Post on 01-May-2018
Presented to:
By:
Date:
Federal Aviation Administration
MARPA Conference
2016
FAA PMA Update
Robert Sprayberry and Ian Lucas
Oct. 27, 2016
Conference Attendees
2 Federal Aviation Administration
MARPA Conf. 2016 – PMA Update
Oct 2016
Topics
• Why do we support PMA?
• PMA Metrics
• Passing the Torch
• PMA Policy Updates
– Re-use of data
– Minor mods and PMA
– Additive Manufacturing
• Future Initiatives
3 Federal Aviation Administration
MARPA Conf. 2016 – PMA Update
Oct 2016
Why does the FAA support PMA?
• Confidence in FAA PMA
– Long history of safe approvals dating back to the
early 1970’s
– Often fills a need within the industry for timely and
airworthy replacement articles
• Many PMAs are on articles no longer produced or
supported by the OEMs
• Over 60% of all PMAs are Licensing Agreements
– Robust and mature process
• Studied and vetted on multiple occasions since the 1980’s
• Order 8110.42 originally released in 1995
• Operational safety tracking supports our position
4 Federal Aviation Administration
MARPA Conf. 2016 – PMA Update
Oct 2016
Why does the FAA support PMA?
• International Acceptance
– What do the International Agreements say?
• Nearly ALL foreign CAAs accept FAA-PMA without further
showings or validation
• Many international manufacturers support and supply US
TC holders with Licensing Agreement PMAs
– Several bilateral partners are now working towards
implementing their own versions of PMA regulations
and guidance materials
6 Federal Aviation Administration
MARPA Conf. 2016 – PMA Update
Oct 2016
PMAs Issued Over Time Test and
Comp
2008 16049
2009 26189
2010 25786
2011 43564
2012 53197
2013 26783
2014 18490
2015 26570
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MARPA Conf. 2016 – PMA Update
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Passing the torch • As of October 2, 2016 Mr. Ian Lucas has
assumed the FAA role as the PMA National
Policy focal.
– He is your new “target” now so feel free to lob all
your questions and comments his way
• I am still with the FAA and have moved over
into a new position within our International
Office (AIR-400)
– I have not left the PMA party totally and will help
ensure as smooth a transition as possible
– My new role will allow me to work on international
policy effecting all areas of aviation including PMA
8 Federal Aviation Administration
MARPA Conf. 2016 – PMA Update
Oct 2016
Alas,
a parting gift
• Intended uses:
– Fond remembrance
– Artful expressions
– Dartboard target
9 Federal Aviation Administration
MARPA Conf. 2016 – PMA Update
Oct 2016
Who is Ian Lucas?
• BS and MS from Penn State University in
Engineering Science and Mechanics
• 5 Years as Civilian with US Army, Aviation
Engineering Directorate
– Structural Engr. on Apache and Blackhawk platforms
• 4 Years in Boston ACO as Structural ASE
– Certification, COS, Validation, 3 OMTs (TC, STC, PMA)
• Joined AIR-111 in April 2016
– PMA and Commercial Parts Focal
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MARPA Conf. 2016 – PMA Update
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Re-use of Data
• Memo AIR100-16-110-PM03
– Signed on 4-22-2016
– Reminder to use of discretionary function when
reviewing new PMA applications that utilize data
from existing PMAs
– Does not allow “PMA transfer”
– Assumes a new and complete application
• Amount of “re-review” is a function of the new applicant’s
competence and standing within the ACO
– Previous PMAs are still approved and legal for sale
and installation per FAA regulations
11 Federal Aviation Administration
MARPA Conf. 2016 – PMA Update
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Re-use of Data, Cont’d
• Changes in Licensing Agreement status
– A change in status is allowed and continued sales
are allowed within the regs, until minor changes
occur and need approval
– Identicality with licensing to Identicality w/o
• A major change per 14CFR 21.319 but it’s still identical and
therefore the previously approved data is directly applicable
to the new application
• No minor Changes
– Identicality to Test and Comp
• A major change per 14CFR 21.319 that requires full re-
evaluation from the ACO of the data since reverse
engineering data is NOT Identicality data
12 Federal Aviation Administration
MARPA Conf. 2016 – PMA Update
Oct 2016
Minor Mods and PMA • Policy Statement PS-AIR-21-1601
– Signed on Oct. 6th, 2016
– Rev. D of the Order clarified the definition of a
Modification Article as new to the product via a
major or minor change
• Historic precedence has allowed PMAs for mod articles
outside the use of a STC (this is NOT new)
– Onus of utilizing this guidance is on the applicant
• NOT to be used to subvert a STC project
• Will not be reliant on any comparative analysis but rather a
general analysis only
• Will NOT be applicable for most modification articles
• Supplemental ICAs will almost always be required
13 Federal Aviation Administration
MARPA Conf. 2016 – PMA Update
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Additive Manufacturing • Current data shows limited AM application
within the PMA industry
– Changes to the current regulations is not necessary
– Policy is being developed for near term release
• Additional marking requirements are on the table for
anyone desiring to utilize AM technology
– FAA does not desire to limit or infringe on this emerging
market
– FAA is seeking to gain better understanding on trends and
usage
• PMA policy is being developed to align with the AM team’s
policy and regulatory determination once they are
established
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Future Initiatives • 8110.42D Change 1 – FY 2018
– Incorporate Minor Mods/Additive Manufacturing
– Adjust for Air Transformation
– Adjust for Possible Design and Manufacturing Split
– Clarify PMA of TSOA articles
– Add International Considerations
• Special Projects – FY 2017
– Clarify appropriate uses of Special Projects
– A Cert project that is not a TC, STC, amended TC,
amended STC, or PMA project under 14 CFR 21.8d
– Should have viable future use on Article or Product
15 Federal Aviation Administration
MARPA Conf. 2016 – PMA Update
Oct 2016
Contact Info.
Ian Lucas
Aerospace Engineer / PMA Policy
FAA Aircraft Certification Service - L'Enfant
Plaza
Aircraft Certification Service -
Certification Procedures Branch AIR-110
Design Certification Section, AIR-111
T: 202.267.1693
E: ian.lucas@faa.gov