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Ryan Aggergaard

Ryan Aggergaard has written 51 posts for MARPA

MARPA Files Comments on Propeller PMA Policy

Late last month MARPA filed comments with the FAA on Draft Policy Statement ANE-35.1-01-R1 Parts Manufacturer Approval (PMA) for Propeller Critical Parts and Category 1 Propeller Parts. As we previously explained on this blog, the draft language of the policy would substantially broaden the definition of “propeller critical parts,” thus rendering a significantly larger set parts subject to the requirements of 14 C.F.R. § 35.16 (without regulatory justification), which establishes the requirements for propeller critical parts.  This could create several challenges for manufacturers of propeller PMAs.

MARPA’s comments noted several problems the proposed policy statement would create:

  • A broadened (and unsupported by the Federal Aviation Regulations) definition of “propeller critical part”
  • An undefined requirement for a “Life Management Program” that appears contrary to the Regulations
  • Conflating “Critical” and “Category 1” parts such that they are all held to the same increased requirements
  • Arbitrarily designates certain parts as “critical” without technical justification
  • Could have the inadvertent effect of barring many PMA propeller parts from Europe.

MARPA’s comments addressed each of these issues–and more–and explained why the Draft Policy Statement should be withdrawn or at the very least amended.

MARPA is always working diligently to protect the PMA industry and advance the PMA industry’s interests, both with regulators and TC/PC holders.  Our goal is to support the PMA industry–and especially our members–in every way we can, and make sure the PMA industry continues to grow and thrive. Filing comments like these to push back against potentially harmful policy is one of many things MARPA member dues go to support.

You can read MARPA’s full comments here.

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MARPA Joins Industry Groups Securing Reissuance of FAA Notice 8900.380 Policy

On August 2 MARPA joined a petition signed by 12 other industry groups seeking the extension of FAA Notice 8900.380.  This effort was spearheaded by the Aviation Suppliers Association (“ASA”), the trade association that represents aircraft parts distributors. The policy serves to formalize a repair station’s ability to receive, inspect, and approve for return to service new articles that are not accompanied by an 8130-3 tag. Yesterday, the FAA responded to the petition by agreeing to reissue the policy for another year.

The FAA-EASA Maintenance Annex Guidance revision 6 (“MAG 6”) made the 8130-3 tag a requirement for new parts received into a dual-certificated repair station, even though the 8130-3 tag is not required by the regulations. Not only was this requirement contrary to the actual regulations, it also had the effect of making it difficult for distributors to sell many new parts received from a PAH, and for repair stations to receive new parts released from a PAH, because many PAH’s do not issue 8130-3 tags for new parts (something that is also not required under the regulations).

Notice 8900.380 provided a temporary solution to this issue by ensuring industry knew that repair stations could receive and inspect new parts within their ratings without an 8130-3 tag.  This was particularly important for low-dollar value parts for which obtaining a tag from a designee was economically infeasible.  This solution is expected to be permanently memorialized in MAG 7, but with only weeks before the expiration of the Notice no draft of MAG 7 has yet appeared on the horizon, and so a different solution was required. Notice 8900.380 was scheduled to expire on August 26 before a permanent solution to this tag problem was reached.

In order to support industry the FAA responded to the petition initiated by ASA and signed by MARPA by reissuing the policy in the form of Notice 8900.429.  This notice continues the policy established by Notice 8900.380 for another year, until August 9, 2018.  Hopefully this will give the FAA, EASA, and industry time to develop a permanent solution to the 8130-3 problem created by MAG 6 and memorialize that solution in MAG 7.

MARPA is thankful to ASA for leading this effort, as it allows our members–and the PMA community generally–to continue operating our business in the ways we deem most effective, whether we choose to issue 8130-3 tags with our parts or not. Implementing the optional procedures to issue 8130-3 tags described in 14 C.F.R. § 21.137(o) comes with inherent costs, and so it is valuable to not have that requirement forced onto PMA manufacturers by a de facto requirement arising from MAG 6.

You can read the full Notice 8900.429 here.

MARPA Extends its Partnership with ITA

MARPA is happy to announce that it has extended its partnership with the U.S. Department of Commerce International Trade Administration through the Market Development Cooperator Program (“MDCP”) for another year. The extension of our partnership means MARPA can continue to draw upon the expertise and wide network of contacts the ITA can bring to bear, and in exchange will continue to report export data to ITA, honoring the commitment MARPA made at the beginning of the MDCP relationship.  Although there will be no additional direct funds from ITA as a result of the extension, the support and resources ITA staff will continue to offer will be invaluable to MARPA’s continued PMA promotional efforts going forward.

As readers of this blog know, MARPA was awarded an MDCP award of $300,000 in late 2014 for a program to promote the export of PMA parts to certain international markets of emphasis. These markets included Europe, the Middle East, and the Asia Pacific region.  In exchange for this award, MARPA agreed to put up $900,000 in cash and in-kind contributions in support of its new initiatives as well as collect export data from participating companies and report it to ITA to validate the MDCP program. (The obligation to report data is an import condition of receiving the MDCP funds and helps ITA justify this program to Congress to promote U.S. exports.)  The vast majority of MARPA’s contribution was of the “in-kind” sort, primarily arising from the labors of MARPA staff in organizing conferences and participating in trade shows to promote PMA.

MARPA’s MDCP award has already borne fruit. The matching award has allowed MARPA to establish a second conference: the MARPA EMEA Conference. The conference was held in three different locations in the past three years: Istanbul, Madrid, and Dublin, and has resulted in new customer contacts for attendees, and generated new business for a number of U.S. companies.  The conference has been such a success that even though the MDCP funds have been depleted, MARPA has determined that the conference will be held again in 2018, when we return to Dublin to build on our success generating new customers and engaging the leasing community.  MARPA’s long-term goal is to make the MARPA EMEA Conference an annual event that people attend every year, much like the MARPA Annual Conference in the U.S. (Orlando, FL, October 25-26, 2017).

The MDCP award also allowed MARPA to participate in several trade shows around the world that we would otherwise not have had the resources to reach.  These have included events in Europe, the UAE, Japan, Singapore, China, and South and Central America.  MARPA is working internally to determine the value proposition of  our continued participation in these events. If our members believe there are events MARPA should be at to promote PMA, we would love to hear from you.

As we continue our cooperative efforts with ITA, MARPA will continue to need your help. We need our members to provide us with export data that we can report to ITA as part of our MDCP obligation.  ITA keeps all this information confidential and are well versed in protecting sensitive information and trade secrets. However, MARPA is happy to report trade information anonymously if you prefer.  But we need your help to provide us with export data so that we can honor our commitment to ITA.  Your export data will also help MARPA better craft its conference agendas to offer the best and most helpful programming possible. Our goal is to help our members export more PMA parts to the world.

We look forward to continuing our relationship with ITA, and we look forward to seeing all of you at future MARPA events!

Questions or suggestions about the conferences? Contact Senior Program Manager Katt Brigham at katt@washingtonaviation.com.

Export data to report or questions about reporting? Email VP of Government and Industry Affairs Ryan Aggergaard at ryan@washingtonaviation.com.

MARPA to Return to Dublin in 2018!

Mark your calendars!  After a successful third annual MARPA EMEA Conference, MARPA has decided to return to Dublin, Republic of Ireland to continue building upon the success we have made in engaging the leasing community and expanding the use of PMA across Europe and the Middle East.  MARPA has chosen to return to Ireland and hold its fourth annual MARPA EMEA Conference April 30 – May 1, 2018 at the Hilton Dublin Kilmainham hotel.

MARPA knows our members are busy and that there are many conferences fighting for your time and attendance.  We are therefore continuing with our pattern of running a very efficient two-day conference with a great networking reception on Monday, April 30, and a full and informative general session on Tuesday, May 1, with plenty of opportunities to network throughout the day.

Locating the MARPA EMEA Conference in Dublin allows for easy travel from the United States and Europe, and the efficient two-day event also allows members traveling from the U.S. to tie in visits to existing customers and potential customers across Europe after the event concludes. (Attendees have also taken advantage of event in the past to enjoy a little time off with their families afterward.)

MARPA looks forward to continuing our discussions with the aircraft leasing companies that call Ireland home, and working with our air carrier friends and friends in government to continue the promotion and global acceptance of PMA.  The MARPA EMEA Conference reliably produces an excellent ratio of customers to suppliers and provides ample opportunities to both expand current business and develop new business with customers you might not see anywhere else.

Visit the MARPA EMEA Conference page to learn more, and check back often as we add speakers to the agenda.

Are there speakers or topics you would like to see addressed?  Email your recommendations to MARPA Senior Program Manager Katt Brigham at katt@washingtonaviation.com so that we can provide you the most valuable conference agenda we can.

2017 MARPA EMEA Conference a Success

This month marked the third annual MARPA EMEA PMA Parts Conference. After successful events in Istanbul (2015) and Madrid (2016), MARPA hosted this year’s conference in Dublin, Republic of Ireland, with the twin objectives of engaging the aircraft leasing community, and making attendance convenient for both MARPA’s manufacturing members and air carrier members.  Building on the success of the previous two years, MARPA was able to bring together more than a dozen different customers and potential customers to meet and network with PMA manufacturers and hear from government representatives and members of industry about the opportunities and benefits of PMA.

One of the primary reasons for selecting Dublin as the site of the 2017 MARPA EMEA Conference was to work to engage the leasing community in discussions about the acceptability and use of PMA on leased aircraft. The use of PMA on leased aircraft is one of the most important issues that members mention to MARPA, and restrictive clauses in lease agreements often create challenges for member operators in implementing and achieving their maintenance program goals, whether driven by cost, efficiency, or reliability.  As leased aircraft continue to expand as percentage of the global fleet, it will become more and more important to work with lessors to ensure PMA remains an option for operators of leased aircraft.

MARPA worked closely with representatives from the International Trade Administration and the U.S. Embassy in Ireland to secure a meeting with members of the leasing community. This initial meeting was hosted by the Charge d’affaires Reece Smyth and was attended by representatives of the ITA, FAA, representatives from each of MARPA’s conference sponsors, and representatives of several leasing companies.  This was a very productive luncheon in which the lessors were able to explain their positions and concerns, and government regulators and MARPA members were able to address and discuss those concerns, as well as describe how and why PMA are beneficial not just to operators, but to the lessors themselves.  (Due the sensitive nature of these discussions, and potential competitive issues, the lessors have asked us to refrain from broadly naming them at this time.)  The challenges of PMA and leased aircraft were not solved by this luncheon, but it was an important step in continuing the conversation and addressing lessor concerns. MARPA hopes that this was just the first of many productive conversations that we will have with the aircraft leasing community.

The MARPA EMEA Conference also provided an opportunity to meet and network with a number of air carriers and MROs, some of whom can’t be seen (or previously haven’t been seen) at the MARPA Annual Conference in the U.S. Attendees included operators such as Aer Lingus, Emirates, Swiftair, and the Dubai Royal Air Wing, among others, as well as MROs like Luthansa Technik and Dublin Aerospace.  The combination of receptions, lunch, and breaks, provided several hours of time to meet with the attendees and begin to develop or further build customer relationships, and for the operators to get new and useful information from manufacturers.

And, as always at a MARPA event, there was a robust agenda featuring presentations from all sides of the industry.  These presentations included the keynote address by Aer Lingus Chief Technical Officer Fergus Wilson, as well as presentations from Stobart Air and Delta Air Lines, in which each discussed the role PMA plays in their operations, how they use PMA now and what they see in the future, and anecdotes about the successful use of PMA in their maintenance programs. Charge d’affaires Reece Smyth also offered remarks on the efforts by the U.S. and Ireland to encourage small businesses, stimulate trade and job creation, and the excellent trade and diplomatic relationship between the U.S. and Ireland.

Manufacturers also offered their insight into the industry, described hows and whys of some of their successes, and made predictions about the direction of PMA.  Finally, speakers from the FAA made presentations about the status of initiatives that could affect the PMA industry, both domestically and internationally, and recapped for attendees the regulatory basis for PMA.

MARPA hopes to build on the success of the past three EMEA Conferences going forward and continue to deliver quality content and networking opportunities to our members domestically and internationally. MARPA also looks forward to seeing everyone in Orlando for the 2017 MARPA Annual Conference for more great speakers, workshops, and business development opportunities.  Register today!

It’s Not Too Late! Meet Air Carriers and MARPA in Dublin!

The 3rd Annual MARPA EMEA Conference, this year being held in Dublin, Ireland, is less than two weeks away.  The event, scheduled May 8-9, with a special tour of MRO Dublin Aerospace’s facility May 10*, will be a great opportunity to meet air carriers, MROs, suppliers, and government officials, that you don’t see at other conferences, including the MARPA domestic conference.

Even now we are still adding air carrier attendees, including two new additions just this week that we know our members will want to speak with.  We typically see air carriers register even up to the day of the conference, so we don’t want you to miss out on an opportunity to develop a relationship with a new potential customer. You can find an updated list of conference attendees here.

We will also have as a part of the conference agenda a Panel Discussion on how PMA improves safety and reliability, moderated by MARPA board member Josh Krotec, from First Aviation Services. This panel will offer the panelists a great chance to provide real-world examples of how they have worked with customers to use PMA to solve problems for air carriers.  Due to a scheduling conflict, there is still one slot available for an interested conference attendee to participate on this panel! If you would like to have the opportunity to sit on this panel and provide testimonials about your company’s successes in front of your current and potential customers, please reach out to MARPA Program Manager Katt Brigham at Katt@washingtonaviation.com for details.

We look forward to seeing you all in Dublin!

*Please RSVP to Katt if you would like to participate in the Dublin Aerospace facility tour.

Tour MRO Dublin Aerospace at the MARPA EMEA Conference!

MARPA is very excited to announce that Dublin Aerospace has agreed to host a tour for attendees of the MARPA EMEA Conference on the morning of May 10, 2017. The MARPA EMEA Conference itself is scheduled for May 8-9 at the Dublin Hilton Kilmainham in Dublin, Ireland. This is the third year that MARPA has put on a European conference, and it will be a great opportunity to meet and network with customers you may not get a chance to see at the MARPA Annual Conference in Orlando, as well as hear the latest information and developments from the PMA world.

Dublin Aerospace is based at Dublin International Airport, and is equipped to perform work on aircraft, APUs, and landing gear.  Dublin Aerospace’s primary focus is on the Airbus A320 family and the A330 aircraft, as well as the Boeing 737NG and Classic aircraft. Their APU repair shop focuses on most Boeing and Airbus APUs, and the landing gear facility performs work on both the A320 family and the Boeing 737 family landing gear. Dublin Aerospace has the capacity to process 70 aircraft, 400 APUs, and 250 landing gear annually.*

Last year in Madrid, about a dozen attendees had the opportunity to tour the Iberia Maintenance facility the morning after the conference. The site visit was viewed as a highlight of the event by those who participated, and it was generally agreed that there was great information and ideas to be taken away from the tour. Many participants suggested MARPA hold a similar event this year, and we are pleased to partner with Dublin Aerospace to bring our conference attendees this opportunity.

Don’t miss out on a great chance to meet with your current and potential new customers, and to take a tour of a leading MRO facility. Register for the 2017 MARPA EMEA Conference in Dublin today, and we look forward to seeing you in there!

For more information about Dublin Aerospace, visit: http://dublinaerospace.com/

For more information about the MARPA EMEA Conference, visit: http://www.pmaparts.org/EMEAconference/about.shtml

Questions? Email MARPA Senior Program Manager Katt Brigham at katt@washingtonaviation.com.

*Credit: Dublin Aerospace at http://dublinaerospace.com/grid-12/.

MARPA Attends 2017 Aviation Summit

On March 2, MARPA had the opportunity to attend the U.S. Chamber of Commerce 2017 Aviation Summit in Washington, DC.  The event featured addresses and panels by the presidents and CEOs of aerospace industry leading operators, manufacturers, and service providers. Although the focus was primarily on operational issues affecting air carriers like Open Skies, airport infrastructure, and air traffic control, there were a couple of points raised by speakers that are relevant to MARPA members and the PMA industry.

During the manufacturing panel, HEICO Corporation Co-President and past MARPA Annual Conference keynote speaker Eric Mendelson, discussed the importance of choice and competition without which it becomes difficult for carriers to operate cost effectively. He used the decrease in suppliers relied upon by Boeing for successive new aircraft to illustrate the challenges facing both operators and aftermarket parts manufacturers, as competition becomes more and more restricted. He noted that the original 777 had three engine options, and approximately 17 component suppliers provided 75% of components. For the 787, those numbers fell to two engine options, and about four component suppliers for 75% of components. In the case of the new 777 there will be only one engine option and fewer still component suppliers.

This on-going reduction in suppliers means that operators face fewer and fewer choices both at the initial purchase stage and in terms of maintenance over the life of the product. This also means that those suppliers have a great deal of leverage in locking operators into long-term service agreements, which threaten PMA manufacturers.

In order to fight this phenomenon, it is vitally important that our customers be educated through their organizations as to the value of ensuring PMA is viable replacement part option, to ensure that they aren’t locking themselves into unfavorable maintenance agreements that needlessly restrict their replacement part options and drive up their costs. This will become even more important if fuel prices begin to rise, causing operators to look more aggressively for areas to realize cost savings.

Another interesting point was made later in the day, by Dennis Muilenburg, Chairman, President, and CEO of Boeing. He noted the importance of the Ex-Im Bank to financing export of US-manufactured goods, and stated that there is approximately $30 billion in deals merely awaiting the Ex-Im Bank’s board to reach a quorum. This requires one more confirmed nominee (currently, only 2 of the 5 seats are filled, and a quorum is required to approve deals over $10 million).

Although MARPA’s members aren’t generally making deals that require that level of financing from Ex-Im, having Ex-Im move out of limbo would be valuable for MARPA’s members. We’ve talked previously at conferences about the various ways the Ex-Im Bank can support MARPA’s members in exporting goods to credit-worthy customers abroad who may otherwise lack the cash flow to complete a large purchase. If Boeing’s willingness to throw its weight behind Ex-Im results in securing the stability of the bank for the future, the benefits would ripple out to the rest of the industry.  This is something we will be keeping an eye on.

If you have questions about how Ex-Im can be leveraged help your PMA business, don’t hesitate to let MARPA know.

 

Should MARPA Support Repeal of the Estate Tax?

MARPA has been asked to sign onto a letter supporting a bill that would repeal Subtitle B of the Internal Revenue Code of 1986 that relates to estate, gift, and generation-skipping taxes. The Bill is entitled the Death Tax Repeal Act of 2017.

Although it is typically thought of as only affecting the very wealthy, the estate tax can also have an effect on small and family-owned businesses; particularly those that are land- or asset-rich but cash poor. One oft-cited example is that of the family farmer, whose is land-rich (the value of his real property is high) but operating on very thin margins and doesn’t have a large amount of cash saved or other liquid assets. The family of the farmer may be forced to sell off a piece of the farm land in order to raise the money to pay the estate tax assessed against the total value of the farm upon the farmer’s death.

More close to home, in the aviation industry, companies may have millions of dollars in inventory that would be counted toward the value of a family business owner’s estate. This sort of inventory often cannot be quickly liquidated upon a business owner’s death to cover an estate tax assessed against the value of the business (that includes that inventory). Additionally,  because many companies rely on their inventory as collateral against which to take out loans or lines of credit, they cannot simply depreciate the value of the inventory to zero to minimize the value of the business for estate tax purposes, or they risk also minimizing the apparent value of the business as a whole.

On the other hand, many people feel that the estate tax is something that only effects the very wealthy and thus repeal should not be a high priority (or a priority at all).

I would like to hear what our members think. Is a letter supporting the Death Tax Repeal Act of 2017 something MARPA should sign on to? We have been asked to respond by Monday, January 23, so please let us know what you think before then.  You can email your thoughts to MARPA’s VP of Government and Industry Affairs Ryan Aggergaard at ryan@washingtonaviation.com.

FAA-AIR Transformation Process Continues

Those readers of the MARPA blog who have attended a MARPA Annual Conference in the past two years probably heard the FAA’s David Hempe give a presentation discussing the transformation currently underway at the FAA’s Aircraft Certification Service (AIR) division. As we have previously discussed here and elsewhere, the goal of this transformation is to shift AIR from a compliance-based certification strategy (wherein an applicant makes a showing and the FAA issues a finding on a one-for-one basis) to an oversight-based certification strategy (wherein the FAA focuses more broadly on standards and systems oversight in order to ensure applicants are remaining compliant).  Mr. Hempe’s presentations have provided a great deal of information and insight into this transformation, and MARPA is grateful for his participation and willingness to answer conference attendee questions over the course of the conference.

Obviously, such a transformation will require change by industry; but more importantly the FAA understands that it will also require a culture shift within the agency itself to reflect this change away from a compliance model toward an oversight model.  To that end, the FAA has offered a briefing to applicants and approval holders (those who will be affected by the AIR transformation) to offer an update on where the transition stands and what to expect as AIR reorganizes.

The briefing first notes the benefits of the AIR transformation. These are worth reiterating:

  • Encourage early industry engagement and risk-based monitoring to eliminate later unnecessary FAA involvement
  • Improve consistency and standardization
  • Foster innovation by engaging industry applicants early to understand new concepts and ensure path to compliance
  • Provide agility and adaptability
  • Establish practices for using metrics to determine efficacy

The next step in reorganization implementation will be the first step visible to industry. AIR will begin realigning the organization to shift the existing offices, like ACOs and MIDOs out of the current directorate structure and into alignment with AIR’s functional divisions. For instance, ACOs will all be aligned under the Compliance & Airworthiness Division, while MIDOs will align under the System Oversight Division.  Currently, both ACOs and MIDOs are spread across the Transport Directorate, Small Airplane Directorate, Engine and Propeller Directorate, and Rotorcraft Directorate. This creates significant unnecessary redundancy and confusion, particularly if a company designs and manufactures parts for different categories of products.

After realignment, the Directorate structure will no longer exist.

Because of the nature of the process, existing industry Points of Contact will be retained during realignment to ensure relationships are maintained and contact with appropriate employees is facilitated. This is an important feature because as with every transition there exists the possibility for confusion.

AIR will continue to brief industry on the transition and solicit industry feedback as it progresses. MARPA encourages you to maintain a consistent dialogue with your FAA contacts to let them know about any problems with the transition or implementation that you identify, particularly if it the transition messages don’t seem to be reaching the personnel you deal with regularly. MARPA would also be happy to hear feedback from our members so that we can bring any concerns or positive feedback from you to the FAA. Please feel free to email VP of Government and Industry Affairs Ryan Aggergaard at ryan@washingtonaviation.com if you have feedback on the AIR transformation process.