Sunday, February 1, 2004
Air France Industries Moves Toulouse
Late last November, Air France Industries began the process of transferring its Toulouse, France maintenance facilities from the old location in Montaudran to a more modern one in Blagnac, finishing the move by the end of the year. A $48-million investment, the new facility covers 290,000 square feet. It is a neighbor of the new building that Airbus has built for the giant A380 at Toulouse Airport. Air France’s maintenance, repair and overhaul subsidiary broke ground on the new site in August 2002.
Operations in Blagnac started in early December. The first aircraft to be serviced there–with a D check–was a Boeing 737 that Air France is phasing out. In mid-November, 10 Air France Industries employees left Montaudran as “scouts” in Blagnac, spokeswoman Anne Leroy-Sanguinetti told Aviation Maintenance. Late in the same month, another 15 persons joined them to prepare the new site. Their first job there was to install Boeing 737 equipment and tools.
The rest of the employees moved progressively in December. The total number of employees Air France Industries has in Toulouse is 603. Out of these, 200 stayed in Montaudran until the end of the year. The last work to be done there was a D check on a MyTravel Airbus A320, and the people who worked on that switched off the lights and closed the door behind them. “It is noteworthy that we will end Montaudran’s life and begin Blagnac’s operations with different aircraft types, in order not to disperse teams, equipment, and tooling,” Leroy-Sanguinetti emphasized.
The new hangar has six aircraft bays. Two configurations are possible. In the first one, Air France Industries personnel can service six narrowbody airliners, four for heavy maintenance and two for light maintenance. In the second configuration, the facility can accommodate three narrowbodies for heavy maintenance and one widebody for light maintenance. In the new hangar, light or heavy maintenance can be accompanied, including cabin refurbishing activities.
Compared to the existing facilities in Montaudran, one might think the only improvement is the widebody bay. But Air France bets on much-improved efficiency. Facility layout and outfitting will be more modern and better organised. The old facility inherited 50 years of history, which does not always allow optimizing the layout of the workshops. An important advantage will be to have one single hangar instead of several that were relatively far from one another, Leroy-Sanguinetti said. As a result, the turn-time for an A320 D check, including paint, should be shorter than 28 days, the record at Air France Industries.
The new site will be certified under the ISO 14001 environmental standard. “And it will also feature an audacious architecture, with a 2,000-ton, wave-shaped, metallic roof and sheds to provide light,” Leroy-Sanguinetti added. Another significant benefit of moving from Montaudran’s small airfield is eliminating ferry flights. Being based at Toulouse Blagnac airport–a major airport in France–should be more convenient and thus more attractive for AFI customers.
By leaving Montaudran, AFI precipitated the closing of a historic airfield. It was bought by aircraft manufacturer Lat�co�re in 1917, before becoming the base of operations for the A�ropostale, the airline Antoine de Saint Exup�ry flew for. As soon as Air France was founded in 1933, it established its maintenance centre in Montaudran.
Boeing and Air France Industries Offer 777 Component Service
Boeing and Air France Industries (AFI) are jointly offering a new component service program for the Boeing 777. The aircraft manufacturer and the maintenance subsidiary of the French carrier say their customers will benefit from a reduced inventory, easier spare equipment management, and up-to-date components. The 777 Component Service Program is available at a per-flight-hour rate for dispatch-critical line replaceable units (LRUs).
Typically airlines sign up for 300 to 500 pieces of equipment per aircraft. Boeing and AFI help the airline avoid holding an inventory of high-value LRUs, such as avionics boxes and precision mechanical assemblies. They guarantee the customer that components will be provided on time with a replacement LRU if one is faulty. Boeing and AFI do this thanks to a pool of LRUs they jointly manage. Optional services include training, technical support, and on-site inventory at the customer’s base. In the latter instance, the provider still retains ownership of the components. Air Austral is the first 777 operator to sign up for the service.
AFI and Boeing currently manage $70 million worth of LRUs for 12 customer aircraft and 25 Air France aircraft. “We hope to reach a total of 60 aircraft in three years,” said Bruno Delile, AFI’s director for hardware and services. Savings from the program can be as much as 30 percent of an airline’s component repair and inventory cost.
Delile emphasized that the partnership between the aircraft manufacturer and a big 777 operator brings several features. “We combine the knowledge of the manufacturer and our operational experience; in addition, our logistical organizations nicely fit,” he said. Of course, the customer has a single point of contact, either Boeing or AFI.
How does a component travel to its destination? It begins at Air France’s logistical hub at Paris Charles-de-Gaulle Airport. “The customer can ask us for its own delivery schedule; we can, for example, ship the component within 24 hours or even ensure, depending on the customer’s location, a delivery within a few hours,” Delile said. Quick deliveries are possible thanks to the Skyteam alliance of airlines, of which Air France is a founding member. But components sometimes fly on competing airlines, Delile acknowledged. Customers can track the shipment on a dedicated website.
When the customer sends back the faulty unit, Boeing or AFI will then restore it to airworthy condition, upgrade it to reflect the latest design changes, and return it to the exchange inventory pool. Customers can therefore be sure that they always have up-to-date components that integrate recent improvements or corrections. This should help Boeing and AFI salesmen convince 777 operators to sign up, especially in North America and Asia. “In these regions, airlines are not used to having a common pool of parts and are quite reluctant to mix their own inventory with others,” Delile said. He added that he has to prove to potential customers that they can keep fleet standards and airworthiness under their control. In Europe, airlines often use such schemes.
�Boeing and Air France have jointly invested “between $6.8 to $8.5 million in the existing hub for the new program,” Delile said. The hub will soon be accompanied by a new test operation. In 2004, a facility dedicated to equipment repair will open in Villeneuve-le-Roi, near Paris. An $85-million investment, it will mainly consist of component test benches and employ 850 people.
Despite FAA Rules, Repair Stations Can’t Get ICAs from Some OEMs
Who decides which aeronautical repair stations are entitled to ICAs (Instructions for Continued Airworthiness; also known as ICAWs): the Federal Aviation Administration or aircraft manufacturers (OEMs)?
Legally, it’s the FAA. But based on what’s been happening in the real world, it’s the OEMs that are calling the shots. The result is that repair stations say that they aren’t getting all the ICAs they need, even though the FAA requires them to have the latest technical manuals on hand.
The Rules:Under FAA regulation 14CFR 21.50(b), “the holder of a design approval ... shall furnish at least one set of completed Instructions for Continued Airworthiness to the owner of each type of aircraft, aircraft engine, or propeller upon its delivery ... and thereafter make those instructions available to any other person required by this chapter to comply with any of the terms of these instructions.”
This seems clear enough. Yet, according to Dr. Michael Romanowski, the Aerospace Industries Association’s (AIA) assistant vice president of civil aviation, “There is an open debate on what is meant by the term Instructions for Continued Airworthiness. Another question that remains is whether all FAA-certificated repair stations are included by the phrase ‘any other person.’”
�The first question may be open to debate, as Romanowski said. But the second issue was resolved in a letter written by FAA deputy chief counsel James W. Whitlow on December 13, 1999. (This letter was authenticated by FAA spokesperson Les Dorr. “I gave a copy of the 1999 letter to James [Whitlow] when you originally inquired,” Dorr replied to this reporter by e-mail. “He didn’t question its authenticity, so it must be legit.”)
The letter stated: “FAA-certificated repair stations are ‘other persons’ required by [Chapter I of Title 14 of the CFR] to comply with any of the terms of the instructions,” Whitlow wrote to Ronald Mrozek, counsel for GE Engine Services. GEES was in a dispute with British Aerospace (BAe) at the time because BAe refused to supply ICAs to GE Accessory Services—Grand Prairie for the BAe-146. Added Whitlow’s letter, “BAe’s apparent refusal [to provide ICAs] is puzzling, at best, and, at worst, is an artificial obstacle to ensuring that each BAe-146 airplane is maintained in an airworthy condition.”
Given the 1999 FAA legal opinion above–and the fact that Whitlow is still the FAA’s deputy chief counsel–one would expect OEMs and their agents to supply ICAs to repair stations without question.
This isn’t the case. In fact, the Aeronautical Repair Station Association (ARSA) recently filed a formal complaint with the FAA against Airbus for withholding ICAs. The complaint alleges that Liebherr Aerospace Lindenberg, one of Airbus’s component suppliers, refused to sell ICAs to two repair stations in 2003: Aerotron AirPower and Texas Pneumatic Systems (TPS).
According to ARSA’s complaint, Leibherr’s Erika Matern told Aerotron that “[Liebherr] does not sell such documentation to repair stations. We only deliver to the aircraft operators. Therefore we are not in a position to supply the requested technical information.” Aerotron then contacted Airbus to request the ICA, but received no response. Still, it did better than TPS, which wrote to both companies requesting the same ICAs, and neither responded.
In both cases, ARSA charges that Airbus and Liebherr (which acted on Airbus’s authority in this matter) are violating 21.50(b). “The FAA regulations say that OEMs must make this information available to us,” said ARSA executive director Sarah MacLeod. “We have filed this formal complaint in an effort to compel the FAA to enforce this rule.”
�David Venz, Airbus North America’s vice president of external communications, said he had yet to see ARSA’s complaint, although he had read the press release that accompanied it. Asked about the merits of ARSA’s case, Venz said the charges “were simply not true. We provide complete ICAs to our airline clients. If they farm out their maintenance work to a third party, then they can provide them with the appropriate literature.”
As for the argument that Airbus must supply its ICAs directly to all ‘any other person,’ as stipulated by 21.50(b)? Venz replied that Airbus’s ICAs contain “some level of proprietary information. We don’t want to get into the business of freely giving that information out.”
This argument doesn’t wash with Jason Dickstein, a Washington, D.C.-based lawyer who has represented both OEMs and MROs before Congress and is also president of the Washington Aviation Group. “The FAA’s regulations require all ICAs to be made public,” Dickstein explained. “Anything you put into an ICA is, by definition, no longer proprietary.”
Continuing his defense of Airbus’s position, Venz noted that “the companies named in ARSA’s press release [Aerotron and TPS] don’t do any work on Airbus equipment. Which begs the question: why do they want the manuals if they don’t do Airbus work?”
The logical answer is that Aerotron and TPS want to work on Airbus equipment, but can’t without the ICAs. By withholding them, Airbus has made sure that this can’t happen.
So why is Airbus–and other OEMs, according to James Whitlow’s 1999 letter–doing this in apparent violation of 21.50(b)? “The OEMs have realized that they can no longer rely on new plane sales as their primary source of income,” replied R.C. Cannady, Aerotron’s chairman. “As a result, they are going after the service and support sector.
“The trouble is that independent repair stations, by virtue of their smaller size, can run meaner and leaner than the OEMs,” Cannady said. “Only by refusing to release ICAs to us, and reserving this information for themselves, can they hope to gain dominance in the service and support market.” He added that Aerotron is seeking Airbus ICAs because his company’s airline clients “have urged us to offer them a capability that would compete with Airbus OEMs.”
This begs a big question: If ARSA’s interpretation of 21.50(b) is correct, then why hasn’t the FAA followed its own counsel Whitlow’s advice and cracked down on OEMs? The reason is that “the FAA is not enforcing its own rules,” said Cannady. “They are not even enforcing what their own legal department tells them to do.”
Jason Dickstein agreed. “The chief counsel’s office has the right to issue opinions on the FAA’s regulations, but not the power to enforce the law,” he told Aviation Maintenance. “The OEMs know this. This is why the only way repair stations can force OEMs to comply with 21.50(b) is by taking them to court. Only the largest MROs can afford this, but since they’re the ones the OEMs would rather do business with, these MROs don’t have trouble getting ICAs anyway.”
Not unexpectedly, the Aerospace Industries Association has a different take on the withholding-of-ICAs issue.
The AIA’s core argument is that “repair procedures may not be part of the Instructions for Continued Airworthiness,” Romanowski told Aviation Maintenance. In fact, in the AIA’s view, there is no “may” about it: all that OEMs are obligated to release under 21.50(b) is enough information to ensure “that aircraft are in a safe condition to fly,” he said. By the AIA’s definition, this means how to inspect parts, evaluate their condition, and remove and replace them with new ones. As for providing data for fixing used components? “What you do with the old component after you take it off the aircraft is a business decision,” Romanowski said. “As a result, there is no 21.50(b) obligation to provide information about it.”
But is this true? It is longstanding industry practice for MROs to repair failed components where possible, as part of their FAA-certificated status. As a result, some argue that under 21.50(b) all such data should be released to them.�
In rebuttal, Romanowski said that repair stations often develop their own FAA-approved procedures independent of OEMs and market these procedures competitively. In doing so, these repair stations “are under no obligation to share this proprietary information with others,” he noted.
Beyond these reasons, OEMs want to ensure that repair stations are qualified to work on their equipment, Romanowski said. This is why OEMs withhold certain ICA information until the repair stations have proven themselves capable. “Manufacturers take an active and important role in the safety oversight of facilities that work to procedures they provide,” he said. “This extends beyond any regulatory requirements.”
Dickstein doesn’t buy Romanowksi’s arguments about ICA repair procedures not being covered by 21.50(b). “There is case law out there that says when the manufacturer publishes ICAs, that is the acceptable method, technique, and practice, and barring unusual circumstances, the FAA won’t authorize something alternate,” Dickstein said. “If you take the case law into account, repair stations are companies that are required to comply with the manufacturers’ manuals and if they don’t, case law says that they can be subject to civil penalties under other FAA regulations.”
As for OEMs wanting to ensure that FAA-certificated repair stations are up to the task of maintaining equipment properly? Although this motive is commendable, one would think that this task properly belongs to the regulator–namely the FAA–rather than the regulated. If OEMs have concerns about the competency of FAA-certificated repair stations, they should be raising this issue with the FAA, rather than trying to play policeman.
The real issue here is money, and how to make it. In this case, the OEMs believe that by withholding repair-related ICA information, they can gain a competitive edge on repair stations. The repair stations agree, which is why they want all ICA-related data made available to them.
As for legalities, FAA spokesperson Dorr refused to say who is covered by 21.50(b), even thought the FAA’s deputy chief counsel is on the record as clearly agreeing with the repair stations. The most Dorr would offer is the following faxed statement: “The FAA declined to comment, citing the pending complaint from ARSA.”