CAVU Café: Royboy’s Prose & Cons, Page 5 of 17

The views expressed in CAVU Café: Royboy’s Prose & Cons blog are those solely of the writer and are not necessarily shared by the Aviation Suppliers Association or the Association’s staff, members, or Board of Directors. About Roy Resto

Certifications For Avionics Technicians

Posted By Jeanne Meade | October 02, 2022

Many of you buy and sell avionics parts and/or have Repair Stations/Approved Maintenance Organisations. As such I’d like to share with you the options that exist globally regarding the credentials which avionics technicians may bring to your attention during the hiring process, including the relatively new NCATT (National Center for Aircraft Technician Training) Certification.

Before starting, since this article is addressing a global topic, we need to point out that generally, the terms Technician, Mechanic, and Engineer will all mean the same thing; their use varies geographically.

BACKGROUND

As with any evolving field of interest, when advancements produce increased levels of complexity, an expected progression would be new fields of expertise, and so it has been for avionics (Aviation Electronics). During and after WW II, aircraft electronic systems became increasingly complex, particularly in the fields of communication and navigation. Technicians who demonstrated talents in these systems were singled out for their aptitude. Despite this recognition, certifications for aircraft maintenance technicians remained stubbornly centered around airframe and powerplant qualifications, with avionics training coming under the airframe category. So, where are we today with certification for avionics technicians? Currently the dominant patterns for maintenance technician certification are the ICAO, EASA, and FAA models.

ICAO

In past articles I’ve shared my hope that in the future the world would go to a single set of globally recognized and accepted aviation regulations. This desire stems from the dizzying number of duplicative certifications a company might require doing business globally. When this happens, it is likely that ICAO will be the organisation which establishes the standards everyone follows. This is likely because ICAO is not anchored to any nation-state, and therefor does not carry any political or geographic ‘baggage’ which might otherwise arouse the sensitivities of any nations. So, who is ICAO?

The International Civil Aviation Organisation (ICAO) is a specialized agency of the United Nations and is funded and directed by 193 national governments to support their diplomacy and cooperation in air transport. ICAO is always quick to point out that they are not a global regulator but that “The stipulations ICAO standards contain never supersede the primacy of national regulatory requirements.1” This is an important distinction; a country’s civil aviation authority maintains its jurisdictional sovereignty over its nation’s aviation operations while implementing globally accepted ICAO standards. It’s this distinction which makes conceivable the promise of ICAO being the global model.

ICAO’s standards are contained in 19 Annexes, and Annex 1 is titled “Personnel Licensing” and contains a section 4.2, Aircraft maintenance (technician/engineer/mechanic). This section further refers to ICAO Training Manual Doc 7192, and its Part D-1 which specifically addresses Aircraft Maintenance (Technician/Engineer/Mechanic), and includes Avionics, Radio, Autoflight, and Instruments.

The ICAO standards, although valuable as a global influencer, do not require that Aircraft Maintenance Engineers have a specific license for Avionics.

EASA

The European Aviation Safety Agency has its part 66 regulation which deals with the licensing of Aircraft Maintenance Engineering personal. This licensing falls into 3 categories:

  CATEGORY A

       Category A1 – Certifying Mechanic Piston Engine powered Fixed-wing Aircrafts.

       Category A2 – Certifying Mechanic Turbine Engine powered Fixed-wing Aircraft.

       Category A3 – Certifying Mechanic Piston Engine powered Helicopter.

       Category A4 – Certifying Mechanic Turbine Engine Powered Helicopters.

  CATEGORY B

       B1.1 – Certifying Technician Piston Engine powered Fixed wing Aircrafts

       B1.2 – Certifying Technician Turbine Engine powered Fixed wing Aircraft.

       B1.3 – Certifying Technician Piston Engine powered Helicopter.

       B1.4 – Certifying Technician Turbine Engine powered Helicopters

       B2 – Certifying Technician Avionics

       B3 – Certifying Technician Ultra Light Aircraft.

   CATEGORY C

       Category C – Certifying Engineer.

Significantly, note that which I have bolded, the B2. To the best of my knowledge this represents the first instance of a Civil Aviation Authority certifying the Avionics specialty. Many countries have copied the EASA model for licensure of AMEs.

FAA

The Federal Aviation Administration regulation for mechanics falls under Part 65, Certification, Airmen other then Flight Crew Members, and its subpart D addresses Mechanics. Mechanics can have an Airframe and/or Powerplant certificate (A&P). There is no certificate available from the FAA for avionics. Note however that regarding the privileges and limitations of mechanics, FAR 65.81(a) states that

“A certificated mechanic may perform or supervise the maintenance, preventive maintenance or alteration of an aircraft or appliance, or a part thereof, for which he is rated (but excluding major repairs to, and major alterations of, propellers, and any repair to, or alteration of, instruments)…”

My italics. Note the A&P limitations on instruments. So, how does FAR 1 define instruments?

“Instrument means a device using an internal mechanism to show visually or aurally the attitude, altitude, or operation of an aircraft or aircraft part. It includes electronic devices for automatically controlling an aircraft in flight.”

That definition curiously includes topics which many of us would include as avionics. The go-around for this limitation has always been to obtain a Repairman Certificate for those systems. Repairman Certificates are not quite ‘Certifications’ such as an A&P, however, since they are only active with the employer you are with, and upon your departure must be surrendered. The pesky question in the US then, is how have employers recognized any level of license to equate with avionics/electronics knowledge for hiring purposes?

The FCC, Federal Communications Commission has licensing options for those engaging in operations on the radio frequencies, for example, radio station operators, TV stations, and amateur operators (AKA Hams). Engineers which work on and can sign off on work performed for radio station and TV station transmitters must have a General Radio-Telephone Operators license, commonly called a GRO. In the past this was called the First-Class FCC license. The GRO test is a difficult test whereby you must know electronic circuits of all kinds, a plethora of electronics formulas, and FCC regulations. The GRO has the option to have additional endorsements, and one of those is a ship radar endorsement.

Although not aviation specific, the GRO was for decades, and continues to be, an acceptable measure that the possessor knows their electronics, which applies to avionics. In fact, many job descriptions for avionics technicians included the desired GRO license, and the radar endorsement was very good to have. For example, many repair stations and airlines hired avionics technicians based on their having the FCC GRO. I should know, in addition to my A&P and I have the GRO with the radar endorsement and was hired into a major airline as an avionics technician based on this credential.

Nonetheless, there is the continued and correct perception that the FCC GRO is not aviation specific, and there does not appear to be any FAA efforts to address this or to have any certifications of avionics technicians. In recognition of this, NCATT, the National Center for Aerospace & Transportation Technologies, created the Aircraft Electronics Technician (AET) certification.

ASTM NCATT

In 2014 the standards setting organization ASTM absorbed the aviation technician certification products that the National Center for Aerospace and Transportation Technologies developed.

The NCATT 61-page study guide2 for the Aircraft Electronics Technician details an impressive list of topics the student will be tested on. There are 90 questions and the passing grade is 73%. In addition to these core requirements, there available several endorsements in the following areas:

  • Autonomous Navigation Systems (ANS) (AET Endorsement)
  • Dependent Navigation Systems (DNS) (AET Endorsement)
  • Onboard Communications & Safety Systems (OCS) (AET Endorsement)
  • Radio Communication Systems (RCS) (AET Endorsement)
  • Aerospace/Aircraft Assembly (AAA)
  • Foreign Object Elimination (FOE)
  • Unmanned Aircraft Systems Certification (UAS)

Each endorsement has its own 50 questions with a passing grade of 70%

Significantly, the Aircraft Electronics Association (AEA) endorses this program, and the FAA, in response to an October 2018 petition from the AEA, formally recognized ASTM’s National Center for Aerospace and Transportation Technologies (NCATT) Aircraft Electronics Technician (AET) certification as equivalent to formal training when showing eligibility for earning a repairman certificate3.

Keep in mind however, that like the FCC GRO, the AET certificate does not empower you to perform Return to Service actions; you still need an FAA Airframe or Repairman certificate. This contrasts with the EASA model (B2) which does permit this.

Over ‘n out

Roy ‘Royboy’ Resto

AimSolutionsConsulting.com

1 https://www.icao.int/about-icao/Pages/default.aspx

2 https://www.spacetec.us/wp-content/uploads/2019/03/AET-Study-Guide-v5-12.pdf

3 https://generalaviationnews.com/2019/01/10/faa-recognizes-aircraft-electronics-technician-certification/

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NOTEWORTHY, Ed 2

Posted By Jeanne Meade | August 01, 2022

Noteworthy is a compilation of interesting news items presented in summary form.

In this issue:

  • Stats: buoyancy of the freighter aircraft marketplace1
  • Millions retired early during the pandemic. Many are now returning to work, new data shows2
  • Bolen Calls for 'Bold Actions' To Address Aviation Workforce3
  • Changes to inventory: Stock on Hand4
  • Stats: Advanced Air Mobility (Drones)5
  • World’s Largest Jet Engine6
  • Boeing Commercial Forecast Excerpts7
  • From Just In Time to Just In Case8
  • Global aviation will need 602,000 pilots by 20419

    IBA outlines continued buoyancy of the freighter aircraft marketplace

    The Boeing 737-800 freighter fleet has almost doubled in size to 113 from 59 a year ago, demonstrating its sustained appeal as an aircraft of optimal size and value for conversion. Despite its increasing legacy status, the Boeing 767-300 freighter fleet has also continued to grow from 127 to 156, driven by the plentiful availability of feedstock aircraft from retiring passenger fleets.

    Despite their much smaller baseline numbers, data from IBA’s InsightIQ platform demonstrates a clear growth in the Airbus converted freighter fleets. The A321 freighter fleet has doubled from four to eight aircraft over the past year, while the size of A330 (-200 and -300) fleet has also increased from 10 to 16.

    The growth in demand for all of these aircraft types is illustrated by the increasing number of conversion centres for each, with at least nine facilities becoming active for the A321, six for the A330 (with IAI still to announce) and 15 for the Boeing 737-800.

    The number of conversion lines for the Boeing 777-300ER is also growing as demand increases. IAA, which initially unveiled its conversion programme for the aircraft in 2019 with a single line, has approved two others. Further conversions programmes have now been rolled out by NIAR WERX and Mammoth Freighters.

    Over the past twelve months, IBA estimates that the market values of most freighter types have remained stable with only a slight drop, especially in younger model aircraft. The value of a 2006 build Boeing 737-800BCF has dropped by just 3.7% to US$21.23 million, and the value of a 2001 build A321-200PTF has declined by 6.3% to US$22.79 million. The only major exception are the Boeing 737 ‘Classic’ types where, for example, a 1999 build 737-400BDSF has fallen by a more significant 14% to US$7.05 million.

    IBA’s initial views on the new purpose built wide-body freighter types is that both will command a considerable premium on the existing in production Boeing 777F which is valued at US$157 million. IBA estimates that a new Airbus A350F, with its cargo capacity of 109 tonnes, will have a value of US$172 million while a new Boeing 777-8F, with its marginally greater capacity of 112 tonnes, will have a value of US$187 million.

    During the webinar, IBA also outlined the impact of the Russia – Ukraine crisis on the freighter aircraft market. InsightIQ information shows that there are 23 freighter aircraft on lease within Russia from non-Russian lessors – a fraction of the notable number of passenger aircraft in the same situation, though still significant in terms of asset value. The non-Russian lessors with the greatest exposure in the freighter market are AerCap, with ten freighters placed in Russia, followed by Voyager Aviation and Airwork both with five, although the latter has repossessed one of its aircraft.

    More widely, the restrictions on Russian wide-body freighters operating outside of the country, coupled with detours caused by airspace closures and rising fuel prices have cumulatively affected air freight rates which, as of March 2022, were up 27% year on year.

    Millions retired early during the pandemic. Many are now returning to work, new data shows.

    Millions of older Americans stopped working during the pandemic, far more than usual, stoking fears that the workforce had been permanently altered, but the country is close to closing the gap in early retirements, according to new data.

    An estimated 1.5 million retirees have reentered the U.S. labor market over the past year, according to an analysis of Labor Department data by Nick Bunker, an economist at Indeed.

    Many retirees are being pulled back to jobs by a combination of diminishing covid concerns and more flexible work arrangements at a time when employers are desperate for workers. In some cases, workers say rising costs — and the inability to keep up while on a fixed income — are factoring heavily into their decisions as well.

    Bolen Calls for 'Bold Actions' To Address Aviation Workforce

    Bolen said, citing a need for nearly 100,000 new business aircraft pilots and 770,000 maintenance technicians globally through 2038.

    Changes to inventory, Stock on Hand

    • Two-thirds (66%) of large enterprises globally say they are keeping more stock on hand now compared to the pre-pandemic period, with nearly one in five in total (18%) retaining “significantly more” stock. This growing focus on taking innovative measures to address supply chain disruption…
    • Further highlighting the impact of supply chain disruption, seven out of ten respondents polled for the survey (70%) said they had increased the number of suppliers of materials/products they use in response to recent supply chain issues.
    • Moreover, nearly three-quarters (72%) of the survey sample claimed to have grown the proportion of materials/products they source from domestic suppliers as a result of these issues.

      Royboy’s Note: See related below: From Just In Time…

      Stats: Advanced Air Mobility (Drones):

      The advanced air mobility market, which includes self-driving “flying cars” or passenger drones and electric aircraft that can deliver goods without a pilot, is expected to be $1.5 trillion by 2040, according to MorganStanley.com. An Aerospace Industries Association 2022 report predicts “breakthrough growth” in the industry between 2022 through 2040 and nearly 100,000 jobs will exist in 2040 as a result.

      World’s Largest Jet Engine:

      British engine manufacturer Rolls-Royce has entered the final stage of the assembly of the world’s largest aero engine demonstrator, the UltraFan, 16 months after the company announced the start of the engine’s development.

      Rolls-Royce expects that the UltraFan demonstrator, which has a fan diameter of 140 inches (3.56 meters), will perform the first test run on 100% Sustainable Aviation Fuel (SAF) later in 2022.

      Boeing Commercial Forecast Excerpts:

      • Boeing anticipates demand for more than 41,000 new airplanes by 2041 due to the growing demand for international air travel and easing travel restrictions, according to the company’s 2022 Commercial Market Outlook (CMO).
      • Aircraft deliveries and commercial services together will be valued at $10.8 trillion over the next 20 years.
      • Asian markets are estimated to require the most new aircraft by 2041, accounting for roughly 40% of long-term global demand for new planes.
      • Europe and North America are each estimated to account for just 20% of global demand for new aircraft.
      • Boeing estimates that the freighter fleet will grow by 80%, including new and converted aircraft models.
      • Carriers will need 2,800 additional freighters overall, including 940 new widebody models in addition to converted narrow-body and widebody freighters over the forecast period

        From Just In Time to Just In Case:

        “We’re moving from Just In Time to Just In Case”. Roderick McLean. Vice President and General Manager of Lockheed Martin’s Air Mobility & Maritime Missions business, explaining how supply chain shortages have turned Just In Time Manufacturing on its head.

        Royboy’s Note: See related Changes to inventory… above.

        Global aviation will need 602,000 pilots by 2041

        Boeing has estimated that 602,000 new pilots, 610,000 new aircraft maintenance technicians, and 899,000 new cabin crew members will be needed in order to “fly and maintain the growing commercial aviation fleet” by 2041, in its latest long-term Pilot and Technician Outlook (PTO).

        Over ‘n out

        Roy ‘Royboy’ Resto
        www.AimSolutionsConsulting.com

        Linkedin.com/in/royresto

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          THE USE OF 3PLs IS ON THE RISE

          Posted By Jeanne Meade | June 03, 2022

          The use of 3PLs by manufacturers, distributors, and MROs are noticeably on the rise. This article will examine the phenomenon.

          First, what is a 3PL?

          As the illustration below demonstrates, a 3PL (3rd Party Logistics) performs logistics processes on behalf of manufacturers and distributors. In other words, your material is being inventoried by a company who specializes in warehousing.

          Source https://3plmanager.com

          Why use 3PLs?

          Everyone is looking for ways to trim and simplify operations, reduce overhead, and save on costs. For all these reasons 3PLs are on the rise. Typical reasons include:

          • Warehousing is not your core competency, why not outsource this task?
          • You expect to be entering into an agreement in which you will acquire or be consigned a large inventory which exceeds your current storage capacity; you’re not sure if the storage capacity requirement will be permanent, so you don’t want to invest in long term brick and mortar
          • You need to downsize and have less employees.
          • A proposed business relationship requires that you place inventory in a geographic location far away from your existing place of operations.

          Did you know 3PLs can be Accredited to the ASA-100?

          There’s a little-known nook in the ASA website which lists the current 3PLs which are accredited to the ASA-100. Here’s the link:

          https://aviationsuppliers.org/ASA100-List-3PL

          Some Accredited Distributors are already performing 3PL operations, but are not holding themselves out as such

          Are you Accredited but have empty warehouse space, and consider yourselves experienced with expertise for logistics and warehousing? Why not make that space more productive! Consider diversifying your services portfolio and holding yourself out as a 3PL.

          If you are already ASA-100 accredited and entering this growth area, consider asking the ASA to post your firm among the separate list of 3PLs.

          Operational, Quality, and Contractual considerations between the 3PL and inventory owners

          No two 3PL arrangements I’ve seen are exactly alike. There are peculiarities in every situation. The following should be considered for operational, quality, and inclusion in subsequent contracts or agreements between the parties:

          • If AOG service is part of your operations, will the 3PL have personnel availability?
          • The Roster. This is interesting and will vary. Does your Roster include those who are authorized to perform functions such as receiving and shipping inspections? It may be that you keep your own inhouse Roster and create a separate one for the 3PL. Or, if the 3PL is already ASA-100 accredited perhaps you rely on theirs. The Roster topic suggests two other subjects: training, and documentation such as your Material Certs.
          • Training:
            • The ASA-100 requires training for Unapproved Parts and Counterfeit Parts. “Personnel involved in procurement, receiving inspection, shipping inspection and material control shall be trained in these topics” Does your 3PL already have this or will you assure it is imparted and documented?
            • Will they be handling ESD parts? Are they trained and equipped?
            • Will they be handling Hazmat/DG? Are they trained?
          • Certs: Material Certifications or ASA Statement Forms or ATA Spec 106s or equivalent:
            • Will the 3PL or you be issuing these? If the 3PL does it, will you authorize them on your Roster or theirs?
            • Scrapping: Who will perform this when needed, and how will it be documented?
            • Shelf Life? How will this be tracked?
            • Records: The distributor is responsible for records. Is the 3PL creating any documents considered records? How will you bring these into your records storage system?
            • Many of you use a Receiving Discrepancy Log as a means to have a Quality History for your approved suppliers (ASA-100 5.C.). If so, how will this be implemented with a 3PL arrangement?
            • Make sure your 3PL is on your Approved Suppliers List or equivalent.
            • Packaging details: Will the 3PL use your shipping labels on the outside of the boxes/containers?
            • Pictures: Many of you take pictures of the products to be shipped for insurance purposes and protection against allegations of damaged goods. Will the 3PL do this for you?
            • Defense/Government. Some of you engage in DoD/Government work. ITAR guidelines have strict requirements regarding inventory storage and security. Is your 3PL able to address these? Also, many military and defense contracts require packaging which is strictly compliant to the MIL-STD-2073. If so, how will that be handled?
            • ERP integration: This will vary considerably if at all. For example, will they have access to, and be able to make entries into your ERP system such as Pentagon, Quantum, or Avsight? If yes, this will increase your own productivity, but is also likely to increase your costs.

            Royboy’s tips:

            • Will your inventory be covered by the 3PL’s insurance?
            • Are you empowering a possible competitor? Careful. While interviewing people for this article, a person advised that if you use another distributor, they’ll have access to who your customers are, and the parts being sold. Protect yourself with a clause in your agreement similar to a non-compete; talk to your lawyer for the proper language. Of course, if the 3PL is a firm that does this and nothing else (they are not an existing distributor), this scenario is less unlikely.
            • Self-Audit: Your self-audit should include the operations of the 3PL. Even if the 3PL is ASA-100 accredited (meaning they’re required to have their own self-audit program), their self-audit sampling may not include your inventory, or the scope of the contracted responsibilities between you and the 3PL.
            • Records: Unless the 3PL is making direct entries into your ERP system, there’s the possibility that files originating from the 3PL which are records (for example, pictures, scanned documents, etc.), are being emailed to you. If so, make positively sure that those files are moved from your email server to your applicable record files.
            • Your Quality Manual: A favorite word I often use is ‘transparency’. For your manual, plainly state what it is you’re doing with the 3PL, particularly if the 3PL is fulfilling any portion of the ASA-100 Quality System you would otherwise perform yourself if not for the 3PL.

            Over ‘n out

            Roy ‘Royboy’ Resto

            www.AimSolutionsConsulting.com

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            NOTEWORTHY, Ed 1

            Posted By Jeanne Meade | April 01, 2022

            Noteworthy is a compilation of interesting news items presented in summary form.

            In this issue:

            • Airbus Targets Chinese Demand For Storage And Recycling 1
            • Aviation industry jobs have not only rebounded from the pandemic slump, but they have also soared 30 percent from pre-Covid levels 2
            • Over 70% of workers regret quitting their jobs 3
            • The number of working Americans testing positive in drug tests hit a two-decade high in 2021 8
            • Hybrid work isn't working for many 9
            • Business Aviation is red hot 4
            • Joby Aviation close to achieving Part 135 Air Carrier Certification 5
            • EASA issues world’s first design specifications for vertiports 6
            • What are the Global Top 10 International and Domestic Routes? 7

            Royboy’s comments are in italics.

            Airbus Targets Chinese Demand For Storage And Recycling

            ‘To capture the emerging demand for aircraft storage, transition and dismantling in China, Airbus is joining forces with specialist Tarmac Aerosave and the city of Chengdu.” “Between leasing contracts, a commercial aircraft may have to be stored. It may also have to undergo maintenance and upgrade work in that transition phase, such as receiving a new cabin layout and livery. “Chinese lessors store two-thirds of their aircraft outside the country, whereas they tell us they are looking for a solution in China,” says Wolfgang Kortas, head of Airbus’ life-cycle solutions development.’

            Aviation industry jobs have not only rebounded from the pandemic slump, but they have also soared 30 percent from pre-Covid levels

            ‘Aviation industry jobs have not only rebounded from the pandemic slump, but they have also soared 30 percent from pre-Covid levels, according to employment service JSFirm. “Companies are scrambling and competing with each other to attract and retain qualified candidates,” said JSFirm’s executive director Abbey Hutter. “The current job market is candidate-driven and they have plenty of job opportunities in front of them.”’ ‘Pilots, airframe-and-powerplant mechanics, sheet metal technicians, avionics specialists, engineers, flight instructors, dispatchers, line service personnel, and sales managers are in high demand, according to JSFirm.com.’

            On the other hand…

            Over 70% of workers regret quitting their jobs

            ‘The majority of U.S. workers who changed jobs during the "Great Resignation" actually regret quitting and even feel a sense of buyer's remorse, according to a new survey. Seven out of ten workers — about 72% — admitted that they were surprised to learn that their new roles or companies were different from what they were led to believe during the interview process, according to the survey of more than 2,500 millennial and Gen Z job seekers by The Muse. The Muse CEO Kathryn Minshew described the trend as "shift shock." "They'll join a new company thinking it's their dream job and then there's a reality check," Minshew told FOX Business… As a result, Minshew said, more people are quitting rather than sticking it out.

            "It used to be that if you started a new job and didn't like it, you needed to stay for one or two years to avoid a black mark on your resume," she said. "But we've seen this really interesting shift in perceptions."

            About 80% of millennials and Generation Z workers say it's OK to leave a new job in six months if it's not as advertised, according to Minshew.
            About 1 in 5 job seekers even admitted they would quit within a month if it's not as expected, and 41% say they would give it between two and six months. Just under half of job seekers — 48% — would actually try to get their old job back, according to the data.
            Minshew said the wave of employees quitting after a short period of time could fuel another "Great Resignation," which refers to millions of Americans leaving their jobs during the COVID-19 pandemic.
            To change this pattern, Minshew says companies need to be more upfront because it could help retain workers who aren't totally satisfied but could be over time.’

            Related, a high on highs…

            The number of working Americans testing positive in drug tests hit a two-decade high in 2021

            ‘The number of working Americans testing positive in drug tests hit a two-decade high in 2021, according to The Wall Street Journal. Yet, as more states loosened their drug laws, fewer companies tested their employees for THC (one of the main ingredients in marijuana) and other substances. The shortage of workers looking for jobs in the last two years has also meant some companies relaxed their testing requirements. Despite this, the proportion of U.S. workers in 2021 who tested positive for the various drugs screened for rose to 4.6% — the highest level since 2001 — per drug-testing laboratory Quest Diagnostics.

            That percentage is over 31% higher than the low of 3.5% ten years ago, in the early days of a resurgent heroin epidemic in the U.S., said the Journal.’

            Hybrid work isn't working for many

            ‘Many businesses have pitched a hybrid work schedule as the “best of both worlds” for employees, with benefits that include escaping the commute on work-from-home days and enjoying in-person collaborations on office days. Yet, as Alison Green notes in Slate, many workers who return to the office for part of the week are finding that they are the only ones there, or that the colleagues who are present aren’t mingling, with most communication still happening over Zoom and Slack. This "worst of both worlds" scenario risks souring many on hybrid work.

            With WFH becoming a permanent feature of the economy, office vacancy rates in major cities keep climbing and signs of distress in commercial real estate loans are growing, per Axios.’

            Business Aviation is red hot

            ‘Business aviation is red hot, thanks to the COVID-19 crisis. U.S. business jet departures were up 51% year over year in November, led by fractionals and charter operators. Just 3.8% of the pre-owned business jet fleet is for sale, a historical low. Demand is so strong that NetJets, Executive Jet Management and Jets.com recently suspended jet card sales. While it is difficult to gauge accurately, business aviation captured tens of thousands of new customers since 2020, industry insiders estimate.’

            Joby Aviation close to achieving Part 135 Air Carrier Certification

            This is fascinating given that certification issues regarding manufacturing and operations of eVTOL aircraft are just being established. Having a Part 135 for scheduled or on-demand eVTOL passenger flights seems to make sense.

            ‘A Part 135 Air Carrier Certificate is required for Joby to operate its revolutionary electric vertical take-off and landing (eVTOL) aircraft as an air taxi service in cities and communities around the United States. Alongside a Type Certificate and Production Certificate, this is one of three regulatory approvals critical to the planned launch of Joby’s all-electric aerial ridesharing service in 2024.’

            EASA issues world’s first design specifications for vertiports

            As with the previous Joby article, this too is an example of emerging guidance to address the nascent eVTOL industry.

            ‘The European Union Aviation Safety Agency published the world’s first guidance for the design of vertiports, the ground infrastructure needed for the safe operation of Urban Air Mobility services such as air taxis in locations across Europe, including in urban areas.

            The Prototype Technical Design Specifications for Vertiports offers guidance to urban planners and local decision-makers as well as industry to enable the safe design of vertiports that will serve these new types of vertical take-off and landing (VTOL) aircraft, which are already at an advanced stage of development.

            “Urban air mobility is a completely new field of aviation and we therefore have a unique opportunity to develop a set of infrastructure requirements from scratch,” Patrick Ky, Executive Director of EASA said. “With the world’s first guidance for safe vertiport operations, EASA’s ambition is to provide our stakeholders with the ‘gold standard’ when it comes to safe vertiport design and operational frameworks. By harmonising design and operational standards for vertiports we will support European industry, who are already starting to embark on exciting projects in Europe and around the world to make new urban air mobility a reality.”’

            What are the Global Top 10 International and Domestic Routes?

            This list, which was a snapshot of operations at the time, likely changes seasonably and is influenced by global events. Nonetheless these are likely to surprise you…


            Over ‘n out
            Roy ‘Royboy’ Resto
            AimSolutionsConsulting.com

            1 https://aviationweek.com/air-transport/maintenance-training/airbus-targets-chinese-demand-storage-recycling
            2 https://www.ainonline.com/aviation-news/general-aviation/2022-03-08/jsfirm-everyone-hiring-aviation
            3 https://aviationweek.com/business-aviation/aircraft-propulsion/opinion-business-aviation-growth-structural-or-temporary
            4 https://www.foxbusiness.com/lifestyle/workers-regret-quitting-great-resignation
            5 https://www.jobyaviation.com/news/joby-nears-completion-part-135-air-carrier-certification/?msclkid=716b9312a91c11ecb1a1a34094692162
            6 https://www.easa.europa.eu/new...
            7 Aviation Week & Space Technology; Looking Long-Haul; page 42; February 7-20, 2022.
            8 https://www.linkedin.com/news/story/lots-of-us-workers-are-getting-high-4734825/
            9 https://www.linkedin.com/news/story/hybrid-work-isnt-working-for-many-4727857

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            WILL OEMs MAKE MANUALS AVAILABLE TO INDEPENDENT MROs? INDUSTRY COALITION ASKS FOR FAA INVOLVEMENT

            Posted By Roy Resto | January 31, 2022

            There is no doubt that the movement of OEMs into the aftermarket in the last 15 years has caused tectonic change in the MRO (Maintenance, Repair, and Overhaul) and Distribution ecosystem. Such evolution is not uncommon, but unfortunately there appears to be ample evidence that more than a few of the OEMs are unfairly leveraging their monopolistic positions to withhold reasonable access to their repair/overhaul manuals (Instructions for Continued Airworthiness) from independent MROs.

            Independent Maintenance, Repair, and Overhaul (MROs) exhibit these characteristics:

            • They are not an extension of, or affiliate of an OEM Manufacturer.
            • They are not an extension of, or part of an airline.

            If you’re such an independent MRO, you’re already painfully aware that many OEMs are making it unreasonably difficult, or impossible, to obtain their maintenance manuals; without these you can’t add new capabilities to your repair station/AMO (Approved Maintenance Organisation). The unavailability of these manuals clearly places an independent MRO at a competitive disadvantage, in fact it may be that this and other OEM behaviors are anti-competitive or monopolistic.


            There have been quite a few unheralded skirmishes between the MROs and the OEMs, and to characterize these as David vs. Goliath would not be an embellishment. The latest attempt to get help, this time from the FAA, has come in the form of a jointly submitted letter dated December 27, 2021, from 14 industry groups representing the widest of constituencies in the aviation industry. The letter was addressed to the top Administrator of the FAA, the Honorable Steve Dickson. I’m happy to report that the ASA cosigned the letter, which is attached at the end of this article.
            The well authored letter likely originated with ARSA, contains interesting aspects concerning its tack and tone. Regarding these OEM (in which the letter uses the more-specific term DAH, Design Approval Holder) behaviors, it says:
             


            The letter proposes addressing the issue as a task delegated to the Aviation Rulemaking Advisory Committee, ARAC. The expected result would be that there would be new or revised, clear Regulations for the OEMs to make available these manuals. If the ARAC takes this on, expect closure, but at a glacial pace.
            This is not the first time I’m writing about these OEM issues. Here’s a compilation of the articles and links:

            “AIRLINE MAINTENANCE COSTS WILL GO UP”

            “OEM ANTI-COMPETETIVE, MONOPOLISTIC PRACTICES IN THE AFTERMARKET”


            The International Air Transport Association (IATA) which represents hundreds of airlines globally, deserves special recognition since they have taken on one of the largest OEMs to court, since settled, and may be taking on more (for more information, read my previously cited articles). Given the impressive lineup of IATA, the 14 Organizations cosigning the letter, the thousands of airlines, business aircraft operators, distributors, repair stations/AMOs, and aircraft owners which they represent, it is clear they are fed up with these OEM practices and lack of government intervention.

            I’d like to conclude this article with an appeal to those OEMs exhibiting these behaviors. All these people know who you are, and your names are mentioned in terms which if quantified and made known, would puncture your ESG score (Environmental, Social, and Governance). Is it really worth a blemished reputation to continue these behaviors?

            The letter:

            Over ‘n out

            Roy “Royboy” Resto

            www.AimSolutionsConsulting.com

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            TWENTY-FIVE YEARS OF FAA AC 00-56

            Posted By Roy Resto | December 02, 2021

            A banal cliché overheard during political campaigns is ‘working together’. I figuratively roll my eyes at the lack of creativity in that diluted, overused utterance. Fortunately, despite cynics, there really are examples in governance where that term bore fruit.

            Every government organization has its head; the Administrator, or Director for example. An oft heard refrain among those leaders is that the goals of the organization can’t be met without the active participation of industry; in other words, working together (there’s that term) to achieve mutual goals. So…are there any examples of such collaboration? Without question, a paragon model has been the FAA’s Advisory Circular 00-56. Later in this article are some interesting statistics and facts, but let’s not get ahead of the story.

            To understand the profound impact the AC had on the industry, it’s important to understand the environment that existed at the time of its creation.

            Bogus Parts: those were the trigger words on everyone’s lips in the early 90’s. News programs and articles were saturating the marketplace warning of the perils of bogus parts. In fact there was such a tumult that Politicians held public hearing on the issues, and many independent ‘experts’, airline representatives, trade Associations, and FAA employees, among others gave testimony which at times painted a dire picture, and in some instances a somewhat sensationalistic, scary portrayal of the issues. At the conclusion of the hearings the Senate gave the FAA a list of problems that had to be fixed. In response the FAA established a special office whose charter was to fix the problems contributing to Unapproved Parts (or now commonly called SUPs – Suspected Unapproved Parts). Most of you recall Ken Reilly who headed that office for a long time and who, for his efforts was a recipient of the prestigious ASA “Eddy” award. But, back to the AC…

            One of the problems cited by the Senate for the FAA to fix regarded the state of distributors. Unlike manufacturers, operators, and repair stations, distributors were not regulated, had no oversight, and were not required to implement and follow aviation style quality systems. It was felt that if bogus parts were to find their way into the industry, the weak link would be the distributors who supplied parts to both manufacturers and operators. There were some in the industry (and at first I counted myself among them) which took the position that distributors should be regulated and certificated by the FAA. At the time I recall a number being bandied-about was 2000 regarding the estimate of the number of distributors (including stockists and brokers) globally. Certificate that! As you can imagine, the FAA was not going to be funded to regulate even a fraction of that number. So, the standoff stood; what to do about the wild-west among distributors? Enter the draft of the AC 00-56, ‘Voluntary Distributor Accreditation Program.’ To be sure, there was government-industry collaboration in writing, editing, and fielding it. A few names that come to mind in that campaign are Dennis Piotrowski, Ed Glueckler, and Al Michaels (also an “Eddy” recipient) among others.

            Out came the initial FAA AC. The Air Transport Association (now Airlines for America, A4A) distributed it to their constituent airline members, and here was my first exposure to it. I was working for a major airline and was handed the job of determining what the airline’s position was going to be regarding its substance. In a rather large meeting held with the heads of Purchasing, Material Control, and QA, I introduced the AC and solicited feedback. There were, and still are two lines in the AC that stood out to this management group: “We (the FAA) consider obtaining parts through accredited distributors is a sound safety practice.” And “If a certificated customer uses an accredited distributor, and voluntarily reports any known potential violations of 14 CFR rules, we would recognize the fact that the certificate holder obtained the part from an accredited distributor as a mitigating circumstance in any subsequent administrative or enforcement action.”

            The terms, “…sound safety practice”, and “…mitigating circumstance…” rang pretty well for this safety conscience airline. It took about 15 minutes of discussion and a senior Director gave the order to send out a letter to all its after-market distributors which stated they had a year to become accredited or risk being dropped from the airline’s approved supplier list, and oh yes, I was to administer this, and out went the famous letter to its suppliers. So-much for being a ‘voluntary’ program. Other airlines and manufacturers saw the benefits of the program and similarly used the program as a basis to approve their distributors. Thus steadily, the AC became a success and gained global acceptance.

            Interesting: When the AC was being drafted there was the thorny issue of who would administer the listing of firms meeting the requirements of accreditation; the “Database Listing”. This is not just a simple matter of posting a listing on a web site. There are administrative procedures that must be followed, records kept, follow-ups, and yes the web site upkeep. Read paragraph 10 of the AC and you’ll get the picture. At first it was thought that the FAA would perform this task, but alas, this too was not likely to get funded. The ASA volunteered. In the AC, the FAA delegates the keeping of the Database to the ASA. It’s an unheralded fact that the ASA has been flawlessly performing this mission pro bono since the AC’s inception; bravo ASA!

            The FAA has twice updated the AC and participated in ride-along audits. The AC and the accreditation program is a living document. Every day there’s countless activity in many parts of the world triggered by the AC; Manuals being updated, external and internal audits being performed, training imparted, records updated, findings and non-conformities being addressed, Approved Suppliers Lists being updated, documents generated, orderly scrapping of parts, inspections performed, and rosters updated, just to name a few, and all in conformity with… AC 00-56.

            25 years of a very effective cooperative effort between government and industry.

            Some interesting Stats:
            • Who were the first six companies to become accredited?
              • AVTEAM, Avio-Diepen, and AvioSupport were all accredited the same day followed by International Aircraft Associates, Baron International Aviation, and Norcross Air, Inc.
            • How many are in the accreditation database?
              • Today there are 804 companies/locations listed in the database.
            • Which company has the most locations accredited?
              • Boeing with 25 locations.
            • How many nations are represented in the database?
              • Globally, 32 nations are represented.
            • Which current company has been accredited the longest?
              • International Aircraft Associates
            • Of the 804 listed in the database, how many are ASA-100 accredited?
              • The ASA-100 continues to be the dominant Quality Standard chosen comprising 425 of the 804; cool…

            Over ‘n out

            Roy ‘Royboy’ Resto

            www.AimSolutionsConsulting.com

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