The FAA has released for comment two guidance documents pertaining to Instructions for Continued Airworthiness (ICA): Draft FAA Order 8110.54B and Draft Advisory Circular 20-ICA. As many readers of the blog know, MARPA has done, and continues to do, a significant amount of work to ensure that ICA are available and accurate in accordance with the Federal Aviation Regulations.
Draft Order 8110.54B is guidance directed at FAA personnel and persons responsible for administering the requirements for ICA. Among other changes, the draft reorganizes the Order to reflect material moved to AC 20-ICA (below), and importantly incorporates guidance implementing the FAA’s Policy Statement PS-AIR-21.50.01, Type Design Approval Holder Inappropriate Restrictions on the Use and Availability of Instructions for Continued Airworthiness. MARPA and the PMA industry were closely involved with, and supportive of the FAA in, the adoption that Policy Statement intended to protect the industry from anti-competitive ICA restrictions.
Draft AC 20-ICA is a new Advisory Circular that removes industry-specific guidance from the internal FAA Order and places it in a stand-alone AC. This effort is similar to the FAA’s actions in revising Order 8110.42D – Parts Manufacturer Approval Procedures and developing the new AC 21.303-4 – Application For Parts Manufacturer Approval Via Tests and Computations Or Identicality. Like Draft Order 8110.54B, the draft AC implements the FAA policy on ICA established in the Policy Statement. The proposed AC provides guidance to design approval holders (DAH) and design approval applicants for developing and distributing ICA.
After a preliminary review these documents appear to offer very positive guidance for the PMA and aviation maintenance industries, and appear in line with the policy positions for which MARPA has advocated for many years. MARPA will be reviewing both of these documents closely and offering comments and support for these policies to the FAA. We encourage the PMA industry to review both documents as well.
Comments on both guidance documents must be submitted by October 6, 2015, and may be submitted to the FAA via email to 9-AVS-ICA@faa.gov. If you have comments or observations that you feel MARPA should include in its comments to the FAA, email them to Ryan Aggergaard at firstname.lastname@example.org so the we can include them.
The MARPA Air Carrier Committee, led by Michael Rennick, Delta Air Lines Component Engineering Manager, is hard at work supporting PMA users and MARPA members. In June, members of the MARPA Air Carrier Committee, including Air Wisconsin, American Airlines, Republic Airways, US Airways, Air Canada, and Delta Air Lines, submitted to the FAA a letter seeking clarification on the issue of PMA parts that are alternates to post modification Airworthiness Directive (AD) related parts.
This clarification is necessary because confusion has sometimes arisen between operators and local regulators over the need for an Alternative Method of Compliance (AMoC) for post-modification AD-related PMA parts. It is the position of the MARPA Air Carrier Committee that if the PMA is an alternate to an OEM part contained in a post-AD configuration, no such AMoC is required.
When a PMA is issued for a replacement part for a post-modification AD-related OEM part, it is uncommon for the PMA applicant to request an AMoC to the AD, or for the FAA to note the AD on the PMA approval. This makes some sense because a post-AD PMA part is inherently an alternative method of compliance without being described as one. However, an issue arises because many ADs call out only the modified OEM part as a means of compliance. Because ADs are technically regulations under Part 39, alternate approvals such as PMAs might not satisfy the regulatory requirement and so an AMoC may be required.
It would be beneficial to both operators and PMA manufacturers to see this change.
The OEM part is the source of the condition giving rise to the AD. The post-modification part must resolve the condition in order to satisfy the AD. During the PMA approval process for the same part, the AD is also taken into consideration.. In order to receive PMA approval, the subject PMA part must resolve the condition resulting in the AD, just as the post-modification OEM part does. There should be no need to call out an AMoC for the PMA part related to the AD; the underlying condition that necessitated the AD has changed because the approved PMA part has replaced the post-AD OEM part. The PMA should be a valid terminating action for the AD.
There are limited circumstances in which this reasoning may not apply, but these limited circumstances are not the subject upon which the Air Carrier Committee seeks clarification. For instance an AMoC may be necessary in a scenario in which an AD applies to a higher level component or assembly. In this scenario the PMA replacement for the OEM part may not address the AD for the higher assembly because it is a replacement at the piece-part level, and thus an AMoC may be necessary for the higher assembly.
Generally, however, an AMoC should be inherent in an approved PMA part and therefore unnecessary as a separate approval. This is the policy clarification that the Air Carrier Committee seeks in the form of a formal FAA communication. If an approved PMA part is a replacement for a post-AD OEM part, the FAA’s policy should clearly state that the approved PMA is a terminating action for the AD and that no additional approval or discrete AMoC is required. In the alternative, an AMoC could automatically issue for each post-AD PMA to show compliance.
MARPA greatly appreciates the Air Carrier Committee’s work on this project. MARPA will be working with the FAA and the Committee to determine whether future ADs will list an approved PMA as a valid terminating action, or whether an automatic AMoC should automatically issue with a PMA to show compliance to the AD, or some other solution is desired. We will keep our members apprised of these developments.
If you are a MARPA member air carrier and want to get involved with the Air Carrier Committee, please email Katt Brigham at email@example.com. If you are not yet a MARPA member but would like to get involved, visit our membership application page. MARPA membership is free for air carriers!
Edited to clarify that ADs are regulations and identify possible solutions to the issue raised in the Air Carrier Committee’s letter.
Those who attended MARPA’s inaugural European conference last month in Istanbul were treated to an excellent presentation by Delta Air Lines Manager of Component Engineering and MARPA Air Carrier Committee Chairman Mike Rennick on the impressive reliability benefits of PMA parts in Delta’s fleet.
As many know, Delta operates a very diverse fleet of aircraft, which are on average older aircraft than many other carriers’ fleets. Yet Delta also operates one of the most reliable mainline fleets in the world. In 2014, Delta had an impressive 169 maintenance cancellation free days; a metric that has improved each of the last three years. Mr. Rennick pointed out that one of the important contributing factors to this success was the widespread use of PMA parts.
MARPA and its members frequently tout the many benefits PMA provide to operators. Operators are generally aware of the lower prices offered by PMA parts. They are also aware that PMA parts may be their only option, or one of very few options, for replacement parts for legacy aircraft. However, operators may not be aware of the significant reliability benefits that PMA parts also provide.
Mr. Rennick explained that in order to maintain its fleet to the level it requires Delta wants options. Service experience has demonstrated that PMA parts match, and in some cases exceed, the performance of OEM parts. Based on this experience Delta has found PMA parts to be acceptable for use throughout the aircraft, components, and engines.
Mr. Rennick’s presentation included exciting metrics showing an upward trend in Mean Time Between Unscheduled Removals (MTBUR) and Mean Time Between Failures (MTBF) on certain applications in which Delta had utilized a PMA solution. Metrics like these indicate the great value proposition that PMA’s can offer air carriers; not only from a purchase price standpoint, but importantly, from a reliability standpoint. These metrics, along with shortened lead times, are part of the greater holistic value proposition offered by PMA parts and something we should remember to emphasize when talking to potential customers.
Mr. Rennick also stated that because of Delta’s close cooperation with its vendors it is able to address issues more quickly than might otherwise be possible.
Delta’s comfort level born of experience with PMA parts has led to the carrier using PMAs in even very critical applications, including engine gas path and rotating parts, life limited parts, and power generation.
The emphasis on the reliability of PMA parts is one that we, as an industry, should be sure to promote to our customers. Cost savings means more than just lower prices (an obvious benefit of PMA!) Keeping aircraft safely and reliably operating without unscheduled removals and increasing time between failures generates cost savings for operators by allowing them to get planes turned quickly and keeping their passengers happy. MARPA always makes it a point to emphasize the reliability benefits of PMA wherever we go.
If you were unable to join us in Istanbul you will still have a chance to see this great presentation on the reliability benefits of PMA parts. We anticipate Mr. Rennick giving a similar presentation at the 2015 MARPA Annual Conference. This will be a great opportunity for PMA manufacturers to hear directly from Delta on the air carrier’s take on PMA parts, and an excellent opportunity for operators to see how one carrier is making PMA parts an important element of their maintenance program success. Register today to take advantage of Early Bird rates!
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 firstname.lastname@example.org.
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 email@example.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 firstname.lastname@example.org. 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 email@example.com. 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 firstname.lastname@example.org. We look forward to your feedback.