After urging from industry trade associations, thehas withdrawn a policy memorandum (AIR100-16-160-PM09) regarding “influencing parts,” a term referred to in Advisory Circular 33.70-1, Guidance Material for Aircraft Engine Life-Limited Parts Requirements, as “other engine parts [that] can affect the life-limited parts, including their life capability.”
According to the Aeronautical Repair Station Association and Airlines for America, the agency improperly sought to impose additional requirements for “influencing parts” without specific regulatory authority or public comment. In a letter asking that the memo be withdrawn, the trade associations cited the FAA’s own internal policy that states: “[A]s a minimum, the public shall be notified, given access to the policy and guidance, and given an opportunity to comment. It shall also be the norm that public comments shall be appropriately considered before a generic policy is issued.”
In its letter withdrawing the memo, the agency added: “[A]dditive manufacturing is a new and novel technology without current statute, regulation, guidance or industry-wide accepted standards,” and it suggested that future regulatory action is in the works.
This is not the first time the trade organizations have joined forces to prevent FAA incursion into the parts markets. Last summer, a coalition of aviation groups sent a letter to congressional leaders in response to a legislative proposal to require the identification and marking of “influencing parts.” According to the group, the law would have mandated duplicative requirements without enhancing safety: “The current regulatory framework (including rules and related guidance) dealing with all aircraft parts, particularly ‘life-limited’ and so-called ‘influencing parts,’ has a proven safety record. Unfortunately, without any safety justification, self-interested parties are targeting the alternative parts industry by pursuing anti-competitive policies that will increase costs for private aircraft owners and operators, small and large businesses, air carriers, repair stations and the flying public.”
Thus far, the coalition has successfully prevented legislative action on the issue.