The Uptime Blog
Aviation Week reported that the FAA is entering the debate about instructions for continued airworthiness (ICA). Specifically the FAA is trying to define what is, and is not, included in the definition of ICA. According to the article, “FAA proposed the policy to clarify its position on the availability of instructions for continued airworthiness (ICA), saying it was not acceptable for manufacturers/design-approval holders (DAHs) to limit the distribution of ICA by placing contractual requirements or adding restrictive language to control the use of the instructions.” The article goes on to say that the FAA’s attempt to clarify ICA has generated a lot of resistance from a number of sources.
At the heart of the problem is Boeing and Airbus (and probably others) who find themselves in a price war, with profits becoming scarce even as they roll out expensive new airplanes. In response, they are trying to generate more revenue by controlling the maintenance, repair and overhaul (MRO) market. Their strategy is based on restricting access to service and parts information, which is considered to be ICA by the airlines, MRO shops and FAA. The OEMs restrict information in two ways: 1) by making ICA available only via their own proprietary software applications; 2) by imposing highly restrictive contract language that limits what airlines can do with ICA. As a result, airlines that purchase the newest breed of aircraft must agree to these terms or they won’t be able to keep those fleets airworthy. (The whole situation is quite ironic because the OEMs have been advertising S1000D data compliance but the purpose of the S1000D standard is data exchange and re-use across multiple software systems. Prohibiting airlines from re-using ICA eliminates the very basis for S1000D.) If they submit to the OEMs' demands, airlines are then forced to learn new software systems and integrate those systems into their own maintenance and engineering (M&E) environments, both of which cost a lot of money. (This assumes the Boeing and Airbus systems work as advertised.)
The reason the FAA is getting involved now is that any restriction on ICA is detrimental to safety—not to mention fair competition. There seems to be a fundamental conflict of interest when the DAH (Boeing, Airbus, et al) has the ability to decide what information qualifies as ICA and what information is proprietary. Any OEM trying to dominate the maintenance business would consider all forms of service and parts information to be proprietary, which is exactly what Boeing and Airbus have done.
Boeing and Airbus' strategy has been emerging for years. It all started with parts, which are typically sold at a big markup (>300% in some industries). To help fight price gouging, the FAA authorized alternate parts (PMA) as a way to lower airline operating costs (and ticket prices) without sacrificing safety. However, that hasn’t stopped the OEMs from (mostly) eliminating PMA through restrictive warranty and lease agreements that prohibit the use of PMA. They now appear to be doing the same thing for maintenance services by controlling ICA and creating restrictive contracts.
This Aviation Week article supports what Enigma has heard from a number of airlines, that Boeing and Airbus are now moving past their (near) monopoly on parts and are starting to dictate which organizations can maintain their products and when the work must be done. The new contract language defines who may access, use and modify the airline’s manuals, bulletins, catalogs, etc. From what we’ve heard, if an airline comes up with new ways of repairing those aircraft then Boeing and Airbus claim to own the new procedures. If this OEM strategy is successful the result will be a complex environment where airlines are responsible for maintaining safe aircraft but Boeing and Airbus will define how much it costs to be “safe.” In other words, airlines will hold all the responsibility and OEMs will hold all the authority.
As described in Aviation Week, the FAA now believes that certain manufacturers have gone too far. FAA Order 8110.54A Chapter 2 Paragraph 3 says, “As stated in paragraph 1 of this chapter, we require DAHs to furnish acceptable ICA to product owners per 14 CFR § 21.50(b). We also require that they make the ICA available to any persons required to comply with the ICA.” That is a clear statement that the people responsible for keeping aircraft flying must be given the information necessary to do their jobs. Since airlines are responsible for airworthiness, how can OEMs restrict critical information? Apparently, Boeing and Airbus are putting their lawyers to work debating the meaning of words like safety, instructions, maintenance, airworthy, etc.
None of this bodes well for airline profits or ticket prices. Monopolies are illegal because they create an unfair business environment. If the OEMs restrict access to ICA then they control the supply chain and can dictate prices. Although we’ve heard that airlines are fighting the Boeing and Airbus strategy, it’s unclear what kind of short-term incentives the OEMs might offer to make the airlines surrender. However, as stated in a previous blog airlines should realize that short-term savings often turn into long-term costs. The OEMs will probably even lean on government politicians to slow down the FAA, but if this isn’t resolved soon only two things are sure: 1) lots of lawyers will get rich; 2) the flying public will get poor.
I recently returned from MRO Americas, where I spent some time walking the exhibit hall, listening to various presentations and serving on a speaking panel, “Regulatory Compliance in the Digital Age.” Here are a few observations from my time in Dallas: the show was busier than I expected, despite the economy; airline concerns regarding the aging MRO workforce are increasing; although my speaking panel was the last one of the entire show it was very well attended. From this I reached the following conclusions:
- MRO remains a critical priority for airlines (no surprise there)
- Airlines don’t know who will be fixing their airplanes in the future (or how they will be trained)
- Airlines want the FAA to give clear guidance and help resolve the significant issues that arise when implementing digital systems
Since this panel was the last topic before attendees left to go home, the Q&A session was informal. Nevertheless, we were surrounded by people asking questions about how to achieve a truly efficient, and compliant, digital MRO environment. The airlines made it clear that they need the FAA to synchronize maintenance regulations with current IT capabilities. Furthermore, they expect the FAA to focus on more than just the airframe and engine OEMs, looking also to the airlines, MRO shops and technology suppliers for input. Airlines want FAA regulations that synchronize safety, maintenance and data standards so that they can be protected from being forced into rigid single-provider systems. (The issue of data standards is very important to airlines as they try to avoid OEM-only systems that may limit their flexibility for procuring parts and service.)
Despite years of IT investment, today’s reality is that airplanes are still being fixed with paper documentation. The result is that after one or two years it is nearly impossible for a maintenance planner to understand an airplane’s service history. It is no wonder that planning organizations take months to properly schedule fleet maintenance and must still repeatedly revise the plan throughout the year.
Paperwork is the bane of our industry, not regulation but literally paperwork. Anyone that has ever been forced to sit on a plane, on the tarmac, waiting for the paperwork to be completed knows exactly what I mean.
The Obama administration is a huge advocate of e-government, green initiatives and consumer safety. These are all issues that the MRO industry embraces. With help from the FAA digital MRO can become a reality, which will improve maintenance operations, simplify safety compliance and accelerate AD (Airworthiness Directive) adoption.
In future blog posts I will speak more on this subject and address some of the preconceived notions that exist around aircraft MRO and the technology that supports it.
With all the news about the mass cancellations of flights across the country in the past two weeks, it’s hard not to think about aviation maintenance, even if you’re not in the business as we are here at Enigma. And I count myself blessed that I was not one of the 250,000 would-be passengers stuck somewhere. In an age when everyone is accustomed to getting what they want instantly—by shopping on the Web, talking on the cell phone, ordering fast food, emailing documents and getting instant messages—being stuck at an airport hundreds or thousands of miles from your destination is incredibly frustrating, to say the least.
Of course, it’s not only hard on the passengers, it’s hard on the airlines too. This problem causes major grief for the airlines; not only are their customers upset, but an aircraft on the ground represents thousands, and sometimes hundreds of thousands of dollars, each day. It’s a crisis, no doubt about it.
We wish we could say, “If the airlines used Enigma software, this problem wouldn’t exist right now!” But it’s not that simple. Automating labor-intensive job card processes and accelerating the delivery of service bulletins are just two of our technology applications that improve aircraft maintenance and compliance. And it’s true that airlines can fix aircraft faster, more efficiently and consistently when they use Enigma 3C, InService Job Card Generator or InService MRO. However, the real problem for aircraft maintenance has been one of economics and technology integration.
Over the past decade airlines have been forced to grapple with overwhelming economic challenges namely: airfare de-regulation, the rise of low-cost carriers and the resulting demand to maximize aircraft uptime. These economic challenges are compounded by the increasing volume and complexity of aircraft maintenance information and the inability for many of these airlines to get that data in a usable format—SGML and XML. (See earlier post.) As a result, maintenance departments have been forced to use manual processes to investigate and compare the many revisions, service bulletins and updates sent out by the OEMs. Performing these tasks by hand is time consuming, expensive and error prone. To make matters worse, once a change in the maintenance data is detected, someone else needs to update the relevant aircraft work plans and job cards as well. All this manual intervention makes the whole process reek of inefficiency.
What is needed is a way to automatically identify technical content changes, combined with a fully integrated maintenance workflow. Regular readers of this blog won’t be surprised to hear me say that this technology is available today. Enigma and other software vendors provide solutions that address these issues, except of course for that nasty little problem of getting usable OEM info.
While the current airline problems seem to be the result of stricter FAA enforcement combined with process flaws in aviation maintenance, the OEMs can’t be let off the hook entirely. The airlines’ ability to use technology to address those flaws didn’t exist in the year 2000 but it certainly does in 2008. Now that the public knows that aircraft safety is at stake, perhaps the OEMs will loosen their grip on the maintenance content and help their customers who have been buying all those shiny new airplanes. If so, it will be the dawn of a new age for airlines, an age where safety and compliance can be easily accommodated within the normal routine of aircraft maintenance. Then all those passengers can get out of the terminals to catch their flights to wherever they need to go.