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New FAA Policy Concerning § 33.83 Engine Surveys

The FAA has released a new draft Policy Statement concerning the vibration surveys and engine surveys required by § 33.83.  The new guidance clarifies that this regulation is intended to require a full engine test (for type certificate applicants).  The draft guidance, known as “PS‑ANE‑33.83‑01,” is currently available for public comment.

Members will recall that MARPA successfully opposed a final rule that would have applied the “full engine test” standard to PMA and STC applications.  At the time, our discussions with FAA representatives revealed that their real concern was applying the full engine test standard to engine type certificate applications, and not to PMAs.  The reference to PMAs and STCs, they explained, was an unfortunate mistake.

This draft guidance attempts to more narrowly address the FAA’s concerns about full engine test for type certificate applicants.

In order to ensure that the FAA’s intent is clear, MARPA plans to offer some additional language designed to clarify that this Policy Statement does not supersede the discussion laid out in FAA Advisory Circular 33-8 (Guidance for Parts Manufacturer Approval of Turbine Engine and Auxiliary Power Unit Parts under Test and Computation).  We will also look for opportunities to help the FAA meet their policy goals.

Comments are due to the FAA by November 21, 2014.  They can be emailed to dorina.mihail@faa.gov or mailed to her at:

Federal Aviation Administration
Engine and Propeller Directorate
Standards Staff, ANW-111
12 New England Executive Park
Burlington, MA 01803

Please share your comments with MARPA, too, so we can make sure our comments are consistent with the concerns of our members.

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About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

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  1. Pingback: Draft Policy Concerning § 33.83 Engine Surveys Due Next Week | MARPA - November 13, 2014

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