AIR-12-205-E 

May 8, 2012 

 Exemption No. 10531 

 Regulatory Docket No. FAA-2012-0120 

Mr. Marshall S. Filler 

Counsel for the Pratt & Whitney Division of 

 United Technologies Corporation 

117 North Henry Street 

Alexandria, VA 22314-2903 

Dear Mr. Filler: 

This letter is to inform you that we have granted your request for exemption. It transmits our 

decision, explains the basis for our decision, describes its effect, and gives you the conditions 

and limitations of the exemption, including the date it ends. 

The Basis for Our Decision 

By letter dated January 30, 2012, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Pratt & Whitney (P&W) for an exemption from §§ 21.142 and 21.147 (14 CFR). 

That exemption from §§ 21.142 and 21.147 of Title 14, Code of Federal Regulations 

(14 CFR) would allow P&W to amend its production limitation record (PLR) to allow the 

installation of certain interface components (IC) described in an aircraft type certificate (TC) 

held by P&W’s commercial partners rather than P&W. Additionally, P&W requests an 

exemption from § 21.146 to the extent necessary to manufacture completed engines that do 

not conform to their approved design solely because of the installed IC. 

The FAA has determined that good cause exists for not publishing a summary of the petition 

in the Federal Register because the requested exemption would not set a precedent, and any 

delay in acting on this petition would be detrimental to P&W. 

The FAA has issued grants of exemptions in circumstances similar in all material respects to 

those presented in your petition. In Grant of Exemption Nos. 10079, 10079A, and 10079B 

(copies enclosed), the FAA found that the IC can be installed during production without 

adversely affecting safety provided the conditions and limitations of this exemption are met. 

The manufacturing process and configuration of the IC installation must be documented and 
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approved in a manner acceptable to the FAA. This relief is consistent with the agency’s 

efforts to refine and develop its regulations and explore processes that realize efficiencies and 

reduce risk. 

Having reviewed your reasons for requesting an exemption, I find that— 

 they are similar in all material respects to relief previously requested in the enclosed Grant 

of Exemption Nos. 10079, 10079A, and 10079B; 

 the reasons stated by the FAA for granting the enclosed Grant of Exemption Nos. 10079 

10079A, and 10079B; also apply to the situation you present; and 

 for the reasons in Grant of Exemption Nos. 10079, 10079A, and 10079B, a grant of 

exemption is in the public interest. 

Our Decision 

Under the authority contained in 49 U.S.C. §§ 40113 and 44701, which the FAA 

Administrator has delegated to me, I hereby grant Pratt & Whitney Division of United 

Technologies Corporation an exemption from 14 CFR §§ 21.142, 21.146 and 21.147 

(14 CFR) to the extent necessary to allow the manufacture and installation of IC described in 

an aircraft TC held by P&W’s commercial partners rather than P&W, subject to the 

conditions and limitations described below. 

Conditions and Limitations 

1. P&W may manufacture IC, which includes single articles or kits that are part of a 

product TC under parts 23, 25, 27 and 29, and install those components during 

production on P&W engines under P&W’s production certificate PC2. The design 

data for the IC must be licensed to P&W and the IC to be installed must be identified 

on the P&W PLR.

2. The IC added to the P&W’s PLR is limited to airframe components specified in 

condition No. 1. The relief provided by this exemption is limited to the manufacture 

of IC that is to be installed on P&W engines during engine production, shipped loose 

with a new engine or, as spare or replacement articles. 

3. To exercise the privileges of this exemption, P&W must apply to the manager of its 

FAA managing office using FAA Form 8110-12, Application for Type Certificate, 

Production Certificate, or Supplemental Type Certificate, requesting amendment of 

P&W’s PLR for the manufacture and installation of IC. The data licensed to P&W 

must be a complete data package and include design and installation drawings. That 

data must be made available to P&W and the FAA upon request. 

4. The IC listed on P&W’s PLR is limited to IC manufactured by P&W under P&W’s 

production certificate. The design data must be licensed from the holder of a U.S. TC 
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(including an FAA-validated TC) for the aircraft on which the P&W engine is to be 

installed. 

5. The application by P&W to its FAA managing office to amend its PLR must contain 

the following information: 

a. A comprehensive description of the scope of the proposed manufacturing and 

installation activity for the IC on each affected engine model under the 

provisions of this exemption. 

b. A specific description of the IC to be installed on each affected P&W engine 

model, including the part number. Kits combining IC must define the 

individual IC included in the kit. 

c. The licensing agreement between P&W and the holder of the TC that 

specifically identifies the IC to be installed. 

d. A description of the documentation to be maintained by P&W identifying the 

IC by its associated TC, P&W’s supplier of the IC (if applicable), and the 

P&W product on which the IC is installed. 

6. The holder of type design data identifying the IC installed on the P&W product under 

this exemption retains all the continuing airworthiness responsibilities for the IC. 

P&W is responsible for all issues related to quality, manufacturing, and installation of 

the IC by P&W. The P&W quality manual must include a description of how those 

responsibilities will be separated, identified, and fulfilled by P&W and the holder of 

the TC identifying the IC. 

7. When exercising the privileges of this exemption, the IC may only be installed under 

the provisions of P&W’s production certificate. 

8. P&W must have procedures and processes in place to ensure the engine, 

notwithstanding the installed IC, conforms to its approved type design, the IC 

conforms to its approved type design data, and the P&W product with the installed IC 

is in a condition for safe operation. 

9. Prior to manufacturing and installing IC on an engine under the provisions of this 

exemption, P&W must receive confirmation from its FAA certificate managing office 

that the FAA Transport Airplane Directorate and the FAA Engine and Propeller 

Directorate have determined that any component P&W intends to manufacture and 

install under the provisions of this exemption is an IC and that installing the IC during 

engine manufacture provides a level of safety that is equivalent to that achieved by 

installation of the IC after engine manufacture. 

 
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10. P&W must amend its quality manual to indicate that any FAA airworthiness approval 

documentation issued for an engine containing IC manufactured and installed under 

the provisions of this exemption must specify that the IC was installed on the product 

under a licensing agreement. 

11. Prior to the issuance of any FAA Form 8130-3 for a P&W engine manufactured under 

the P&W quality system and containing IC manufactured and installed under the 

provisions of this exemption, P&W must specify in block 13 of the form that: 

a. the IC was installed on the engine during manufacture in accordance with this 

Exemption No., 

b. the IC manufactured and installed under the exemption conforms to its type 

design, and 

c. the engine, excluding the IC installed, conforms to its type design. 

12. The privileges of this exemption are extended to P&W consortium engines when the 

engines are manufactured under P&W's quality system and completed as a product 

under P&W’s production certificate. This exemption does not apply when P&W is 

manufacturing components of a consortium product and the engine is completed under 

a separate production certificate. 

13. Before exercising the privileges of this exemption, P&W must have procedures for 

dispositioning discrepancies with the IC. Any authority granted by the TC holder in 

the licensing agreement, allowing for nonconforming material dispositions to be made 

by P&W, must be documented in P&W’s quality procedures. P&W has no authority 

to amend the type design of the IC. All changes to the type design must be made by 

the design approval holder (i.e., through mainenance review board action). 
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14. P&W’s manuals relevant to the exempted activity, such as maintenance/operation 

manuals, and parts catalogs, must be revised to reflect the exempted activity. 

This exemption terminates on May 31, 2014, unless sooner superseded or rescinded. 

Sincerely, 

/s/ 

Dorenda D. Baker 

Director, Aircraft Certification 

 Service 

Enclosures