Russian CAA issues authority to produce Airbus, Boeing…spare parts
That alone does not make them “airworthy”, will be treated as SUPs
Massive DER/DAR research will be required, infected aircraft likely not be exportable
Other CAAs will question safety of MC21 and SSJ100
A well-intended ministerial act by Putin’s First Deputy Minister of Transport, who is also the Director of the Federal Air Transport Agency (Федеральное агентство воздушного транспорта) [Rosaviatsiya ], Alexander Neradko, may have permanently isolated Russia’s aviation from the rest of the world in the near term or perhaps permanently. Because of the Western boycott, the supply of critical replacement parts is dwindling with a likelihood that soon operations will have to be curtailed. The Russian CAA, which was already suspect in the airworthiness arena, took a step to address this problem, which may alleviate its supply issues, but likely will make all Russian commercial aircraft suspect.
The manufacture of spare parts is highly regulated because unscrupulous entities copy designs and offer them at lower prices than the certificated parts. Obviously it is difficult to differentiate between the actual items and what is known as suspected unapproved parts. Differentiating between the two is extremely difficult, frequently requiring highly trained experts to examine the items and the accompanying documents.
On many occasions, the information available is inadequate to meet the airworthiness standards; they become scrap, worthless.
Rosaviatsiya grant of extraordinary authority does nothing to create credible evidence that the parts meet standards. In order to manufacture airworthy parts, it is essential to have access to the original TC holder’s documents as well as the specifications for the manufacturing. Dimensions can be replicated by sophisticated reverse engineering, but the design is not enough. The function of a part may require special metals, unique treatments, coatings, heat curation of extreme degrees, etc. Neradko, most probably, could not provide this highly proprietary information to the eleven companies on which he has “conferred” his special authority.
Essentially a team of VERY expensive DERs and DARs would have to examine every major part and every accompanying document in order to issue the required 8130-As. Even then, there would be no assurance that the aircraft will be acceptable to the world’s CAAs.
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The Rosaviatsiya extraordinary action is likely to result in its colleague CAAs to reject Russia’s #1 export due to a suspect Certificate of Airworthiness
Russia Plans To Certify MC-21 And Sukhoi SuperJet By End 2023
The war between Ukraine and Russia had a correlate of Western sanctions against the latter, including the supply of aircraft and spare parts from European and US companies.
The Russian government took drastic measures to guarantee the continuity of domestic and, to a lesser extent, international airline operations, but the doubt was in the air: beyond the aircraft, the logistic and supply chain has always been finite, and aircraft depend on spare parts and systems provided by manufacturers or their chain of suppliers.
As reported by the Russian newspaper Vedomosti, in April and May the Russian aviation authority (Rosaviatsia) issued aircraft developer certificates to five companies to authorize them to perform modification, certification of minor changes and issuance of technical documentation, including approval of repair documentation and changes.
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The measure, which was not almost expected, comes after China’s refusal to supply parts for Western aircraft fleets operating in Russia, forcing it to look for spare parts and rotables in smaller but important markets such as India and Turkey.
While initially the certificates issued by the aviation authority are aimed at the replacement or repair of interiors, seats and comfort items or galley tooling, the pressure to keep airline aircraft operational could lead to a move towards the replacement of more complex parts.
The loss of traceability resulting from the installation of non-approved parts could mean that the aircraft would not be able to recover their airworthiness even if they were returned to the lessors claiming them, so there is a serious chance that the equipment affected by these changes would lose their commercial value.
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PATRICK KY OF EuASA agrees https://www.reuters.com/world/europe/european-official-concerned-about-russia-flying-western-made-airplanes-2022-06-14/