You are on page 1of 10

REFERENCE 12-032/MSG-281 - Page 1

AVIONICS MANAGEMENT AND PHILOSOPHY

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

1 The Technical Loop All All AFR

Airlines are worried concerning the breakdown of the technical loop. The technical loop is constituted by the OEM,
the Airframers, and the Airlines. Since the beginning of civil aviation, this loop has been made of exchange of
information between system integrators, component manufacturers, and operators. The three of them are speaking
about in-service issues and are working together to find the efficient solution in term of operational impact, keeping
safety as the key factor.

Since several years ago, due to the necessary investment to succeed in performing the required level of repair,
Airlines have started to build common shops with a pool of components. Technical loop has continued to be effective
through major Airlines who have gone on speaking with OEM and Airframers. Nowadays, to keep their standards,
the smallest operators can choose to work with OEM or with MRO.

The aeronautic business is changing, the OEMs would like to keep repair and overhaul cash flow for themselves.

If this situation happens, it would impact the Airlines, among other effects; what would become of the technical loop?
Airline could not work anymore on their components, could not understand what’s occurred inside. OEMs would not
feel concerned at all by the consequences that component failures can have on Airline operations and would
minimize the issues even more than today. Airframers will lose valuable information from Airlines due to the resulting
lack of technical skills. The loop will then be broken over a no return point.

AMC’s participants are actors of this loop. SPSA and GPC should consider this technical loop as well. Airframers,
and Airlines have to work together in a win-win spirit and have to focus on the technical loop necessity. EASA and
FAA regulations are totally in accordance with this philosophy, as the rules are implemented for safety.

Airlines, Airframer, and OEM comments, please.

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

2 CMM Level III Repairs All Boeing KLM

The current trend is to have independent repair stations perform only level 1 (swapping out boxes) and level 2
(taking out boxes and testing them to filter out no-fault-founds) support. Failed boxes must be sent to OEM for
exchange or level 3 (component replacement) repairs

KLM would like:


1. Current and future CMM’s to contain Level III repairs.
2. Current and future CMM’s to contain all part number information required to perform Level III repairs.
3. That Level III repairs in CMM’s are not limited to OEM parts, but also include information for modules not
manufactured by the OEM.

We are interested in hearing comments of other operators, MRO’s, vendors, and Boeing.
REFERENCE 12-032/MSG-281 - Page 2

AVIONICS MANAGEMENT AND PHILOSOPHY

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

3 Incomplete CMM All All All All TAP

Over the years, airlines have been struggling with incomplete information concerning Level 3 repairs included in
CMMs. TAP is concerned with the new trend where CMMs are more often being replaced by ACMMs (Abbreviated
CMMs) and regular repair chapters are being removed.

Comments from other airlines, Airbus, and suppliers appreciated.

Estimated Annual Cost Penalty: $1,000,000

******11-001******

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

All Components All All type DAL

14 CFR 145.205 requires repair work accomplished on behalf of an operator with a CAMP to be accomplished
per that operator’s maintenance program. That maintenance program would include the operator’s manuals,
work scopes, and other technical documents.

As OEMs get into the MRO business, we are seeing more and more units returned to us with items on the 8130-3
form that are outside of the published manual or our desired work scope. These items include OEM build
specifications and ATE items. The use of that data without the operators express permission constitutes a
violation of 14 CFR 145.205. When we have approached the OEM MROs for access to that information for
evaluation to allow incorporation into our maintenance program, we are frequently hit with barriers under the guise
of proprietary data.

Under what regulatory authority do the MROs feel that they can use OEM data without operators consent? What
near term solutions are the MROs undertaking to add this content to the published manual system? What
precautions are the OEM MROs taking to ensure that the data is not used prior to consent being given by the
operators?

Other operator and vendor comments, please.

Estimated Annual Cost Penalty: $50,000

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

4 Piece Parts All AMC Steering

The AMC Steering Group understands the AMC is a technical forum, but commercial issues are becoming a larger
part of effectively managing the life cycles of components.

The AMC Steering Group would like to ask the airframers if there are provisions in their Product Support
Agreements to control piece part cost escalations. If not, would this issue be a consideration for future revisions to
the PSAs to protect the operators from escalations greater than the Industry accepted escalation indexes?

Airframers, comment please.


REFERENCE 12-032/MSG-281 - Page 3

AVIONICS MANAGEMENT AND PHILOSOPHY


Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

5 PMA Parts/Obsolescence Misc Misc All All FDX

Obsolescence issues are becoming more and more a fact of life as we utilize aircraft later into their life-cycles. For
various reasons, when OEMs declare a piece part or sub-assy obsolete, it can be very costly to re-qualify a new
replacement part for that application. For cases where the OEM has the original specification data for that part and
its unique application, we would like to see that data shared with the operators so we can research and pursue an
existing replacement part or work with the PMA Houses to develop a replacement solution as a new PMAed part.
This strategy could alleviate the burden placed on the OEMs for dealing with some obsolescence issues and make it
more effective for the operators for a long-term solution.

Other operator, supplier, and airframer comments, please.

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

6 CMMs for PMA Parts Misc Misc Misc All FDX

FedEx would like to put forth a better understanding of the confusion surrounding the use of OEM CMMs for PMAed
(Test & Computation) parts. When the operators obtain the Intellectual Property rights to use an OEM's CMM via the
Airframer's Product Support Agreements, the operators then become obligated to use that CMM only for test and
repair of the OEM P/Ns listed on the title page of the CMM.

However, there are statements on PMA paperwork signed by the FAA that basically state there is no technical
requirement for the PMA holder to develop separate CMMs when the original part and the PMAed part are no
different. FAA Special Airworthiness Information Bulletin NE-08-40, dated 08AUG08, also discusses this subject. We
feel the legal compliance associated with the OEM CMM obligates us to use that CMM for the OEM parts only -
even though the FAA states there is no technical requirement for a separate PMA CMM. We're putting the PMA
Houses on notice that for us to consider their PMAed parts, they must come to us with their own CMM.

Other operator, supplier, and airframer comments, please.

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

7 PMAed Parts in LRUs Misc All Misc FDX

We would like to open dialog with the OEMs so we both better understand the maintenance practices surrounding
PMAed or DER repaired parts installed in LRUs. We are aware of instances where an LRU that has a PMAed or
DER repaired part installed is sent to the OEM for test/repair, and that PMAed or DER repaired part is removed from
the LRU even though it is not failed. The OEM states that since they do not recognize the configuration of the PMA
or DER repaired part, they have the authority to remove and replace it with the OEM authorized part.

As long as the operator has published Engineering documentation that approves the installation of the PMAed part
or documents the approval of the DER repair that is operator specific as part of the Operator's Instructions for
Continued Airworthiness for that LRU, any Part 145 repair station that we select to test/repair that LRU must follow
the operator's documented maintenance instructions. These same rules apply for an OEM that has a Part 145 repair
station the same as it applies to a 3rd party repair station. We would like to hear a commitment from the OEMs to
stop this wasteful practice and follow the FAR rules for the Operator's Continued Airworthiness Maintenance
Program.

Other operator, supplier, and airframer comments, please.

Estimated Annual Cost Penalty: $250,000


REFERENCE 12-032/MSG-281 - Page 4

AVIONICS MANAGEMENT AND PHILOSOPHY


Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

8 Service Bulletins All All All All TAP

We have come across SBs in which the required parts are only available months later. We feel that it is pointless to
release SBs if the parts are not ready to be ordered; this leads to time consuming processes in order to get things
straight. SBs are meant to solve problems, not to create them.

Another recurrent problem is that some of the needed parts are not even quoted; again, this will lead to long strings
of emails in order to clarify the loose ends and assess the economic impact of having these modifications embodied.

Other operator and vendor comments, please.

Estimated Annual Cost Penalty: $100,000

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

9 Obsolescence: Last All All All All TAP


Time Buy

This is a very old but still actual issue. ARINC Report 662 addresses this problem, but unfortunately it is not being
entirely followed by some of the players in the market.

We have come across situations in which we were informed by the OEM that they could not fulfill our placed orders
because the parts have become obsolete and were not procurable anymore. To sum it up, the term “last time buy” is
just another buzzword in this industry. We are not particularly happy with this kind of approach.

To ensure that there is a minimal impact to the airlines, we strongly encourage vendors to be more proactive as far
as piece part obsolescence goes. We need to be informed of any LRU internal part discontinuance well in advance.
Let us emphasize once again that we need to be in the loop as well; timelines and action plans ought to be shared
with the operators (SILs and more visits are welcomed).

Other operator and vendor comments, please.

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

10 IFE Systems All Panasonic All 44-20 DAL


Thales
Rockwell Collins

Satellite TV systems, dynamic interactive GUI, cell modems, WI-FI, and other mechanisms allow for upload of
onboard loadable software directly to an aircraft without intervention by a technician on the ground and without
necessarily going through an airline's software configuration control process. We would like to set up a robust
process that has been thoroughly vetted by engineering and quality control to ensure that only certain changes can
be made using only approved tools and procedures, and that there is an adequate verification of the new load on an
aircraft prior to releasing to the remainder of the fleet.

Panasonic, Thales, and Rockwell Collins comments, please.


REFERENCE 12-032/MSG-281 - Page 5

AVIONICS MANAGEMENT AND PHILOSOPHY

******11-020******

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate
Airline

Quality Issue Honeywell MD-11 FDX


Boeing

In APR09, Boeing and Honeywell released a report “Causal Analysis of the Impact on In-Service Performance of
Aging Aircraft System Controllers, Computers, etc.” This report was followed by Honeywell SIL pub
#D200903000055 that states the Flight Control Computer, Display Electronics Unit, Hydraulic System Controller,
Environmental System Controller and Miscellaneous System Controller were experiencing high No Fault Found
rates & intermittent failures due to cracked solder joints on several components on the circuit card assemblies.

Further, they detailed the cause of the cracked solder joints were “due to different temperature coefficients of the
board material and the ceramic integrated circuit cases” and also “in cases for the electronic components
assemblies (ECA), the difference in the coefficients of thermal expansion between the board material and the
aluminum core of the ECA is a factor”.

Considering the MD-11 was less than 20 years old at the time of this report, FedEx finds these revelations most
disturbing since we have fleet types with components much older than this that do not exhibit these problems. The
time and resources to accomplish and the negative financial impact to our operation is astronomical if we were to
implement the 'recommended' solutions. FedEx feels the design deficiency associated with this kind of failed solder
joint integrity is solely the responsibility of the Supplier with over-sight by the Airframer.

Other operator, supplier, and Boeing comments please.

Estimated Annual Cost Penalty: $1,000,000

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

11 Consumables All All THY Turkish Airlines


Technic Inc.

In all CMMs, in Pages 9001 SPECIAL TOOLS, FIXTURES, EQUIPMENT AND CONSUMABLES section, the
consumables are listed with vendors. However, when we go through these vendors, most of the time, obtaining that
specified material is not possible. In most cases, the part numbers are not recognized by both the equipment
manufacturer and the consumable manufacturer.

I propose, to all LRU manufacturers to prepare SPECIAL CONSUMABLE KITs covering all what are stated in the
CMM with few amounts. The package should contain all consumables with necessary last usage date information,
MSDS data, etc. This way all users can request the specific Consumable Kit from related IPC.

This will help to save the environment, will lead to an income via consumables to each LRU manufacturer, will save
time for users, and help each user during FAA, EASA audits.

Other operators, comments, please.


REFERENCE 12-032/MSG-281 - Page 6

AVIONICS MANAGEMENT AND PHILOSOPHY


Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate
Airline

12 EE Compartment Airbus Avionics EE A320 UAL


Unit Corrosion Bay Components
A319

United is submitting this item to request an update of Airbus progress and research on the problem to date. An
Airbus response stated that:

“Airbus has defined an Avionic Equipment Ventilation Controller (AEVC) software change. The principle is to
delay the skin air valves opening after landing. In addition, a new duct temperature sensor will be installed
downstream to assure the blowing duct temperature. The skin air valves opening will be affective when the air
temperature into the blowing duct reaches a defined temperature target. A higher temperature should avoid cold
spots inside avionics computers and thus should reduce the condensation events”.

In addition, different type filters have been tested, but to the best of our knowledge, an alternate has not been
selected.

Has the research been completed, and if so, when will it be incorporated into a SB for operators to install?

Other operator and vendor comments, please.

Estimated Annual Cost Penalty: $500,000

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

13 Avionic Corrosion Airbus A320 All AFR

Referring to AMC 2011 Discussion Item 13 & 14

To reduce Avionic corrosion phenomenon Airbus is working with Thales on an AEVC software change.

Could AIB make a statement on the in service evaluation for the upgrade and let us know if they have reached any
improvement on the matter?

Airbus comments, please.


REFERENCE 12-032/MSG-281 - Page 7

AVIONICS MANAGEMENT AND PHILOSOPHY

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

14 IAWA All AMC Steering

The AMC steering group would like to make our constituents aware of an organization, International Aviation
Warranty Association (IAWA) that is providing industry best practices and guidance on airframe, engine, and
component warranty. The reason for bringing this up is in recognition of numerous AMC Discussion Items related to
warranty issues.

All issues pertaining to component lifecycle management are open for discussion.

Other operators, airframe, and vendors comments?

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

15 Digital Rights All AMC Steering


Management

DRM is short for digital rights management, a system for protecting the copyrights of data circulated via the internet
or other digital media by enabling secure distribution and/or disabling illegal distribution of the data. Typically, a DRM
system protects intellectual property by either encrypting the data so that it can only be accessed by authorized
users or marking the content with a digital watermark or similar method so that the content cannot be freely
distributed.

In addition to DRM, document authenticity as verified from the author to the recipient needs to be addressed.

This might be an opportunity for the AMC to suggest a standards activity on document security so that each
individual supplier does not choose different methods for document security.

Other operators, airframers, and suppliers comments?

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

16 Time Since
All All All All BAW
Workshop Visit

BA currently has a standard early removal Time Since Workshop Visit (TSV) of 1250 hours. This TSV triggers an
additional work package in the workshop to identify the root cause of the removal and a detailed examination of the
unit’s reliability.

What hours do other operators and vendors consider an early removal, and how do they manage it?

Other operator comments, please.


REFERENCE 12-032/MSG-281 - Page 8

AVIONICS MANAGEMENT AND PHILOSOPHY


Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

17 Service Order Misc All All All FDX


Quoting

FedEx controls the configuration and maintenance actions (SB/SIL incorporation) we want accomplished on our
LRUs via the FedEx Policy Sheet process. All Operators should have a similar process to communicate to their
repair vendors the Engineering approved documents and procedures we want accomplished on our LRUs when
they are sent for test/repair.

On occasion, a repair vendor will contact our service order admin group to get approval to accomplish a service
bulletin on an LRU that is not stated on our Policy Sheet. Or worse yet, the repair vendor accomplishes the
unapproved SB work and then expects us to amend the original service order to cover the additional cost. We would
like the repair vendors to understand that since our Engineering Department is responsible for review, approval, and
documenting the maintenance actions we want accomplished on our LRUs, the repair vendor should use either their
on-site rep to work with Engineering directly to inquire about the status of the SB, or in cases for no on-site rep,
contact Engineering Management to assign you a focal contact person to work with.

Other Operator and Supplier comments, please.

Estimated Annual Cost Penalty: $200,000

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

18 Boeing-Designated Boeing B787 AAL


Common-Core
Automated Test
Equipment

We request Boeing provide the status of B787 Boeing-Designated Common-Core Automated Test Equipment
(BDCC ATE) development and projected availability date. We also request other operators comment on
desire/requirement for this equipment.

Other operator comments? Boeing comments?

Estimated Annual Cost Penalty: $10,000 per aircraft (+ $100,000 per aircraft initial cost of additional spares OR $XX
MM for individual component ATE)

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

19 SFAR 88 CMM Boeing All 28 AAL

It is our understanding that the FAA is in the process of changing SFAR 88 CMM requirements. We request Boeing
(or the FAA, if available) provide an explanation of what the changes are, the projected impact these changes will
have on the industry, and the plan for implementing the changes in SFAR 88 related CMMs.

Boeing or FAA comments, please.


REFERENCE 12-032/MSG-281 - Page 9

AVIONICS MANAGEMENT AND PHILOSOPHY


Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate
Airline

20 HP/LP2/LP3/LP4/ ASxxxxxxx Technofan A380 21-21 LHT DLH


LP5/Blowing/ Extract (Safran)
Fan FSCM: F4957
21-26

The CMMs 21-21-43 (P/N AS2222A0x), 21-21-44 (P/N AS1718A0x), 21-21-45 (AS1910A0x), 21-21-46 (P/N
AS2010A0x), 21-21-50 (P/N AS1718C00), 21-26-66 (P/N AS1720A0x), and 21-26-67 (P/N AS2316A0x) contain a
lot of references to ITE-, MOF-, and TSM- documents (example: “Do the procedure given in the MOF4611744600.”).

Technofan informed LHT that these documents are for internal use only and cannot be made available. Without
these documents it is impossible to perform test, repair, disassembly, assembly, balancing, and trouble shooting for
the mentioned part numbers according to the related CMMs. All together we found one TSM, eight MOF, and 19 ITE
references in the seven mentioned CMMs.

Was any airline or MRO able to get the referenced documents from Technofan or able to build up capability
successfully?

Airbus and Technofan, please comment.

Other operator and MRO comments, please.

Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate Airline

21 CNS/FANS B737 SWA

Recently (15 Dec 2011) the FAA posted a proposed policy change regarding the transition from ground-based
NavAids to satellite-based navigation infrastructure. An alarming statement was that WAAS would be required in
Class A, B, and C airspace per 14 CFR 91.225 by the year 2020; in order to meet the availability and continuity
required for ADS-B. This is, essentially, a backdoor mandate to equip with WAAS.

In the Manufacturer’s view, is WAAS required to meet the availability and continuity requirements?

We want to work with Boeing and our Avionics vendors to develop an upgrade path to MMR's that support WAAS,
and preferably other SBAS systems with a partiality to EGNOS.

Southwest would like to hear each of the major avionics suppliers product “roadmap” plans for meeting the mid-
term mandates such as ADS-B and CNS/FANS on both new and retrofit aircraft to meet all planned NextGen
initiatives (ADS-B, WAAS, ATN B2 DataComm, CPDLC, etc.).

What specific equipment do the manufacturers expect to become required? What equipment is already
available? And most importantly: Of the equipment that is expected to be required AND is not presently available
… when??

Airframers and Equipment Manufacturers, comment please.


REFERENCE 12-032/MSG-281 - Page 10

AVIONICS MANAGEMENT AND PHILOSOPHY


Item LRU Name LRU PN Vendor Aircraft ATA From If MRO, the
Associate
Airline

22 Data Loaders All Next TechSAT


Gen

Next generation aircraft are now typically supplied with onboard data loading functions. Do airlines anticipate the
need for shop data loaders beyond repair shop and test applications? How many airlines anticipate off-aircraft data
loading of LRUs to have service ready, fully data loaded spares?

Operators comments, please.

You might also like