Tag: Featured Story

WHAT TO KNOW ABOUT THE PROPOSED CHANGES.

Aircraft maintenance is a broadly defined term involving the care and keeping of aircraft. The industry continues to develop best practices, and maintenance tactics evolve directly proportional to aircraft developments. Accurately documenting such actions is not to be taken lightly. It is often jested among maintainers that eventually, one would need to operate two aircraft in tandem; one to fly passengers and cargo and the other to haul all the airworthiness paperwork.

Aircraft maintenance record-keeping is a serious business. During my MRO ownership stint, the Feds spent almost the entire annual inspection visit pouring over work orders, looking for non-compliance. Only when satisfied that the paperwork was in order, would they take a lap around the shop. While conducting this portion of the inspection, they typically looked for tool calibration labels, correctly identified aircraft parts and appropriate repair station-specific signage. The question of workmanship rarely entered the conversation. They stuck to their checklist and ticked off each block unless they received a formal complaint.

I say this not to cast shade on FAA inspectors but to highlight how vital record-keeping is to aircraft safety. After an accident or incident, inspectors will review the aircraft’s logbooks, maintenance records, and airworthiness information. Refer to Section 7. Safety, Accident, and Hazard Reports of the Aeronautical Information Manual (AIM), in which the Federal Aviation Administration (FAA) aircraft safety includes maintenance and record-keeping.

AC 43-9C – Maintenance Records

The FAA issues Advisory Circulars (AC) to inform the aviation public systematically of nonregulatory material. Unless incorporated into a regulation by reference, the contents of an advisory circular are not binding on the public.

Advisory circulars are issued in a numbered subject system corresponding to the subject areas of the Code of Federal Regulations (CFR) (Title 14, Chapter 1, FAA). In other words, ACs keep the public informed concerning FAA rules and regulations. And they are plentiful.

AC43-9C, entitled Maintenance Records, is up for revision even after receiving two change notices during its tenure:

• Change one, issued on April 7, 2017, simply clarified regulatory references.

• Change two, issued on May 8, 2018, updated paragraph 15 by adding maintenance manuals to the list of documents containing aircraft/powerplant part life limits and reorganized the table in Appendix 1, Airworthiness Directive Compliance Record (Suggested Format).

• Revision D will be the first significant overhaul of the AC since its inception in 1998.

The FAA granted an extension to October 18, 2024, for comments on the Advisory Circular AC No: 43-9D. Currently in draft mode, this latest revision would replace AC43-9C, published on June 8, 1998. The Feds use comment periods to get public input on various issues.

The FAA Flight Standards Service, updated September 11, 2024, provides details on the AC revision, including 1) a summary, 2) a list of references, 3) documents for downloading, 4) a comment portal, and 5) related information.

At first glance, the FAA may need to catch up on aircraft record-keeping. However, aviation maintenance is making great strides in advancing electronic records, artificial intelligence (AI), and predictive maintenance. With advancements moving at unprecedented speed, updating maintenance records is timely.

The draft of AC43-9D, Maintenance Records, describes acceptable methods, procedures, and practices for demonstrating compliance with General Aviation (GA) maintenance record-making and record-keeping. Why is that important? We shall discuss that shortly. At first glance, you will notice that Rev D weighs in at a hefty 20 pages compared to the 12 pages of Rev C.

I spoke with Ian Gregor, a public affairs specialist at the Office of Communications for the FAA, who stated, “This is a draft document for public comment. We can respond to questions about the document when we finalize it.” Once the public comment period closes, the FAA reviews those comments, taking the industry’s thoughts into consideration. When asked about the period between closing the comments and the AC going live, Gregor responded, “It takes time for us to review, respond to, and possibly make changes as a result of comments we receive before finalizing an AC.” We agreed to reconnect after the new revision goes live.

Ric Peri, vice president of government and industry affairs for the Aircraft Electronics Association (AEA), shares his thoughts on the proposed revision, stating, “The current AC 43-9 has never been complete or either regulatory requirement, 43 or 91.” Even in 1998, AC43-9 lacked clarification on critical aspects of aviation maintenance.

Sarah MacLeod, executive director of the Aeronautical Repair Station Association (ARSA), and I sat down to discuss Rev D. Her initial thoughts concerning the FAA’s revision were, “The FAA is using this update to move the information currently contained in Order 8130-21 for maintenance providers. This AC will now contain the information for completing that form.”

Sarah is speaking of the AC introducing procedures for completing FAA Form 8130-3, Authorized Release Certificate, and Airworthiness Approval Tag for approval for return to service under part 43. Sarah and I highlighted that the 8130-3 tag is typically completed by the type certificate holder on the left side or returned to service by a Part 145 Certified Repair Station on the right. She also commented that completing the FAA Form 8130-3 is in the AC, not Order 8130.21. The 8130-3 tag has been in play for quite a while. The FAA is taking this opportunity to include language to aid in completing the form. It is important to note that every 8130-3 tag accompanying parts and components to the airplane becomes part of the aircraft record. In its publication Common Logbook Mistakes, Business Aircraft Records lists Not Including the FAA Form 8130-3 Approval Tag with the Logbook Entry When Components are Changed as one of the common errors. The 8130-3 is strikingly similar to the EASA Form 1, thereby ensuring continuity among component airworthiness recording and part traceability.

MacLeod goes on to say that the AC needs to adequately address roles and responsibilities. For example, 90% of the AC deals with 14 CFR Part 91 General Operating and Flight Rules, as opposed to 14 CFR Part 43 Maintenance, Preventative Maintenance, Rebuilding, and Alteration.

Peri echoes that sentiment. He states, “The major change is specific to part 43 in that the FAA has included expensive instructions on using FAA form 8130-3. Opening up this AC for comment is generating a proposal to separate the part 43 maintenance records (combining AC 43-9 and 43.9-1) from creating a new part 91 record-keeping AC specific to the requirement of part 91. This concept will better differentiate the two regulatory requirements.”

Another addition to Rev D is section 22.2, Information Systems and Automation. The FAA introduces language stating, “With advances in technology, the collection of the form data can be generated electronically in a variety of ways and then be stored that way.” They also mention AC120-78, Electronic Signatures, Electronic Recordkeeping, and Electronic Manuals, which provide guidance that may be useful in developing such a system. This is a step forward in electronically recording maintenance, paving the way for predictive maintenance and, eventually, the use of artificial intelligence (AI). For further information on AI, check out the Aviation Maintenance article AI/ML is A-OK for aviation maintenance tracking and predictive maintenance published in March 2024.

Why Request an Extension for Comments?

With the added material comes increased responsibilities. Industry leaders felt the need for additional time to review the proposed changes. It is no secret that every time the FAA makes a change, the effects flow downstream, and everyone must comply. Ignorantia juris non excusat.

On August 9, 2024, eleven leading aviation trade organizations sent a letter to the FAA requesting additional time to comment on the Draft AC43-9D. The FAA quickly responded with an extension. (ARSA) published an announcement stating in part: This AC provides acceptable means of showing compliance with general aviation record-making and record-keeping requirements according to parts 43 and 91. Though not regulatory, it provides a method, not the only method, and the industry continues to push the FAA to carefully align its guidance with the regulations.

Some of the entities credited with the letter include, but are not limited to:

• Aeronautical Repair Station Association (ARSA)

• Aircraft Electronics Association (AEA)

• Aircraft Owners and Pilots Association (AOPA)

• General Aviation Manufacturers Association (GAMA)

• National Air Transportation Association (NATA)

The letter contains the complete list of those requesting the extension, and mentions form 8130-3 clarification, bilateral agreements, and maintenance implementation documents.

The entities mentioned above constitute only five of the industry leaders petitioning the FAA to extend the review period of AC43-9D. Please download the letter and keep a copy in your digital toolbox. These organizations work tirelessly to ensure safe and efficient operations. How important is their role, and does it make a difference? I spoke with Suresh Narayanan, founder and CEO of Jets MRO at DFW, and his answer was an emphatic yes. After starting his business, Narayanan joined the National Business Aviation Association (NBAA). “By surrounding oneself with like-minded individuals, one has opportunities to gather good intel. The NBAA badge is a sign of respect for the company. Our industry’s strength is the self-policing credibility. There is no fake it ’til you make it.”

Organizations like ARSA, GAMA, and NBAA offer a place to gather and network with other aviation professionals. Actions like the letter mentioned above are just the tip of the iceberg. Advocacy is only effective in groups. There is indeed strength in numbers. Other benefits include safety workshops, industry panels, and focus groups. The industry used this extended time to investigate AC43-9D and review all the FAA’s proposed changes.

What Does This Mean for the Aviation Industry?

When I asked AEA’s Ric Peri what these changes mean for the aviation industry, he replied, “The proposed change is reasonably benign, mostly editorial changes.” That said, it is crucial to understand what the FAA requires, especially in record-keeping. The 8130-3 does have particular nuances that maintainers need to understand. For example, Block 8. of the form, labeled Part Number, indicates the Type Certificate Holders’ identifier for that component. This includes Parts Manufacturer Approval (PMA) parts, regardless of type. A specific instance occurs when an Identicality by License PMA gives the manufacturer authority to produce and distribute parts that replace original equipment manufacturer (OEM) parts. The replaced part or specification can be referenced in Block 12. of the 8130-3 labeled Remarks. Block 12. can also include information such as technical publications, Supplemental Type Certificates (STC), Engineering Orders (EO), or other specific documented maintenance references.

Sarah MacLeod and I also discussed the revision and its ramifications for owner/operators and pilots. She mentioned, “The average pilot needs to understand the requirements of part 91—this AC currently contains that information. It is not the mechanic’s job to ensure maintenance records are complete; it is the owner/operator’s responsibility. That fact is not understood by many pilots who own and operate their aircraft.”

The industry group working on the issue will propose to separate the requirements for maintenance providers to complete maintenance and inspection records correctly from the information owners and operators of aircraft subject to part 91, which are required to obtain, maintain, and make available to the government. In other words, AC 43-9 would be directed solely at the maintenance providers’ requirements of part 43, and a new AC would be directed at part 91 records. The bottom line is this revision principally deals with the guidance of the FAA 8130-3 form and language concerning electronic record-keeping.. Many Certified Repair Stations have already deployed the 8130-3, and many more have adopted electronic records. The FAA has simply updated AC43-9 to bring it current with standard industry practices.

Now that the comment period is closed, the industry will follow the pattern as the FAA collects, reviews, and determines appropriate action for the intel it gathered. In many ways, aviation maintenance has come a long way since the first version of AC 43-9 launched on February 2, 1975, but the bottom line remains the same: Document what you do, nothing more, nothing less.

NOT JUST COSMETIC, AIRCRAFT DENTS REQUIRE ATTENTION AND SOME INNOVATIVE SOLUTIONS CAN HELP.

Aircraft dents happen. While some dents may have minimal effects, others can damage thin aircraft skin and compromise the aircraft’s structural integrity and aerodynamic performance via the damaged area that is pushed in from its normal contour. Varying in size and severity, dents can range from minor indentations to more significant distortions of the aircraft’s surface.

Dents on an aircraft’s surface can disrupt the smooth flow of air over the wings’ fuselage and other surfaces. These disruptions can increase air resistance, resulting in decreased lift, increased drag and reduced fuel efficiency. Dents can trap moisture and lead to corrosion. Furthermore, they can shorten fatigue life and contribute to the propagation of cracks. Failing to repair a dent in time can result in non-compliance with aviation regulations, leading to fines, aircraft grounding or other penalties.

Dents can result from old age and also impact with foreign object debris (FOD) like hailstorms, loose objects, small rocks, bird strikes and even accidental impact with service vehicles during loading operations. Regardless of their origin, Leonard Buck, marketing and business development manager at 8tree, Constance, Baden-Württemberg, Germany, says, “Dents are safety critical since they influence the structural integrity of the aircraft. Any dent has to be assessed prior to continuing aircraft operations.” Airports, airlines and maintenance crews must be aware of dents and their origins, and take the necessary precautions to minimize them via proper training, procedures and maintenance programs.

Dent Detection Methods

There are procedures and equipment in place for MRO engineers to find, measure, evaluate, document and repair dents on aircraft skin, but it’s not always easy. Dent detection via visual inspection is tedious, time-consuming and subject to human factors. They can be located in hard-to-reach areas of the aircraft with complex curved geometries or on leading edges, not always clearly distinguishable even by trained engineers. Also, inspection can occur at height and in challenging conditions, outdoors, where light and weather can interfere. Because dents can be smooth and without well-defined boundaries, with a depth often lower than 1 mm, they can be difficult to detect.

Buck explains that there are three distinct, different methods for dent assessment:

• Traditional Tools (ruler, flashlight, depth-gauge and pen).

“This is the manual inspection method. Very time-consuming and error-prone. It’s industry knowledge that ‘you get 10 results if 10 people measure the same dent’.”

• General Purpose 3-D Scanners.

“3-D scanners require significant surface preparation (stickers applied on the surface) and produce datasets and point clouds, which must be post-processed in specialized software and demands the expertise of highly trained metrology personnel.”

• 1-Click 3-D Dent-Mapping Tools.

“Application-specific designed tools developed for the needs of mechanics and engineers. This tool contains a projector that displays the dent dimensions directly on the surface i.e., augmented reality.”

• AR-enabled 1-Click 3-D Dent-Mapping Tools.

“Application-specific designed tools developed for the needs of mechanics and engineers. Using Augmented Reality (AR), the tool projects the dent dimensions directly on the inspected surface. Mechanics will always receive instantly actionable results with the click of a button. That’s what is needed on the line or in the hangar.”

Despite these tools’ dent-detection benefits, Buck believes that while “Dents are highly safety-critical and aviation (maintenance) is a highly regulated field … when we’re looking at dent measurements, many airlines and MROs are still relying on guess work. Industry knowledge and studies show that traditional dent measuring is nothing but guesswork.”

However, Buck adds that there are tools available today to solve this issue. All 8tree tools are calibrated under ISO17025 — the highest standard a metrology device can achieve. “The dentCHECK measurement results are therefore traceable to national standards and cannot be manipulated (thinking of compliance — big issue),” he says. “Any mechanic can operate the tool after a few minutes training. The AR-enabled dentCHECK tool was purposely designed for dent-mapping on aircraft. The projection of instantly actionable results on the aircraft surface is a giant leap for any airline/MRO/OEM operation and for passenger safety.”

Levis, Canada-based Creaform’s VXintegrity–Aerospace, is dedicated 3-D visualization software designed to assess and characterize dent damage on different aircraft components, sizes and surface finishes. Its guided workflow approach simplifies the measurement extraction of 3D scan data and obtains the exact dimensions required for the assessment. More accurate and faster than traditional methods, the software limits operators’ impact on measurements and shortens the time needed to generate final reports, providing airlines with comprehensive data on issues that require further analysis.

Complex Geometries and Curved Surfaces

Complex geometries and curved surfaces have been known to be the bane of aircraft dent detection, but that’s changing. Buck says it’s becoming less difficult. “Inlet cowls, leading edges, acoustic panels etc., can be inspected with dentCHECK. Double-curved and highly curved surfaces are almost impossible to measure by hand (referring to the ‘guesswork’ statement again).” dentCheck has 1-Click 3D dent-mapping with real-time visual feedback providing go/no-go damage inspection through augmented reality. It can be used at the line, in the hangar, on the tarmac or in AOG situations.

Computer vision (CV) is an application of artificial intelligence (AI) that trains computers to identify, interpret and track objects in photos and videos. The technology is primarily driven by recognizing patterns that repeat themselves over a given set of data. For inspection purposes, AI can detect dents automatically on an aircraft, which could take a human worker up to hours to inspect, while trying not to lose focus on the task.

Jake Bauer, senior data scientist at Striveworks, Austin, Texas, says, “CV models are trained on ‘ground truth’ data: properly labeled examples of what the analyst expects to encounter in the real world. If an analyst is using AI to review complex geometries, then those same complex geometries need to be part of the model training. Striveworks pairs data scientists with customer subject matter experts to better understand the nuances and challenges in manual workflows. Together, they can create an optimal training dataset for a complex task like dent detection. A CV model optimized for complex geometries and curved surfaces will outperform general CV models at the same task.”

AI and Dent Detection

AI has indeed provided real improvements in efficiency for aircraft dent detection. Striveworks worked with a leading Fortune 500 logistics company to create CV models — fine-tuned on imagery of aircraft dents — to help inspection teams identify dents and process vast amounts of imagery.

“Inspection teams using AI were able to find 27% more dents and work through images 50% faster than by doing the work manually,” Bauer says. “These improvements allow teams to review vastly more aircraft surface in a shorter period of time, an obvious benefit when entire fleets are grounded following hailstorms. Because of the complicated challenge of teaching machines how to identify dents in photographs, advanced ensembling i.e., majority voting’ and data preprocessing techniques are needed to add resilience.”

When using AI to perform dent detection, Bauer believes specificity is key. “This starts with capturing data that is as similar as possible to what would be expected during an actual aircraft inspection. Using the exact same type of aircraft, lighting, paint color, camera sensor, camera angle, etc., for model training will improve a model’s ability to correctly identify dents during a real inspection. There is no substitute for expertise when it comes to safety and inspection. While AI can recommend locations of possible dents with high accuracy and speed up the process, a trustworthy inspection should always have a human in the loop. Ultimately, the safe maintenance of aircraft requires a well-trained inspection crew.”

Drones and Dent Detection

Improvements in drone technology have allowed analysts to capture dent imagery faster and at less expense. “Drone photography provides a critical AI input, both to tune CV models to perform optimally on the task of dent detection and during actual inspections,” Bauer says. “Tuning models on the same sensor data (drone altitude, camera angle, image sensor, etc.) that is used during actual inspections improves the performance of models. When any changes occur with the environment or sensors, the dent-detection models can quickly be retrained on the new, real-world imagery to improve performance.”

Buck predicts drones used in dent detection represent the future. They will complement the handheld measurement capabilities. “The first IRIS dentCHECK dent-mapping drones are being delivered to the end customers. The IRIS dentCHECK is the ‘flying version’ of 8tree’s handheld dentCHECK dent-mapping tool. It is the result of a partnership between Donecle and 8tree.”

Back in April of this year, Rhinestahl acquired HYDRO Aero. Now the two companies have merged to form RH Aero. The newly rebranded, combined company touts capability across custom-designed ground support equipment (GSE), OEM-licensed engine and airframe tooling and 26 global service centers as well as engineered solutions for OEMs, MROs and operators across the globe. The two companies say they have a globally diverse workforce of more than 850 skilled professionals and unprecedented supply capacity. Aviation Maintenance editor-in-chief, Joy Finnegan, sat down with the new president and CEO, Anthony Turner, and Dieter Moeller, chairman, to discuss how things are going with the combining of these two companies and their continued development of new and innovative solutions for their customers.

AVM: Why did these two companies decide to come together?

Anthony Turner: We set out to create a powerhouse that’s going to be able to provide levels of service and support, and products that just haven’t been available to our customers out there before. Through the acquisition, by combining Rhinestahl’s engine OEM licenses and HYDRO’s highly skilled service centers, we have become expertly positioned to support OEMs, MROs, and operators across the globe. With more than a century of experience delivering reliable full life-cycle solutions, we are setting the standard in comprehensive life-cycle solutions for aviation support equipment and services.

AVM: What’s it like to acquire a company and merge two companies?

Dieter Moeller: So first I’d say it’s a lot of fun, right? I mean, these things aren’t always easy. I think there’s great alignment from a values perspective in these two companies and these two teams.

Turner: The transaction was done because of the complementary nature and the commonality and values. Two high-quality companies that believe in their products, their brands and really believe strongly in high levels of customer support. The geographic complements, the product and service complements across each of the companies, the relative strengths and weaknesses. This goes back to the question you asked earlier, which is the service. There’s great strength in the history of HYDRO, of product development and innovative solution design. And I would say Rhinestahl’s historical strength technically has been about the use of the practical application products in the field, supporting our OEMs and customers. And so, when you bring that great engineering capability together with practical applications for customers, we think that’s really where the sweetness curves, right? We create something really differentiated from the market. So that’s the synergy.

AVM: Talk about the current supply chain situation and how your newly combined company can help.

Moeller: With the combination of the two companies RH Aero now has, by far, the leading supply capability in the industry for the products and services that we offer our customers. We’ve been working really hard over the last two years because we saw the ramp coming, right? I think that’s one of the things that we do really well, and I think sets us apart.

AVM: The ramp coming out of the pandemic?

Turner: Yes. We understood we had a pretty good view of what we thought was going to take place. So, we started working on capacity, capability and development early. We started that process two years ago. We were here, we were ready, and we’re prepared to meet the needs of our customers. Our objective is all about reliability, making sure we’re ready for our customers and they’ve got a reliable source for the products and service they need. Our expectation when customers are dealing with us is they’re not hearing a lot about supply chain challenges, because we’re taking care, we’re ahead of the wave.

AVM: Talk about supporting your customers.

Moeller: The way the industry is today, everything is just in time. Schedules are hypercritical. We’ve really developed a reputation for when a customer calls us, they know that they can expect if this is a critical AOG-type situation, we’ve got somebody on the way as soon as the phone is put down. With having the in-region sites normally we’ll have somebody there that afternoon to take care of them. And for customers today, that type of support is critical. We recently announced four new in-house manufacturing and service centers opening in Q4 2024 and Q1 2025: Hong Kong, Chengdu, China, Hyderabad, India, and Jeddah, Saudi Arabia. Standard capabilities across all locations include inspection, testing, calibration, repairs/overhaul, recertification, test of electrical equipment, modification of tools, local customer support service, pressure measurement and load testing.

Turner: Combined with GSE and airframe tooling, RH Aero offers a complete portfolio of end-to-end service and support for more than 100,000 tools in our installed base. This service is provided by technicians located in 26 service centers in 10 countries. Our strategy is to have qualified technicians located in-region for our customers to drive market leading turn-times and customer service. Using our Readiness Hub tooling inventory system and our Managed Services program, our Readiness Managers provide an unprecedented level of collaboration and service through our on-site, in-your-shop approach to conducting tooling management and partnering with OEMs and MROs.

AVM: Why had these things not been available before?

Turner: It was a matter of capability and the size. It’s a critical mass issue with customers today asking for much more in-region support. With our level of support, which has always been at a very high level, being able to do that at customers’ facilities just requires an awful lot of resources. And with this combination, we do have the resources to be able to go and supply that footprint around the world.

AVM: You mentioned high levels of support in-region. Talk about what that means to this company.

Turner: It means being able to basically be the experts in aviation support equipment and services for our customers and handle that for them. They don’t have to worry about that anymore. We’re taking care of it for them. We’re able to reach out to customers around the world and take care of customers at 26 major service centers. Then we’ve got a hub and spoke network where we’ve got a lot more reach even than in those 26 centers.

AVM: RH Aero has just unveiled new landing gear equipment, the MLGTMULTI-2. This is a solution specifically designed to enhance the removal and installation of main landing gears on common widebody aircraft. It is designed for the Airbus and Boeing wide body passenger and freighter fleets. You say this landing gear change equipment is designed for a safer, faster and more cost-effective operation. Tell us about the advanced features of it that are designed for safety and efficiency.

Turner: It enables quick and secure trunnion disconnection thanks to its maneuverability and flexible design. The ergonomic handheld control panel makes for user-friendly operation. The MLGTMULTI-2 electrically controlled, high-precision movement provides significant advantages and ease of use compared to the traditional processes. Ground-based operation eliminates the need for cranes or on-wing work, significantly increasing safety during the process. Additionally, the system is optimized for easy transport, enabling transport on standard pallets, without the need for special handling or exceptional transport measures.

AVM: Tell us more about your COBRA system and how it helps engine changes go quickly.

Moeller: It allows us to change engines out within hours, which is something that used to take days.

Turner: The COBRA system basically is a purpose-built cradle electronic system that is able to take the engine off at the angle it needs to be taken off and to be replaced. And it’s able to do this in a way that is secure and safe with much less time than the old way of doing this.

Moeller: It can be up to about an 80% reduction in time. This kind of plays into the scarcity of qualified labor, right? The lack of technicians in the market, which is not going away. It’s going to get worse. All of these things that used to take multiple people, these products reduce the skilled manpower to do these types of procedures. And given the lack of people in this field that’s going to be crucial for customers.

AVM: How do you encourage innovation?

Turner: It’s about being with your customers, because the best product and service ideas come from the needs of the customers. And you can’t really learn about these problems unless you’re spending time with customers. Voice to customer is critical. It’s key. We’re very much a customer-first organization, and we really, really put an emphasis on our team being with our customers, understanding their environment, the challenges they face. That’s where the best ideas come from.

AVM: What can customers expect from this new powerhouse in the future?

Moeller: We are well on our way through the integration process and bringing the synergies of both companies to the combined organization. We’ve done that symbolically through our rebranding effort of RH Aero being consolidation of the two, Rhinestahl and HYDRO, groups, and within our leadership structure and the organization. I’ve moved my position from being president and CEO of the organization to being CEO and chairman. We put Anthony in and just recently announced that he is the new president of RH Aero which sets us up for the next generation. Another step toward supporting our customers worldwide. We are really excited about that.

Turner: From the company itself, customers are going to see the broadest capability in support equipment-related services in the market. They’re going see the highest level capacity and they’re going to see the most innovative solutions coming from our company. We’re pretty far out ahead of this race. Our plan is to create more distance from our competitors.

Moeller: Take a look at our history. I’ve been with the company now 34 years, and throughout those 34 years, the times when the organization, and our ability to serve customers, has been at its highest, were those times that we were experiencing the strongest growth. Those things go hand-in-hand because our people are really excited about being in a strong growth environment. I think there’s so much more opportunity to take care of customers than what has been done in the past. And I think with where the industry is going, that’s going to be more and more important.

According to the training firm CAE, the demand for new MRO technicians will hit the half-million mark in less than a decade. To understand the impact of this demand on the aircraft technician training industry, Aviation Maintenance spoke with Shaun Kuldip, global leader of CAE’s Maintenance Training Centre of Excellence. In this exclusive interview, Kuldip explores the trends driving MRO technical training these days, the new teaching products that CAE is bringing to market, and what’s coming next in this training space.

Aviation Maintenance: For context, please tell us about CAE’s work in aviation training.

Shaun Kuldip: CAE, the company that trains the most pilots in the world, operates over 70 civil aviation training centers globally. Known for its innovative approach, CAE trains pilots and aircraft maintenance technicians. We also train air traffic controllers and commercial aircraft cabin crew.

AVM: The demand for new MRO technicians going forward is astounding. What is CAE doing to address their varied training needs?

Kuldip: Our 2023 CAE Aviation Talent Forecast predicted a need for 402,000 new maintenance technicians industry-wide by 2032. As a result of the critical need for maintenance technicians we are developing training programs that will spool up technicians more efficiently, leveraging new technologies.

As part of CAE’s Ready to Lead Program, we offer a variety of courses tailored towards aircraft technicians to help them improve their leadership skills and support career advancement. This includes CAE’s Aviation Interpersonal Management (AIM) course, which gives students the skills and knowledge required in managing people and projects, finance, legal issues, communication, and many other business responsibilities.

CAE teaches entry-level aircraft maintenance technician courses and in-depth initial training courses on specific aircraft. This includes the latest and most technologically advanced business aircraft being built today. Courses range anywhere from a three-day “REALCase” course to five-plus weeks for a full aircraft tip-to-tail initial course.

Our Master Technician Program is geared towards organizations and individuals who seek to attain the highest standards of technical excellence and professionalism in business aircraft maintenance. The innovative program allows technicians to enhance their skills and competencies on two distinct tracks: Specialist and People Leader. With three levels of achievement — Certified, Advanced, and Master — trainees can reach a Master Technician status in less time than in previous Master Technician career development programs.

AVM: What are the trends driving technical training for MROs these days?

Kuldip: There are multiple factors contributing to the increased demand for maintenance technicians. One is the increase in the average age of the technician workforce leading to waves of retirement, which was accelerated by Covid. The loss of one highly experienced technician cannot be simply replaced with one new technician entering the field.

A seasoned technician in business aviation, with decades of experience on the job, is most likely certified to support, on average, four different aircraft types. In the short term, it would often require four new technicians to replace the one. In the long term, it would take many years for one new technician to gain the same level of on-the-job experience as the ones retiring, creating an ever-growing bottleneck.

AVM: What can be done to address this problem?

Kuldip: The first step in overcoming some of these challenges is exposure. We need to promote aviation maintenance to teens in the pre-college years to better attract the next generation of new aircraft technicians. This is crucial for long-term recovery.

In the interim, the industry must do a better job at retaining talented and experienced aviation technicians and attracting experienced technicians from the military. These veterans could provide a much-needed boost to the business aviation sector, however too many are not made aware of the possibilities and opportunities that exist for them and seek alternative career paths.

Training providers such as CAE also need to produce new and innovative ways to accelerate a new student’s ramp-up time to become an “effective” technician that can contribute sooner. How do we cram four years of training experience in two years? This includes leveraging new technologies (VR) that resonate with the youth of today to better retain knowledge.

AVM: Why is the aviation industry finding it difficult to recruit entry-level aircraft maintenance technicians, and what can be done to address this problem?

Kuldip: I think the industry is unfortunately seen as less attractive for new job seekers. Since Covid, the graduation rates at aviation maintenance technical schools are not keeping pace with the numbers retiring.

A lack of incoming technicians for many years and the retirement of a significant number of long-time technicians has created the perfect storm. The reality is that most future aircraft technicians are not training yet today, which is a problem.

[Fortunately] Media coverage of the current pilot shortage has benefited maintenance technicians as an awareness around the pending workforce shortfall has increased. This is now a topic that all operators are interested in seeing solved and is a topic that government workforce development programs are looking to address.

More marketing and media coverage of the improved wages, number of open jobs, and career progression potential for aircraft maintenance technicians will be necessary to continue to bring eyes to the industry and convince more people to take up the training to begin their path to a license. Government grants or scholarships will also bring in necessary attention and give more access to those willing to join the industry.

AVM: What new approaches is CAE considering to train the next generation of aircraft maintenance technicians?

Kuldip: CAE is exploring new learning methodologies, such as Just-in-Time, that takes long and complex type-specific maintenance initial courses and breaks them down into easily accessible shorter courses that offer training when the technician is ready. This gives technicians time to learn new concepts and practice them on the shop floor before returning to training to learn the next area. This predictable cadence of training offers technicians a clear line of sight on what they will be learning and how their career will evolve.

AVM: Where does virtual reality (VR) fit into your training systems?

Kuldip: CAE is deploying the latest in VR technology and simulation via the cloud on our latest Gulfstream and Dassault maintenance programs for the G500/600, G650, and 6X that allow technicians to experience the entire aircraft in a virtual environment. We are coming up on the one-year mark since we started using VR.

As we gather feedback from our customers on VR, the intent is to roll out across other aircraft platforms. Technicians can perform maintenance tasks in this virtual environment in several teaching modes, including an evaluation mode that allows technicians to measure their skills independently. An instructor-led mode also exists that will guide students through the various steps to perform certain troubleshooting tasks. Technicians can experience the aircraft with no fear of damaging expensive parts or putting wear and tear on sensitive interior components. Maintenance tasks that are safety sensitive or cost prohibitive are now available for technicians to practice as much as they require.

AVM: What about adding artificial intelligence (AI) to your VR training systems?

Kuldip: The future convergence of AI and VR represents a transformative synergy which will revolutionize how we build immersive training and skills-development solutions within the aviation industry. As these technologies continue to evolve in tandem, the convergence of AI and VR is poised to redefine the boundaries of human interaction and pave the way for new and innovative applications across diverse domains within the aviation industry. Aviation is one of the industries where the adoption of emerging technologies is accelerating.

An example of how we may converge AI and VR for maintenance technician training is to improve performance monitoring and evaluation. Our CAE Rise™ technology uses Metrics-Based Insights (MBI) and telemetry data to show pilot instructors objective data during live training, allowing them to focus on evaluating soft skills.

The technology, which CAE has developed for both civilian and military pilot training, also provides analytics to proactively detect, and ultimately address, emerging safety trends. The technology uses analytics to identify trends and optimize training programs, ultimately enhancing the quality of training and ensuring pilots are better prepared. CAE Rise is currently only being used for pilot training but could potentially be used in maintenance technician training and other programs in the future.

AVM: What will the impact of AI and VR be on the training of aircraft maintenance technicians?

Kuldip: As CAE gains more experience on how to deliver training with these new tools, student retention will continue to improve. Additionally, training times will start to decrease, and this comes at a time when technician demand is growing due to many factors in the aviation industry. Getting technicians trained and back to the hangar floor in less time is a key objective for CAE and VR is one of many tools that will help us do just that.

AVM: How is the MRO market responding to these new training tools?

Kuldip: Customers love being able to bring an aircraft inside of the classroom environment. The special orientation that VR allows makes objectives such as component locations and removal and installation tasks much simpler to deliver.

Students enjoy being able to access parts of the aircraft that they normally would not be able to during routine maintenance. They can explore the maintenance computer and evaluate faults that they may not have on their aircraft.

OEMs have come to expect this level of technology from us and push us to develop further VR applications.

AVM: Finally, what’s new and on the horizon for aircraft maintenance technical training?

Kuldip: Modern day aircraft have advanced technologically whereby integrated systems now talk to each other and can to a great degree, assist technicians in the troubleshooting of aircraft issues in an automated manner. One such system is the “Centralized Maintenance Computer”, a highly complex system that is difficult to teach without the use of simulation.

CAE’s high-tech capabilities are an important element to effectively teach the maintenance of today’s modern aircraft. The use of these tools is integrated through many of our courses so that the technician is very familiar with its use by the end of the class. Trying to work on a modern-day jet without knowledge of how these onboard systems work is all but impossible for almost any modern-day aircraft.

While CAE Rise could potentially be used in other programs in the future, it is currently only being used for pilot training.

Suppliers, MROs and operators have announced new developments in their maintenance activities and laid out plans for expanding services that support repair, overhaul and inspection efforts.

The latest developments range from new offerings of inspection and maintenance tools and software, parts manufacturer approval (PMA) and supplemental type certificate (STC) initiatives for business jets and expansion of airline spares inventory and maintenance base operations. Here’s a rundown.

4D InSpec AT’s Use in Engines Grows

4D Technology’s 4D InSpec AT fully automated, non-contact, 3D surface gauge will be measuring specifications, damage and wear on more aircraft engine parts following a recent customer order.

The 4D InSpec AT is compatible with automated systems like robot arms and rotary tables. Combined with a robot arm, the gauge provides a substantial increase in productivity and precision for customers measuring edge break, chamfer and round-off on aerospace parts, the company says. With the gauge rapidly positioned by a robot arm, the 4D InSpec software can take a measurement, calculate adjoining planes and determine the shape, curvature and slope of the remaining surface after edge break and round-off. (The 4D InSpec AT also can be used as a handheld instrument.)

This allows customers to check critical specifications of aircraft and engine parts like airfoils, disks and bearings, as well as to prevent crack propagation and ensure proper fit and seal. The 4D InSpec can help overcome difficulties in measuring the numerous callouts on an engineering drawing, such as hard-to-reach inside corners, areas between blades and samples that must be perpendicular to adjoining edges.

In addition to measuring machined edges, aircraft mechanics and inspectors use the device to assess wear, scratches, dents, corrosion and other damage that occurs in aircraft engine operation. It can assess features ranging from 0.1 inch to 100 mils deep or tall. The measurements—completed in seconds on the shop floor or on-wing — quickly determine whether critical parts are safe for use or need to be discarded.

For engine parts makers, the 4D InSpec’s short measurement-to-measurement time of — about a second — means they can save hours over tedious preparation of rubber replicas for feature assessments.

“The aerospace industry has some of the most stringent parts specifications found in any macro-scale manufacturing process,” 4D Technology general manager, Erik Novak, said. The selection of 4D InSpec “validates the precision of our measurement and the great value added by its speed and versatility.”

Based in Tucson, Arizona, 4D Technology is a leader in innovative products for measuring surface quality and defects on precision surfaces. The company is a wholly owned subsidiary of Onto Innovation Inc.

Snap-on Kit Reliably Moves Impact Tools

Snap-on Industrial’s Portable Heavy-Duty Impact Sets help technicians reliably transport their impact tools on the work site.

The 25-piece, heavy-duty cordless impact set with portable storage (425IMCT) comes with an assortment of tools, including:

• A 17-piece shallow-impact socket set with Snap-on Flank Drive technology, which provides superior gripping power while guarding against rounding of fasteners.

• A ¾-inch drive swivel-ball impact universal joint.

• ¾-inch drive extensions of three inches, seven inches and 10 inches.

• An 18-volt, ¾-inch drive Monster Lithium cordless impact wrench set, with 1,300 foot-pounds (1,763 Newton-meters) of bolt breakaway torque and 1,000 foot-pounds (1,355 Newton-meters) of working torque; the set includes two Lithium 5.0 amp-hour batteries and a charger.

• A sturdy, all-weather-resistant Pelican case with a collapsible handle and rugged wheels.

• Two-toned (red and black) colored tool control foam to securely house the tools.

The kit weighs 72.13 pounds (32.72 kilograms). The case measures 24.8 by 19.7 by 11.9 inches (62.99 by 50.04 by 30.23 centimeters).

The kit is sold through Kenosha, Wis.-based Snap-on’s franchisees and its company-direct, distribution and web-based channels. For more information on the kit, visit https://b2b.snapon.com/.

Performance Plastics Expands EnduroSharp Line

Performance Plastics has expanded its EnduroSharp line of aircraft maintenance tools, adding Torlon sealant removers, three EnduroSharp adhesive reamers and the Deluxe EnduroSharp Scraper Blade Sharpener for keeping those and other tools well honed.

The sealant removers are non-metallic, spiral single-fluted cutters designed to cleanly remove non-metallic debris such as cured sealants, fillers, coatings and adhesives from larger surface areas such as fuel tanks with no abrasion to the underlying paints, primers or metal substrates. Designed for use with a power drill, the cutters have a hex-drive mounting feature.

The cutters are made of Torlon, a material that itself can be re-sharpened. This makes the cutters and other tools made of Torlon reusable.

The multi-fluted, straight-walled adhesive reamers can be used to remove debris such as cured sealants and adhesives from fastening and bushing holes in metallic or composite structures without damaging the structures. Originally offered in nine sizes, the company has added three sizes to the lineup: the TAR 171 (0.171-inch diameter, straight-fluted, ¼-inch hex drive), TAR 234 (0.234-inch diameter, straight-fluted, ¼-inch hex drive), and TAR 296 (0.296-inch diameter, straight-fluted, ¼-inch hex drive). The reamers are also made of Torlon and are reusable.

The Deluxe EnduroSharp Scraper Blade Sharpener features a diamond abrasive material surface for sharpening and restoring a factory edge to all EnduroSharp consumable products. The diamond abrasive material itself can be resharpened.

Performance Plastics developed all EnduroSharp aircraft maintenance tools with the University of Dayton Research Institute (UDRI), and the Air Force Research Laboratory (AFRL) to provide reliable and dependable material removal tools for military and commercial aircraft maintainers.

EnduroSharp tools are approved for use by the U.S. Air Force, Marine Corps and Navy and military organizations of many other nations.

Performance Plastics is a Pexco company. Headquartered near Atlanta, the Georgia-based Pexco is a custom precision injection molder of high-performance, tight-tolerance thermoplastic components. It specializes in geometrically complex precision parts that consist of chemically inert materials. The company’s expertise led to the development of the patented EnduroSharp line of aircraft maintenance tools.

For more information, visit www.endurosharp.com.

Streamlight Unveils Brighter Tactical Light

The high-performance lighting maker Streamlight has introduced the ProTac HL6, the newest and brightest addition to its line of tactical lights.

The ProTac HL6 features a multi-function, easy-access head switch that allows for one-handed operation of the light’s momentary, variable intensity or strobe modes. It also has an anti-roll face cap and a sure-grip rubber sleeve.

The system includes a charge cord and two Streamlight SL-B48 5000 milli-Amp-hour lithium-ion rechargeable battery packs with an integrated USB-C charge port.

“The ProTac HL 6 is like a handheld flood light, allowing users to see all around them while also providing a powerful beam reach to put more light on a target at a distance,” said Michael F. Dineen, chief revenue officer of Eagleville, Pa.-based Streamlight. He said it is the ideal light for many uses, including troubleshooting repairs under low-light conditions.

The ProTac HL6’s high setting delivers up to 5,300 lumens and 80,000 candela over a range of more than 1,850 feet (566 meters). On medium, it produces 1,500 lumens, 23,000 candela and a 990-foot-plus (303-meter) beam distance. On low, the light provides 450 lumens and 6,700 candela over nearly 540 feet (164 meters). Streamlight said the ProTac HL6 can run for 12 hours and 30 minutes on low to two hours on high; in strobe mode, the light can run for four hours.

The ProTac HL 6 measures 10.5 inches (26.7 centimeters) in length and weighs 1.3 pounds (0.6 kilograms) with two SL-B48 rechargeable batteries. It is rated IPX7, making it waterproof to one meter for 30 minutes. The light also is impact resistance-tested to 3.28 feet (one meter). It comes with Streamlight’s limited lifetime warranty.

For additional information, call +1-800-523-7488, visit streamlight.com or connect on facebook.com/streamlight, Instagram.com/streamlightinc or LinkedIn/company/streamlight-inc.

New Part 91, 135 Maintenance Tracking Software

Miami-based WingWork has launched its cloud-based maintenance tracking platform for Part 91 and 135 mechanics.

With a modern, intuitive interface, the WingWork platform is designed for ease-of-use and comprehensiveness, the company said, allowing operators to spend more time fixing and less time clicking. The initial launch has features covering maintenance tracking, work orders, inventory control, invoice generation, logbook ingestion and data entry. WingWork said its goal is to empower operators to better forecast maintenance events and associated costs, reducing downtime spent servicing their aircraft.

WingWork said it tapped a team of 50-plus industry advisors, including maintenance personnel at operators and seasoned aviation experts, to develop the platform.

“Our network of advisors has been a crucial element to our success,” said CEO Matt Castellini. “They give us invaluable feedback on building a world-class tool to power the modern aircraft mechanic.”

The WingWork team plans further product expansion driven by customer feedback.

“The maintenance industry is ready for a 21st-century solution that will utilize cutting-edge technology widely adopted in other industries,” WingWork chief technology officer Karthik Srinivasan said. “We want to develop best-in-class software to help the maintenance industry make the transition from relying on manual processes to harnessing the power of next-generation technology.”

For more information, visit www.wingwork.com.

PWI Gets PMA for Citation LED Step Lights

Wichita, Kan.-based PWI, Inc. is bringing the long life and low power-draw efficiency of LEDs to Cessna Citation jet steps with its receipt of PMA on components for that Textron Aviation series of aircraft.

The Citation models covered by the PMA include the Citation II, the 550 Bravo, the S550 II/SP, the Citation V 560, the Excel 560XL and the 650, as well as the Citation III, VI and VII.

The new LED step light replaces the original incandescent step lights in the door of the Citation (part number 6900163-000 and Textron part number 1021LIGHT). No aircraft modifications are required, according to PWI. It says the single PWI LED part number (6910163-003) simply screws into the steps using the original mounting holes. The installation reuses the original aircraft lighting wiring and runs on the aircraft-supplied 28 volts. All PMA-approved LED cabin lighting systems have a three-year PWI warranty.

The door-mounted step light is designed to resist cabin ingress and egress wear-and-tear. The new design uses impact-resistant polycarbonate lens material to deliver long-term durability. It also offers greater liquid and contaminant resistance to such common elements as deicing fluid, rain, snow and mud, PWI said.

“This new LED step light puts a nice touch on one of the first things you notice when entering the cabin: the doorsteps,” said PWI president and CEO Robi Lorik. The PMA installation “adds a level of safety and convenience that passengers appreciate before they are seated.”

PWI has been an original equipment manufacturer of fluorescent cabin lights for the Citation as well as other business jets (Dassault Falcons, Gulfstreams, Challengers and Learjets) and King Air turboprops for decades. PWI FAA-approved LED aircraft lighting upgrades can be purchased direct or through its authorized dealer and distribution network. Contact PWI at +1-316-942-2811 or sales@pwi-e.com.

Skyservice Targets G280 Gogo Galileo STC

Skyservice Business Aviation is developing an STC to install Gogo’s Galileo HDX on Gulfstream G280s by early 2025, giving operators access to the latest high-speed in-flight internet solutions.

“The demand for reliable, high-speed in-flight connectivity is higher than ever,” said Skyservice president and CEO Benjamin Murray. “Our development of this STC for Gogo Galileo HDX is a direct response to meeting that demand with cutting-edge solutions.” There are about 240 of the popular super-midsize G280 in operation worldwide, the company said.

Gogo Business Aviation’s latest innovation, Gogo Galileo is designed to provide operators worldwide with global, high-speed, in-flight internet and low-latency performance for business aircraft from light jets and turboprops to the largest business jets. The compact HDX aims to leverage Eutelsat OneWeb’s enterprise-grade low-Earth-orbit (LEO) satellite network, which is designed for mobility to deliver low variability and consistent performance across all routes globally.

Mississauga, Ontario-headquartered Skyservice aims to get the G280 Gogo Galileo HDX STC validated by Transport Canada Civil Aviation (TCCA), the FAA, the European Union Aviation Safety Agency (EASA), the National Civil Aviation Agency of Brazil (ANAC) and the U.K. Civil Aviation Authority (CAA).

Operators can contact Skyservice (www.skyservice.com) to submit a purchase order for the Galileo HDX, which is designed to be an easy upgrade to any AVANCE system (AVANCE L3, L5, LX5, SCS). Installations are planned for 2025’s first quarter. A special promotional rebate of $25,000 is also available for a limited time to current Gogo customers operating a legacy air-to-ground system (ATG 1000, 2000, 4000, 5000) when installing AVANCE SCS and HDX, Skyservice said.

AvAir Broadens Lufthansa Technik Component Pact

AvAir has broadened its partnership with Lufthansa Technik Component Services, acquiring more than 1,600 overhauled wheels and brakes from the German MRO’s excess inventory.

Chandler, Ariz.-based AvAir’s inventory acquisition includes components for Bombardier CRJ700s and 900s, Embraer E190s and the complete range of Boeing and Airbus models, including the 787 and A350. AvAir said all parts are serviceable and come from Lufthansa Technik’s material pool and aircraft teardowns. Their transfer from Lufthansa Technik facilities in Germany to AvAir’s Chandler warehouse is expected to be complete by early February 2025.

The transferred material from this transaction is to come with dual or triple release certification (the FAA, EASA and/or the Civil Aviation Administration of China) from Lufthansa Technik and with a 12-month warranty, AvAir said. Most parts were maintained by Lufthansa Technik’s component maintenance, repair and overhaul organization.

“We are thrilled to expand our inventory with such a diverse range of wheels and brakes, enhancing our offering for our customers,” said AvAir president Brandon Wesson. “Our partnership with Lufthansa Technik has been invaluable, and we look forward to the new opportunities this acquisition will bring.”

The companies established their long-term aftermarket sales agreement in 2020, with AvAir acquiring more than 9,000 line-replaceable units from Lufthansa Technik’s global material pool. In 2022, AvAir expanded its inventory by purchasing 9,000 more aircraft components.

Lufthansa Technik is to receive a share of proceeds from resold components under a profit-share arrangement.

For more information about AvAir, visit AvAir.aero.

DHL Express Building New Maintenance Base

DHL Express in October began constructing a state-of-the-art facility and expanded aircraft apron in its global hub at the Cincinnati/Northern Kentucky International Airport (KCVG) to improve the express shipper’s ability to maintain its Boeing 737, 767 and 777 fleets.

The 305,000-square-foot (28,335-square-meter) facility in Covington, Ohio, will enable more efficient repairs, reducing aircraft downtime and improving service reliability to support timely customer deliveries, the company said. It is to include a hangar that accommodates two 777s or four 767s. The facility is also to have a ground service equipment staging area, underground foam containment, a loading dock and service entrance, backup generator capability, HAZMAT storage, a large water tank, offices and employee parking.

The expanded apron, covering 50 acres (20.2 hectares), will include eight new aircraft gates and three new maintenance gates.

That will allow DHL to accommodate more aircraft and handle a larger volume of shipments.

The $292-million facility is expected to be fully operational by January 2026.

DHL’s KCVG hub currently operates on 194 acres (78.5 hectares) with 67 aircraft parking gates and 6.4 million square feet (594,579 square meters) of ramp area. The heart of DHL Express’ Americas network, it handles 117 daily flights and a fleet of 64 aircraft and connects customers from more than 220 countries and territories worldwide to every corner of the U.S. KCVG is one of three DHL global superhubs, with the others in Hong Kong and Leipzig, Germany.

“Over the last several years, we have been enhancing our network capabilities with newer and more fuel-efficient aircraft,” said Rob Hyslop, EVP Global Aviation, DHL Express. “This new facility complements those efforts with additional space for more aircraft to be maintained at the same time.”

DHL expects to hire 300 more employees to support the new maintenance facility as part of a recently developed joint venture between DHL Express and Kalitta Air, a long-time DHL service partner. Kalitta Air and DHL will jointly oversee the critical aircraft maintenance activity at the new facility.

The Department of Defense has established a critical one-two regulatory punch for protecting sensitive defense information through its Cybersecurity Maturity Model Certification 2.0 Program. The first component, 32 CFR Part 170, takes effect December 16, 2024, with the second component, 48 CFR Part 204, following in 2025. This coordinated regulatory approach addresses a stark reality: malicious cyber activity costs the U.S. economy between $57 billion and $109 billion annually, with the defense industrial base facing persistent targeting from sophisticated threat actors.

The Council of Economic Advisors calculates these attacks could burden the U.S. economy with up to $1.09 trillion in costs over a decade. To combat this threat, CMMC 2.0 creates new requirements for more than 220,000 defense contractors who process, store, or transmit sensitive defense information. 32 CFR Part 170 establishes the program structure and security standards, while 48 CFR Part 204 implements contractual mechanisms through the Defense Federal Acquisition Regulation Supplement.

Three-Year, Four-Phase Implementation for Defense Contractors

CMMC 2.0 establishes three distinct control levels based on information sensitivity. Level 1 requires 15 basic cybersecurity controls from FAR 52.204-21 for protecting Federal Contract Information, focusing on fundamental practices like access control and basic system security. Level 2 mandates all 110 security requirements from NIST SP 800-171 Rev 2 for protecting Controlled Unclassified Information, encompassing comprehensive controls across 14 domains including access control, incident response, security assessment, and system integrity. Organizations must achieve a minimum score of 88 out of 110 points. Level 3 builds upon Level 2 by requiring a perfect score of 110 on NIST SP 800-171 Rev 2 controls plus 24 additional enhanced security requirements from NIST SP 800-172, including advanced threat monitoring, 24/7 security operations center capabilities, and cyber incident response teams that can deploy within 24 hours.

The DoD’s implementation strategy spans four distinct phases over three years:

• Phase 1: Initial Implementation

Begins at 48 CFR Rule Effective Date.

• Where applicable, solicitations will require Level 1 or 2 Self-Assessment.

• DoD estimates 1,104 small businesses will participate in this initial phase, allowing organizations to adapt to new requirements while limiting broader impact.

• Phase 2

• Begins 12 months after Phase 1 start.

• Where applicable, solicitations will require Level 2 Certification with assessments conducted by CMMC Third Party Assessment Organizations (C3PAOs).

• Projected 673 C3PAO certifications during this phase, enabling the assessment ecosystem to mature methodically.

• Phase 3

• Begins 24 months after Phase 1 start.

• Where applicable, solicitations will require Level 3 Certification.

• During this phase, DoD projects completion of 2,252 C3PAO certification assessments.

• Phase 4: Full Implementation

• Begins 36 months after Phase 1 start.

• All solicitations and contracts will include applicable CMMC Level requirements as a condition of contract award.

• Annual C3PAO assessments will reach 4,452, covering approximately 20,395 small entities and 9,148 large entities.

Understanding the CMMC 2.0 Certification Verification Process

CMMC certification scoring varies by level, with each tier requiring progressively more rigorous verification by C3PAOs. Level 1 employs a straightforward met/not-met scoring system for its 15 basic safeguarding requirements from FAR 52.204-21. For Level 2, organizations must achieve a minimum score of 88 out of 110 possible points based on NIST SP 800-171 Rev 2 security requirements, while Level 3 demands a perfect Level 2 score plus successful implementation of 24 additional enhanced security requirements from NIST SP 800-172.

C3PAOs, accredited by the CMMC Accreditation Body, serve as the primary assessors for Level 2 certifications, conducting comprehensive evaluations that have replaced the previous self-attestation model. During assessments, C3PAOs examine both technical implementations and organizational processes, including detailed reviews of system configurations, security policies, operational procedures, and control implementations. The assessment process includes documentation review, system testing, personnel interviews, and direct observation of security practices.

The CMMC Accreditation Body maintains oversight of C3PAOs by establishing assessment standards, monitoring performance, and ensuring consistent evaluation methodologies. Additionally, the Defense Industrial Base Cybersecurity Assessment Center provides another layer of quality control by conducting regular evaluations of C3PAO capabilities and performing high-priority assessments. Organizations seeking certification must submit assessment results and maintain current status in the Supplier Performance Risk System, with a senior company official required to affirm continued compliance annually or when security changes occur. If deficiencies are identified during assessment, organizations may achieve conditional certification through Plans of Action and Milestones (POA&Ms), which must address permitted gaps within 180 days.

180-Day Conditional Certification Pathway for Addressing Security Gaps

CMMC 2.0 permits limited use of Plans of Action and Milestones (POA&Ms) for Level 2 and 3 certifications. Organizations meeting minimum scoring requirements can achieve conditional certification by addressing permitted deficiencies within 180 days. This flexibility supports transition while maintaining security standards. POA&Ms must address specific remediation timelines, resource requirements, and technical solutions for each identified gap.

Governance and Supply Chain Obligations

The regulations establish clear contractual implications through 48 CFR Part 204, expected to be published in 2025. Contractors must achieve their required CMMC level before contract award. Contracting officers cannot award contracts, exercise options, or extend performance periods without verification of current certification. Prime contractors must validate subcontractor compliance based on the sensitivity of information in the supply chain, ensuring security requirements flow down appropriately.

The certification ecosystem includes several oversight components. The CMMC Accreditation Body establishes assessment standards and monitors C3PAO performance. The Cybersecurity Assessor and Instructor Certification Organization manages training programs and maintains certification standards. The Defense Industrial Base Cybersecurity Assessment Center conducts high-priority assessments and validates C3PAO capabilities through regular evaluations.

Oversight Framework

Organizations must submit assessment results and maintain current status in the Supplier Performance Risk System. A senior company official must affirm continued compliance annually or when security changes occur. The DoD requires current certification or self-assessment results for each contractor information system processing sensitive defense information, with specific documentation requirements for system boundaries and security implementations.

CMMC 2.0’s dual regulatory framework creates comprehensive cybersecurity enhancement across the defense industrial base. The phased implementation balances security imperatives with practical considerations about industry readiness and assessment capacity. As both regulations take full effect, they establish increasingly robust protection for sensitive defense information while maintaining supply chain vitality. Organizations must prepare now for these mandatory requirements, understanding that certification will soon determine their ability to compete for defense contracts involving protected information.

Frank Balonis is chief information security officer and senior VP of operations and support at Kiteworks, with more than 20 years of experience in IT support and services. Since joining Kiteworks in 2003, Balonis has overseen technical support, customer success, corporate IT, security and compliance, collaborating with product and engineering teams. He holds a Certified Information Systems Security Professional (CISSP) certification and served in the U.S. Navy. He can be reached at fbalonis@kiteworks.com.