MARPA Conference Federal Aviation 2016 Aviation MARPA Conference ... •BS and MS from Penn State...

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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



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



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



Oct 2016

PMAs by Type and Product



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



Oct 2016

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



Oct 2016

Alas,

a parting gift

• Intended uses:

– Fond remembrance

– Artful expressions

– Dartboard target



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



Oct 2016

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



Oct 2016

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



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



Oct 2016

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



Oct 2016

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



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: [email protected]



Oct 2016

MARPA Conference Federal Aviation 2016 Aviation MARPA Conference ... •BS and MS from Penn State...

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