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

Yes, China accepts FAA-PMA parts.

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

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

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

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

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

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

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

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

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

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

MARPA Efforts to Increase PMA Sales to Southeast Asia and China

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

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

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

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

Tails at Beijing Airport

Tails at Beijing Airport

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

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

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

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

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

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

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

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

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

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

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

MARPA Founder Jim Reum; Dead at 83

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

Jim Reum

Jim Reum chaired the first MARPA Board meeting in 2000

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

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

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

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

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

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

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

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

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

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

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

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

2005-10 Powell Dickstein Reum

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

Covenant Village
9215 West Broward Blvd
Plantation, FL 33324

Flowers and Cards may be sent to:

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

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

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

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

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

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

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

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

FAA Seeks Experts to Develop Airframe Crashworthiness and Ditching Standards

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

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

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

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

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

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

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

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

Customers Customers Customers!

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

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

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

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

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

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

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

 

 

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

FAA Issues New Guidance for Part 33 Turbine Engine Endurance Testing

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!

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.

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.

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