PMA Briefing Moscow February 26, 2015 Agenda PMA legal basis - - PowerPoint PPT Presentation

PMA Briefing

Moscow

February 26, 2015

WENCOR GROUP CONFIDENTIAL

Agenda

• PMA legal basis
• Bi-Lateral Airworthiness Agreement
• PMA Market
• PMA Value Proposition
• Leasing
• Barriers to PMA Use

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Replacement Part Options

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Substantiation Basis

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Bilateral Agreement – Russia/FAA

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• Interstate Aviation Committee Aviation Registry (AR)

and Federal Aviation Authority of Russia (FAAR)Bilateral Airworthiness Agreement signed in 1998

• Each agency considers certifications/findings as valid

without further finding

The AR will accept FAA Airworthiness Approval Tags on parts only when the FAA certifies that each part(s) conforms to AR approved design data Is marked in accordance with approved procedures Meets all additional requirements of the AR, as notified Parts must have an 8130-3 tag referencing document for approved design data

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Who Produces PMA

Source: FAA GRL website

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A “Typical” PMA

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–Over 6,000 PMAs –Systems Supported:

• Air Cycle

Machines

• Airframe
• Auxiliary Power

Units

• CSDs, IDGs

and Generators

• Engines
• Fuel Systems
• Hydraulics
• Cabin Interiors
• Landing Gear
• Pneumatics
• Starters
• Thrust

Reversers

• Other systems

WENCOR PMA – Supported Systems

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WENCOR GROUP CONFIDENTIAL

Airline D Integrated PMA Approach

1285 Wencor Group PMAs

A320: 503 Parts A330: 231 Parts B767: 1049 Parts B777: 577 Parts ERJ170/190: 20 Parts

ATA System Parts

21 Air Conditioning 120 24 Electrical Power 158 25 Equipment & Furnishings 41 27 Flight Controls 39 29 Hydraulic Power 105 30 Ice & Rain Protection 25 32 Landing Gear 60 36 Pneumatic 64 38 Water Waste 20 49 Auxiliary Power Unit 180 72 Engine 90 73 Engine & Fuel Control 103 75 Engine Air 38 78 Exhaust 39 79 Oil 24 80 Starting 104 Star Alliance Carrier – Approximately 170 Aircraft

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50 100 150 200 250 300 350

BEARING, ELEMENT SEAL BUSHING BEARING GEAR RETAINER O-RING RING RING, PISTON WASHER BOLT ROTOR RUBSTRIP GEARSHAFT PLATE LINER SLEEVE GASKET PLUG SHAFT SHROUD SPRING NUT RIVET CLAMP FILTER GEAR SET BRUSH BLOCK PIN COVER INSERT POPPET CABLE ASSEMBLY SEAT

Most Common Wencor PMA Types by Description

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755350 IDG Carrier Shaft

OEM Price PMA Price Savings $ 37,785.55 $ 15,864.80 $ 21,920.75

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Lavatory Filter

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PMA PN: A225400454-204WE : $9.00 OEM PN: A225400454-204 : $22.50 Airbus A330

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Slow Close Toilet Seat

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Typical OEM Toilet Seat price: $500 - $800 PMA “Slow Close” Toilet Seat price: $280 - $450

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Seat Cushions (molded & fabricated)

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Typical OEM Seat Cushions price: $800 - $1,000 Dixie Aerospace Owner Operator Part / PMA Seat Cushions price: $400 - $600

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System Approach

Average material saving on an overhaul - $18k

PMA parts are generally as reliable or more reliable than OEM

• parts. Why?
• 1. PMA developers have the benefit of understanding the OEM’s

shortcomings

• 2. PMA developers often have newer materials, manufacturing

methods and hold tighter tolerances due to the re-engineering process

• 3. Generally PMA developers avoid major problem areas that ADs
• r major service bulletins have been written against

Reliability

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PMA in Fixed Price Maintenance

500 1,000 1,500 2,000 2,500 3,000 3,500 4,000 2010 2011 2012 MTBUR Current Cost Trendline

416 series BE Coffee makers

MTBUR (hours)

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Barriers to PMA

Wencor Group Confidential

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Airline Perspective Airline Perspective

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The Argument for PMA

0% 100%

1990 1994 1998 2002 2006 2010 The Lease Market

Airline Accepting PMA

Belief That PMA Devalues The AC/Engine Upon Lease Return Airline Demand For PMA Overcomes Market Concerns

Airline NOT accepting PMA

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Leasing Companies Allowing PMA

(A Few Examples)

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Part Replacement. Lessee, at its own cost and expense, will promptly replace all Parts which may from time to time become worn out, time-, cycle- or calendar-expired, unserviceable, lost, stolen, destroyed, seized, confiscated, damaged beyond repair or permanently rendered unfit for use for any reason whatsoever (unless not replaced as a result of a Modification permitted under Section 12.7.1 or unless such Part is obsolete and removed in accordance with the Maintenance Program). In the ordinary course of maintenance, service, repair, overhaul or testing, Lessee may remove any Part provided that Lessee replaces such part as promptly as practicable in the ordinary course of Lessee’s business. All replacement Parts will (i) be free and clear of all Liens (except Permitted Liens) of any kind or description, (ii)be in airworthy condition and of at least equivalent model and modification status and have a value and utility at least equal to the Parts replaced, assuming such replaced Parts were in the condition and repair required to be maintained by the terms hereof and (iii)have a current "serviceable tag" of the manufacturer or maintenance facility providing such items to Lessee, indicating that such Parts are new, serviceable or overhauled to the extent that a "serviceable tag" for such Part is required by the Aviation Authority.

Lease Verbiage 1

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Lease Verbiage 2

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Substitution of Parts. Lessee, at its own cost and expense, will promptly replace all Parts that may from time to time be incorporated or installed in or attached to the Airframe or any Engine that may from time to time become worn

• ut, lost, stolen, destroyed, seized,confiscated, damaged beyond repair or

permanently rendered unfit for use for any reason whatsoever. All replacement parts shall be in as good operating condition as the Parts replaced assuming such replaced parts were in the condition and repair required to be maintained by the terms hereof, shall be of comparable make and model or an improved or advanced version thereof approved for installation on the Aircraft, shall have origin (back-to-birth) traceability and valid FAA certification, and shall not impair the airworthiness or diminish the overall value of the Aircraft, and any such replacement Part, upon installation on the Aircraft, shall thereby be

• wned by Lessor and become subject to this Agreement without the necessity
• f further act.

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ARTICLE 12: MAINTENANCE OF AIRCRAFT 12.2 Specific Engine Requirements. 12.2.2 When replacing Parts in an Engine, LESSEE will use original equipment manufacturer parts ("OEM Parts"). If LESSEE wishes to replace Parts in an Engine with parts which are not OEM Parts, LESSEE must obtain approval from LESSOR before such parts are installed. If given, LESSOR's approval will generally be given only for the installation of parts manufactured in accordance with FAR Part 21.303 (or its EASA equivalent) ("PMA Parts") which are consumable parts such as brackets, gaskets and seals. The use of stationary and high energy rotating PMA Parts in the gaspath will not be approved by LESSOR. Any proposed repair to an OEM Part or PMA Part in an Engine which has been approved by an FAA Designated Engineering Representative (DER) (or its EASA equivalent) must also be authorized by LESSOR prior to performance of the repair, such LESSOR authorization not to be unreasonably withheld.

Lease Verbiage 3

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Hurdles to Successful Use of PMA

• Unclear direction
• Lack of data package clarity
• Manpower limitations for review
• Certifying Agency Interactions
• Lack of trust
• Manual updating
• Stocking considerations (traceability)
• Effectivity changes

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OEM Tactics on ICA

• “It is not appropriate for a DAH to place limitations on the use of

its ICA between the owner/operator and the maintenance provider, whether the maintenance provider is rated or not, to perform that maintenance...“

• “..a DAH may not inhibit an owner/operator from distributing ICA

to current or potential future maintenance providers. Therefore, it is not acceptable for a DAH to limit the distribution of ICA through restrictive access or use agreements, or by adding restrictive language that would control the use of ICA by an

• wner/operator with respect to the maintenance of its product.”
• “In addition, while a DAH must identify the applicability of its

ICA, the FAA will not accept restrictive statements or terms in ICA documents, or restrictive access or use agreements that limit the appropriate availability or use of the ICA where the FAA has determined the ICA are acceptable for maintaining a DAH’s product with FAA-approved replacement parts, articles, or materials installed (e.g., Parts Manufacturer Approval (PMA) items).”

Source: FAA Policy Statement, PS-AIR-21.50-01: March 23rd 2012

WENCOR GROUP CONFIDENTIAL

Questions?

Wencor Group Confidential

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