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UPDATE: The FAA has withdrawn Policy Memorandum AIR100-16-160-PM09.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issuance of the policy memorandum conflicted with the agency’s document release procedures and should likewise be withdrawn.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

Training Series Underway – Part 145 in Total

In July and August, ARSA is administering a series of online training sessions combining to walk through every section of 14 CFR part 145, “Repair Stations.” The new series replaces…Read More

ARSA Remembers – Dave Harrington

Colonel David R. “Dave” Harrington , a decorated Air Force pilot, Distinguished Flying Cross recipient, former FAA Flight Standards Service director, husband, father, Pop Pop, and friend, died peacefully on…Read More

On Demand Workshop – It All Starts with the Law

The recording of ARSA’s special workshop providing the regulatory and statutory foundation for compliance is available on demand. The resource was presented to FAA personnel as part of the association’s…Read More

On Demand Training – Employee Reporting & Root Cause Analysis

Two Safety Management Systems Training Sessions are now available through ARSA’s training program for registration and immediate on-demand viewing. The trainings were co-administered by ARSA and the Aircraft Electronics Association…Read More

Digital Attention Dominates FAA/EASA Conference

The 2026 FAA/EASA International Safety Conference returned to the United States with outsized focus on digitalization and artificial intelligence. ARSA’s Christian Klein and Brett Levanto joined several member company representatives…Read More
ARSA