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.
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!
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!
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):
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.
Are you looking to increase your export sales? MARPA export promotion program is creating new opportunities to get your company and your PMA articles in front of the customers!
MARPA’s export promotion program is in full swing. After productive meetings in Buenos Aires, Dubai, Munich and Miami, MARPA is looking forward to a series of opportunities to promote PMA, and to promote our members, around the world.
MARPA is committed to providing education about PMA parts. We want installers to know what they can do with PMA parts (and what they can’t do). We believe that education about PMAs is the best way to promote PMA parts – the more the aerospace community knows, the more attractive PMA parts become.
But we also believe that it is important to market your PMA articles to the customers. Many of our members are small companies and have limited marketing budgets. So MARPA is working to increase the opportunities to reach the customers on a cost-effective basis.
This is not a complete list – but it lists a few of the most important upcoming events at which MARPA will be promoting PMA. These events are important to the members because they reflect opportunities to promote YOUR PMA articles, as well as promoting PMA generally.
There are many ways that MARPA members can start working now to take advantage of these marketing opportunities.
1) Start working NOW on putting together the paper and digital literature you’d like MARPA to include in their PMA literature packages. This distribution is a MARPA benefit that is free to our members.
a) Paper products can include brochures, one-page advertisements and short white papers;
b) Digital packages can include more information, including your product catalogues.
2) Register and attend the Istanbul and Las Vegas conferences – we are constantly working to get the customers there, so that you will have the best opportunity to network and make sales (and so that they will have the best opportunity to improve safety, reliability and the bottom line by using your parts).
3) Mark all of the the dates (above) on your calendar – we’d love to see our members at these events!
4) Consider whether you’d like to join MARPA on the Asian mission in November. Preliminary statements of interest are not firm commitments – but they will help us in our planning efforts.
5) Send us your ideas for additional marketing events and activities. But be warned that we may invite you to join the Marketing Committee!
We want you to get value out of your membership – so let MARPA know what the trade association can do to help you meet your sales and marketing objectives.
Looking for good business partners? Look no further than the AEA/MARPA Conference in Istanbul on May 25-26, 2015.
Our keynote speaker will be Dr. Temil Kotil, the CEO of Turkish Airlines, who will discuss how his airline has used PMAs as part of their safety strategy. This is an excellent opportunity for PMA manufacturers to meet Dr. Kotil in an intimate atmosphere that is designed to foster networking and discussions of solutions like PMA.
A recent article in Turkish Weekly announced that Turkish Airlines has been awarded corporate family ratings of Ba1 (from Moody’s) and BB+ (from S&P). By way of comparison, American Airlines was recently upgraded by Moody’s to a positive outlook, and at that time Moody’s confirmed a B1 rating for the corporate family. Last fall, S&P upgraded Southwest Airlines from BBB- to BBB. This shows that Turkish Airlines is situated well within the range of the finest airlines.
Rehan Akbar is Moody’s lead analyst for Turkish Airlines. Akbar explained that “Our decision to assign a Ba1 CFR to Turkish Airlines balances the company’s healthy financial profile and role as the national carrier against the execution risks associated with its high-growth strategy.” The Moody’s press release explained that “Turkish Airlines’ healthy financial profile is underpinned by its low-cost structure and historical above-peer-average profitability metrics. The airline has a well-diversified passenger revenue base that is supported by the economic and tourism growth seen in Turkey, while Istanbul’s geographic location allows the Ataturk International Airport to act as a hub for international transfer traffic. ”
What does this mean for PMA companies? It means that Turkish Airlines is a serious airline that is recognized internationally for its profitability. And part of what makes an airline like this successful are good business practices that ensure safety while providing good value that can be passed on to the traveling public. PMAs are one of the solutions that the leading airlines are using to ensure that they remain safe and profitable.
This meeting is co-hosted by the Association of European Airlines (AEA), and they have confirmed that they expect significant airline attendance; so make sure your sales force attends!
I look forward to seeing all of MARPA’s members (and a few non-members) at the Istanbul meeting in May!
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.
Do your export 8130-3 tags have the right language on them? If they don’t then you run the risk that they may be rejected in Europe.
The Bilateral Aviation Safety Agreement (BASA) between the United States and the European Union specifies that the documentation that accompanies a PMA part bound for the European Union must include specific language in order to be acceptable to the European Union’s airworthiness authority, EASA.
The BASA Technical Implementation Procedures (TIP) direct that PMA parts being exported from the United States to the European Union bear appropriate language in block 12 (the remarks block) of the export 8130-3 tag. In order to meet this requirement properly, the export 8130-3 tag must identify the part as falling into one of these three categories (by using the authorized language):
1. For a PMA part which is not a critical component, the remarks block of the 8130-3 should state:
“This PMA part is not a critical component.”
But if the PMA part is a critical component, then there are two options for the language in the remarks block.
2. In the first option for critical components, if the PMA holder also holds an EASA STC design approval which incorporates the PMA part into an EASA certified or validated product, then the language should say:
“Produced by the holder of the EASA STC number [INSERT THE FULL REFERENCE OF THE EASA STC INCORPORATING THE PMA].”
3. In the second option, if the PMA holder holds a licensing agreement from the TC or STC holder (giving the PMA holder the rights to use the TC/STC design for the PMA parts), then the following statement should be written in the remarks block:
“Produced under licensing agreement from the holder of [INSERT TC or STC NUMBER].”
These options 2 and 3 are the only two options for exporting FAA-PMA critical components from the US to the EU.
The PMA “criticality statement” is something that is requested under the technical implementation procedures (TIPs) that accompany the US-EU bilateral aviation safety agreement (BASA).
Under the US-EU TIP, a “Critical Component” is defined as:
“a part identified as critical by the design approval holder during the product type validation process, or otherwise by the exporting authority. Typically, such components include parts for which a replacement time, inspection interval, or related procedure is specified in the Airworthiness Limitations section or certification maintenance requirements of the manufacturer’s maintenance manual or Instructions for Continued Airworthiness.”
The determination of whether a PMA part is critical is made by the design approval holder (the FAA-PMA holder) and confirmed as part of the FAA approval. Section 4.4(c) of Order 8130.21H states that “The determination of a PMA article’s criticality, as required to be entered in Block 12 when exported, can only be determined by the actual design approval holder (that is, the FAA-PMA holder).” This is important language because certain parties (foreign governments and competitors) have attempted to gainsay the FAA-approved “critical part” decisions of the FAA-PMA holders.
we have heard of DARs who thought that this language meant that only the PMA holder could obtain the export 8130-3 tag. This is not so. This language is not meant to prevent a designee issuing an export 8130-3 tag from making a PMA “criticality statement” on the 8130-3 tag that is consistent with the determination of the design approval holder. Thus, any designee issuing an export 8130-3 tag for any FAA-PMA part may rely on the (PMA) design approval holder’s determination as to whether the PMA part is a critical component.
This critical parts language generally does not appear to apply to most bilateral airworthiness agreements – it is a special nuance of the US-EU Agreement. Adding the “criticality” language does not hurt the 8130-3 tag (and may be useful if the end-user is not yet known), but the criticality language generally remains unnecessary unless the part is destined for Europe.
The FAA has released a new draft Policy Statement concerning the vibration surveys and engine surveys required by § 33.83. The new guidance clarifies that this regulation is intended to require a full engine test (for type certificate applicants). The draft guidance, known as “PS‑ANE‑33.83‑01,” is currently available for public comment.
Members will recall that MARPA successfully opposed a final rule that would have applied the “full engine test” standard to PMA and STC applications. At the time, our discussions with FAA representatives revealed that their real concern was applying the full engine test standard to engine type certificate applications, and not to PMAs. The reference to PMAs and STCs, they explained, was an unfortunate mistake.
This draft guidance attempts to more narrowly address the FAA’s concerns about full engine test for type certificate applicants.
In order to ensure that the FAA’s intent is clear, MARPA plans to offer some additional language designed to clarify that this Policy Statement does not supersede the discussion laid out in FAA Advisory Circular 33-8 (Guidance for Parts Manufacturer Approval of Turbine Engine and Auxiliary Power Unit Parts under Test and Computation). We will also look for opportunities to help the FAA meet their policy goals.
Comments are due to the FAA by November 21, 2014. They can be emailed to firstname.lastname@example.org or mailed to her at:
Federal Aviation Administration
Engine and Propeller Directorate
Standards Staff, ANW-111
12 New England Executive Park
Burlington, MA 01803
Please share your comments with MARPA, too, so we can make sure our comments are consistent with the concerns of our members.
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.