Join ARSA Ask ARSA Pay ARSA

FAA Officially Withdraws Memo Incorrectly Defining ‘Engine Influencing Parts’

On Dec. 19, ARSA received a letter from Susan Cabler, acting manager of the FAA’s Design, Manufacturing & Airworthiness Division (AIR-100), announcing the withdrawal of FAA Policy Memorandum AIR100-16-160-PM09.

The announcement came in response to an Oct. 14 request jointly submitted by ARSA and Airlines for America (A4A) to the agency. That original letter noted the memo erroneously relied on Advisory Circular 33.70-1 to define “engine influencing parts.” Cabler’s response was light on details, but noted the FAA will continue to coordinate future policy regarding additive manufacturing – the subject of the memo in question –  meaning that maintenance providers must remain attentive to continued attempts to constrain parts production.

To read the response letter, click here.

For information on ARSA and A4A’s initial request, review the content below.

For information on a legislative effort joined by a number of aviation associations to prevent Congressional incursion into parts markets, click here.

Previously from ARSA...

11/1/16 - (UPDATED) ARSA, A4A Remind FAA It's Never Defined 'Engine Influencing Parts'

November 1, 2016

UPDATE: The FAA has withdrawn Policy Memorandum AIR100-16-160-PM09. Although no reason has yet been specified by the agency, the association is hopeful it was because of the joint request filed by ARSA and A4A on Oct. 14 (see below).


Oct. 17, 2016

On Oct. 14, ARSA and Airlines for America (A4A) jointly requested the withdrawal of FAA Policy Memorandum AIR100-16-160-PM09 because it erroneously relied on Advisory Circular 33.70-1 to define “engine influencing parts.”

Despite the memo’s contention to the contrary, the term does not appear any of the agency’s guidance nor 14 CFR part 33. The associations’ request further noted that the FAA’s issuance of the policy memorandum conflicted with the agency’s document release procedures and should likewise be withdrawn. Both organizations emphasized the agency should not impose any additional requirements for influencing parts without specific regulatory authority or public comment.

To read the full ARSA/A4A submission, click here.

To see all the ways ARSA works on behalf of the aviation maintenance community, visit the ARSA Works page.



More from ARSA

Grantham Gets Cycle’s First ARSA PAC Contribution

Air Force and aviation industry veteran Travis Grantham, a candidate for Arizona’s fifth congressional district, has received the first ARSA Political Action Committee (PAC) contribution of the 2026 election cycle.…Read More

Review FAA’s Methods, Techniques, and Practices

The FAA has engaged industry to help review AC 43.13-1B Acceptable Methods, Techniques, and Practices—Aircraft Inspection and Repair that is applicable to aircraft inspection and repair. The AC primarily supports…Read More

FAA/EASA MAG Change 10 Released

NOTE: Following the publication of change 10 to the FAA/EASA Maintenance Annex Guidance, ARSA updated its cross-reference matrices for tracking bilateral compliance. The matrices provide a method to compare quality system/manual…Read More

Drafting Regulatory Purpose into Order 8130.21

On June 17, ARSA and the Aircraft Electronics Association (AEA) jointly submitted a rewrite of the FAA’s Draft Order 8130.21J, “Completion of FAA Form 8130-3 under 14 CFR part 21.”…Read More

ARSA Leads D&A Action at EASA-FAA Conference

ARSA Executive Vice President Christian Klein joined global aviation regulators and industry leaders in Cologne the week of June 9 for the annual EASA-FAA Safety Conference. Klein attended to present…Read More
ARSA