Aircraft modifications are back in season as airlines return aircraft to service, vie for returning business and other premium travel, and seek to exploit the revolution in inflight entertainment and connectivity enabled by the new low-earth-orbit satellites.
But mods can be delayed, made more expensive and create problems over the longer term when an operator has separate contracts with the mod’s design organization and its production organization. Nina Shulz, managing director of the Independent Aircraft Modifier Alliance (IAMA), says neither organization is really an integrator, responsible for all aspects of the mod project. The companies are separate and may even be competitors.
“You don’t have anyone take full responsibility. Workscopes may be unclear, quotes may be based on incorrect assumptions,” Shulz explained in a recent webinar. She adds that there will be many technical and commercial interfaces in any large mod program: “All could be potential problems.”
To prevent or minimize difficulties, IAMA has developed rules for IAMA members and for IAMA-endorsed supplemental type certificates (STC). IAMA Technical Affairs Director Ian Devine outlined these rules for efficient cooperation between design and production organizations working under separate mod contracts with the operator.
The principles of efficient cooperation are thorough project management, proper documentation, continuous communication and full visibility into costs and risks for the customer. These principles apply during the entire mod lifecycle, from initial request for proposal through project kickoff, development, prototyping, after-sales support and management of ‘orphan’ STCs.
Devine stressed that the rules may also apply to other companies that provide critical parts and services for the mod—what IAMA calls ‘key contributing parties.’
For example, the communication plan must have collaborative tools for “honest and proactive reporting,” Devine said. The customer is thus informed about all subjects at the important interfaces between design and production organizations.
And these organizations must have documented processes for monitoring and controlling those key contributing parties. If one of these key parties is not under subcontract—for example, buyer-furnished equipment—the prime mod organization must define interfaces, working arrangements and risks.
Further, design and production organizations must track costs and risks throughout the project and share these with the customer at major milestones.
At the Initial Technical Coordination Meeting, these organizations should agree on the project milestones and the interdependencies between the organizations. Afterwards, they monitor and control schedule drivers such as dynamic testing, schedule buffers and instructions for continued airworthiness. All initial plans must be updated as the project unfolds.
Shulz noted that in many mods, data is developed by third parties—for example, separate design and production organizations when these are used. IAMA has written a white paper on how access to this third-party data should be handled, including who gets access, the extent of access and how to protect the intellectual property of the data developer.
Data requirements arise in three major categories: First, in the case of similarity using already approved parts, where a limited set of declarations of design and performance, testing and reports is required; second, for retests and examination of already approved parts, where a larger set of declarations, tests, reports, drawings, software and process documentation is required; and thirdly for new parts, where a full set of all the above will be required.
For all three categories, Shulz recommends that data requirements be handled up front by the design organization and the design approval holder at the initial technical coordination meeting. These companies should then identify any potential data gaps and make sure the key contributing parties understand the benefits of providing data. The design organization and approval holder should also prepare data usage and non-disclosure agreements well in advance of the mod project itself.
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