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certificate still apply. If the ICA from the design approval holder is not applicable, the PMA holders must provide a supplemental ICA.”


Lessor Issues Nor are lessor issues completely dormant. Lessors are concerned about the residual value and transferability of their assets at the end of the lease period. This is becoming less of an issue, however, because FAA has “done a good job at putting in BASAs in virtually every major airline market in the world,” says David Doll, president of Doll Consulting. The wording, particularly in the later BASAs, “has been very specific to authorize PMA.” Another line of thought is that


agreements that prohibit the use of PMA and DER repairs as a condition to receive the required maintenance instructions, he says. The OEMs are somewhat disingenuous,


as well, since they use PMA parts, too. Every year OEMs buy a small number of Wencor’s PMA parts, says Keith Coleman, president of Wencor unit, Dixie Aerospace. These “customers”— including companies like Honeywell and Raytheon—are probably compensating for material shortages, he says. “The point is that they recognize that these are FAA-approved parts.” In a response to AM, FAA’s Aircraft


Certification Office did not comment on the legality of restrictive agreements. Officials stated that “PMA holders may [emphasis added] show and state that the maintenance instructions for the corresponding parts from the type


lessors—who aren’t necessarily aircraft component experts—don’t know exactly what they’re doing when they try to exclude PMA. To begin with, most PMA approvals are held by OEMs, maintains Sarah MacLeod, executive director of the Aeronautical Repair Station Association (ARSA). So if lessors are drawing up agreements that exclude PMAs, they are shooting themselves in the foot. Moreover, “OE is a business term,” not a regulatory concept. The lessor issue may be more a matter


of agreements being made by people who don’t understand the industry, Markham agrees. Airlines really have more power than they think they do, he says. He advises carriers to go back and talk to their lessor, read the contract, and say they’d like to use specified PMA parts that are noncritical, consumable items. Explain to the lessor that if these parts failed they would not cause an


uncontained failure. “Minor parts do not affect the value or operability” of the airplane. Lessors are not as firm on the issue


as people think, Markham says. Along with other PMA’ers HEICO is trying to educate the lessees and answer the lessors’ questions about the safety and reliability of the PMA parts and the engineering that went into them. “Since 90 percent of what we do is not [critical or life-limited], we’re heading toward a 90 percent solution,” he says. Dickstein worked with the Aircraft


Fleet Recycling Association on the residual value question. “Most PMAs are expendable parts that are not saved when you part out an aircraft,” he says. “When we went through the list of things that are typically PMA’d on aircraft being parted out today—like A320s—we were able to show that they are not losing any value at all, regardless of the residual value of the PMA parts.”


Engines The biggest PMA issue in the future, in terms of OEM strategy, is the effort to completely block out these parts from the engine aftermarket, Doll says. On next-generation engines, the OEMs are “busy tying everything up with patents.” And by closely holding the maintenance organizations, the OEMs either do the maintenance work themselves or have it done through a license from them, he says. Propulsion was always the leader for


PMA, Doll points out. But once they have a monopoly position to sell parts, the OEMs can literally give the engine away.


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