On Monday the FAA released new guidance that provides a method of compliance for the test requirements of 14 CFR § 33.84 – engine overtorque test – when the applicant chooses to run that test as part of the endurance test of § 33.87. The new guidance is AC 33.87-1A and can be found on the FAA’s website at http://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_33_87-1A_.pdf.
The AC also provides information and guidance on the test requirements of § 33.85 (calibration test), § 33.87 (endurance test), and § 33.93 (teardown inspection).
The guidance is directed at engine manufacturers and engine type-design applicants, as well as foreign regulators and FAA designees. However, it is still worth reviewing the guidance to determine whether there are any ways in which you might be affected.
The AC explains that the primary effect of the guidance is to eliminate some previously approved methods of engine testing that were designed to represent expected in-service operations rather than the endurance cycle described in § 33.87. This is because § 33.87 is not intended to reflect in-service operation, but rather to demonstrate a minimum level of operability and durability throughout the engine’s assigned ratings and limitations.
We encourage all of our members to take a look at this (and any other) new guidance to make sure there are no surprises. If you see anything that concerns you please let MARPA know!
MARPA is extremely pleased to announce that Dr. Temel Kotil, President and CEO of Turkish Airlines, and President of the Association of European Airlines, will serve as the Keynote speaker for our first-ever AEA/MARPA PMA Aircraft Parts Conference.
Dr. Kotil began his career at Turkish Airlines in 2003, serving as the Deputy General Manager of Turkish Technic. He became the CEO of Turkish Airlines in 2005. Dr. Kotil has served on the Board of Governors of IATA since 2006 and on the Board of Directors of AEA since 2010. Dr. Kotil became president of AEA on January 1, 2014.
Turkish Airlines is the national flag carrier of Turkey and the largest air carrier in the country. As of February 2015, the Turkish Airlines fleet consists of 253 passenger and 9 cargo aircraft. Turkish Airlines offers scheduled service to over 260 destinations in Europe, Asia, Africa, and the Americas. It’s cargo operation serves 47 destinations.
MARPA wishes to extend its sincere thanks to our partner AEA for their efforts in securing Dr. Kotil as keynote speaker for the conference, as well as their ongoing support in organizing the AEA/MARPA PMA Aircraft Parts Conference and ensuring the attendance of their members. The participation of AEA’s member airlines provides an excellent opportunity for our members to meet and network with customers. It is also an opportunity to continue the ongoing discussion about the benefits and value of PMA parts. MARPA looks forward to seeing our members in Istanbul networking with the air carriers of not only Europe but also the Middle East.
PLEASE NOTE OUR NEW CONFERENCE DATES! Due to an unforeseen conflict we have revised the dates of the AEA/MARPA PMA Aircraft Parts Conference. The new dates are May 25-26, 2015, in Istanbul, Turkey. If you have any questions about dates, venues, or speakers, please feel free to contact MARPA by emailing Program Manager Katt Brigham at email@example.com.
We look forward to seeing everyone in Istanbul!
UPDATE: Due to an unforeseen conflict the dates of the AEA/MARPA PMA Aircraft Parts Conference have CHANGED! The new dates are May 25-26, 2015 in Istanbul, Turkey. Please visit the conference website for latest hotel and registration information.
Over the past several months MARPA has been in discussions with the Association of European Airlines (AEA) to work together to put on a PMA conference specifically designed to further education about PMA in Europe and the Middle East, and open new export opportunities for our members. MARPA is pleased to officially announce its partnership with the Association of European Airlines and formally announce the dates and location of our first ever European MARPA conference.
The AEA/MARPA PMA Aircraft Parts Conference conference will be held May 18-19, 2015, in Istanbul, Turkey at the Hilton Istanbul Bosphorus.
AEA and its members have expressed considerable enthusiasm for this event. AEA has pledged to work with its members to ensure their attendance at the conference, and will be holding its own meeting the afternoon of May 18 to provide additional incentive for its members to attend. AEA and MARPA expect a significant number of the European air carriers to be in attendance at the conference. MARPA is also reaching out to contacts in the Middle East to encourage air carriers from that region to attend as well.
This will be an excellent opportunity for MARPA members to meet and network with European and Middle Eastern air carriers, or to continue to develop preexisting relationships. Of course, we will also present a slate of educational and informational speakers to give attendees the very latest information about PMA, export regulations, and developments in air carrier and leasing issues.
The AEA/MARPA PMA Aircraft Parts Conference is one element of MARPA’s partnership with the International Trade Administration under its Market Development Cooperator Program, intended to increase the export of U.S.-made PMA parts.
MARPA is very excited to work with AEA to present an excellent conference program and provide substantial opportunities for our members to meet and network with air carriers. Be sure to mark your calendar for May 18-19, 2015 in Istanbul! For more information, visit the conference website at http://www.pmaparts.org/EMEAconference/about.shtml.
MARPA looks forward to seeing you in Istanbul!
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 firstname.lastname@example.org 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 email@example.com. 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.
MARPA is proud to announce that it is the recipient of a $300,000 matching grant from the Department of Commerce International Trade Administration Market Development Cooperator Program! MARPA was one of eight recipients of funding under the Market Development Cooperator Program (MDCP), which is intended to help organizations boost exports and create U.S. jobs. With the receipt of this assistance, MARPA plans to implement a number of initiatives to help grow the international PMA market and most importantly help our members grow their businesses by exporting more PMA parts!
The first of these initiatives will be to establish a European MARPA Conference, similar to the MARPA Annual Conference held in Las Vegas. Our current target is for the inaugural MARPA Europe conference to occur in May 2015, in Istanbul, Turkey. The primary goal of MARPA Europe will be to bring together PMA manufacturers (our members) and customers from both Europe and the Middle East. Air carriers reliably account for 25% of our Las Vegas attendees, and we expect to meet or exceed that rate at MARPA Europe.
Another initiative will be to lead educational missions to regions that present an opportunity for expanded PMA penetration. These include Japan, China, Southeast Asia, and the Middle East. MARPA will lead technical and regulatory seminars explaining the benefits of PMA and the way PMAs fit within the regulatory framework of the various countries we visit. MARPA also plans to attend regional MRO shows and other trade shows to educate the global aviation industry about the benefits of PMA.
Finally, MARPA will work with our partners and air carrier contacts to continue to bring more air carriers to both the MARPA Annual Conference in Las Vegas as well as MARPA Europe. The significant and growing attendance by air carriers at MARPA’s conferences make them the premiere events for PMA manufacturers to meet and network with air carriers in an intimate setting.
Of course nothing in life is free! One very important element of MARPA’s participation is the MDCP program will be measuring the effects our efforts have on growing the export PMA market. In a previous post we explained that MARPA would begin collecting export data from our members to get a better idea of the global PMA market share and identify to what market PMAs were being sold and where opportunities lay. As a part of our commitment to the Commerce Department, MARPA will track and measure the increases in exports reported by our members. This will be an important part of the next three years, as MARPA works closely with the Commerce Department to grow exports of PMA. MARPA will also need the help of its members to collect and report accurate data to measure the effects of our initiatives. We will be working with our members to help them increase their exposure to foreign markets and increase their exports in order to optimize the return on the Commerce Department’s investment as well as to develop accurate PMA export data.
Fred Elliot from the Department of Commerce and Ryan Aggergaard from MARPA will be on hand at the MARPA 2014 Annual Conference in Las Vegas to discuss some of MARPA’s planned initiatives and the requirements related to the award of the MDCP grant, as well as to answer member questions on how they can benefit from MARPA’s new programs. We look forward to seeing you there!
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 firstname.lastname@example.org. We look forward to hearing from you, and continuing to build the future of PMA.
One of the many ways MARPA supports the PMA industry is through the issuance of its Continued Operational Safety (COS) system guidance material. In order to continue to improve safety and address industry and regulatory concerns, MARPA regularly revises its COS guidance and makes the revised guidance available to the public.
MARPA recently issued Revision 3 to MARPA’s Guidance Material for a PMA Continued Operational Safety (COS) System for review and comment. The COS guidance is available on the MARPA website under the Government Affairs Continued Operational Safety menu, or by clicking the direct link in this post.
As with any guidance material it is important that we receive comments and feedback from our members to ensure that the revisions to the COS guidance are workable and make sense. We are therefore asking our members and the PMA industry to review the revised COS guidance and provide us with feedback.
Comments are due to MARPA by September 19, 2014. You can submit comments to MARPA by emailing them to Ryan Aggergaard at email@example.com. We look forward to your feedback.
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:
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.
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 firstname.lastname@example.org soon!
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 email@example.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 firstname.lastname@example.org