number 425-227-2145
facsimile number 425-227-1232

Please describe your interest in the task and state the expertise you would bring to the working group. The FAA must receive all requests by July 6, 2015. The ARAC and the FAA will review the requests and advise you whether or not your request is approved.  For MARPA members, if you would like MARPA’s endorsement for such a position, please contact us before the deadline.

Customers Customers Customers!

The customers will be there in Istanbul in twelve days – will you?

MARPA and the Association of European Airlines (AEA) will co-host a PMA meeting in Istanbul on May 25-26.  By my count we have 29 customer-personnel attending the conference – these are air carriers and MROs that are interested in PMA solutions.  You can see the current “early registration list” online to see who has already committed.  And we are hoping to confirm a few more European carriers before the end of this week.

“29 customer representatives in an intimate setting like that?  Unlimited access to air carrier and MRO purchasing representatives?  I can’t think of a better networking opportunity for a PMA company that wants to sell into Europe”

Customer attendees will include (but not be limited to):

  • DHL
  • KLM
  • Lufthansa Technik
  • Pegasus Airlines
  • SunExpress
  • Turkish Airlines
  • Turkish Technik

Why are they gathering?  To learn more about PMA and to network with PMA companies that can provide them with solutions.  Why have AEA and MARPA gone to the effort to bring these air carriers together?  To help educate the world about PMA and to help our members make sales to air carriers in the region!

If you’ve been dying for an opportunity to have one-on-one time with air carriers and MROs that are eager to learn more about PMA, then this is the conference for you.  If you aren’t yet registered for the conference, then you should be.

 

 

Looking for more opportunities like this one?  Take a look at everything that MARPA is planning for the remainder of the year to help promote YOUR export sales.

Upcoming Opportunities for Marketing/Selling PMAs (especially for our smaller members)

Are you looking to increase your export sales?  MARPA export promotion program is creating new opportunities to get your company and your PMA articles in front of the customers!

MARPA’s export promotion program is in full swing.  After productive meetings in Buenos Aires, Dubai, Munich and Miami, MARPA is looking forward to a series of opportunities to promote PMA, and to promote our members, around the world.

MARPA is committed to providing education about PMA parts.  We want installers to know what they can do with PMA parts (and what they can’t do).  We believe that education about PMAs is the best way to promote PMA parts – the more the aerospace community knows, the more attractive PMA parts become.

But we also believe that it is important to market your PMA articles to the customers.  Many of our members are small companies and have limited marketing budgets.  So MARPA is working to increase the opportunities to reach the customers on a cost-effective basis.

MARPA’s Upcoming Promotional Activities

This is not a complete list – but it lists a few of the most important upcoming events at which MARPA will be promoting PMA.  These events are important to the members because they reflect opportunities to promote YOUR PMA articles, as well as promoting PMA generally.

  • AEA/MARPA PMA Parts Conference in Istanbul (May 26, 2015)
    • This is an excellent opportunity for the PMA community to meet non-US air carriers and MROs while learning about the future of the European market.
  • MARPA at ACPC (August 29-September 1, 2015)
    • MARPA plans to exhibit at the Air Carrier Purchasing Conference.
    • We also plan to make available a literature package that will be provided to the customers with whom we meet.  This will be made up of PMA catalogues, brochures  and other literature from MARPA members.
  • MARPA in Europe (October 13-15, 2015)
    • MARPA plans to attend the MRO Europe Conference in October
    • We also plan to make available a literature package that will be provided to the customers with whom we meet.  This will be made up of PMA catalogues, brochures  and other literature from MARPA members.
  • MARPA in Japan (October 14-16, 2015)
    • MARPA plans to attend the ASET (Aerospace Exhibition Tokyo) Conference in October
    • We also plan to make available a literature package that will be provided to the customers with whom we meet.  This will be made up of PMA catalogues, brochures  and other literature from MARPA members.  we recommend considering translating your literature into Japanese for this package.
  • MARPA Annual Conference in Las Vegas (October 28-29, 2015)
    • Our annual conference typically boasts a roughly 3-1 ratio of manufacturers to air carriers.  This is one of the best ratios of ANY conference and it makes the MARPA Annual Conference one of the best networking opportunities ANYWHERE among PMA manufacturers, air carriers and MROs.  With only about 300 participants, it is intimate enough to have real conversations and make new connections.
    • The MARPA Annual Conference is also structured as an educational conference and is the best place to learn about the latest trends affecting the PMA market.
  • MARPA Asian Mission (Early November, 2015)
    • Plans are still being developed, but we plan to attend MRO Asia and also arrange side meetings with Asian Carriers to discuss how PMA can help them improve reliability, safety, and profitability.
    • We hope to make this an opportunity to have members join us on the mission so they can take advantage of our pre-arranged meetings.
    • For members who cannot join us, we also plan to make available a literature package that will be provided to the customers with whom we meet.  This will be made up of PMA catalogues, brochures  and other literature from MARPA members.

HOW CAN I PARTICIPATE?

There are many ways that MARPA members can start working now to take advantage of these marketing opportunities.

1) Start working NOW on putting together the paper and digital literature you’d like MARPA to include in their PMA literature packages.  This distribution is a MARPA benefit that is free to our members.

a) Paper products can include brochures, one-page advertisements and short white papers;

b) Digital packages can include more information, including your product catalogues.

2) Register and attend the Istanbul and Las Vegas conferences – we are constantly working to get the customers there, so that you will have the best opportunity to network and make sales (and so that they will have the best opportunity to improve safety, reliability and the bottom line by using your parts).

3) Mark all of the the dates (above) on your calendar – we’d love to see our members at these events!

4) Consider whether you’d like to join MARPA on the Asian mission in November.  Preliminary statements of interest are not firm commitments – but they will help us in our planning efforts.

5) Send us your ideas for additional marketing events and activities. But be warned that we may invite you to join the Marketing Committee!

We want you to get value out of your membership – so let MARPA know what the trade association can do to help you meet your sales and marketing objectives.

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