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!
The early registration deadline for the 2015 AEA/MARPA PMA Aircraft Parts Conference is fast approaching. In order to qualify for the earliest registration discount, registrants must register by January 31, 2015.
For the first time, AEA and MARPA will host a conference to bring together experts and leaders, manufacturers and customers within the PMA industry in a location designed to facilitate business between USA FAA-PMA manufacturers and the international air carrier community. The 2015 AEA/MARPA PMA Aircraft Parts Conference will be held in Istanbul, Turkey on May 18-19, 2015, in cooperation between the Modification And Replacement Parts Association (MARPA) and the Association of European Airlines (AEA).
You can find more information about the event and registration online at http://www.pmaparts.org/EMEAconference
This week, MARPA is at the MRO Latin America show to promote PMA. The meeting is being held in Buenos Aires, Argentina.
Aerolineas is the flag carrier of Argentina. The carrier was formed in 1950 from the merger of four other air carriers. Today they have 69 aircraft. They expect to reach 73 soon with an expected delivery of four new A330s.
Forecasts continue to show Latin America as a leading growth area for aviation MRO. Latin America is expected to grow from 2226 aircraft to 4911 aircraft (commercial passenger and cargo) from 2010 to 2030, according to ICAO. This will reflect a growth from 10% of the global totals to 12% of the global totals.
Argentina has 119 Argentine MROs and another 52 foreign MROs certificated by Arentine Civil Aviation National Administration. 74 of the domestic MROs are in Buenos Aires and 6 of them focus on commercial aviation with the other 68 focused on General Aviation.
Aerolineas has a significant labor force focused on MRO. They have 1600 maintenance personnel working for the air carrier and their sister airline, Austral, has 520 maintenance personnel.
Aerolineas wants to generate partnerships with other air carriers, MROs and training organizations. They are building a new hanger in Buenos Aires and plan to expand their capabilities to support their fleet. The new hangar will have enough space to house an A380.
Aerolineos has been working to focus their fleet. Older types have been retired in favor of a more narrow fleet. The new fleet is focused on just four major types: A340-200/300, A330-200/300, B 737-700/800, and E190. They are retaining capabilities for other types, though, because they perform MRO services for other operators, including Tame, BahamasAir, and the Argentine President.
Fleet standardization means that there is less time spent on training for the maintenance personnel, which helps to Ake their team more efficient.
Today, the Aerolineas MRO is certified by ANAC, FAA and the Argentine military. As such, they seem like a prime target for PMA!
Don’t forget that the 2015 MARPA Winter Meeting will be held February 9, 2015. This is our annual “open Board meeting,” to which MARPA members are invited in order to participate in MARPA strategic planning.
EVENT: MARPA Winter Meeting
DATE: February 9, 2015
TIME: 9:30 AM – 4:30 PM
PLACE: 2233 Wisconsin Avenue, NW
COST: Free for MARPA Members
WHAT IS IT: The MARPA Winter Meeting is a strategic planning meeting attended by the Board and other members. We also typically meet with government officials from the FAA and other agencies.
WHO: Any MARPA member is welcome to attend. Please RSVP to Katt Brigham at (202) 628-6777 OR by using the response form, below. We have limited space, so please RSVP by January 26th so we can make appropriate plans for attendance.
WordPress.com has prepared statistical information about the MARPA blog …. click below for the 2014 annual report for this blog.
Interested in helping us produce content for the blog? We are always interested in additional writers with an interest in PMA. Contact us if you would like access to the blog in order to share useful information that benefits the MARPA community.
Have you ever been frustrated to learn that an AD went out that references a service bulletin, and (too late!) you later learned that the service bulletin made disparaging remarks or provided inappropriate directions about your company or your parts?
How do you prevent this situation? You need to get a copy of the service bulletin that is cross referenced by the AD, and review it before the AD rule becomes final. But sometimes no one will provide the service bulletin to you!
That just shouldn’t be the case. If an AD might indirectly affect you because of the cross referenced service bulletin, then you should be entitled to review the service bulletin before it becomes part of a regulation.
The U.S. government agrees!!
The U.S. Office of the Federal Register has published a new rule designed to make government rules more transparent. It accomplishes this by addressing incorporation-by-reference.
Incorporation-by-Reference (or IBR) is the term for regulations that make reference to some other document that is not published in the rule. Historically, incorporation-by-reference came about because it cost money to print the Federal Register, and wasting a lot of pages on a standard that could easily be obtained outside of the Federal Register. But today, most people access the regulations and the Federal Register on line, so there is not as much of a burden associated with publishing such documents. Incorporation-by-reference can be an issue for the public because when an incorporated document is merely technically available – but it is not really available – then this can make it difficult or impossible for an affected person to comply with the regulation (and can make it impossible for the affected person to even know that (s)he is subject to the regulation).
In short, unavailable-but-incorporated documents can reflect secret regulations that are impossible to comply with.
With this in mind, the Administrative Conference of the US began to study what could be done to update the rules to reflect modern technology. This ultimately led to the Office of the Federal Register looking into potential changes to the rules on incorporation-by-reference.
The aviation industry faces many challenges related to incorporation-by-reference. An issue that can be very important to MARPA’s members is the availability of referenced documents in Airworthiness Directives(ADs), like service bulletins. Service bulletin language can affect PMA parts, and can even disparage PMA parts in ways that are inappropriate.
Timely availability to the PMA community of these service bulletins can be a serious issue. It is typical for the FAA’s incorporation-by-reference statement to insist that the incorporated service bulletins be obtained either from the FAA office or from the OEM who published the document. In order to test this system, I emailed an FAA office and an OEM who were described as the sources of a service bulletin (the Federal Register listed the emails and listed this as an acceptable way to make contact). The FAA response was that I should go to the OEM. The OEM response was to ask me why I wanted the service bulletin. When I responded that the service bulletin was incorporated by reference in a proposed AD, and I wanted a copy of the service bulletin to determine whether the trade association needed to file comments on behalf of the membership, I received no further communication from the OEM. They just stopped responding to me.
MARPA filed comments on the Advance Notice for this proposal and offered a number of suggestions in 2012. MARPA also participated in face-to-face meetings with the government to discuss ways to improve the current system.
The result was a new rule that clarifies obligations related to regulations that incorporate standards by reference.
It is important that incorporated material be available in proposed rules so that the public can comment on the proposed rule with full knowledge fo the proposed rule’s impact. Under the new standards (1 C.F.R. 51.5(a)), the preamble to a proposed rule must :
When the agency is ready to publish a final rule with an IBR, the agency must do the following (1 C.F.R. 51.5(b)):
An important feature of the regulations is the requirement to discuss availability to “interested parties.” This is an expansion of the traditional language, which merely required availability to “the class of persons affected by the publication.” Interested persons should include persons who are indirectly affected (like those whose PMA parts MIGHT be affected in the case of an airworthiness directive) in addition to class of persons directly affected by the publication (which is generally operators).
The regulations continue to explain that IBR is limited to the edition that is incorporated. So if a subsequent revision of a service bulletin comes out, only the version that was approved by the Office of the Federal Register is the version that is IBRed (and not subsequent versions). 1 C.F.R. 51.1(f).
One sad omission was that the new rule does not define “reasonably available.” The Office of Federal Register was worried that a definition might be inappropriate, so they were hesitant to offer a definition, and instead they have left it to a case-by-case analysis as defined by each agency. But it seems certain that if you make a reasonable effort to obtain an IBRed service bulletin using the mechanism in the Federal Register, and you are denied, then you may have a claim that the service bulletin was not reasonably available.
While we did not get every change we requested, this nonetheless represents a good start on the process of providing better transparency in the situations of incorporation-by-reference.
The Statistics AC is going to be revised.
We have been working with the FAA to study the Advisory Circular (AC) 33-10, Statistical Analysis Considerations for Comparative Test and Analysis Based Compliance Findings for Turbine Engine and Auxiliary Power Unit Replacement, Redesign and Repaired Parts. We have pointed out a number of concerns with respect to this advisory circular in both our formal comments and in subsequent discussions with the FAA. These can be summarized as saying that the AC does not appear to get the FAA to where the FAA wants to be, and consequently will not appreciably contribute to safety.
The FAA has let us know that they will be rescinding the version of AC 33-10 that was published in late August. It must go through the internal FAA process so the rescission will not be immediate, but applicants should probably treat it as if it no longer existed because the text did not suit the FAA’s intended purposes.
This is not the end for statistics. The FAA still wants to provide useful guidance to the industry. But they have recognized that the current draft of the statistics AC is not what they want and have decided to take a step back and revisit the scope and intent of the AC. They plan to incorporate changes and solicit formal comments on the revised document in order to make sure that they meet their goal of creating a useful document that helps to move the industry towards our mutual safety goals. This will give everyone in the MARPA community an opportunity to contribute to the document.
This action reflects a joint efforts by the FAA and MARPA to understand the true impact of the guidance, and the rescission is a triumph of both good government and good industry efforts.
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.
The FAA has released two new advisory circulars that may affect the PMA community. Both advisory circulars are issued by the Transport Aircraft Directorate and apply to Part 25 aircraft (and parts thereof).
We would be interested in hearing from any MARPA member who is affected by one of these new advisory circulars.
The FAA Aircraft Certification Service has issued their sequencing document. This document provides guidance on how the FAA will prioritize certification / approval projects.
Projects will be provided FAA resources based on a Safety Index, Applicant Showing or Designee Finding (ASDF) value, and a project priority which will be calculated from the first two values. Anyone who plans to seek FAA approval from the Aircraft Certification Service needs to understand this Standard Operating Procedure (SOP) in order to know how to best formulate their project to get the highest score (and the highest priority) when seeking FAA data approval resources.
The first value calculated will be the Safety Index (SI). The sequencing program’s SI calculation puts a tremendous emphasis on safety-related projects needed to prevent an accident (described as “very high/immediate safety benefit”). This is good to the extent that it prioritizes airworthiness directives (ADs). When you look at the numbers, an AD that only affects five small general aviation aircraft will get a safety index of 450, while a national/strategic priority for a typical airline aircraft would be given a safety index of 350. This shows that ADs will always take priority over other projects in other categories.
Unfortunately, this category that strongly emphasizes ADs is broader than just ADs. The descriptive language of “very high/immediate safety benefit” could be interpreted to mean other projects as well. This category could undermine the system if it is misused to describe projects as having “very high/immediate safety benefit” when they don’t really meet the normal parameters for an AD.
The sequencing program also prioritizes large aircraft over small, and large fleets over small. This will put projects designed to support general aviation aircraft or rare aircraft (small fleets) at a distinct disadvantage.
The ASDF is a function of the complexity of the project and the amount of the project that will be approved by one or more designees. You take the total number of findings of compliance that will be performed by the FAA (0, 1-5, 6-15 or more than 16 – any amount that is more than sixteen findings will be capped in the table). Then you identify the percentage of findings of compliance that will be handled by one or more designees (so the finding of compliance does not need to be performed by an FAA employee). These percentages will fit into one of these categories: 100%, 90-99%, 75-89%, 50-74%, or <50%. You cross reference these two values in a table to obtain the ASDF, which will be low, medium or high. A High ADF will be reserved to those projects with nearly all of the findings performed by a designee (or findings based on applicant-only showing which is a theoretical notion that is being developed by an aviation rulemaking committee). For these projects, the FAA will have very little interaction with the application’s approvals.
In projects where the FAA has a high number of retained findings and/or the percentage of FAA-retained findings exceeds a metric established by the FAA (50-75% depending on the circumstances), the FAA will assign a low ASDF rating.
Project priority is then determined by cross referencing SI and ASDF. An AD-level safety index will always lead to a priority one ranking, even when ASDF is low. Everything else will fit into priority status two through four. The FAA will break ties among priorities by using SI, so this means that SI is your most important metric.
Those performing projects with negligible safety impact (which includes interiors projects like passenger entertainment systems and cabin modifications) get a zero value for safety impact. This will mean that the safety index for these projects is always zero, which will place them in the lowest possible project priorities.
Why is project priority so important? Because a project with a priority level one gets processed according to the office’s normal project flow times, but a priority level four project can be processed according to the office’s normal project flow times PLUS 90 DAYS! So (for example) the FAA may delay the response to your application (and thus the start of your project) by an additional 90 days if your project falls into priority level four; and then after that, additional 90 day response delays are permitted for each ‘resource-limited’ response.
These 90-day-delays are on top of office flow times (OFT), which are the amount of time allocated to a response by the local office – this time is set by the local office at the local office’s discretion based on staffing and workload. OFTs will apply to responses to discrete elements like test plans or test reports.
The new guidance also gives an automatic safety index of zero to applications that come in without a certification plan. This will be a tremendous strike against new market entrants, and could stifle innovation, because new market entrants typically do not know how to draft a certification plan.
We have always believed that a certification plan is a good idea. But such a plan is not required by the regulations and thus there is no regulatory guidance in how to create such a plan. The Paperwork Reduction Act (PRA) forbids government agencies from imposing information-collection burdens on the public without first obtaining OMB approval for the collection. The certification plan will become a de facto requirement for anyone that does not want to placed at the back of the line with a zero SI.
Certification plans are good things. They help to focus the applicant’s efforts by identifying which regulations are relevant for the showing of compliance, and how will the applicant show compliance with each. But for the FAA to engage in a de facto refusal of tax-payer-funded services to new market entrants who are unable to produce such a certification plan seems to be fundamentally unfair, as it creates yet another barrier to entry for the new market entrants.
Perhaps most damaging is the FAA’s failure to provide firm guidance concerning a certification plan. Without firm guidelines, any FAA office is free to reject any certification plan as inadequate. The rejected applicant will then have to face a “zero” SI (thus denying him/her timely services) or go back and try again until the applicant is able to meet the requirements of the local office (thus delaying the projects entry into the FAA oversight system). Imposing internal FAA workflow requirements that impose a de facto requirement on the public to produce a document that is not required by regulations (by making it de facto requirement for obtaining timely FAA services) is a back-door way of circumventing the regulatory process that is described by the Administrative Procedures Act.
What should the solution be? If the FAA fails to publish a certification plan guideline to aid applicants in meeting this de facto requirement, then perhaps industry should work with the FAA to develop standard guidelines for a certification plan. This does not relieve us of the problem of using internal work flow documents to impose pseudo-regulatory requirements, but at least it provides some guidance to permit industry to meet the FAA’s de facto requirements.
Many existing approval applicants already have an internal process for creating a certification/approval plan (often one that was worked out with the local FAA office to meet their particular requests as well as regulatory requirements). For these companies, it is important to review and understand this sequencing SOP in order to calculate how best to achieve a high SI in order to get treated earlier, rather than later.
Another important solution for PMA applicants is the streamlined PMA process found in FAA Order 8110.119. That document allows PMA manufacturers with non-safety-sensitive (NSS) parts to obtain an expedited review (which should be outside of the normal sequencing mechanism). It is not without its own burdens, though. The applicant must perform an additional analysis (not-required-by-the-regulations) to show that the parts are not safety sensitive, in order to qualify for NSS treatment, and then must have full evidence of compliance (as with any other application).