John Walton: Hello and welcome to Runway Girl Network In Conversation, a deep dive into aviation and the passenger experience. I’m RGN deputy editor John Walton and today I’m in conversation with Nicole Noack, head of IAMA, the Independent Aircraft Modifier Alliance.
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Walton: Now, Nicole, welcome to In Conversation.
Nicole Noack: Thank you, John. Thank you for having me. I am, at the same time, grateful and excited for the chance and happy to talk to you here.
Walton: I’m delighted to have you on the show. So, let’s kick off immediately. Who and what is IAMA?
Noack: That is actually easy to tell. So, who is IAMA? Above all, IAMA is partners and competitors from the STC – Supplemental Type Certificate – providing sector. We’re doing aircraft retrofit modifications. Its partners and competitors, and the four founding members, are EAD Aerospace, Envoy Aerospace, Etihad Airways Engineering, and Lufthansa Technik. They are equal founding partners.
Noack: And the good thing is we already gained one additional partner and future member of our IAMA association, which is Euro-Composites who lately joined in early September.
Walton: Fantastic. So, let’s talk about your members and what exactly they do. I am an airline: how would I approach one of your members and what would I be approaching them for?
Noack: So, as an airline, you are interested in getting your modifications. So, if you want to invest into a new connectivity solution, if you want to invest in a new cabin upgrade, you have two possibilities to do so. You either do it via an OEM SB, or you can go over some supplemental type certificate. And that is where IAMA comes into the place.
Noack: So we faced a lot of feedback having the STC being a bit of an uncertainty, and that is where your airline would come to: IAMA, which we see as a home of the STC, where they can get independent information about the values of the STC and where they find reliable partners. We stick to a certain standard that they can be ensured [of] meeting the requirements they have with their modification until we fit it into their aircraft.
Noack: So, they can reach out by our website and we will, in the future, also build an IAMA platform online. And, of course, we are real people so we can be also contacted by email or phone.
Walton: Right. So, when we’re talking about the OEM SBs, which now let me make sure I get this right, that’s the original equipment manufacturer. That would usually be Airbus, or Boeing, or Bombardier, or Mitsubishi, or someone. And the SB is a service bulletin, right?
Walton: Okay. What’s the difference between a service bulletin from an airframer and a supplementary type certificate?
Noack: So, basically they are doing the same thing. They are there to approve a modification into an aircraft by a national authority like EASA in Europe, or the FAA in the United States. So, those follow the same requirements, you have an OEM SB or supplemental type certificate. There is a few differences when you go while you’re in OEM SB, that becomes very technical. It is an amendment of the TC, which is handled a little bit differently by the authorities than the STC. The OEM SB can only be done by the manufacturers like Airbus and Boeing. The STC can be done by any design organization under EASA, or by an applicant on the FAA side. So, that’s the independent part.
Walton: I see. Okay. So, what would I be wanting if I’m an airline coming and looking? Is this a new set of seats? Is it installing Wi-Fi? Is it winglets? Is it all of those?
Noack: So, basically is it mainly related to passenger experience within the cabin, and also in the connectivity sector. It also can be related to cockpit upgrades, when you have an AD note from an authority to fulfill. And as we see lately that airlines are also investing into sustainability measures into reducing fuel consumption. It, of course, could be modifications done on the airframe itself. What we mainly talk about is major STCs, so really having a modification with a major impact.
Walton: Right. And so a major impact versus a minor impact would be what kind of thing?
Noack: A minor impact could be like a just exchanging seat cushions, or something like that, which are already approved and you would only go into a minor change in your cabin layout, or cabin feeling.
Walton: Why was IAMA created? Why did these four, now five, providers decide that actually what we need to do is we need to come together? Because this is quite a disparate set of organizations, right? I mean, you’ve got people from all across the world here. What was the driver behind it?
Noack: So, actually that the driver behind it is that the challenges the STC providers and integrators face at the moment in the retrofit market, they unite us and they unite us us worldwide. And those challenges, they appear because of the rising influence of the lessors, so there is more and more aircraft, as you’ll certainly know, being on lease, and the lessor has very different demands than an airline which might operate an aircraft in the whole life cycle.
Noack: So, when it comes to the transferability of your aircraft from Europe to the United States to Japan, there’s always different national authorities to be involved, so. And the lessors, of course, demand that there’s an easy process. We do not have that at the moment, it’s not easy. So, we also have quite often uncertainty on the customer side how STCs affect the aircraft value, like the operational limits of the aircraft when it comes to aging aircraft. When it comes to AD notes there’s a lot of uncertainty. What does a modification, a major modification, do to my aircraft?
Noack: And last but not least for the independent providers of STCs, also the access to intellectual property, which we need as a base for certification and approval, becomes harder with the new technologies on the Airbus 350, or on a Boeing 787, and that is actually where the partners felt, even though they are also competitors like EAD and Lufthansa Technik, that a joint approach would help all of us and would really also help the whole retrofit community to solve those challenges. And that is why we created IAMA to have an umbrella where we can solve the challenges I just named.
Walton: Okay, interesting stuff. So, what are some of the first things that IAMA has been doing? So as you know, I think we were all first introduced to IAMA this April in Hamburg at the Aircraft Interiors Expo. What’s been the response and what have you folks been doing in the meantime?
Noack: So, their response was quite good. So, in the meantime what we are concentrating on is our core of the IAMA and our key initiative number two, which is the STC rule book. We named it like that because what we aim to do is to gather the pains and demands of the operators, and also the lessors, as I just named, to really evaluate them over the whole lifecycle of an aircraft and to create requirements for a standard to overcome those pains and to fulfill those demands.
Noack: So, that is the very core. That is on the one hand side, really technical work to do. And on the other hand, we of course will also create an online access to that standard. So, we call it a IAMA Community Platform where our members then can access the standard and the best practices developed. That is the very core here.
Noack: We also already had a first attempt to address key hurdles in modification while taking part in CabinSpace Live at AIX LA, and we will go on with that throughout the year 2020 to really address pains where we know the answer is already there, right? And beside that, last but not least, of course we do win new members like Euro-Composites, and we are in extensive talks also with other potential members to join.
Walton: Okay, so when you talk about this STC rule book, what does that look like? Is it a standards document? Is it a set of specifications? Is it when you … I don’t know, I’m just brainstorming here. Is it when you replace a radome and we’d have to do these 15 things to make sure that you’re doing compliance? What does it look like?
Noack: So, first of all, it will not look like a simple standard document. So, we will make it interactive and this standard will not refer to technical requirements because there is already standardization organizations like the SAE or ARINC doing those technical standards.
Noack: Our attempt is to really go through the whole process of a modification project approved by STC, from an RFP phase over the development of the solution, to the serialization into the aircraft, up to the after-sales, and at the final end maybe the de-modification of the modifications. So, that is the phases you always have in a modification project, and if every single phase you have the pains of the operators, which actually are addressed to our members in feedbacks. But also if you look to IATA, they have a best practice document for doing cabin modifications, which is full of addressing risks.
Noack: And we see us as being the answer to those risks to develop solutions for those, to put it into our IAMA rule book so we will have smart measures, and to really audit our members against that so that an operator or lessor can be sure that we will follow those rules. And his provider, coming from an IAMA member, will follow those rules when doing a modification project. And this will significantly reduce the commercial risk, which is at the moment, seen in some major modifications.
Walton: Right. And so the end result is, if I’m understanding you rightly, that airlines who are taking aircraft from lessors can do more improvements, and more easily improvements, inside their cabins without having to go back to the lessors who are they concerned about what that does to the residual value of the aircraft to subsequent operators?
Walton: Okay, right.
Noack: So, that is where we see the big advantage. When we achieve an IAMA standard, which is comparable with the advantages at some points the SB might have when it comes to transferability, and also combines the advantages the STC has with its flexibility and the speed you can bring into a project. Then there is more choice for an operator to go either the one or the other solution. And at the end for the final customer, for the passenger, it will ensure that new technologies and new comfort will be brought up into the aircraft at a certain speed into the whole fleet of an operator.
Walton: Right. So, then that sounds like that’s a whole bunch of benefits. You were mentioning the different phases of a modification and then of course the de-modification at the end of an … Well, either an aircraft’s life cycle rather or between operators. Which of those phases do you see as having the most complicating pain points, as you call them, for for operators and also for for lessors?
Noack: So, I think from the operator side … If we just put out at the moment the lessors side and only think on the operator side, the pain might already start at the very beginning of putting together a really good statement of work for that request or proposal, because the statement of the work is the core of everything it sets up. So, that is from the operator side, to have a supplier who really fulfils certain requirements in the RFP process already would set up the success of the whole project from the beginning on because you can lose the modification project already at the very, very beginning with a weak statement of work.
Noack: But also, after-sales is a heavy impact for the operators. So, if we consider that modification being safe and secure because of past approval from the authorities, and if we consider it being in the aircraft in operation, then of course the operator needs the support from the STC provider and owner in case of impacts, in case of a defect, when it comes to spare materials.
Noack: So, the whole availability of your provider during the the phase you operate that modification is also a crucial point from an operator’s side and to be safe here.
Walton: Looking back at the statement of work before you begin, what are some of the common pitfalls that you’d see airlines falling into? Is it just that they don’t go far enough down the track of how this all works? Is it that they don’t have enough of, I guess what in a project management terms you might call, a quote-unquote intelligent customer function and they don’t understand well enough how the MRO world works? What are the things that go wrong there?
Noack: So, I think we cannot expect, as an STC provider, to always have an, as you called it, intelligent customer, right? Because there is airlines who might not have that deep technical understanding of putting together a statement of work, there is other airlines which have engineering departments which can.
Noack: But, I think the most important thing is to be aware that a statement of work really influences the whole project. And what we see here from the STC provider side is statements of work which are very detailed, which are a good base to get a quotation on, and also to plan for the work on. But, we also see requests for proposals just saying, “I want a new premium economy class installed. This is my seat manufacturer.” And that’s it, and that it’s really something where you then have to work together with the operator to really get an idea of what they really want, except those seats.
Walton: Right, exactly. So, I mean you could literally have an airline saying … and I’m assuming this would generally be smaller airlines, right?
Noack: Yeah. Generally, yes. But, as I said, I would never blame that airline for that because they might not be aware of the impact of a statement of work, so.
Noack: But, from the IAMA perspective, what we put together here in our rule book that our members have to make them aware and have them to guide through that RFP process, in this case the statement of work, so that there is an achievable goal at the end of the project. So, that is the other part. So, it is one thing to just blame the airline, which I will never do because there’s limited resources, but there is a responsibility on the STC providers side to say, “Look guys, I need more information. Otherwise, I cannot give you a reliable quotation and milestone planning for such approach.”
Noack: So, this is on both sides, and we on the IAMA side we sit on the STC providers side saying, “Okay, we take that responsibility and we guide you through if you do not have the resources in-house.” So, this is something we will put into requirements, and also develop best practice material for the STC providers so that they have help already in that space, right?
Walton: Yeah, right. I mean, that makes a lot of sense. So are you going with the airline then to their seating provider and having joint meetings and joint working and saying, “Well actually, okay. We can install this in this way, it will require X, Y, and Z. What you imagine might happen wouldn’t be able to happen because of A, B and C.” Is that the kind of joint working that IAMA is facilitating at this point?
Noack: So, we will make sure that our IAMA members will facilitate exactly that. IAMA will not necessarily act as a full consultant, we can give advice, independent advice, and we will give that to our airline or lessor members if requested. But, we will make sure that whenever an operator or lessor requests an IAMA member that they follow the requirements in the RFP process, which were developed under IAMA, and this will include a good guidance for the whole RFP process.
Walton: Right. Okay so, and as you say, it’s interactive so that an airline can really customize it to what they’re looking for?
Noack: Absolutely. Because every project is unique, and what we will do is we take the demand and the pain, we break it down into requirements in the several phases. And it could, of course, be that a certain pain isn’t a risk, if it’s just another word, it’s not even seen in a specified project.
Noack: So, if you already know that you will have a de-modification before your lease end period, you do not mind [having] to fulfill all the requirements when it comes to a better worldwide transferability. So, you just cross that out and you can then generate your personal project rule book, which we you can as an operator attach to your RFP. So, that is the idea behind because every project at the end is pretty unique.
Walton: Right, exactly. And let’s come back to that worldwide transferability point that you were just talking about. I feel like there are a lot of people who would imagine that between the joint aviation regulations and all of the partnership working that’s been going on between EASA and the FAA, as, you know, the certifying nation providers there.
Walton: I feel there’s a lot of people who might think, “Well, isn’t it already the same? Why is this not all already harmonized across the world?” What kind of things would differ? Whether that’s between the FAA and CAA or between other national regulations, perhaps regulators that don’t have a domestic commercial aerospace industry?
Noack: Yeah. So first of all, the question why it is not already harmonized is a rather good question to raise with EASA or FAA and all the other national authorities. So, we are already a step further having good bilateral agreements in place, right? But with the EASA, or the FAA, the TCAA [Transport Canada Civil Aviation Directorate], and all major national authorities? I would say with EASA and FAA you can more or less by bilaterals cover every single country and every national aviation authority. But, that’s only the one side of the story, right?
Noack: The timeline you need for validation can differ in a project depending on what you have installed, because the national requirements might not be the same. If you have an EASA project and EASA approval and you hand it over to an authority having higher requirements in a certain area, like in a certain certification area, then you have to redo your certification on that point and that is time costly.
Noack: And the same on the other side is when it comes to the access of the documentation. If you as a lessor do not know where your aircraft goes next because you just lost your customer for whatever reason, and you have an aircraft on ground, you remarket that and unfortunately your new lessee is not from the same national authority, you have to validate it. You have to have access through the STC documentation and this is the pain really the lessors feel and fear when it comes to STCs. Because lets say I have non-reliable processes, even though there’s bilaterals, it is not predictable, the timeline, from the handover of the aircraft to the validation of the STCs. And that is where IAMA wants to work on with our working groups where we indeed combine the knowhow of EASA and FAA.
Noack: So, you very first of all mentioned that we are pretty much spread over the world. So, we cover already with Envoy the FAA, EASA, and also we have Etihad with us. So we will put in those experience together and to see what best practices we have to make that process smoother from the STC documentation side. And we also reach out to the authorities themselves to say, “Okay, what’s actually your pains when you receive STC documentation for validation? How can we make your life easier so that we can have, at the end, a smoother process for everyone?”
Walton: Right. I mean, and that seems to make lot of sense. I mean, I just wanted to dive a little bit deeper into the kind of differences that you’ve be seeing here. Is it the kind of thing where, for example in terms of seating certification say, EASA allows a little bit more grandfathering of 9g certification for certain aircraft whereas the FAA doesn’t? The FAA had that cut off a few years back where they said, “No, look, every aircraft now has to be certified to 16g —
Noack: The 16g, yeah. That’s a pretty good example. And you have to know that in advance so if you go to FAA or EASA, that is easy to overlook, let’s say, the differences between those two. But, when there comes then other national authorities in, there might not even be the overview at every STC provider to fulfill that, and you usually do not fulfill that: if you are requested for an EASA STC you go on the EASA approval base, right? Or certification base. You will not automatically fulfill harder requirements because you set those together with the authorities at the very beginning of a project.
Noack: And that’s where we really need to start and where we need to start to evaluate and develop some methods which we pulled into the standard rule book, if it comes to such a requirement, to have that insight at the very beginning of the project.
Walton: To try and put this into a little of a real world context. Is this something like … I’m a lessor and the first operator of my aircraft is a certain LCC in Europe, and let’s just say it’s an A320 family aircraft for sake of argument. And then either I know, or I know that I might want to then, for the second operator of the aircraft some six to eight years later, say move it to the United States or somewhere that has those higher standards.
Walton: What do I do as a lessor and/or first operator airline? Is it that I make decisions about the cabin outfit based on what I assume will later be necessary? So for example, I make sure that I don’t take 9g seats if I’m going to want to pass those seats onwards? Is that the kind of decision that this helps to steer and to form?
Noack: Well, this is actually something which probably the lessor might already have in the contracts. So, we go even further. The example is still pretty good with coming from the seats because the one thing is you have the seat approved on a 16g or 9g base, that is the one thing. If you have the equipment of fulfilling the tasks up to 16g, you are on the safe side on the equipment.
Noack: But it also … you have to have it approved within the modification project itself. If that analysis only reflects 9g then you still would have a problem in validation. Luckily, not because the seat doesn’t fulfill the 16g, but just the certification. But, you would have to redo your certification paper on that point. And we know that as an STC provider in advance that we say, “Okay, you guys have to be compliant with EASA and FAA.” Well, that is a requirement which could be fulfilled, but you just have to state it somewhere and to know it and make it a requirement.
Walton: And the benefit of IAMA in all this is that IAMA’s STC rule book tells people this in advance in, as you’re saying, this kind of interactive way so that they understand exactly what they’re going to need to do to minimize later headaches down the road.
Noack: Absolutely. So, that is the advantage on the operator’s side. And we also go that far that we say, “If we do not have a simple solution, like: just do certification for EASA and FAA in parallel.” That would be simple because you already … Well, simple is hard work here. You already do that, right? So there is a certification basis answer, and you can do that, you can do the validation very much in advance, and you can have the awareness here.
Noack: But, we also go any further and will step any further to see how we can develop solutions where there is no simple answer at the moment. So, you have STCs which might not be validated in the very beginning of a project, so how can we make also the work of the authorities easier? What is their pain point so that we can maybe adjust a bit in the STC documentation where it makes sense to have on the authority side, unless impact time-wise. Because at the end, it is about the time, it’s about the time you get an STC validated if your AOC switches to another national authority.
Walton: I think what I find fascinating about what IAMA is doing is really seeking to work with all the players here rather than just being a helper to one set, right?
Noack: Absolutely. So, we really see that we want to include all players and all stakeholders from the process. So we see as members in the IAMA, the STC providers, the experienced STC providers, which we say have also a responsibility to give a certain quality into the market, right? And that is what we want to do with IAMA.
Noack: We do see the supplier OEMs, the seed OEMs, or the equipment manufacturers like Euro-Composites, they have a lot of experience they can bring into what causes pain on their side. And they also have solutions, right? Then we have the airlines, we have the lessors. The best way really to understand what a lessors pain is is to talk with them, and to talk it through once and you can imagine that a lessor does not want to explain that to every single potential provider, so let them explain it to IAMA. Let them hand it over to us and we find a solution collectively.
Noack: And we also want to integrate the airframe manufacturers because we see that they also have an advantage here. If you have STCs which are of a certain quality … which we might fulfill even their needs because they will have the aircraft back in their engineering and after-sales maybe at a certain time. So, we want to integrate them, as well. And we also reach out to the authorities, so this a very collaborative intent we have here, which is the beauty of IAMA but also a challenge.
Walton: Right. And it’s going to be fascinating to see that challenge developing over the years. What’s next for IAMA? Is it putting this stuff into practice? Is it expanding in terms of membership?
Noack: So, what’s next? So, first of all, we need our legal entity and that will be there in January. So, we are working on the contract with the four plus one partners, but of course we want to gain more members and they are to come. And to have that we have an entity, we will have a German association. I’m actually based in Hamburg, as we see Hamburg as being aviation assembler in Europe beside Toulouse of course, so that will be based on Hamburg. That’s the organizational stuff, but we have to do it and we will do it.
Noack: So, what is way more interesting probably for your listeners is that we develop the rule book and the concept and the prototype until an end this year. We will go into selective feedbacks with airlines and lessors, so if there is anyone out there who really wants to dig into it just give me a shout. But, we also have, of course, some of our stakeholders already in our, let’s say, database on who to talk to. We will evaluate that and then we will hand out the first rule book, version one, at the AIX 2020.
Noack: So, that is our major goal. There is a lot of things happening around it. We have all working groups running, so we have working groups evaluating the access to IP. We have a working group evaluating also the transferability issues. But, the major attempt is really to bring the rule book to life at the AIX 2020.
Walton: Yep. Hey, fantastic. And Nicole, thank you so much. This has been a really interesting conversation. Listeners, we certainly hope you enjoyed it and we’re always keen to find out what you think. Please feel free to E-mail me at email@example.com with any suggestions. Thanks also to our guests, Nicole Noack. Nicole, where can folks continue the conversation with IAMA online?
Noack: You can reach out always to www.iamalliance.aero, or just message me on LinkedIn or give me a private email, which is also written on the website. And I’m happy to answer all questions again and going even deeper into any topic, and I really enjoyed that conversation. Thank you, John, for having me.
Walton: My absolute pleasure. As ever, listeners, you can find me on Twitter @thatjohn, and everything from RGN on Twitter @RunwayGirl, and of course at runwaygirlnetwork.com. If you’re enjoying these conversations, please do leave a rating and review wherever you get your podcasts — and thanks for listening.