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Saturday, May 1, 2004

FAA Wants New Rules for Operator Parts Fabrication

- Dale Smith- Dale Smith

Over the years, many questions have come up concerning when the creation of a part by maintenance personnel constitutes fabrication under Part 43 or crosses the line and becomes a part manufactured under stricter Part 21 requirements. To help clear it up, the FAA is proposing a new advisory circular (AC) that establishes a set of guidelines that would allow certificate holders to fabricate parts in accordance with Part 43, and to do so with the same level of safety that applies to parts manufactured under Part 21. The draft AC, provisionally titled AC43-FAB, Fabrication of Aircraft Parts By Maintenance Personnel, was developed by the Aircraft Maintenance Division of the FAA Flight Standards Service and is the result of more than 12 years of effort at the FAA.

The chief requirement of the proposed AC43-FAB is that any fabricated parts or products be airworthy and conform to the type design and be in accordance with safe operation. In order to fabricate parts, a certificate holder will use designs approved under Part 21.305(d). The fabrication must be performed within the privileges and limitations for the FAA certificate holder's ratings, in accordance with private markings and the fabricator must provide instructions for continued airworthiness.

The proposed AC identifies a number of key criteria that a repair station must meet in order to fabricate conforming parts including: required data, fabrication inspection systems, part marking, instructions for continued airworthiness, multiple part fabrication control, and record keeping. Certificate holders must ensure that they have written procedures addressing these criteria and that they are contained in their general maintenance manual, general procedures manual, repair station manual, or similar document.


Superior Joins Ranks of OEMs

On March 31, Superior Air Parts, a manufacturer of PMA parts for piston aircraft engines, officially became an original equipment manufacturer. On that date, the FAA awarded Superior a type certificate for the company's 180-horsepower Vantage Engine.

The new engine is the culmination of a long process that began when Superior first started making parts for Continental and Lycoming engines under FAA parts manufacturer approval regulations in 1967. Over the years, Superior has gained FAA certification of more and more parts that make up Lycoming's 180-horsepower 0-360 engine and the company finally reached the point where it has PMA certified 100-percent of the 0-360's parts. "As we obtained more approvals on various parts," said Superior senior vice president Tim Archer, "it's come up to where it's an engine."

Superior's first whole-engine project was the XP-360, an experimental 180-horsepower engine targeted at the homebuilt aircraft market.

In 1996, Superior executives decided to seek FAA certification of a 180-horsepower Superior engine, which at first glance appears to be a version of the Lycoming 0-360. The Vantage Engine is not a clone of any Lycoming engine, according to Superior, which prefers to call the engine "the next-generation of piston engines." Nevertheless, every part used in the Vantage Engine also will fit on Lycoming 0-360s because all of these parts were originally certificated as PMA replacement parts for the Lycoming engine.

Few new piston engines have received FAA certification during recent years, probably because of the small volume of the new-aircraft market. What makes the Vantage Engine unique is that it is the first FAA-certificated piston engine to receive a type certificate that allows it to run on unleaded automotive gasoline. The engine also is approved to run on the proposed 91/98 avgas, which is not yet being marketed.

The Vantage Engine will be available in many configurations, from carbureted, fixed-pitch propeller to fuel-injected and constant-speed propeller and turbo-normalized. Key features include a dynamically balanced VAR steel crankshaft, computer-optimized camshaft lobe design that delivers better efficiency and smoother operation at idle and higher power settings, crankcase with thrust-face lubrication and reinforced cylinder decks, dynamically balanced connecting rods and pistons, balanced-flow intake system, tri-metal bearings, and 80-percent cruise power setting. TBO is currently 1,000 hours, but Superior expects that to be increased to 2,000 hours by the time production engines ship later this year.

Superior has already applied to the FAA for a production certificate, which is needed for high-volume production of the Vantage Engine. Superior is also seeking supplemental type certificates for Vantage Engine installations in popular airplanes such as the Cessna 172, Piper PA28 Series, and older Mooneys.

"I think the price is going to be fairly competitive," Archer said. "From an outside dimensional and horsepower rating point-of-view, it's virtually plug and play. That will keep the STC costs low."

Superior's new status as an OEM puts it in an odd position, as the manufacturer not only of PMA parts for a competitor's engine, but also as an OEM of a product that may see its own PMA parts. Lycoming, for example, could seek to obtain PMA for parts for Superior's engines.

For its part, Lycoming remains skeptical about Superior's long-term prospects with the Vantage Engine. "While it's always positive when the customer is provided choices," said Michael Wolf, Lycoming Engines president, "only time will tell if Superior can provide the performance, reliability, and support that our market demands. For over 75 years, Lycoming has been the reliable choice for the majority of the general aviation fleet; their certification of this engine gives us no reason to expect that fact to change. One could say that imitation is the sincerest form of flattery; however, preliminary evaluations have indicated that some of their parts may have substantial weight penalties that could affect desired performance."

Superior sees a large market for the Vantage Engine, not only in the homebuilt market that it already serves but also for fellow OEMs, that is, manufacturers of new aircraft. Archer said that Superior is in discussions with airframe OEMs.

Meanwhile, Archer and the Superior crew are celebrating the new type certificate. "It's exciting," he said, "it really is. It's part of making history in our industry."


Raytheon Taps Aviall to Improve Parts Availability

In a strategic effort to improve parts availability and delivery times to its customers, Raytheon's Parts Inventory & Distribution (RAPID) has teamed with Aviall, a large distributor of parts to all segments of the aviation industry. "Raytheon isn't in the business of supplying third-party and aftermarket parts. That has always been a challenge for all manufacturers," said Charlie Elkins, Aviall's director of marketing and supplier services. "But that type of service is our specialty. We have millions of dollars of available parts and accessory inventory ready to ship out."

In creating the alliance, Elkins explained, Raytheon and Aviall targeted some 60,000 non-factory items including batteries, hoses, wheels, brakes, PMA parts, and even paint-mixing services. "The goal is to greatly improve the company's ability to meet its customers' needs on a timely basis," he said. "Our parts selection will serve to complement the factory production parts Beech and Hawker customers are looking for."

The Aviall product basket is tied into RAPID's new Worldwide Inventory Network (WIN), which links the entire inventory to participating Raytheon authorized service centers. The RAPID sales representative will have real-time access to the entire inventory of parts so they know what is in stock and when it will ship either from the RAPID warehouse or Aviall's distribution center. "Our part of the operation is invisible to the customer," Elkins said. "They order from and are billed by Raytheon."

Even though the program was just initiated late in 2003, Elkins says that early indications point to it being very successful. "The goal is to satisfy the customer's needs as quickly and accurately as possible," he said. "Now FBOs, corporate operators, and maintenance facilities have access to a much larger inventory of the parts and accessories they need to keep Raytheon aircraft flying."

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