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  1. To quickly update, we received the following information from one of MARPA’s members regarding the potential sale of PMA parts to EasyJet-

    “Most, if not all of EasyJets aircraft are under a sale/leaseback program that precludes the use of PMA. We do stay in touch with them just in case anything changes. ”

    -Jessica Stubbs, MARPA

    Posted by jessstubbs | November 21, 2008, 5:51 pm
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  2. Politics aside, I think Panarin and his map may have unwittingly provided a solution to those calling for a college football playoff solution.

    Posted by hotoffthepress | December 29, 2008, 3:28 pm
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  3. Thanks for your “academic” interpretation of the new legislation. But it is not applicable in the real world. Although I find fault with every issue that you’ve addressed, the most egregious on is your interpretation of the “credit elsewhere” test.

    Decades ago, SBA required that prospective borrowers obtain two lender turndowns before applying for an SBA-guaranteed loans. Since then, SBA tells lenders to make loans that meet their current underwriting standards. That means acceptable credit scores, critical financial ratios and collateral requirements.

    The difference is that SBA loans have a longer maturity and marginal borrowers may qualify when they would not fit conventionally. The interest rates may also be a bit lower.

    A noticeable difference is that SBA Express lenders will also make smaller loans because they use more streamlined process.

    Unlike your assertion, borrowers that are not creditworthy will be rejected. Your other assertions are also incorrect as well but I won’t take the time to explain at this juncture. Instead, speak to SBA lenders to get the real skinny.

    Jerry Chautin is a volunteer SCORE business mentor, business columnist and SBA’s 2006 national “Journalist of the Year” award winner. He is a former entrepreneur, commercial mortgage banker, commercial real estate dealmaker and business lender. You can follow him at http://www.Twitter.com/JerryChautin
    http://tenonline.org/sref/jc1bio.html

    Posted by jerryscore93 | September 27, 2010, 12:45 pm
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  4. Thanks Jason!

    This is of major concern to our segment of the aviation industry.
    We are constantly embattled between the end user and the OEM’s.

    Posted by David Kirby | July 7, 2011, 10:22 am
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  5. Hi Jason,
    I just read through the proposed order and it does not appear to excise references to “ATA Spec 2000” but just the references to “Chapter 16″. It would make sense to remove references to the specific chapter in case Spec 2000 should re-number its chapters, but to leave the reference to Spec 2000 as the guiding standard.
    Sean

    Posted by Sean Melia (@SeanMelia1) | December 21, 2011, 9:58 am
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  6. Nice write up about PMA parts; I liked

    Posted by Avitech (@Avitech101) | January 30, 2012, 9:27 am
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  7. How does this coincide with the Presidents speech about our being competitive, and helping manufacturers stay competitive in this world economy? In a word ~ IT DOESN’T !!! When manufacturers are forced to pay taxes on raw materials not yet produced or converted into products and those products are not pre-sold then the US manufacturing community is woefully behind that which a manufacturer overseas can and will produce.

    Unbelievable ~ this administration has not on scintilla of common sense about business nor how it works.

    Posted by David Kirby | January 30, 2012, 3:12 pm
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  8. WAY TO GO JASON !!!

    And I suspect the MARPA team !! you have saved this industry from OEM tyranny.

    Posted by David Kirby | March 30, 2012, 10:21 am
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  9. Jason, nicely written and very timely (for us, at least!). Although, I am still a bit confused as to whether parts repaired by PMA/PAH will fit neatly into this “acceptability” criteria. The company I work for manfactures and sells several proprietary STC’d devices for large transport aircraft (B737, B757, etc). These devices also have EASA STC approval and are flying on European based airplanes.

    We have PMA and PAH status to maintain, rebuild and or provide alterations to our product. We are not (yet) a part 145 repair facility; however, Section 2 of Order 8130.21 allows a PAH (without part 145 Repair status) to use form 8130-3 for approval for return to service … at least in the US. Does the bi-lateral agreement with EASA extend this Section 2 rule to repaired parts from a (non-part 145) PAH on EASA regulated airplanes?

    Thanks in advance,
    Adrian Alting-Mees

    Posted by Adrian Alting-Mees (@am_embed) | October 5, 2012, 2:44 pm
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    • Thanks for your comment, Adrian.

      A review of the US-EC BASA MAG and BASA TIP will show that the EC acceptance of US rebuilds is largely focused on engines; however, the answer to your question turns on a number of facts that are not stated, so it is impossible to give you a precise answer.

      If you need a legal opinion on acceptability, then you and I should talk about having the law firm (Washington Aviation Group) address your concerns. Usually, the best way to approach a client concern is NOT to ask “does my fact pattern fit a particular solution.” I usually like to talk to potential clients about their end goal(s), and then try to find the law and policy that supports their desired end-state. This avoids the technically correct but less useful answers that state that one cannot do something, without explaining alternatives ways to accomplish exactly what the client wants to accomplish (and can accomplish using a different approach).

      If you want to pursue a discussion of your potential options, then please feel to give me a call or email me.

      Posted by Jason Dickstein | October 8, 2012, 10:58 am
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  10. Jason: OUTSTANDING and timely article. Thanks for sharing. Everyone senior manager in the FAA I know understands the simple fact that the more government help one receives the less money and brain power there is to apply to real safety concerns that ONLY the company understands. We can lose site of the forest for the trees I believe is the appropriate statement here. Another great example of how senior management within the Agency is trying to help themselves as well as industry and therefore improve safety is the 21 ARC.

    Posted by Dennis Piotrowski | June 19, 2013, 10:18 am
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  11. Leading manufacturers and suppliers of Roof ventilators and roof ventilation systems in chennai, India. Turbine Roof Ventilator Suppliers and ventilator dealers in chennai.

    Posted by pareshpaul0 | June 27, 2013, 8:26 am
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  12. I agree with your point of view of this article. This is a good article. Very timely given us so much useful information. Thank you!

    Rapid prototype

    Posted by broadi_cn (@BroadiCn) | July 6, 2013, 2:19 am
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  13. Thanks for sharing your valuable opinion towards Supply Chain Management Handbook. I hope it is a great way to monitoring the suppliers. Without keeping a proper ledger, handling the task in logistic management may be tough.

    Posted by logistics4 | July 18, 2013, 2:25 am
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  14. Jason,

    Thank you for the kind words that you’ve written which are all very positive. One thing I would like to point out is that we’re not just focused on parts for Regional Jet Aircraft but are approved and willing to undertake work on all fixed winged aircraft types.

    If anyone would like to further discuss any “Replacement Part” issues please feel free to contact myself philip.beard@baesystems.com

    Phil Beard

    Posted by Philip Beard | January 27, 2014, 5:02 am
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  15. Phil – Sorry, you had mentioned that in your presentation. I have updated the main test to reflect the full breadth of your DOA approval.

    Posted by Jason Dickstein | January 27, 2014, 11:52 am
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  16. Helicopter Rule Follow-Up:

    Yesterday we posted about the planned FAA Helicopter rule. That final rule was published today is available online:

    http://www.gpo.gov/fdsys/pkg/FR-2014-02-21/pdf/2014-03689.pdf

    Posted by Jason Dickstein | February 21, 2014, 4:01 pm
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  17. Is this a real thing? It shares a nearly identical title and the same date as AC 21.303-2.

    Posted by Steve Keith | June 11, 2014, 10:38 am
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  18. Although it doesn’t explicitly cancel Order 8100.1D (and in fact may serve to muddy the waters even further), Notice N 8000.372 Paragraph C does instruct:

    “AIR manufacturing employees managing designees using FAA Order 8100.8D, Designee Management Handbook, will discontinue use of that policy and comply with FAA Order 8000.95 when DMS is deployed in their office per the schedule in appendix A to this notice.”

    Google search for “N 8000.372” to view the complete notice, and take care not to confuse it with Order 8000.372, which addresses DARs affiliated with UAS test sites. I am curious why and how the same number was used twice, even though it was in different guidance/policy categories.

    Posted by William Denihan | December 12, 2014, 11:18 am
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    • Good point! I will update the blog post to reflect this information

      Posted by Jason Dickstein | December 12, 2014, 11:40 am
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      • Thank you for the attribution! Just for the sake of clarity, in the second sentence of the second paragraph of your update you refer to ‘Order 8000.372’ where I believe you intended to reference ‘Order 8000.95’. It is a bit confusing since the FAA has both an active ‘Notice 8000.372’ and an active ‘Order 8000.372’ that address different subject matters. Although I can’t help but find this practice puzzling, I did some cursory research on faa.gov under Regulations & Policies/Orders & Notices and discovered the use, reuse and cross duplication of numbers between Notices and Orders is apparently rather common. It serves to keep everyone on their toes, I suppose.

        Posted by William Denihan | December 12, 2014, 2:37 pm

  19. Very interesting topic. But what about signed contracts that effectively restrict use of ICAs? For example, is there a legitimate way out of a signed licensing agreement between a maintenance provider and design approval holder where the contract grants the MP rights to use the ICAs for services but is conditional on not using the data therein to develop DER repairs or PMA parts? If the contract would have to be adjusted at the outset to preclude this language, then it is unlikely that the MP would obtain a license in the first place.

    Posted by Tim Blaskovich (@TimPathfinder) | February 1, 2016, 10:49 am
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  20. Given the stress on smaller companies of the AD requirements, is this likely to stimulate even more M&A in the US PMA industry? Are there any US players who are in a competitive position to actually benefit from this?

    Posted by Allen Farrington | February 17, 2016, 12:24 pm
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  21. We know that some of you may have experienced difficulties in booking through the link yesterday, and are glad to confirm that the NH Ventas has made the necessary changes to make it possible to book now. Thanks for your patience!

    Posted by Katt Brigham | April 13, 2016, 12:41 pm
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  22. Hi Jason, could you update the links to the advisory circular and 2015 CAAC revision? They seem to not exist.

    Posted by loriying | October 19, 2016, 8:54 am
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  23. Our company has obtained a PMA approval for producing several avionics parts through Identicality by Showing Evidence of a Licensing Agreement with a FAA STC holder. Furthermore, the parts have been sold later on to several OEM which are not part of the initial PMA eligibility list. The OEM created their own major changes to install these parts into their TCed products.
    We are struggling as a PMA holder to define a way we could manage a design change to our parts.
    if our initial STC holder (the one was behind our PMA approval) approves the minor changes we do…we could produce a part with this new approved design data… however,, could we ship these “new” parts to other STC holders that install our parts on other products? is there a specific approval process for this? do we have to evoke a minor change to all other STC/major changes that install our parts whenever we perform a minor design change to our part (e.g. SW update)??? I appreciate your help here.

    Posted by Anas Rezk | April 21, 2017, 9:19 am
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    • Anas: The answer to your question is going to depend on some facts that are not in your query. And it is going to require legal analysis of those facts. So you may want to call our firm to discuss that, rather than going back-and-forth in a public forum like this. I will be at MRO Americas next week if you want to chat a bit, there.

      Posted by Jason Dickstein | April 21, 2017, 12:14 pm
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  24. Thank you for sharing the article. Keep sharing the good work

    Posted by Imcfareast | November 19, 2018, 7:22 am
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  25. Nice summary Jason, thanks for posting!

    Posted by Stephen Jude Szpunar | September 12, 2019, 2:24 pm
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  26. Hello, In your article you mention that MARPA will be developing additional guidance to assist businesses in developing MOU’s for use in establishing a streamlined PMA (MARPA 1100) process with their ACO. Since this article was written in 2013 I will assume that significant progress has been made to that end. Can you direct me to a location where I might review this MOU guidance? Thank you.
    Mark

    Posted by Mark McCormack | September 20, 2019, 1:04 pm
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  27. Jason, I never met the man but based on your beautiful words wish I had! Thanks for posting.

    Posted by Steve Szpunar | November 22, 2019, 8:58 am
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  28. Good to see such a nice blog postsBest Wire harnesses manufacturers in India

    Posted by violintec | January 15, 2021, 4:03 am
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  29. The FAA ACO has been lagging in PMA approvals, we have been waiting on some approvals for over 6 months.
    I work for a PMA company out of Ohio and we submit packages to Chicago ACO.

    Posted by Mike Carabotta | January 29, 2021, 7:57 am
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    • Thanks, Mike. I’d love to know more about the delays, and the causes of them. And I would be curious to know about the level of communication about the delays, and whether you feel that the FAA is keeping you in the loop on their internal timelines. If you click on the “contact” link at the top right of the page then it will show you all of the ways that you can contact us. Please call or email so we can talk further about the issues, and also about ideas for solutions/

      Posted by Jason Dickstein | January 29, 2021, 12:16 pm
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  30. The biggest issue right now is for the government to figure out how we apply and how the funds will be issued!!!!!!

    Posted by Andy Shields | April 26, 2021, 10:31 am
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  31. I think there is some confusion because the guidance is talking about minor changes under 21.93 and Jason is talking about changes under 21.319.

    Posted by Steven Litke | September 28, 2021, 3:19 pm
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    • Hi Steve. This blog article was published twelve years ago concerning a draft FAA Advisory Circular interpreting section 21.93. It did not directly affect section 21.319. Sections 21.93 and 21.319 use two different standards to define categories of changes.

      Posted by Jason Dickstein | September 28, 2021, 3:26 pm
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  32. Hi Jason,
    Years ago you and I had a conversation where I told you in my opinion PMA holders meet a higher level of certitude than PC holders. I based that on the percentage of parts that get inspected at a PMA facility versus how many parts get inspected at a PC facility. I also based that on the number of days that were allocated for a QSA audit. It is and always has been my opinion that PMA holders have been held to a higher standard. Perhaps its time to stop giving the PC holders so much slack and hold them to the same level of certitude. My humble opinion, of course. B/R, Barb

    Posted by Barbara Capron | July 9, 2024, 12:52 am
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  33. ICA – the manuals, service bulletins, and other documentation that provides instructions to properly maintain the aircraft in order to ensure its continued airworthiness or to return it to an airworthy state.

    Posted by dwhittaker | August 22, 2024, 3:35 pm
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  34. picturesque! Update: Progress Reported in [Negotiations/Talks] 2025 delightful

    Posted by 208sdf104 | April 8, 2025, 6:52 am
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  35. superb! Major Airport Introduces Biometric Boarding 2025 enchanting

    Posted by wrenlychurape | April 15, 2025, 5:42 am
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  36. Although this is a great article. We have dealt with this issue in the last 45 days with newer FAA personnel.

    Without defining the word “product” in this case to mean a model or series without reference to the air carrier’s fleet, the FAA is free to interpret this as “the air carriers’ product”, which is still consistent with how the FAA agent has interpreted the use of technical assist letters in the past.

    The article should be edited or clarified to state that the product in question is applicable to a MODEL or SERIES in general and not specific to the air carrier’s fleet.

    Thank you,
    Robert Tacher
    Director of Engineering
    TEAM JAS

    Posted by rtacher | December 3, 2025, 8:49 am
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MARPA 2025 EMEA ConferenceMay 14, 2025
Thank you for being part of this program. Speakers explored new opportunities for the PMA community, and our 1:1 meetings were a great success.