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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 296 posts for MARPA

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.

Right Sourcing to Influence the MRO Market of the Future 

At MRO Americas 2015 today, Kevin Michaels discussed the current trends in “right sourcing.”
Michaels explained that over the past decade, significant manufacturing and design infrastructure has been established in China, Russia, India and Brazil. Within China and India, there were particularly high levels of engineering investment from 2008-2011. A significant factor included the low cost of labor in the locations.
The commercial aviation corporation of China COMAC attracted a lot of western aerospace investment in China in the 2004-2011 period.  
But over the past three years, there has been a shift.  China has experienced significant increases in labor costs, as well as skilled labor shortages.  Automation has continued to erode labor content for many aerospace parts.  Higher oil prices made transportation costs a significant factor in offshoring during 2012-2014.  Factors like these have resulted in more “right shoring” – in which value chain activities are sited in the best locations for long term competitive advantage and market access.  Labor costs are no longer the only factor in locating business units.
This means at in the most recent years, aerospace investment dollars are returning to the US.  The Southeast US has become a hot spot for the balance between labor costs, skilled labor availability, transportation costs, etc.  
China seems to have a customs ‘firewall’ tat can make it much easier to bring product into China of it is assembled in China.  To serve Asia effectively, many companies are getting into China because of the difficulty in bringing product into China.  
What does this mean for MRO?  More heavy checks that were going to Asia are coming back to North America as the asian labor rates increase.  Lufthansa Technik will open a heavy maintenance Facility in Puerto Rico (other companies with significant engineering centers in Puerto Rico, include Lockheed Martin, and Pratt and Whitney). Other new heavy maintenance facilities are being opened in the continental US, including facilities for companies like ST Aero (by the way, Michaels predicted that the US would not be the hot spot for aerospace investment in four years, as industry trends continue to evolve).
But other maintenance still needs to follow the customer growth patterns.  Michaels concluded that growth will still be led by Asia, China, and the Middle East (China will continue to be a separate market from the rest of Asia).  So there is still a need for the MRO community to invest in those regions in order to support those customers.  

New Airline Credit Ratings Issued – Now Come Meet the CEO!

Looking for good business partners? Look no further than the AEA/MARPA Conference in Istanbul on May 25-26, 2015.

Our keynote speaker will be Dr. Temil Kotil, the CEO of Turkish Airlines, who will discuss how his airline has used PMAs as part of their safety strategy.  This is an excellent opportunity for PMA manufacturers to meet Dr. Kotil in an intimate atmosphere that is designed to foster networking and discussions of solutions like PMA.

A recent article in Turkish Weekly announced that Turkish Airlines has been awarded corporate family ratings of Ba1 (from Moody’s) and BB+ (from S&P).  By way of comparison, American Airlines was recently upgraded by Moody’s to a positive outlook, and at that time Moody’s confirmed a B1 rating for the corporate family.  Last fall, S&P upgraded Southwest Airlines from BBB- to BBB.  This shows that Turkish Airlines is situated well within the range of the finest airlines.

Rehan Akbar is Moody’s lead analyst for Turkish Airlines.  Akbar explained that “Our decision to assign a Ba1 CFR to Turkish Airlines balances the company’s healthy financial profile and role as the national carrier against the execution risks associated with its high-growth strategy.”  The Moody’s press release explained that “Turkish Airlines’ healthy financial profile is underpinned by its low-cost structure and historical above-peer-average profitability metrics. The airline has a well-diversified passenger revenue base that is supported by the economic and tourism growth seen in Turkey, while Istanbul’s geographic location allows the Ataturk International Airport to act as a hub for international transfer traffic. ”

What does this mean for PMA companies?   It means that Turkish Airlines is a serious airline that is recognized internationally for its profitability.  And part of what makes an airline like this successful are good business practices that ensure safety while providing good value that can be passed on to the traveling public.  PMAs are one of the solutions that the leading airlines are using to ensure that they remain safe and profitable.

This meeting is co-hosted by the Association of European Airlines (AEA), and they have confirmed that they expect significant airline attendance; so make sure your sales force attends!

I look forward to seeing all of MARPA’s members (and a few non-members) at the Istanbul meeting in May!

US Government Meeting for Foreign Investors Could Be a Good Networking Opportunity for MARPA Members Seeking Capital

The U.S. Commerce Department’s International Trade Administration (ITA) will host a National Aerospace Foreign Direct Investment Exposition (FDI Expo), October 26-28, in Los Angeles.  This is right before the 2015 MARPA Conference in Las Vegas (and it is just a short flight from LAX to LAS).

This ITA event is designed to highlight opportunities in the U.S. aerospace manufacturing sector for foreign investment.  Foreign investors will attend in order to learn about aerospace manufacturing investment opportunities.

The FDI Expo will be focused on offering resources to prospective investors, in an effort to entice them to establish or expand their presence in the United States.  The event will feature one-on-one meetings with state and local economic development organizations.  MARPA members seeking investment capital may wish to attend the ITA event before they join us at the MARPA Conference, in order to network with prospective investors.

I think many foreign investors would be surprised at just how good an investment the PMA industry can be.

For more information, see ITA’s Press Release.

The Argentine Market

This week, MARPA is at the MRO Latin America show to promote PMA. The meeting is being held in Buenos Aires, Argentina.

Aerolineas is the flag carrier of Argentina. The carrier was formed in 1950 from the merger of four other air carriers. Today they have 69 aircraft. They expect to reach 73 soon with an expected delivery of four new A330s.

Forecasts continue to show Latin America as a leading growth area for aviation MRO. Latin America is expected to grow from 2226 aircraft to 4911 aircraft (commercial passenger and cargo) from 2010 to 2030, according to ICAO. This will reflect a growth from 10% of the global totals to 12% of the global totals.

Argentina has 119 Argentine MROs and another 52 foreign MROs certificated by Arentine Civil Aviation National Administration. 74 of the domestic MROs are in Buenos Aires and 6 of them focus on commercial aviation with the other 68 focused on General Aviation.

Aerolineas has a significant labor force focused on MRO. They have 1600 maintenance personnel working for the air carrier and their sister airline, Austral, has 520 maintenance personnel.

Aerolineas wants to generate partnerships with other air carriers, MROs and training organizations. They are building a new hanger in Buenos Aires and plan to expand their capabilities to support their fleet. The new hangar will have enough space to house an A380.

Aerolineos has been working to focus their fleet. Older types have been retired in favor of a more narrow fleet. The new fleet is focused on just four major types: A340-200/300, A330-200/300, B 737-700/800, and E190. They are retaining capabilities for other types, though, because they perform MRO services for other operators, including Tame, BahamasAir, and the Argentine President.

Fleet standardization means that there is less time spent on training for the maintenance personnel, which helps to Ake their team more efficient.

Today, the Aerolineas MRO is certified by ANAC, FAA and the Argentine military. As such, they seem like a prime target for PMA!

MARPA Winter Meeting Update

Don’t forget that the 2015 MARPA Winter Meeting will be held February 9, 2015.  This is our annual “open Board meeting,” to which MARPA members are invited in order to participate in MARPA strategic planning.

EVENT: MARPA Winter Meeting
DATE: February 9, 2015
TIME: 9:30 AM – 4:30 PM
PLACE: 2233 Wisconsin Avenue, NW
COST: Free for MARPA Members
WHAT IS IT: The MARPA Winter Meeting is a strategic planning meeting attended by the Board and other members. We also typically meet with government officials from the FAA and other agencies.
WHO: Any MARPA member is welcome to attend. Please RSVP to Katt Brigham at (202) 628-6777 OR by using the response form, below. We have limited space, so please RSVP by January 26th so we can make appropriate plans for attendance.

RSVP Response Form

MARPA Blog – 2014 in review

WordPress.com has prepared statistical information about the MARPA blog …. click below for the 2014 annual report for this blog.

 

Key statistics

Click here to see the complete report.

Interested in helping us produce content for the blog?  We are always interested in additional writers with an interest in PMA.  Contact us if you would like access to the blog in order to share useful information that benefits the MARPA community.

Treasury Makes It Easier to Comply, When Exporting

PMA manufacturers who are exporting their parts from the U.S. need to ensure that they remain in compliance with the U.S. export regulations.  In addition to the BIS and DDTC regulations that apply to aircraft parts, exporters also need to remain in compliance with Treasury Department regulations.

Some of those Treasury Department regulations include lists of people and entities that you ought not to do business with.  Every agency has multiple lists that you need to examine, but Treasury is doing something to consolidate its lists and make it easier to review them. This consolidation should make it easier to search to ensure compliance, whether you are searching on line or using a computer program to automatically research your business partners.

The Treasury Department office with jurisdiction over export programs is the Office of Foreign Asset Control (OFAC).  OFAC has a list of Specially Designated Nationals (SDNs) as well as other (non-SDN) sanctions lists. OFAC is now offering all of its non-SDN sanctions lists in a consolidated set of data files called the Consolidated Sanctions List. This consolidated list will include the following:

  • Non-SDN Palestinian Legislative Council List
  • Part 561 List
  • Non-SDN Iran Sanctions Act List
  • Foreign Sanctions Evaders List
  • Sectoral Sanctions Identifications List

OFAC announced that it plans to discontinue some of these lists as separate lists, so they will only be available as part of the consolidated list.

Persons seeking to check whether there are OFAC sanctions that might apply to their transaction should be sure to check their export business partners (by personal name and company name) against the Specially Designated Nationals List and the Consolidated Sanctions List.

One can also use the Sanctions List Search which consolidates both lists into a single searchable database. This tool is useful because it can automatically search for names that are close (bot not exact matches) and can be set to find matches with different levels of confidence (which will then be reviewed by a human to assess whether they actually match).

Exporters should also check the details of their transaction (including destination country) against the Sanctions Programs and Country Information page, which list sanctions programs based on country and on certain other criteria.

FAA Publishes Designee Management Policy for Public Comment – All Manufacturers Need to Review and Comment

Do you rely on a Designated Engineering Representative (DER) to approve data for your business? Do you use DMIRs for issuing 8130-3 tags?  If you do, then you know how critical designees can be to the parts approval process.  Often, though, designees are required by the FAA to do things that the FAA employees themselves are not permitted to do, like require paperwork that is not required by law or regulation (this can be a violation of the Paperwork Reduction Act), or impose standards of conduct that are not required by law or regulation (this can be a violation of the Administrative Procedures Act). When this happens, the designee has no choice but to obey the instructions from the FAA-Advisor … even if they would be illegal if undertaken by the FAA’s employees.

Want to make sure that designees are not used to do things that FAA employees can’t do (by law)?  The be sure to take the time to offer comments to the FAA Designee Management Policy that is now out for comment.  The FAA has issued for public comment a draft change to the guidance document affecting designees.  Although only parts are changed, it is a potential opportunity to comment on the entire document.

The original guidance is called “Order 8000.95, Designee Management Policy.” It was first issued in April of 2014.

This guidance document provides a wide variety of guidance on how to manage FAA designees. It has not and does not appear to cancel FAA Order 8100.8 (Designee Management Handbook), although some of the guidance appears to address some of the same issues as that guidance (failure to cancel 8100.8 might have been an oversight).

As a practical matter, designees (who are the people most directly affected by this guidance) will not be able to write comments that are critical to this guidance. This is because designees can be terminated for cause or without cause, at the discretion of the FAA. So the FAA can terminate a designee for exercising his or her First Amendment freedoms (as long as they come up with any other pretext for the action, including a termination ‘not for cause’). Designees are well aware of this and they regularly self-censor their comments because of the chilling effect that the FAA’s discretionary termination power has had. In some cases, designees have contacted me because they know that I will protect their anonymity.

The real-world issue us that designees rely on their designation from the FAA to ply their trade. If they are terminated (for-cause or not-for-cause) then they cannot simply be a designee for someone else. They need to choose a entirely different career path. So the process for reviewing designee termination is very important. And both the current policy and the draft policy are woefully inadequate, because they offer no standards for review, so the FAA employees are able to rubber stamp any termination decision on review. Honest review depends 100% on the personal integrity of the reviewing personnel – and there is no formal training for the employees who act as reviewers in that process (by comparison, state court judges typically attend judicial training).

The FAA’s failure to have effective standards actually undermines the FAA’s own interests. One example arises in the context of designee termination. The lack of effective standards means that individual FAA employees can cause the termination of a designee for any reason, including a reason that would have been considered to be illegal if it was used to terminate an employee, as long as the party who initiates the termination offers a pretextual reason. There is no formal inquiry into such pretext – it is taken at face value – and the VERY short time period for presenting a defense means that it is tough to be effective in assembling a defense: the full appeal including all supporting evidence must be submitted within 15 days – while the designee is given the charges, he or she has no opportunity to review the FAA’s underlying evidence. In comparison, the appeals panel has 45 days to consider the appeal and then another 15 days to notify the designee of their decision for a total of 60 days. We have seen evidence that FAA inspectors will use this period to gather more evidence to refute the defense and bolster the ‘prosecution’ so clearly the FAA is not bound to any sort of deadline for presenting its own case.

There is plenty that could be improved in the designee management process.

This is a great opportunity to help the FAA to better manage the designee community using effective processes that ensure fairness for everyone. MARPA members should strongly consider reviewing and commenting on this draft guidance.

Comments are dues to the FAA by January 7. Please send comments to MARPA, as well, so we can sure that our comments reflect your concerns.

Comments Due: 01/07/2015
How to Comment: Deliver comments by mail or hand to:
Susan Hill
1625 K Street NW
Suite 300
Washington DC, 20006Email comments to: Susan.ctr.hill@faa.gov
Email CommentsFax comments to:
(202) 223-4615, Attn: Susan Hill

UPDATE:

My comment on the cancellation of FAA Order 8100.8 failed to take into account FAA Notice 8000.372.  That Notice directs all AIR manufacturing personnel who oversee designees to stop using Order 8100.8 and being using 8000.95 on a schedule.  The schedule reflects the implementation of the Designee Management System (DMS) in those offices.

Under that schedule, all MIDOs with designee management responsibilities should have transitioned to Order 8000.95 during the summer (of 2014).  So Order 8000.95 will have supplanted 8100.8 for MIDOS (but not necessarily for ACOs and FSDOs).  This means that DMIRs and DAR-Fs have transitioned.  But DERs should still be under 8100.8 until they are formally transitioned (at which time they will fall under the instructions of 8000.95).

Special thanks to William Denihan for pointing this out!

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