Turbine Engine Repairs and Alterations AC

Draft AC 33-XX proposed to substantially revise the current procedures for approving technical data supporting major turbine engine repairs and alterations.

ARSA finds the draft AC to be contrary to existing regulations, exceeds the authority delegated to the Engine and Propeller Directorate, impermissibly attempts to regulate through guidance and would impose new administrative burdens on independent maintenance providers and Designated Engineering Representatives (DER) without an adequate safety basis.

The draft AC created two classes of applicants who seek the approval of technical data supporting turbine engine repairs and alterations: (1) type certificate holders and their licensees, and (2) "independent" maintenance providers.

In most cases, technical data supporting major turbine engine repairs and alterations can be approved today by authorized DERs. The proposed AC would subject many more repairs and alterations to FAA review if they are developed by independent providers. Many independents are among the most highly technologically sophisticated companies in the world whose repairs and alterations have increased safety and reliability. In ARSA’s view, neither the regulations nor the safety record justifies the FAA’s approach.

The Association believes that the existing regulatory scheme for approving technical data has helped the industry achieve a remarkably high level of safety. Operational experience with independently developed turbine engine repairs and alterations supports that view.

To the extent independent DERs have not obtained adequate substantiation prior to making compliance findings, ARSA recommends that the FAA improve the training and oversight of these designees rather than propose wholesale changes to its highly successful data approval process.

Download the AC and ARSA's comments from the ARSA Library at this link.