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UPDATE: The FAA has withdrawn Policy Memorandum AIR100-16-160-PM09.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issuance of the policy memorandum conflicted with the agency’s document release procedures and should likewise be withdrawn.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

AMT Day 2022 – Celebrating Charlie

Charles Taylor, the Wright Brothers’ mechanic and father of aviation maintenance, was born on May 24, 1868. Now – 154 years later – we celebrate him with every safe arrival…Read More

ARSA Survey – Workforce Remains Top Concern

ARSA’s 2022 member survey paints a picture of an industry slowly recovering from the pandemic but still suffering a severe labor shortage. In total, 108 member companies from around the…Read More

Hotline Highlight – Collaboration Brings Results

The hotline – ARSA’s premier member newsletter – contains news, editorial content, analysis and resources for the aviation maintenance community. All members should ensure they receive their edition the first week of…Read More

FAA Issues WebOPSS Access Workaround

The FAA will miss the June 15 deadline for updating its WebOPSS system to operate in the Microsoft Edge browser. Microsoft will decommission Internet Explorer, which was required for accessing…Read More

Quick Question – The Dynamic Regulatory System

It’s been more than six months since the FAA unveiled its Dynamic Regulatory System and the agency is preparing to decommission the Flight Systems Information Management System (FSIMS). As is…Read More
ARSA