There is no doubt that the movement of OEMs into the aftermarket in the last 15 years has caused tectonic change in the MRO (Maintenance, Repair, and Overhaul) and Distribution ecosystem. Such evolution is not uncommon, but unfortunately there appears to be ample evidence that more than a few of the OEMs are unfairly leveraging their monopolistic positions to withhold reasonable access to their repair/overhaul manuals (Instructions for Continued Airworthiness) from independent MROs.

Independent Maintenance, Repair, and Overhaul (MROs) exhibit these characteristics:

• They are not an extension of, or affiliate of an OEM Manufacturer.
• They are not an extension of, or part of an airline.

If you’re such an independent MRO, you’re already painfully aware that many OEMs are making it unreasonably difficult, or impossible, to obtain their maintenance manuals; without these you can’t add new capabilities to your repair station/AMO (Approved Maintenance Organisation). The unavailability of these manuals clearly places an independent MRO at a competitive disadvantage, in fact it may be that this and other OEM behaviors are anti-competitive or monopolistic.

There have been quite a few unheralded skirmishes between the MROs and the OEMs, and to characterize these as David vs. Goliath would not be an embellishment. The latest attempt to get help, this time from the FAA, has come in the form of a jointly submitted letter dated December 27, 2021, from 14 industry groups representing the widest of constituencies in the aviation industry. The letter was addressed to the top Administrator of the FAA, the Honorable Steve Dickson. I’m happy to report that the ASA cosigned the letter, which is attached at the end of this article.
The well authored letter likely originated with ARSA, contains interesting aspects concerning its tack and tone. Regarding these OEM (in which the letter uses the more-specific term DAH, Design Approval Holder) behaviors, it says:
 

The letter proposes addressing the issue as a task delegated to the Aviation Rulemaking Advisory Committee, ARAC. The expected result would be that there would be new or revised, clear Regulations for the OEMs to make available these manuals. If the ARAC takes this on, expect closure, but at a glacial pace.
This is not the first time I’m writing about these OEM issues. Here’s a compilation of the articles and links:

“AIRLINE MAINTENANCE COSTS WILL GO UP”

“OEM ANTI-COMPETETIVE, MONOPOLISTIC PRACTICES IN THE AFTERMARKET”

The International Air Transport Association (IATA) which represents hundreds of airlines globally, deserves special recognition since they have taken on one of the largest OEMs to court, since settled, and may be taking on more (for more information, read my previously cited articles). Given the impressive lineup of IATA, the 14 Organizations cosigning the letter, the thousands of airlines, business aircraft operators, distributors, repair stations/AMOs, and aircraft owners which they represent, it is clear they are fed up with these OEM practices and lack of government intervention.

I’d like to conclude this article with an appeal to those OEMs exhibiting these behaviors. All these people know who you are, and your names are mentioned in terms which if quantified and made known, would puncture your ESG score (Environmental, Social, and Governance). Is it really worth a blemished reputation to continue these behaviors?

The letter:

Over ‘n out

Roy “Royboy” Resto

www.AimSolutionsConsulting.com