Applications for Chinese approval of foreign aviation goods and products are on the rise, putting a strain on that nation’s limited certification resources. China ranked fourth in the number of applications from U.S. manufacturers seeking validation from 2012 through late last year, according to the U.S. Government Accountability Office (GAO). China received 7.7 percent of the applications, behind the European Union, Canada and Brazil.
As the population of business aircraft expands, so too does demand for parts, services and alterations, all of which require resources, noted Walter Desrosier, vice president of engineering and maintenance for the General Aviation Manufacturers Association. “The CAAC is not structured and resourced for the volume,” he said. “The CAAC is [hiring more staff], but not necessarily to align with international manufacturers.”
Hoping to foster the growth of its own aviation manufacturing sector, the country has slowly been adding resources. As in the U.S., however, growth often outpaces the induction and training of new resources as more manufacturers seek validation of their products. In China, certifying products has been a learning curve, not only for the CAAC as it adds staff but also for the manufacturers attempting to win their first validations.
Manufacturers Make Inroads
Company executives agree that the key lies in establishing and building relationships with CAAC authorities. Gulfstream, which had 98 aircraft based in China at the end of last year, opened a Beijing office whose staff are devoted to working with Chinese authorities. The company delivered its first aircraft into China in 2006, a G200, and since then has had success at type validation for the G150, G280, G450 and G550; it is now working on approval for the G650.
“Almost a decade ago, acquiring timely certifications in China for our aircraft [TC and supplemental TC validations] was challenging,” said Steve Cass, vice president of technical marketing and communications for Gulfstream, because business aviation in China was in its infancy and the country’s authorities knew little about the operations and the industry.
But that has improved over time as Chinese regulatory officials and the industry have worked more closely. “The CAAC has been keen to learn more about the industry,” Cass said, noting that the agency has collaborated with the Savannah, Ga.-based manufacturer on various initiatives. Gulfstream has even conducted training events with the agency.
“Education and awareness continue to be integral to improving the certification process,” he said, noting they share a vision of developing safe business and general aviation operations in China. “The strong relationship we share with the CAAC today has resulted in a stable and predictable certification process.”
Quest is another manufacturer that has gotten its foot in the door, with Chinese certification of the Kodiak in the summer of 2013. Although it is a relatively young company, Quest entered the process in China with experience in earning validations. China was its 12th certification of the Kodiak. Company president and CEO Sam Hill also brought to Quest a background of obtaining validations, having gained experience with Embraer’s ERJ and Legacy lines during his tenure at Embraer.
Hill reported Quest had a positive experience with the certification process, but he said the key was ensuring the protocols were worked out in the beginning and that the procedures were carefully followed. The company experienced some short delays but wrapped up the process in seven to eight months, Hill estimated. “The experience was better than we expected. We had received a heads-up from other manufacturers that it could be rough, but that was not our experience,” Hill said.
The CAAC audit was not much different from that of other countries. The contrasts were mainly cultural, but he added that’s true no matter where an aircraft is certified. But he also cautioned that a company seeking certification must be prepared. “Timing is everything,” he said. “You have to make sure you are on the schedule.”
Textron Aviation, which has had experience manufacturing in China, has gained a growing understanding of CAAC procedures. This provided a foundation for successful outcomes, said Michael Thacker, senior vice president of engineering for Textron Aviation. The CAAC, Thacker said, “continues to seek out new opportunities to work with industry and demonstrate its willingness to cooperate with OEMs.”
He cited CAAC’s partnership with organizations such as the Aviation Cooperative Program of China. GAMA hosted CAAC officials at a meeting a year ago, providing OEMs the opportunity to learn more about the CAAC’s Airworthiness and Certification Department. “During these cooperative engagements, we have gained an appreciation for the number of validation requests that the CAAC completes each year and for how critical it is for each OEM to understand the process to allow for timely approvals,” Thacker said.
Challenges to Certification
But even with positive experiences, challenges remain. CAAC resources and budget top that list, executives agree. The industry is watching with interest as the FAA and CAAC negotiate revisions to their bilateral agreement, and protection of intellectual property remains a concern.
“We’re seeing the importance of ensuring effective implementation of the bilateral agreement with China,” Desrosier said, adding, “there is still more opportunity for efficiencies.”
Chinese certification officials have sought information beyond that required in the bilateral. The GAO, which has been conducting an investigation into foreign validations, said it received reports from companies that “China often makes requests for data and detailed product design information that in their view is not necessary for an approval, and sometimes holds up approvals until those requests are fulfilled.” Such probing gives rise to intellectual property concerns among the manufacturers.
Dorenda Baker, director of the FAA’s aircraft certification service, told Congress earlier this year that the FAA will step in if the agency feels the requests go beyond the bounds of what is necessary for certification. The FAA intervened in the case of a Robinson helicopter certification, she cited as an example.
The bilateral discussions between the FAA and China include “implementation procedures for airworthiness,” or IPA, that outline airworthiness technical cooperation. The IPA “will provide clarity on the procedures for U.S. companies seeking foreign approvals,” the GAO said, adding, “This IPA is also expected to reduce the level of involvement of the CAAC in conducting approvals and prevent its certification staff from doing extensive research for each approval project.”
A bilateral agreement has long been in place between the U.S. and China that covers Chinese validation of all U.S. aircraft categories. But for U.S. validation of Chinese aircraft, it covers only those weighing less than 12,500 pounds.
China hopes eventually to expand on that agreement for the U.S. validation of larger Chinese aircraft, providing a strong incentive for the CAAC to partner with the FAA and manufacturers on the certification process. The CAAC is motivated to demonstrate its experience and competency in handling the certification tasks, Desrosier said.