Following a three-year process that involved untangling a bureaucracy associated with surplus military parts, Advanced Composite Structures Florida (ACSF) has obtained U.S. FAA clearance and has seen its order book begin to fill for composite main rotor blades for restricted-category helicopters.
Airworthy replacement parts for restricted-category helicopters—which primarily comprise an aging fleet of surplus military aircraft—are essential for the continued support of government-contracted missions, including firefighting and disaster relief.
The installation of articles on restricted-category aircraft is subject to FAR 21.9, which requires articles to have been declared surplus by and intended for use by the U.S. Armed Forces. This regulation proved to be an exceptional challenge for David Stone, president and founder of Stone Aviation International, and Jeff Small, president of ACSF (Booth C6624).
To provide airworthy items for restricted-category helicopters, Stone obtained composite main rotor blades (CMRB) that had been designed in accordance with U.S. military specifications and manufactured under the same design, data and part numbers as required by the licensor’s contract with the U.S. military. The blades, however, were manufactured for and declared surplus by the German military, and thus not suitable for installation according to FAA regulations. Getting the blades approved under FAR 21.9 became an arduous process that required Stone to seek additional support from Small.
“There was no way around the 21.9 minutia, period. I needed the support of a blade shop,” said Stone. ACSF’s FAA repair station certificate and rotor blade repair capabilities provided Stone with the assistance he thought would be sufficient to supplement his intention to sell the CMRBs.
“David had all of the data on the blades and kept bringing in substantial information,” said Small.
Despite the collective efforts of Stone and Small, they were still met with rejection from the FAA. “I was exceptionally surprised,” said Stone upon initial recognition of the difficulty in determining where the CMRBs fit within FAA regulations. To move the process forward, Stone and Small enlisted the help of Sarah MacLeod, managing member of the OFM&K law firm and executive director of the Aeronautical Repair Station Association.
Stone explained, “Sarah first identified a pathway from A to Z with all the letters in between” and realized “an exemption from 14 CFR § 21.9 was the only way to convince the FAA” that the blades were suitable for installation.
After three years, the FAA found the exemption to be in the public interest and granted it to ACSF, allowing it to sell the CMRB under specific conditions and limitations. “Each blade goes through a developed process to meet all the criteria of the exemption,” said Stone.
Under the exemption, ACSF does not have the authority to determine if CMRBs are eligible for installation on an aircraft; that authority will remain with the maintenance provider that is installing the CMRB. Also under the exemption, ACSF must develop a receiving inspection procedure for review of each rotor blade’s documentation. The approval for the return to service of the blades must also be documented on FAA Form 8130-3.
“We kept the faith in Sarah and each other as this process took a tremendous amount of time,” said Small. “We are now hitting the ground running and people have been calling and jockeying for the position to get blades. We expect sales to be brisk during the firefighting season.”
Stone is now the business development manager at ASCF and Small said, “I have developed an excellent working relationship with David and he is instrumental in our success. We are skyrocketing in business and it really has to do with Sarah and the people at ACSF.”