Many of our members have been communicating with us about their concerns over the proposed Materials AC. We had previously asked the PMA community to send us their comments and concerns so we could assemble them into a single missive to deliver to the FAA.
We’ve heard from a number of you that the large volume of material and the highly technical nature of the proposed AC has made it slow going to put together your comments. With this in mind, MARPA asked the FAA last week for a extension of time to file comments on this draft.
We received the answer today, granting that extension.
Dear Mr. Ryan Aggergaard,
This e-mail is in response to your request to grant a 90 day extension to comment on the FAA public draft Advisory Circular 33.15-3, titled “Parts Manufacturer Approval (PMA) Metallic Part Material Compliance Using Comparative Test and Analysis Method for Turbine Engines or Auxiliary Power Units”.
The FAA will consider comments after the comment period has closed if it is possible to do so without incurring expense or delay.
We have determined there will be no incurring expense or delay, and will grant the MARPA members and the MARPA Technical Committee an extension from July 20, 2016, to October 18, 2016.
Please feel free to contact us if you have any questions or concerns.
Please do not wait until October to review this AC and develop your comments. The earlier you can provide your comments and concerns to the FAA (and to MARPA), the better able we will be to address them in a positive and productive way with the FAA.
As our members know, MARPA has been working over the past two years with the U.S. Department of Commerce’s International Trade Administration (ITA) under its Market Development Cooperator Program (MDCP). Under the MDCP the ITA provided MARPA a $300,000 matching grant to help MARPA promote PMA around the world with the ultimate goal of increasing exports of U.S.-made PMA parts, with the additional benefit of potentially adding U.S. jobs.
One of the conditions of MARPA’s receipt of the MDCP grant is that we are required to report back to ITA on the increase in exports our members are seeing. These reports allow the ITA to demonstrate the results of the program to Congress and keep open the funding to support increasing U.S. exports in various industries around the world.
This requirement is why we need our members’ help. We need to hear from you to know if MARPA’s efforts are working, and if the PMA industry is seeing an increase in export sales. MARPA therefore needs your help in gathering data on new exports of PMA parts.
MARPA is always sensitive to its members’ business needs, so we want to assure you that any information provided to us will be kept confidential, and the only information that is shared with ITA will be the country of export and the value of the export, and no other sensitive business information or data.
We are asking that our members fill out the export survey found by following this link. MARPA needs to know the following information: for any exports that are traceable to a MARPA effort under the MDCP–the MARPA Europe Conference, the domestic MARPA Annual Conference, MARPA’s presence and promotion at trade shows around the world–to what country was the export (or contract for future sales), and what was the value of the export or future export?
That’s it! Just country and dollar value. We don’t need to know your customer’s name, the specific parts or product type involved, or any other detail. Even your company’s name will be kept anonymous unless you expressly tell us to release it to ITA.
If you wish to provide MARPA additional information so that we can better focus our efforts, of course we welcome it. But we only need for the sake of our MDCP requirements a report on export country and dollar value.
Please help MARPA fulfill its obligations to ITA under the MDCP. The ITA was generous in supporting MARPA with this grant so that we can increase our efforts to expand the global PMA market. MARPA needs to make good on its requirement to report back on our efforts and help ITA keep this valuable program going!
If you have questions about MARPA’s reporting obligations under the MDCP or wish to report export data directly rather than by using the survey form, feel free to email VP of Government and Industry Affairs Ryan Aggergaard directly at email@example.com. MARPA sincerely thanks our members in advance for their help!
MARPA had the opportunity this week to attend the 2016 FAA-EASA International Aviation Safety Conference that was held in Washington, DC. The conference provides an opportunity for the regulatory agencies and industry to get together to discuss emerging issues in aviation safety and strengthen the cooperation between both the regulators themselves as well as the regulators and industry.
One notable panel discussed performance-based regulations (PBR) and their development, implementation and oversight as a part of the ongoing safety management adoption. The goal of PBR is essentially to retain the high level requirements and clearly establish what those high-level regulations are trying to achieve, while clearing out more detailed prescriptive regulations. Those detailed regulations would then be replaced by industry consensus standards.
In theory, this should clear the way for innovation by focusing more on ensuring a satisfactory outcome (that complies with the regulations) is the result, rather than focusing on prescriptive compliance-based rules. (How this exactly squares with a safety management system focused on systems and processes rather than the outcome per se is a conversation for another day.) Performance-based regulations can free the hands of regulated parties and avoid the trap of innovation stagnation in which companies are forced to design or produce in only limited ways in order to comply with the regulations.
Although moving to a PBR approach may be a laudable goal, the next panel demonstrated how challenging it may be for regulators to break free of deeply ingrained compliance-based approaches to oversight. Relevant to PMA manufacturers, the “fast-moving technologies” panel spent a significant amount of time discussing certification of projects using additive manufacturing techniques.
In theory, a PBR approach would be ideal for approving parts manufactured using emerging technology like additive manufacturing (AM). If a part can be produced using AM techniques (like 3D printing) that meets all the design requirements (dimensions, material composition, durability, etc) of a part that is traditionally machined, an outcome-focused approach like PBR claims to be should have no problem approving that part. Conversely, if a 3D printed part cannot be made to conform to the approved design, our quality assurance systems reject the part and we go back to the drawing board.
However, it became clear during that panel that we can expect to see more of the same compliance based review of processes in seeking to obtain approval of parts manufactured using emerging technologies like AM. Of course to borrow from Captain Renault I was shocked, SHOCKED to find that the OEM panelist expressed skepticism that “sub-tier” suppliers or those in the aftermarket were capable of producing approved parts using these methods. But of greater concern was his statement that the regulators might also question that ability.
Part of this concern on the part of the regulators arises from the fact that the regulators themselves do not fully understand technologies like AM yet. The FAA is currently working with industry to determine what controls will need to be in place and what the oversight requirements will be with respect to AM. It will therefore be very important for any PMA manufacturer seeking to use new techniques to manufacture parts to engage the FAA early in the process and demonstrate to the FAA its competence with the technique. This may involve educating the FAA in some cases (and refuting the implications of some larger OEMs that only they know the “special sauce” of new technology).
This much was supported by FAA AIR-1 Dorenda Baker, when she explained that the key to getting approval when relying on new technology is ensuring an understanding on both sides. The FAA needs to be brought into the process very early on. When the FAA is brought in at the last minute, problems and confusion can arise, because what might seem clear to the applicant, who has been working with the technology for months or even years, can seem confusing to the regulator seeing it in action for the first time. Ms. Baker explained that we don’t want questions being asked for the first time, or engineers trying to understand new processes, at the time of certification. We, as applicants relying on new manufacturing techniques, need to engage the FAA early and often.
Of course this is somewhat inconsistent with a performance-based approach. As we mentioned above, if the goal of PBR is to ensure an outcome that satisfies high-level regulations, it should be less important how we get to the result than that we obtain a satisfactory result. A need on behalf of the regulator to understand fully the processes by which we obtain the result is more consistent with systems oversight (their stated goal) but doesn’t square perfectly with a PBR approach.
Nonetheless, it thus becomes clear that the PMA industry will have to fight this battle of fast moving technology on two fronts: First, we will have to (again) battle against an OEM-driven (mis)perception that only OEMs are capable of understanding and safely applying emerging technologies like additive manufacturing. Second, we will have to work very closely with the regulators to continuously demonstrate our competence and expertise in applying these technologies, and in effectively implementing systems that consistently produce the desired outcome.
There is a lot happening right now; from fundamental shifts in the role regulators play to the way we design and manufacture parts. By frequently engaging with the regulators we are able demonstrate our competence and abilities (simultaneously refuting any implications by competitors to the contrary) and keep the regulators closely engaged so that the certification process moves smoothly and we are able to nimbly adapt to changes as they happen.
MARPA will continue to keep you updated as old regulations change and new regulations emerge.
As readers of this blog and attendees at MARPA events know the FAA, specifically the Engine and Propeller Directorate, has been releasing a significant number of PMA-related advisory circulars of late. Currently open for comment is AC 33.15-3 Parts Manufacturer Approval (PMA) Metallic Part Material Compliance Using Comparative Test and Analysis Method for Turbine Engines or Auxiliary Power Units. This is a highly complex draft advisory circular that has the potential to affect many MARPA members and the PMA industry as a whole.
MARPA plans on submitting comments on this advisory circular, but we need the assistance and expertise of the MARPA community to make sure we identify all the possible issues that may have an adverse effect on the PMA industry.
I know that some of our members have already looked at this and have begun to identify issues. For those who have not yet had the opportunity, please take the time to review the draft language and identify any issues and possible solutions you see. Please provide any comments you identify to MARPA so that we can include them in our comments that we will submit to the FAA.
The AC is fairly lengthy document, so it may take some time to get through. Because of this complexity, we would like to have all of your comments in well in advance of the July 20, 2016 comment due date. MARPA therefore requests that any comments you identify are provided to us as quickly as possible, and in any case no later than July 8. This should give us ample time to compile all of your comments into a single comment submission on behalf of the members. It will also give us time to circulate our comments back to both the MARPA Technical Committee and MARPA Board for review.
This is a complex and weighty document, so if you plan on reviewing and submitting comments to MARPA or submitting comments on behalf of your company, we encourage you not to wait until the last minute to review the draft AC.
Please email your comments to VP of Government and Industry Affairs Ryan Aggergaard at firstname.lastname@example.org.
GECAS’ Gilberto Peralta turned some heads at CCMA yesterday when he said that he sees no safety or technical issues with PMAs. He explained that his only objections to PMAs are commercial.
Peralta is the GECAS General Manager for Latin America and the Caribbean. ALTA representatives confirmed that GECAS is the most significant leasing company in South America. Peralta was part of the CCMA panel discussing the technical and commercial aspects of PMA parts.
He explained that GECAS’ standard lease agreement excludes PMAs, and therefore he expects that the lease terms will control the use of PMAs. He explained that the reason for this term is because of a fear that air carriers will not accept a leased aircraft with installed PMAs. Several operators in the audience suggested that their only impediment to accepting PMAs is the anti-PMA lease terms. David Linebaugh of Delta, who was also part of the same panel, suggested that this is a chicken-and-the-egg situation, in which operators and lessors blame one another for erecting walls against PMA when they really all just need to get out of the way of progress.
The audience asked Peralta whether GECAS would accept use of PMAs during the term of the lease if those PMA parts were removed and replaced in pars manufacture under a production certificate (“OEM” parts). Peralta explained “I don’t know what you do with the the aircraft during the lease term,” and expressed that his concern was only with the condition of the aircraft at the time of return. He added that he would expect the lessee to take responsibility for such PMA part failures. Mike Garcia of HEICO, who was also part of the panel, explained that HEICO offers a generous warranty to support its parts (so operator liability should not be an issue); but he also noted that HEICO has never experienced an airworthiness directive or service bulletin on any of its articles.
FAA Deputy Associate Administrator John Hickey was also on hand as part of the same panel. He noted that the FAA has issued a very small number of airworthiness directives against PMA parts, but that the FAA issues “two hundred, three hundred, even four hundred ADs per year” against PC holders products and articles. He noted that the PMA community has an excellent safety record, and that the FAA has rigorous design approval and production approval processes intended to ensure that FAA approved designs – and the parts created under them – remain compliant with the FAA’s regulatory safety standards.
MARPA is extremely pleased to announce that Jason Mahoney Director of Engineering & Maintenance – TUI Group will serve as the Keynote speaker for the 2016 MARPA PMA Aircraft Parts Conference from May 23-24, 2016 in Madrid, Spain at the NH Madrid Ventas.
Jason Mahoney was appointed Director of Engineering and Maintenance of TUI Group in 2014, charged with uniting the group’s five independent engineering and maintenance establishments – to create one pan-European organisation.
Previously, Jason was Director of Engineering for Thomson Airways having joined the business in 2011. Prior to joining TUI, Jason worked for bmi and British Airways, having joined BA as an engineering apprentice in 1989.
TUI Group is the world’s number one tourism business. The broad portfolio gathered under the TUI Group umbrella consists of strong tour operators, 1,800 travel agencies and leading online portals, six total airlines with a fleet of more than 130 aircraft, over 300 hotels with 210,000 beds, 13 cruise liners and countless incoming agencies in all major holiday destinations around the globe. This integrated offering will enables TUI Group to provide their 30 million customers with an unmatched holiday experience in 180 regions around the world. A key feature of their corporate culture is global responsibility for economic, environmental and social sustainability. This is reflected in more than 20 years of commitment to sustainable tourism.
MARPA wishes to extend its sincere thanks to our partners at the International Trade Administration for their ongoing support in partnering with our organization to encourage MARPA and FAA-PMA aircraft parts-focused events and trade missions, and for working to promote PMA worldwide. The 2016 MARPA PMA Parts Conference provides an excellent opportunity for our members to meet and network with their international 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 Madrid networking with the air carriers of not only Europe but also the Middle East and Asia.
We look forward to seeing everyone in Madrid!
Several draft FAA Advisory Circulars are currently open for comment of which MARPA members should take note.
Today the FAA’s Engine and Propeller Directorate released draft AC 33.15-3 Parts Manufacturer Approval (PMA) Metallic Part Material Compliance Using Comparative Test and Analysis Method for Turbine Engines or Auxiliary Power Units. This AC is intended to provide guidance to assist PMA applicants in developing tests to demonstrate the equivalence of materials with that of the type design materials.
We will provide a more detailed analysis of this draft AC in the coming days, but want to encourage each of our members to review it and submit comments to the FAA addressing any potential problems you identify–or offering praise if you feel it is a useful document. MARPA will be offering its own comments, so if you do not wish to file on your own, please feel free to provide us with your thoughts and we will incorporate them into the association’s comments. These comments are due to the FAA by July 20.
Two other draft ACs are also open for comment and bear review. The first is AC 39-xx Alternative Methods of Compliance. This AC is intended to provide guidance to those applicants seeking approval of an AMOC. This guidance formerly appeared in FAA Order 8110.103A but has since been removed to a stand-alone AC. Comments are due May 30.
The other is AC 23.10 FAA Accepted Means of Compliance Process for 14 CFR Part 23. This AC provides guidance on how to submit applicant proposed means of compliance to the FAA for acceptance by the Administrator in accordance with proposed § 23.10 (which is one section of the current Part 23 proposed rule revision). Comments are due May 13.
Each of these proposed Advisory Circulars should be reviewed for potential effects on the PMA industry. MARPA will be undertaking its own reviews, but we encourage each of our members to do the same, and file such comments as they believe helpful. All draft materials and FAA contact information can be found at https://www.faa.gov/aircraft/draft_docs/ac/.
If you would like us to incorporate your comments, you should email them to VP of Government and Industry Affairs Ryan Aggergaard at email@example.com
Today, Congress published proposed legislation (known as the AIRR Act) to reauthorize the FAA. The biggest headline in that bill is air traffic control privatization. But there is plenty in this bill that could affect the PMA industry.
Typically, FAA Reauthorization Bills affect higher-level elements of the law and the FAA is more likely to directly affect PMA Manufacturers; but the AIRR Act has a large number of elements that could affect the PMA community:
Sec. 302. Safety Oversight and Certification Advisory Committee. Congress is establishing an advisory committee that will be responsible for advising the Secretary of Transportation on policy-level issues related to FAA safety certification and oversight programs and activities.
Sec. 311. Aircraft certification performance objectives and metrics. The FAA shall establish metrics for progress toward increasing certification efficiency, increasing accountability, “achieving full utilization of FAA delegation and designation authorities,” implementing risk management and systems safety principles, increasing transparency, training personnel in auditing systems and maintaining the leadership of the United States in international aviation and aerospace. All of these foci could be good for the PMA community.
Sec. 312. Organization designation authorizations. Establishes a new provision in the US Code for ODAs. ODAs shall have a procedures manual, shall be entitled to full delegation of functions approved in the manual, but shall be subject to regular FAA inspection. ODA holders shall cooperate fully with the FAA oversight activities. FAA shall establish an ODA Office to coordinate ODA policy and oversight.
Sec. 314. Type certification resolution process. Requires FAA to set policies and timelines for resolving type certification issues, and for elevating them when they cannot be resolved at the lower levels of the FAA. [*** It would be nice to see this provision expanded to all design approvals, including PMAs ***]
Sec. 315. Safety enhancing equipment and systems for small general aviation
airplanes. Requires FAA to streamline the installation of safety enhancing equipment and systems for small general aviation airplanes in a manner that reduces regulatory delays and significantly improves safety. This is something that the FAA has been working on already so they should be prepared to meet Congressional deadlines.
Sec. 317. Additional certification resources. If the FAA needs to travel to a foreign country to help expedite the process of acceptance or validation of a US certificate, then the US applicant can reimburse the FAA for travel expenses (which makes it easier for the FAA to contribute to such efforts). The FAA will have to keep metrics on this, including how often requests from US applicants to enter into such an arrangement were denied.
Sec. 351. Promotion of United States aerospace standards, products, and services abroad. This section gives the FAA promotion responsibilities, which were taken out of the law a number of years ago. This limited promotion authorization is focused on international promotion, like promoting United States aerospace safety standards abroad, and facilitating and vigorously defending approvals of United States aerospace products and services abroad. It will also reiterate our commitment to working with bilateral partners.
Sec. 352. Bilateral exchanges of safety oversight responsibilities. Includes a requirement for the FAA to accept foreign airworthiness directives (ADs) issued by bilateral partners. This could impose an unworkable burden on smaller US companies to track foreign AD proposals, because it will mean that the US companies will have to comment on the foreign AD, because it will have no reasonable opportunity to comment on a US version if the FAA is required to accept foreign ADs. Because ADs can sometimes be worded to exclude PMA alternatives, it is important that the PMA community have some redress with respect to proposed ADs.
Sec. 353. FAA leadership abroad. This will require the FAA to better support US companies in foreign acceptance or validation projects. one clear element of this will be through increased US engagement with foreign authorities.
Sec. 615. Air transportation of lithium cells and batteries. The government will establish a committee, and try to make sure that people actually comply with lithium battery shipping requirements.
Reauthorization is often a slow process, but the last reauthorization bill was a six month extension that went into effect October 1, 2015. That means that the new reauthorization bill is needed by April 1, 2016. It is possible that this ATC privatization may be contentious (General Aviation groups contend that it is an effort to shift the expense of maintaining the system into their pockets) and that could slow down the progress of the AIRR Act. If the AIRR Act cannot be passed by April then we could see another temporary reauthorization (e.g. for another six months). But it is possible that the AIRR Act could move on a fast track, and become law, later this Spring.
MARPA is in Singapore this week for MRO Asia-Pacific promoting all things PMA. The first day of the MRO conference agenda dedicated substantial discussion (as they usually do) to market forecast and trends. Some of these trends could be an opportunity for PMA manufacturers, but others could mean significant challenges down the road if companies are unable to adapt.
The opening session presented a discussion of trends in supply chain logistics. One of the largest takeaways was the change in inventory management practices, especially in the Asia Pacific region, from a just-in-case model, to a just-in-time (JIT) model. This follows the trend in many other industries, including manufacturing and retail, which enable businesses to reduce costs by carrying less inventory.
PMA manufacturers are in an excellent position to benefit those customers shifting to a JIT model because PMA parts can help customers defray the costs associated with warehousing and inventory management, which is outside of the customers’ core competency. This applies to both operators and MRO facilities. This is because PMAers have the parts on the shelf ready to go, eliminating the need for users to maintain parts inventories themselves to ensure availability.
But the shift to a JIT model also presents certain challenges in Asia Pacific, particularly for AOG situations or other scenarios demanding quick turn times. In certain markets with well-established MRO markets, like Japan and Singapore, getting parts to the customer is often a fairly straight-forward exercise and can be done overnight from the United States. However, in less-developed markets and countries in the region, import and customs requirements can pose significant barriers, meaning delays of several days in clearing the shipment and getting the part to the customer. Those companies able to most efficiently navigate those challenges will be at a competitive advantage.
Another trend in Asia Pacific is the MRO spend focused on the narrow body fleet–namely the 737 and A320 families. The narrow bodies currently account for approximately 70% of the MRO spend in the region (and are the two largest fleets by type). This trend should continue over the next decade for two reasons: (1) a significant number of these aircraft have been delivered over the last decade (and continue to be delivered); and (2) the commonalities that exist between the current gen aircraft and the Max and neo versions of the aircraft.
Finally, an emerging trend that should be of great concern to PMA manufacturers is the shift by component and airframe OEMs toward power-by-the-hour agreements. The PMA industry has already seen the problems that are caused when OEMs use PbH agreements as engine OEMs have taken significant steps to lock up the engine spares market. Although the percentage of PbH agreements in component and airframe is still small, it is growing. PMA manufacturers need to get out in front of this trend and remind their customers that they are a) not obliged to sign such agreements and b) demonstrate the value of PMA in terms of cost, reliability, and customer service offered by PMA. It can also benefit smaller PMA companies to form partnerships with other manufacturers of complimentary product lines to offer greater benefits to customers.
MARPA will work to stay on top of these trends. We welcome any information or questions our members have that can help MARPA continue to craft its strategy.
Last week, MARPA participated at the Tokyo Aerospace Symposium 2015 in Japan. The event drew operators, part manufacturers, equipment and tooling manufacturers, and technology companies, among others, to the Tokyo Big Site convention center to discuss current and emerging manufacturing and regulatory issues, as well as display exhibitor capabilities on the trade floor.
Jason Dickstein and Ryan Aggergaard from MARPA, joined by Akira “Jay” Kato, advisor to the Tokyo Metropolitan Government Aviation Industry Participation Support Project and President of JK Tech Consulting Inc., gave a panel presentation discussing PMA and MRO business trends and discussed ways manufacturers can partner with U.S. PMA companies to develop synergistic relationships that can benefit both U.S. and Japanese companies. Many of the manufacturing companies in attendance expressed an interest in seeking out U.S.-based manufacturing partners to develop a supplier or other type of business relationship, and some stated that they had already developed supplier relationships with U.S. PMA manufacturers.
The Tokyo Aerospace Symposium drew nearly 9,000 registered attendees over the course of the three-day event, with most of those attendees participating on multiple days. The MARPA booth saw significant traffic, and we took the opportunity to speak to as many attendees as possible, explain who we are and what we do, as well as the benefits of U.S. FAA-PMA, and discuss the businesses of our members. Several attendees asked for more information about the particulars of our members’ businesses in hopes of developing relationships.
MARPA hopes that our members will be able to participate with us–or provide us with promotional materials–in future years in Japan, because there is strong interest from the Japanese manufacturing community in developing U.S. relationships. As we explained in our panel presentation, the opportunities provided by partnering with high-quality manufacturers that are able to offer product lines that complement your current offerings can greatly expand your business opportunities, because customers often prefer suppliers that can meet as many of their needs as possible all in one place.
MARPA also took advantage of its presence in Japan to meet with a number of air carriers to promote the values and benefits of PMA. We were happy to find these operators are already familiar with PMA and use PMA in their fleets. However, as with all carriers, there is still significant room for growth. MARPA took the opportunity to explain how PMA parts provide great value and savings by solving reliability issues, quality issues, and sourcing issues, as well as offering the obvious benefit of reduced cost off the shelf.
The positive reception toward our discussion of PMA leads MARPA to believe there is still a lot of opportunity for sales expansion in the Japanese market.
There will be several representatives from Japanese carriers and suppliers at the MARPA Annual Conference in Las Vegas next week (October 28-29). The conference will be a great opportunity to network with existing and future customers as well as discuss potential relationships with Japanese suppliers. We look forward to seeing new business connections made!