IAE Quality Assurance

400 Main Street, M/S 121-10

East Hartford, CT 06108

Keith R. Morgan 

IAE Manager 

Certification & Airworthiness

October 28, 2013

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 111, 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.

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The installation of the IC 

would then be accomplished under IAE, AG’s Federal Aviation Administration (FAA) 

Production Certificate No. 114-NE.

IAE, AG has reviewed similar requests for exemptions 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);3and (b) Pratt & Whitney (P&W) on January 30, 2012, which was 

granted on May 8, 2012 (the P&W exemption)

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. IAE, AG agrees with and incorporates the 

justifications offered by GE and P&W in support of their respective petitions. 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 its 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 nos. 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, 2013

Page 2

RE: International Aero Engines AG Exemption 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.

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These responsibilities are fully described in contractual 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 above

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 activities 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 

is the best way to deliver a complete propulsion system 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.

 

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Section 21.139(a) requires 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 located outside the United States. This 

includes, but is not limited to, extending a PC outside the United States. 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 could mitigate a potential undue burden on the FAA. Such agreements 

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

Organization (ICAO).

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Part 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 sections contain the same 

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

Docket Operations

October 28, 2013

Page 3

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

Background

IAE, AG is the holder of engine type certificates issued by the FAA and other National 

Aviation Authorities (NAA) or their technical agents.

It has become increasingly common 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 IC

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) that have been certificated under parts 23, 25, 27 or 29, as applicable.

In this case, the IC for affected aircraft engines includes 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 safety of all installed IC. The quality, manufacturing and 

installation of the IC 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 exemptions, and IAE, AG agrees to comply with same. This includes, but is

not limited to the following: (a) the division of responsibility for design, quality, 

manufacturing, 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

Manufacturing Inspection District Office (MIDO); (c) an agreement would be executed

between IAE, AG and the aircraft TC holders authorizing IAE, AG’s use of the TC holders’

IC data; (d) the exemption would be limited to IC installed in the initial engine 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 through the aircraft TC holder’s Materials Review Board

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) airworthiness documentation

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

the engine.

Public Interest and Safety Showing

 

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

Docket Operations

October 28, 2013

Page 4

RE: International Aero Engines AG Exemption 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 existing commercial arrangements between aircraft and engine manufacturers 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 standards 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 certification 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

installing the IC after the initial engine build was completed.

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It 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 exemptions to both GE and P&W; therefore, this 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 exemptions.

 

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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 not conform 

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

Docket Operations

October 28, 2013

Page 5

RE: International Aero Engines AG Exemption 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 will 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 

implementation 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 the FAA for an exemption from §§ 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 10079 as amended, and Pratt & Whitney, pursuant to exemption 

10531.

Respectfully submitted,

Keith R. Morgan

Manager, IAE Certification and Airworthiness