### IAE Quality Assurance

400 Main Street, M/S 121

- 10

East Hartford, CT 06108

Keith R. Morgan

IAE Manager

Certification & Airworthiness

October 28 , 201 3

SUBMITTED ELECTRONICALLY TO: Federal Docket Management System

, www.regulations.gov

U.S. Department of Transportation

Docket Operations

West Building, Room W12

- 140

1200 New Jersey Avenue, SE

Washington, D.C. 20590

- 0001

RE: International Aero Engines AG for Exemption from 14 CFR §§ 21.142 , 21.146 and

21.147

Dear Ladies and Gentlemen:

Pursuant to 14 CFR part 11 1

, International Aero Engines AG (IAE, AG) hereby petitions for

an exemption from §§ 21.142 and 21.147 to the extent necessary to amend its production

limitation record (PLR) to allow the installation of certain Interface Components (IC)

described in aircraft type certificates (TC) not held by IAE , AG

. Additionally, IAE , AG

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.

If the petition is granted the IC would be installed during the initial build of engines for which

IAE , AG is either the holder or licensee of FAA type design data

. 2 The installation of the IC

would then be accomplished under IAE , AG ’s Federal Aviation Adm i nistration (FAA)

P roduction C ertificate N o. 114

- NE

.

IAE , AG h as reviewed similar request s for exemption s submitted by (a) GE Aviation on

August 19, 2009

, which was granted on June 15, 2010 and amended on September 27,

2010 ( the GE exemption ); 3 and (b) Pra tt & Whitney (P&W) on January 30, 2012, which was

granted on May 8, 2012 ( t he P&W exemption ) 4

. IAE , AG agrees with and incorporates the

justification s offered by GE and P& W in support of their respective petition s . In addition,

IAE , AG agrees to comply with the conditions and limitations imposed by the FAA in its

initial grant of the GE exemption

, the September 2010 amendment to the GE exemption

, and it s grant of the P&W exemption.

1 All citations are to 14 CFR unless otherwise noted.

2 This may include type certificates issued under § 21.21 or § 21.29.

3 Exemption no s. 10079 and 10079A ; docket number FAA

- 2009

- 0772

. 4 Exemption no. 10531; docket number FAA

- 2012

- 0120.U.S. Department of Transportation

Docket Operations

October 28

, 201 3

Page 2

RE: International Aero Engines AG E xemption from 14 CFR §§ 21.142 and 21.147

In accordance with § § 11.81(h) and 11.83

, IAE , AG also requests that the FAA extend this

relief to allow some of the manufacturing activities to be performed outside the United

States in accordance with other provisions of part 21 that are not covered by this exemption

request

. 5 Th e se responsibilities are fully described in co ntractual agreements between IAE

, AG and its various commercial partners

.

Pertinent Regulations and Guidance

Section 21.132 permits qualified persons to apply for a production certificate (PC) when

they hold for the affected product a TC, supplemental type certificate (STC) or rights to a

TC/STC under a licensing agreement.

Section 21.142 states that the FAA issues a PLR as part of a PC. The PLR lists the TC

number and model of every product that the PC holder is authorized to manufacture

.

Section 21.147 specifies that the holder of a PC must apply for an amendment to that

certificate in a form and manner prescribed by the FAA. The applicant for an amendment to

a PC to add a TC or model, or both, must comply with the applicable requirements of

§§21.137, 21.138, and 21.150

The FAA’s Production and Airworthiness Division ( AIR

- 200 ) clarified the a bove

requirements by issuing a memorandum on October 3, 2008 confirming that a PC/PLR may

not be issued or amended based on partial or limited licensing agreements in order to

permit production of only certain parts or components included in a TC or STC. The

memorandum set forth several alternatives that would allow such activ ities to take place,

including requesting and obtaining an exemption from §§ 21.142. 6 IAE

, AG has analyzed

the options in the October 3, 2008 AIR

- 200 memorandum and concluded that an exemption

i s the best way to deliver a complete propulsion sy stem for installation on the affected

aircraft.

For these reasons

, IAE , AG requests an exemption from §§ 21.142 and 21.147.

Additionally, IAE , AG 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.

5 Section 21. 139(a) require s the FAA to find that there would be no undue burden on the agency if the

manufacturing facilities of a production certificate ( PC ) holder are locat ed outside the United States. This

includes, but is not limited to

, extending a PC outside the U nited S tates

. A similar finding is also required

by § 21.325(c) before export airworthiness approvals may be issued for products located outside the

United States. In both situations , bilateral agreements may authorize the execution of technical

assistance arrangements which c ould mitigate a potential undue burden on the FAA. Such agreements

are consistent with the sta ndards in Annex 8, chapter 2 adopted by the International Civil Aviation

Organization (ICAO).

6 P art 21 was amended after the October 3, 2008 memorandum was issued, and the corresponding new

section numbers are §§ 21.142 and 21.147, respectively. The new s ections contain the same

requirements as the old rules with some minor editorial changes.U.S. Department of Transportation

Docket Operations

October 28

, 201 3

Page 3

RE: International Aero Engines AG E xemption from 14 CFR §§ 21.142 and 21.147

Background

IAE , AG i s the holder of engine type certificates issued by the FAA and other Nationa l

Aviation Authorities (NAA) or their technical agents.

It has become increasingly com mon for aircraft manufacturers and air carriers to request

delivery of a complete propulsion system including the type

- certificated engine plus other

articles (i.e., the I C 7 ) that have been certificate d under parts 23, 25, 27 or 29, as applicable.

In this case, t he IC for a ffected aircraft engine s include s the nacelle, engine mounts and

various piece parts for the engine build unit (EBU)

.

The IC will be manufactured by suppliers to the aircraft TC holder and/ or suppliers to IAE

, AG or its partner parties. In all cases , the aircraft TC holder will be responsible for the

design and continued operational safe ty of all installed IC. The quality, manufacturing and

installation of the I C would occur under the authority of IAE , AG ’s PC No. 114

- NE and the

requested exemption

.

Conditions and Limitations

IAE , AG has analyzed the 14 conditions and limitations that were made a part of both the

GE and P &W exemption s

, and IAE, AG agrees to comply with same . This includes , but is

not limited to the following : (a) t he division of responsibility f or design, quality,

manufactur ing, installation and continued airworthiness of the IC would be clearly defined ; (b ) the application for amending the PLR would be submitted to IAE , AG ’s local

M anufacturing I nspection D istrict O ffice (MIDO) ; ( c ) an agreement would be executed

between IAE , AG and the aircraft TC holder s authoriz ing IAE , AG ’s use of the TC holders’

IC data ; (d) the exemption would be limited to IC installed in the initial en gine build (i.e.,

shipment of spare IC would not be authorized under IAE , AG ’s PC ) ; ( e ) amendments would

be made to IAE , AG ’s quality manual and other procedures pertinent to the requested

activities ; ( f ) the exemption would be limited to those engines listed on IAE , AG ’s PC ; ( g )

coordination would take place between IAE , AG and the responsible IAE , AG certification

directorates prior to installing the IC into the engine ; ( h ) procedures would be developed for

dispositioning IC discrepancies throu gh the aircraft TC holder’s M aterials R eview B oard

system ; ( i ) procedures would be developed for ensuring that the completed engine

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

its approved type design and is in condition for safe operation, and the completed engine

with the installed IC is in condition for safe operation ; and ( j ) airworthi ness documentation

would reference the exemption and make the required certifications regarding the IC and

the engine.

Public Interest and Safety Showing

7 The IC includes individual parts and kits comprising multiple parts.U.S. Department of Transportation

Docket Operations

October 28

, 201 3

Page 4

RE: International Aero Engines AG E xemption from 14 CFR §§ 21.142 and 21.147

It is undoubtedly in the public interest for production approval holders to manufacture

aircraft and engines in the safest and most cost

- efficient manner consistent with regulatory

requirements and sound public policy

. Similarly, it is in the public interest for the FAA to

facilitate e xisting commercial arrangements between aircraft and engine manufac turers and

their suppliers. To this end, many such contracts require the engine to be delivered as a

complete propulsion system. This requires engine manufacturers to install articles

certificated under the airworthiness s tandards of parts 23, 25, 27 or 29 during the initial

engine build (i.e., prior to the engine’s complete assembly, test and identification).

Granting the requested exemption would streamline the engine and aircraft manufacturing

process and potentially reduce the need for duplicative c ertification efforts associated with

some of the other options described in the October 3, 2008 AIR

- 200 memorandum. More

importantly, it would enhance safety by reducing the risk of engine damage associated with

install ing the IC after the initial engine build was completed

. 8 I t would also facilitate quick

engine changes on in

- service aircraft by reducing the complexity of the maintenance

process.

For these reasons and in accordance with § 11.81(e) , granting the exemption would be in

the public interest and result in a level of safety at least equal to that required by the

regulations from which the exemption is sought.

Good Cause Exists to Issue the Exemption without Notice and Comment

IAE , AG requests that the FAA issue the exemption without publication for notice and

comment in the Federal Register as is normally required.

Section 11.87 lists four factors that the agency considers in deciding whether a petitioner

has shown good cause for the FAA not to delay action on the petition . Those factors are set

forth below in italics along with the company’s response in plain text :

(a) Whether granting the petition would set a precedent: The FAA has previously issued

similar exemption s to both GE and P&W ; therefore, th is request would not set a

precedent.

(b) Whether the relief requested is identical to exemptions previously granted : The relief

is the same as that requested in both the GE and P&W exemptions, and IAE , AG

agrees to comply with the same conditions and limitations imposed by the FAA in

granting both of those exemption s.

8 IAE , AG has analyzed the potential adverse effects associated with having to partially disassemble the

engine to install IC subsequent to the engine build. This includes possible damage to flight safety critical

parts; scoring of fatigue sensitive parts; air, fuel and oil leaks and damage to the engine flange. Although

processes have been developed to mitigate these risks , the risk is completely eliminated if the exemption

from § 21.146 is granted to the extent necessary to manufacture completed engines that do no t conform

to their approved design solely because of the installed IC.U.S. Department of Transportation

Docket Operations

October 28

, 201 3

Page 5

RE: International Aero Engines AG E xemption from 14 CFR §§ 21.142 and 21.147

(c) Whether delaying action would adversely affect IAE , AG : Delaying action for the full

120 days or longer required for the notice and comment process wil l make it more

difficult for IAE , AG to make the necessary arrangements to conduct the requested

activities. As the FAA is aware, granting the exemption will require the drafting and

implementat ion of many new procedures in accordance with the anticipated

conditions and limitations

. (d) Whether the petition was filed in a timely manner : The petition is timely filed

.

In light of the above considerations IAE , AG submits that good cause exists not to delay

action on this request.

Summary of Exemption Request

In accordance with § 11.81(e), IAE , AG offers the following summary suitable for publication

in the Federal Register in the event the FAA believes that good cause to waive publication

has not been established.

IAE , AG petitions th e FAA for an exemption fr om §§ 21.142 , 21.146 and

21.147 to allow the installation of certain Interface Components (IC)

described in aircraft type certificates (TC) not held by IAE , AG . The

exemption would apply to the initial build of engines for which IAE , AG is the

TC holder or licensee of engine type design data. The relief sought is

identical to that previously provided to both GE Aviation

, pursuant to

exemption 1 0 079 as amended , and Pratt & Whitney, pursuant to exemption

10531

.

Respectfully submitted,

Keith R. Morgan

Manager, IAE Certification and Airworthiness