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Friday, August 1, 2008

ODA Offers Key Advantages, Carries Major Burdens

James T. McKenna

ODA is an abbreviation that promises to transform the completions business.

It stands for Organizational Delegation Authorization and is the U.S. FAA’s effort to streamline certification of equipment and its installations as safe and compliant with aviation regulations. It also marks a recognition by that agency that it doesn’t have the staffing or budget to keep up with the demand for civil aircraft certifications and likely never will again.

"With the FAA’s increasing workload and budget constraints, they simply don’t have the ability to meet the demand for supplemental type certifications (STCs) without imposing a significant schedule risk to a project," said Mike Slattery, director of marketing for Air Methods Product Div, which was among the first outfits to gain FAA approval to operate as an ODA. Sikorsky Aircraft’s Keystone Helicopter also has received that approval, as has Chelton Flight Systems, PHI and Bell Helicopter. The FAA says AgustaWestland’s Agusta USA in Philadelphia has applied for one.

The FAA set up the ODA program in 2006 to consolidate under one umbrella its major "organizational" designations — the Delegation Option Authorization, Designation Alteration Station, Organization Designated Airworthiness Representative and Special Federal Aviation Regulation 36. It has set a target of early 2009 for all holders of those approvals to convert them to an ODA. But it is likely to extend that deadline, in part because the process for gaining ODA approval from the FAA is protracted and detailed.

"This was really a good, solid, two-year effort," said John Kerr, a senior certification engineer at Bell who played a key role in that manufacturer’s drive to win ODA approval. Others said their approvals required similar efforts.

The potential payoff for holders of that authorization is huge. ODA gives an outfit unprecedented authority to sign off on major modifications and repairs. An ODA holder can approve designs and test plans and witness tests. This allows a completions shop holding an ODA to slash the time required to develop, gain approval of and deliver an STC to a customer. Compared to a shop that must pursue the traditional route of getting the STC approved by an FAA inspector, Slattery said, an ODA holder "can turn an STC in a much shorter period of time."

As everyone in the completions business knows, time is money. "Programs can run at the rate of $1 million a month," said Roy Battles, chief technology officer at Bell. "If I can save several weeks during this process, it very quickly adds up to a very large number."

The trick is that an ODA is not a shortcut. "You still have to meet all the FAA regulations," Battles said.

Because that burden falls on people who are not FAA employees, the agency is demanding and cautious in whom it allows to exercise ODA authority. "The FAA’s not rushing to issue ODAs," said one successful applicant. "They’re being very choosy and careful."

The first test an ODA applicant must pass, those who have succeeded say, is persuading the FAA that the applicant’s organization has the qualifications and the integrity to exercise the privileges of the authorization. That is not a institutional matter, they said. The FAA must approve of the specific individuals a company puts in place to run the ODA. Theoretically, the ODA and its staff stand apart from the industry outfit that applied for the authorizations. FAA rules prohibit it from being placed under an organizational unit that can exert undue pressure to put company considerations above regulatory-compliance ones. Bell’s ODA, for instance, is accountable directly to Bell President and CEO Dick Millman.

Another big challenge to gaining an ODA is putting together the operational manual for it. That must lay out every aspect of the ODA’s planned activities, including the names of those in its chain of command and how its personnel will be trained to properly use its authority. If a specific person leaves, the FAA must approve his or her replacement in the ODA.

Bell’s Kerr said the first year of that company’s two-year effort to win an ODA was spent writing that manual. The next year was spent getting FAA approval of it.

"Our procedures manual is FAA-approved and I mean that term ‘approved’ in every sense of the word," said Kerr, who serves as an associate administrator of Bell’s ODA. "Every letter, sentence, paragraph and page is signed off by all of the parties." Those parties, he said, include the FAA officials responsible for oversight of Bell in the agency’s Aircraft Certification Office, Manufacturing Inspection District Office, Flight Standards District Office, Aircraft Evaluation Group and Rotorcraft Directorate.

The ODA is a potent authorization. Bell’s ODA permits it to issue type certificates for new aircraft models.

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