Memorandum of Federal Aviation Understanding – PMA Updates · Presented to: By: Date: Federal...

Presented to:

By:

Date:

Federal AviationAdministrationMemorandum of

Understanding – PMA Updates

An FAA/Industry Workshop

Chris Richards, ANE-112

MARPA Conf. 2016

26 October 2016

Federal AviationAdministration

MARPA Conference26 October 2016 2

Background• Various versions of the concept have been

around for many years• The most current iteration discussed here

was established by the Atlanta ACO in 2005– Focus PMA activities on “everyday” projects– Living document mentality– Regarded as a stepping stone to a PMA ODA

• More companies could use these agreements to increase certification efficiency



PMA MoU goals• Meet FAA safety mission and strategic planning

initiatives• Manage FAA PMA workload• Meet applicant and industry needs• Provide qualified holders with the maximum

authority to initiate, process, show approvable data and test plans, and complete projects

• Top down approach for utilizing Discretionary Authority – Note that this has undergone a significant expansion



What does an MoU Allow?

• Process ConsistencyIncreased Efficiency

• Defined MethodologyLess Guesswork

• May Reduce Turn TimesMore Projects, Fewer Delays



What does an MoU Require?

• TrainingMoU is only effective if people can implement it

• AuditsLess FAA involvement up-front

• Following a Set ProcessWork quickly with less effort



PMA business drivers that impact FAA workload

• Desire for higher market shares• Pressure from Airlines to provide OEM $

alternatives• Thriving MRO opportunities due to aging fleets• Increasing demand of PMAs due to OEM supply

chain issues• Limitations or loss of OEM support for aging

products• Increasing number of STCs which breed more

PMAs



Who does it benefit?• MOUs must be a benefit both parties

– How many projects per month or year would be within the scope of the proposal?

– Past history of projects that would be affected?– Dose applicant and FAA have the necessary positive working

relationship needed to succeed?

• If both parties cannot realize a benefit then the process cannot be utilized– This determination is made by the ACO and should be

communicated to the applicant



How can an MoU help the FAA?• During the initial application and/or kick-off

discussion:– Identify rough number of expected PMA articles that will meet

criteria for the process

– Establish eligibility determination methods up front– Establish material analysis and other testing methods allowed

under the process– Establish applicant experience within the process and technical

aspects– Expectations and ability to self audit



How can an MoU help the Applicant?

• Establish in writing a consistent approach to the PMA process– Specify FAA Designee roles and buy-in– Identify key players within the applicant’s organization

• Minimize the need for designees to supplement the applicant’s knowledge

• Better control of project timeline• Increased systems-level approach to the PMA

– Understand the FAA’s point of view within the process



Getting Started• Pre-evaluation typical guidelines:

– Applicant will submit preliminary MoU (draft)– FAA and applicant will define project types and scope

• Simple to complex articles• MIDO involvement needed

– FAA will work closely with the applicant to understand strengths and weaknesses on both sides

– FAA will review revisions to the draft document– Applicant and the FAA will finalize a “shadow program”

schedule



Getting Started; Cont’d• Post-evaluation typical guidelines:

– After MoU approval, Company will work trial projects under a “Shadow Program”

– Final Draft MoU Approval by ACO, MIDO and Applicant– Company can thereafter work PMA in accordance with

approved MoU– Project(s) status reporting will be required by FAA– FAA will issue notification letters of design approvals and PMA– FAA will conduct audits as needed (different levels per MoU)– Company or FAA can revise MoU as necessary



For Part Suppliers with PMA by Identicality…Increasing problem with TCH no longer supporting a product designCan you make design changes?

VERY limited, if you have PMA by Identicality

So what can you do?

PMA by Test & Computation is an option, but requires you to go through the full PMA process for each article you want to modify.



Shortened Path to a T&C PMA

New FAA policy does provide a smoother path forward, IF:

- You can show that you understand the part and it’s effect on the higher level assembly- The part isn’t critical to flight safety

FAA Policy AIR100-15-150-PM16Guidance for Recognition and Use of Applicant Showings on Standard Certification Projects



Applicant Showing Only (ASO)

Company is still required to show compliance with all applicable regulations

FAA uses discretionary authority to determine what they review

- May do an administrative review and follow up with an audit at a later date



ASO Benefits

Less FAA ‘touch points’ - ACO and DERs don’t need to be directly involved step-by-step through the process- Projects can move at a pace dictated by the company, more than FAA workload

Test and Comp PMA- Holder can make changes as long as regulatory compliance is maintained



ASO RequirementsCompany must still show compliance to all applicable regulations.

- Showing of compliance (testing, analysis, reports, etc.) may be periodically audited by the FAA- Supports FAA’s goal of transitioning to an ‘oversight organization’

ACO needs to be confident you can find compliance without their direct involvement.



What articles fit in the process?• Parts typically not available for increased

autonomy under the MoU process are:– Life limited parts or Critical parts (rotating or static)– Primary propulsion main shaft engine bearings– Single engine aircraft engine parts whose failure

could cause an in-flight shutdown.– Engine gearbox parts whose failure would eliminate

propulsion required for flight– Parts associated with A.D.’s– Parts requiring ICA independent of OEM ICA – Any part whose failure, or whose failure in

combination with one or two other failures, could result in a hazardous or catastrophic event.



Continuing Requirements Under MoU• Service difficulty reporting (no change from any

other design approval). Must satisfy 14 CFR 21.3• The applicant has increased requirements to self-

audit• Suspension/Termination

– MoU’s can be suspended and/or terminated at any time by the FAA

– Suspension/Termination may be due to:• loss of key applicant personnel or a change in FAA

oversight personnel• Violation of agreement requirements and/or PMA policy

– It is a privilege and not a right



Next StepsA company with an established MoU:

- Can expand the scope of the MoU- Can better predict project timelines- Can reduce the overhead associated with FAA certification projects

This MoU can also be a first step towards PMA ODA.

- Optimized balance of workload and oversight between the company and FAA



In Conclusion

• The FAA is here to work with the applicant but not for the applicant.– You must put your best foot forward– You must convince us that we will benefit from an

MoU– You must show us why you deserve this

consideration• Types of articles• # of relevant projects• Positive working history



Your Experiences

• Any suggestions?– Successes– Failures– Stuck in limbo



Questions????

My Contact Information:

Chris RichardsProject Officer – FAA Engine & Propeller DirectorateEmail: [email protected]: (847) 294-7156

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