Manufacturing Environment has changed
The U.S. manufacturing environment has changed in several respects that are not reflected in current regulations. When these regulations were established, a relatively small number of companies manufactured either the complete aircraft, aircraft engines and propellers, or just propellers under a type certificate and production certificate. These manufacturers typically licensed and oversaw the manufacturing of replacement parts for their products. The environment has greatly changed, particularly in the production of replacement parts. Also, the U.S. aircraft fleet is aging, and many companies that originally manufactured the complete aircraft, aircraft engine or propeller, and that oversaw replacement part manufacturing have gone out of business. Thus, the manufacture of replacement parts is a major business and competition is increasing.
In addition, aircraft production and parts production are increasingly global, whether the manufacturer is foreign or in the United States. Often manufacturing is under the control of a consortium of U.S. and foreign manufacturers. Based on the old way of doing business, a few major U.S. TC/PC holders, PMA holders, STC holders, and TSOA holders constituted the industry. With airline deregulation and globalization, major changes have and are still taking place in the aviation community. These changes have significantly increased competition among airlines which have in turn passed their competitive pressures on to their suppliers.
The airlines' demand for lower costs has resulted in a surge of PMA and STC activity as additional manufacturers have competitively entered the replacement parts market. This activity has already provided individual airlines with millions of dollars in annual savings on the purchase of new replacement parts. An increase in product liability costs and other factors has resulted in more aircraft that are out of production, are not supported by the original TC/PC holder, and are depending on the PMA process for replacement parts.
In addition, the perception of the airworthiness of replacement parts by elements of the aviation industry is that products or parts produced under an FAA production certificate are more reliable than parts produced under some other FAA form of approval. Some elements of the aviation industry lack confidence that PMA parts meet the appropriate airworthiness requirements.
While, in reality, the same standards of airworthiness exist for all FAA production approvals. This perception persists among foreign buyers and puts manufacturers who do not have a production certificate at a competitive disadvantage.
To the extent that this perception is based on administrative differences, standardizing the system so that all parts manufacturers will have separate design and production approvals could help to eliminate any perceived inequality among either design or production approvals.
The above reasons, in addition to others, are being considered in the review of Part 21. The committees' eventual set of change proposals are expected to provide a greater credibility to the PMA and STC process, assure a continuation of the excellent safety of flight record of replacement parts and articles, and simplify all certification procedures. There has been significant interest among those in the general aviation sector over the impact of these new draft proposals to change Part 21. All interested parties are encouraged to get involved with the ARAC process and continue to make input.
Participation in the process is one way to have your voice heard. When the NPRM is available through the Federal Register, take time to read and study the proposed changes to Part 21 and submit your written comments per the instructions in the NPRM.
You need to determine if the proposed changes to Part 21 are needed to assure a safe growth of the competitive replacement parts segment of the aviation industry.
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OEM-licensed PMA parts represents one way that the customers can get parts produced by PMA holders while still ensuring that the parts are produced to the FAA-approved OEM (Boeing) design standards.