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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UPDATE: The FAA has withdrawn Policy Memorandum AIR100-16-160-PM09.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FAA’s issuance of the policy memorandum conflicted with the agency’s document release procedures and should likewise be withdrawn.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.



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