The EPA Parts Mystery

With the PMA parts industry long-established in the USA and flourishing, Europe's equivalent, in the form of European Parts Approval (EPA) parts and bearing the approvals of the European Aviation Safety Agency (EASA) since September 2003, remains a nonentity. In short, there are no suppliers of these parts because there still isn't any industry as such in Europe, and EASA is so exercised over the matter that it has been conducting investigatory studies to explain the shyness of potential users of these parts.

"The strange thing to us is that the PMA parts market is a flourishing one, but there are no EPA parts makers in Europe and we don't understand why," Eric Sivel, continuing airworthiness manager at EASA, told Aviation Maintenance, adding that: "Lufthansa, on the other hand, is one of the largest users of PMA parts and a company like Lufthansa would not be such a strong user if this use was not worthwhile."

The matter has moved forward to some degree since this same response was given by EASA in May 2005 insofar as the Agency canvassed the views of MROs and some airline operators with a less than valuable response: "We've found it very difficult to get objective feedback," continued Eric Sivel, "and whatever the final result we did not want to be accused of being biased. So we opened a tender to an outside consultant. As you know, we have lots of rules in the EU requiring things to be free and open and we are on the verge of choosing the company which will perform the study. This should be completed in the first half of 2006. In the choice of consultants we did not want an OEM nor did we want anyone who had anything to do with the manufacture of parts. We wanted something complete; we didn't want a quick-fix answer. We asked for an analysis of the PMA rules, an analysis of our EPA rules. An analysis of everything, so that we could gain a complete understanding. With this we will take action."

"We may find that the safety rules are totally adequate and that we need to review our rules to make it easier for people to make EPA parts, but we don't yet know. Our study will be published," said Sivel. "It should be complete in mid-2006."

THE INDUSTRY STORY

For many operators and MROs in Europe the situation is less clear-cut and for some the issue is no big deal. Marshall Aerospace, the Cambridge-based MRO, buys and uses PMA parts because of its largely government contracts on Hercules, TriStars, etc., which are American aircraft. This business is growing and the company sources these parts from the USA. But it is virtually unfamiliar with EPA parts should they be available to meet a requirement.

Virgin Atlantic Airways, as much of a user of European aircraft as it is of American, generally uses only OEM items and neither PMA nor EPA parts because these were said to offer little or no advantage. A similar view was expressed by Monarch Aircraft Engineering but with interesting additional comments. One of the oldest private MRO companies in UK aviation, Monarch AE has the unique distinction of beginning life in 1966 and creating a year later an operator, Monarch Airlines, which came to outgrow in size and business importance many times that of its originator.

Phil Hall, director of quality and safety at Monarch Aircraft Engineering, said: "We would generally like to use more PMA/EPA parts because they are often made to a higher standard, but there is little or no industry in Europe at the moment because--and certainly in the UK--their manufacture is pretty well just as expensive as making OEM parts. Where Monarch is concerned there is another matter, for the airline operates a largely leased fleet and the lessors will not agree to the aircraft being returned at the end of a lease period having been fitted with PMA parts, so the use of these is out on leased aircraft." Monarch Airlines currently operates a 27-aircraft fleet of Boeing 767s and Airbuses, half of which are operated on lease.

These comments may begin to throw some light on the attitudes towards the PMA/EPA parts industry in Europe, certainly on the part of operators and lessors, and which may provide EASA with its "complete understanding of the situation." But Lufthansa's attitude is significant, for as in so many areas the German flag carrier is a pace-setter, and set the pace two years ago when it bought a 20 percent stake in US turbine engine components manufacturer Heico Aerospace of Hollywood, Florida.

"PMA parts are important for us in order to have a cost-efficient source for spare parts, especially for engines," said Aage Duenhaupt of Lufthansa Technik, "also, customers ask for them as they are totally reliable and there is a price advantage." These parts are for Lufthansa Technik's own needs, and Heico is the only company in which a stake is held, but that does not mean that there will be no such other investment in the future. "But this is only one side of the story," Duenhaupt said. "We have developed high-tech repair methods for engine parts which are bringing down costs by 30 percent per part, which means that we can offer our customers significant reductions during the shop work load. These improvements have been put under the label of EPAR, for engine parts accessories repair."

So for Lufthansa Technik the matter is straightforward: another supply source is guaranteed, while the parts are totally reliable and there is a price advantage. But these are PMA parts for American engines, and of EPA parts there is no word.

UK engine-maker Rolls-Royce has its own, long-running arrangement for the provision of parts and which has been refined over a period of years and now, it would appear, operates in accordance with EPA rules. The company manufactures 30 percent of its engines and outsources 70 percent of the parts to others. This is separate from the "Risk and Revenue Sharing" partners on engine projects such as Mitsubishi, Kawasaki, Hamilton Sundstrand, Goodrich and ITP of Spain, who are prime players on engines like the new Trent 1000.

All spare parts for Rolls-Royce engines can be obtained directly from the company or from officially-approved vendors. Rolls' definition of which is that a vendor must hold company design and manufacturing approval. A `vendor' therefore, is likely to be a manufacturer as well as a supplier, and a contract to that effect is held between both parties in every case. Martin Johnson, for Rolls-Royce, said the vendors could number several dozen but they are certainly producing Rolls-Royce-approved parts and approved also by the appropriate authorities.

So the EPA parts story rumbles on in Europe with the revelations of the EASA study awaited in mid-year. The development of an industry is awaited after that.