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Posted (edited)

As far as I know a type design isn’t protected. There are no parts that I’m aware of that a PMA manufacturer can’t produce and sell.

In the past when one manufacturer gets ridiculous in pricing a PMA manufacturer sees the potential profit and starts producing the part, but also when a manufacturer loses interest in producing parts for old airplanes, that’s Wag Aero and Univair’s business model. They didn’t need to get permission from the manufacturers. Also junk yards start being searched for these ridiculous priced parts. The OEM ends up selling none and their price gouging backfires. I’ve seen it personally, it’s one of the first thing a failing manufacturer resorts to to increase cash flow.

I’m not aware of any part that isn’t available for my little C-140 for instance. I’m not counting major assemblies like wings or a fuselage, just parts.

I’m sure some aren’t available but I’ve not experienced it myself. After I got mine I disassembled and inspected it and I had to replace both front and rear main spar carry throughs and the vertical fin spar from corrosion, all three were shipped as they were in stock and as I don’t remember the cost it wasn’t stupid. I think I got them from Univair, but that’s been almost 20 years ago.

I’ve just assumed neither produces Mooney parts out of respect hoping Mooney will survive, but have no idea really why they don’t, perhaps the market isn’t there?

Cablecraft etc that are price gouging I’m sure are PMA manufacturers. I’d suspect the same type of crap if Univair and Wag Aero got bought by crooks too as it seems that Hartzell was. That really surprised me knowing Joe Brown and Hartzell’s respect for their employees etc. I hope he just got hood winked and didn’t know what was going to happen.

I don’t know how much we can blame it on the FAA to be honest, as a former manufacturer I got the belief that much of the FAA honestly wanted out of the little airplane game and in my opinion the relaxation of recent regulations seem to support that. 

I think it’s crooks, and I have no idea how to protect against that, but I feel sure that Government regulation isn’t the answer.

 

I suspect that maybe the FAA has too many road blocks in place to become a PMA manufacturer and or that they are over regulating the existing ones to death. That’s where I hope that if Elon gets that job that he may do something about that as he has been battling the Federal Government at every step for both Space-X and Tesla

 

Edited by A64Pilot
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Posted

The Type design DRAWINGS are protected 

Univair bought type designs from the old manufactures in many cases and could make parts to those drawings.

That is why you can't just "make a part" that qualifies to the approved type design unless you have the drawing.

Even if you hold a PMA

On OPP you have to show some kind of reference to an approved drawing or reverse engineer the part (DER).

The FAA can't release the drawings as they are controlled by the Type Design Holder.

You can't just "make" a short body elevator spring bungee without reference to the drawing that

Mooney made it to- unless you get a DER to sign off on a reengineered bungee design (just a case in point).

As to PMAs- They only allow someone to manufacture aviation parts  - NOT a specific part unless it comes from

someone's  approved drawing.  

A PMA and Approved Parts are two different animals. 

In the case of a dead manufacturer you can in some cases petition the FAA to release the protected drawings.

Posted
On 11/6/2024 at 3:57 PM, Glen Davis said:

My mixture cable needs replacement and the McFarland replacement cost about $800 according to my mechanic. It’s a 1989 M20J. Could that be correct?  Seems expensive.  

Not sure if it was mentioned in the thread….but…IIRC….the price of the PMA cable is much more than the “owner” produced cable where you simply fill out the form to match what is in the aircraft currently.  The cables are essentially identical, but they are building to your specs vs theirs… I suppose that limits their liability and also likely reduces paperwork burden.  Give them a call about having a custom cable made….and I think the price might be more appealing.  They make good stuff…

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Posted
30 minutes ago, takair said:

Not sure if it was mentioned in the thread….but…IIRC….the price of the PMA cable is much more than the “owner” produced cable where you simply fill out the form to match what is in the aircraft currently.  The cables are essentially identical, but they are building to your specs vs theirs… I suppose that limits their liability and also likely reduces paperwork burden.  Give them a call about having a custom cable made….and I think the price might be more appealing.  They make good stuff…

That is basically the OPP route with them

YOU take a part in designing the cable via their paperwork

I did mine that way. 

They then make it using their APPROVED manufacturing procedures. 

YOU have to sign the log book that you took part in the design of the part (saving the order form)

and then your A&P can install it a sign it off. 

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Posted
40 minutes ago, cliffy said:

That is basically the OPP route with them

YOU take a part in designing the cable via their paperwork

I did mine that way. 

They then make it using their APPROVED manufacturing procedures. 

YOU have to sign the log book that you took part in the design of the part (saving the order form)

and then your A&P can install it a sign it off. 

Thanks Cliffy, do you know if they still do it?  My recollection was that it was almost half price for the same quality..  I did a couple of mine that way a few years ago.  They will also make throttle with the cut outs for the gear switch.

Posted
7 hours ago, A64Pilot said:

Cablecraft etc that are price gouging I’m sure are PMA manufacturers. I’d suspect the same type of crap if Univair and Wag Aero got bought by crooks too as it seems that Hartzell was. That really surprised me knowing Joe Brown and Hartzell’s respect for their employees etc. I hope he just got hood winked and didn’t know what was going to happen.

I don’t know how much we can blame it on the FAA to be honest, as a former manufacturer I got the belief that much of the FAA honestly wanted out of the little airplane game and in my opinion the relaxation of recent regulations seem to support that. 

I think it’s crooks, and I have no idea how to protect against that, but I feel sure that Government regulation isn’t the answer.

You should not be surprised that Joe Brown and his family sold Hartzell to Arcline Private Equity. This is a typical dilemma for family owned companies facing transfer of ownership between generations.  It is exceedingly rare today for all descendants to want to remain involved in and owning equal shares of a family business.  Many times some or all the kids have no interest in the business.  And the kids with “passive” ownership may not be satisfied with the slow drip of cash dividends.  Siblings in a second generation transfer may hold it together “for the sake of dear departed dad” (Joe Brown’s father created the group and I think Joe had a brother in the business). 

But Joe Brown was facing a third generation transfer that involves equal shares of cousins. The fragile family coalition generally falls apart when when the company wants to make a bold move, make an acquisition etc and needs to borrow a lot of money.  Not everyone wants more risk, deferred dividends and longer (but hoped for greater) payouts.  

Some family members will want to cash out now.  It is easy for Private Equity to pick off a disenfranchised family member and get them to agree to “sell out for a few pieces of silver”. This creates a crisis amongst the family. The other family members usually can’t raise the cash personally to buy out the ones that want out. Like a house of cards the family ownership collapses. The easy solution is to sell the entire business out to Private Equity  - everyone gets rich quick  

You are seeing it in all the family owned FBO’s that are selling.  With the accelerating decline in integrity and ethics why would kids want to take risk and work hard when you can “get rich quick”?

BTW .  The same thing is going on in the services trades -HVAC,plumbing and electrical.  Private equity is driving consolidation so that they can stick you with higher prices especially on urgent repairs.  I have started to notice this in Houston - heavy advertising of previously little known companies with everyone driving fancy new trucks. One quoted me 3x the price of a small individual plumber driving an old truck  

https://sherwood.news/business/private-equity-trade-small-business-acquisitions/

https://www.forbes.com/sites/jackkelly/2024/10/17/private-equity-taking-on-skilled-trades/
 

https://www.forbes.com/sites/davidwmccombie/2024/07/16/private-equity-is-coming-for-your-ac-repairman/
 

 

 

 

 

 

Posted
2 hours ago, takair said:

Thanks Cliffy, do you know if they still do it?  My recollection was that it was almost half price for the same quality..  I did a couple of mine that way a few years ago.  They will also make throttle with the cut outs for the gear switch.

I don't know if they still do that. Haven't needed it in years. Mine still works fine :-)

Posted (edited)
On 11/10/2024 at 6:43 PM, cliffy said:

The Type design DRAWINGS are protected 

Univair bought type designs from the old manufactures in many cases and could make parts to those drawings.

That is why you can't just "make a part" that qualifies to the approved type design unless you have the drawing.

Even if you hold a PMA

On OPP you have to show some kind of reference to an approved drawing or reverse engineer the part (DER).

The FAA can't release the drawings as they are controlled by the Type Design Holder.

You can't just "make" a short body elevator spring bungee without reference to the drawing that

Mooney made it to- unless you get a DER to sign off on a reengineered bungee design (just a case in point).

As to PMAs- They only allow someone to manufacture aviation parts  - NOT a specific part unless it comes from

someone's  approved drawing.  

A PMA and Approved Parts are two different animals. 

In the case of a dead manufacturer you can in some cases petition the FAA to release the protected drawings.

You can make parts like cables that aren’t complicated without drawings, even lowly A&P’s can. For example many ribs etc are fabricated every day for repairs without drawings. Yes drawings make it easier but aren’t required.

PMA manufacturers IF they have the capability can build any part, capability is the issue, Univair can’t build Compressor turbines for instance.

What do you think the likely hood is that Lycoming gave Continental their drawings and permission to build their cylinders for instance? Yet they do.

GE entered the turboprop market years ago in response to Pratt building PMA parts for the GE engine used on the 737 (CFM), before then they had an unwritten agreement that they wouldn’t build each others parts. Apparently neither company makes any money from sales of their big Commercial engines, the real money is in parts that keep that engine operating. You can choose engine manufacturer but until Pratt broke the agreement parts were pretty much sole source as it take a LOT of money apparently to be able to build those parts.

So no, unless Patented parts are not protected

Edited by A64Pilot
Posted

Lets digress a little here-

Yes an A&P can make some "parts" that conform to some "approved" method. (accepted? -)

In the two items you cited, ribs and cables both are covered by the "approval" of 43.13 Accepted Techniques and  Practices

But even with that there is the limitation of-

This advisory circular (AC) contains methods, techniques, and practices acceptable to the Administrator for the inspection and repair of nonpressurized areas of civil aircraft, only when there are no manufacturer repair or maintenance instructions. This data generally pertains to minor repairs.

It goes on to state -

 

The repairs identified in this AC may only be used as a basis for FAA approval for major repairs. The repair data may also be used as approved data, and the AC chapter, page, and paragraph listed in block 8 of FAA form 337 when:

a. the user has determined that it is appropriate to the product being repaired;

b. it is directly applicable to the repair being made; and

c. it is not contrary to manufacturer’s data.

SO while yes an A&P CAN "make" some parts they are always made to some kind of approved or accepted data. 

And it is always in the realm of "REPAIRS" to a particular airframe. 

No A&P can  make parts (say a rib) in bulk and sell it on the open market. 

A&Ps do repairs - they don't "manufacture" parts. 

The connections you cite for P&W and GE are way beyond the scope of this forum. 

We are confusing "parts" for repair and parts for manufacture  and sales.

The "Type Design" package that describes every bolt and nut on any complete airplane is the property of the Type Design holder.

That "package" of data is submitted to the FAA for approval so the manufacturer can make exact copies of the airplane for sale.

 Every airplane made is compared to that data package to make sure it "conforms" in every way to the approved data ""Type Design"

Any changes to that data require some sort of approval. 

Every part, item, screw or nut in that package is verified to the approved design on every produced airframe.

Each part has a drawing describing exactly how that part is to be made. What material, what process, what heat teat, etc.

If you don't have access to that approved data you can't make a part conforming to the approved data.

One can always hire a DER to design a part and APPROVE  a part and that also works when the original drawing is not available. 

As I noted in some instances the FAA will open a Type Design package for a request to make a part available but this is a rare occurrence.  

In short = the Type Design package that the holder owns is protected property by the FAA and not usually released

As to the PMA holders- YES they can make any part they have the capability to make YET they still have to make it to an "approved design drawing". they can't just pull the design out of thin air, It has to have 'traceability" back to the original drawing OR be approved by some other manner such as a DER.  

Think of a PMA as approval of your quality control process rather than an approval to make a particular item. A PMA approves the process and not the part. 

 

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Posted (edited)

43.13 doesn’t cover manufacturers.

Like I said, do you think every PMA manufacturer of parts gained OEM approval for the parts they manufacture? 

Pratt building GE parts or Continental and several others building Lycoming parts like cylinders and a whole list of other things is the point.

If Conti, Superior and who knows how many other PMA manufacturers are allowed to build Lycoming engine parts, then certainly one can build a throttle cable. 

Of course they likely get DER approval, I never said they didn’t. Most probably they have DER’s on staff, I did.

I manufactured Type Certificated aircraft from about 2003 to 2017 or so, I’m familiar with the process. A throttle cable would be very, very easy. It’s essentially a standard part with a specified length with a slot cut into it.

 

First sentence of the FAA definition of PMA covers it

“ A Parts Manufacturer Approval (PMA) is a combined design and production approval for modification and replacement articles. It allows a manufacturer to produce and sell these articles for installation on type certificated products”

https://www.faa.gov/aircraft/air_cert/design_approvals/pma

 

Edited by A64Pilot

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