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Some SSJ100 Parts Work In Regulatory Limbo

U.S. suppliers could be surprised to learn that having an EASA-certified U.S. repair station is not enough to authorize maintenance on Sukhoi’s newest airliner.

U.S. and European regulators are working to solve a regulatory challenge that is preventing some major U.S.-based Sukhoi Superjet 100 (SSJ100) program suppliers from performing routine maintenance on their products. 

The aircraft has been certified by several civil aviation authorities, including Russia’s IAC and, notably, the European Aviation Safety Agency (EASA). But despite early plans to seek FAA certification, the SSJ100—which does not have a U.S. operator lined up—does not have U.S. approval.

Under the safety bilateral between the U.S. and European Union (EU), EASA can certify U.S.-based repair stations, but work performed by those shops must meet both EASA and FAA regulations—a practice known as a “dual release.” However, because the SSJ100 is not FAA-certified, U.S. repair stations cannot legally repair parts for the aircraft since they cannot be restored to the agency’s definition of airworthy—a fundamental requirement in the agency’s maintenance regulations.

An exception is if the parts have stand-alone FAA approval, as opposed the blanket approval obtained via the entire aircraft’s certification. While some U.S. suppliers such as Honeywell obtained such approval for their SSJ100 parts, others did not. As a result, providers are scrambling to figure out how to repair parts that SSJ operators are sending in, and in at least one case, the supplier has resorted to the expensive alternative of providing new parts instead of less-costly repairs.

Regulators last month told a gathering of MRO executives that they are aware of the problem, but cautioned that solving it may not be easy. “That’s something we are looking at internally,” FAA International Policy Office Manager Chris Carter told attendees at the Aeronautical Repair Station Association (ARSA) annual meeting.

Carter pointed to airliner development programs in China and Japan that may present similar challenges if major civil aviation authorities do not certify them. “I don’t have an answer for you today, but it is something that’s on our radar,” he said.

The SSJ100’s U.S. content includes B/E Aerospace cabin furnishings, Hamilton Sundstrand electrical systems, Honeywell auxiliary power units (APU), Parker Aerospace hydraulics, and UTC Aerospace Systems wheels and brakes as well as brake control assemblies, which include parts from other U.S. suppliers. 

Honeywell confirmed that it can repair APUs in the U.S. and at a facility in Germany. Several other suppliers declined to speak for attribution or did not respond to requests for comment, but Hamilton Sundstrand and UTC Aerospace Systems are said to be among the suppliers facing the problem.

One supplier source confirmed that Sukhoi currently has no plans to pursue FAA certification for the SSJ100. Sukhoi did not respond to inquiries.

At a minimum, the issue is causing logistical headaches for some suppliers, requiring work planned for U.S. repair stations to be done in Europe—since EASA certified the aircraft—or elsewhere. But several say their U.S. repair stations are their only options, meaning they cannot work on their SSJ100 components. The suppliers emphasize that while the problem is small—the SSJ100 entered service in 2011—it will escalate as the fleet expands and matures.

Among the possible solutions: obtaining full EASA certification for U.S.-based repair stations, says Karl Specht of EASA’s Approvals and Standardization Directorate. This is not the same as an EASA-approved shop based on the U.S.-EU bilateral, however. Those approvals take FAA’s certification and apply a set of conditions. A full EASA approval means treating a repair station as if it is on European soil, “with the associated costs and the associated audits,” he says. An FAA certification would carry no weight for the purposes of the EASA approval, and the shop would lose all of the efficiency benefits, such as fewer audits, that the bilateral’s mutual acceptance creates.

Specht revealed that one U.S. supplier has approached EASA about obtaining a stand-alone EASA airframe rating to install cabin configurations on green SSJ100s. For large-scale work like interiors airframe maintenance, “it makes sense to invest the money” in a stand-alone EASA certificate, he estimates. But for work such as component repairs, “it will never be cost-effective.”

EASA and FAA are exploring several options, including authorizing releases that would permit U.S.-based, EASA-approved repair stations to meet only EASA regulations on SSJ100 work.

The problem appears to be limited to U.S. content shipped to the U.S. for repairs. Authorities that oversee the SSJ100’s main operators—Russia’s Aeroflot and Mexico’s Interjet—have certified the aircraft, clearing the way for in-country maintenance at approved facilities. Aeroflot and Interjet combined operate 31 of the 43 SSJ100s in service and have 29 of the 65 on order, Aviation Week’s fleet database indicates.

AAR Corp. signed a letter of intent with Sukhoi in 2009 to be part of the SSJ100 maintenance network, but that deal would go forward only if a U.S. operator—which would require FAA certification of the aircraft—emerges.

Specht, citing the SSJ100’s EASA approval, offered another option for U.S. suppliers: “You could always have someone in Europe overhaul [components],” he told ARSA attendees. “That’s one solution.” 

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