AIR-14-167-E

April 2, 2014

 Exemption No. 10531A

 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 petition to extend Exemption No. 

10531. It explains the basis for our decision, describes its effect, and lists the conditions and 

limitations.

The Basis for Our Decision

By letter dated February 6, 2014, you petitioned the Federal Aviation Administration (FAA) 

on behalf of Pratt & Whitney (P&W) to extend Exemption No. 10531 from §§ 21.142, 

21.146, and 21.147 of Title 14, Code of Federal Regulations (14 CFR). The exemption allows 

the manufacture and installation of interface components described in an aircraft type 

certificate held by P&W’s commercial partners rather than P&W. 

In your petition, you indicate that there has been no change in the conditions and reasons 

relative to public interest and safety that were the basis for granting the original exemption.

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

in the Federal Register because the requested extension of the exemption would not set a 

precedent, and any delay in acting on this petition would be detrimental to P&W.
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Our Decision

The FAA has determined that the justification for the issuance of Exemption No. 10531

remains valid with respect to this exemption and is in the public interest. Therefore, under the 

authority provided by 49 U.S.C. 106(f), 40113 and 44701, which the FAA Administrator has 

delegated to me, I grant Pratt & Whitney (P&W) Division of United Technologies 

Corporation an exemption from §§ 21.142, 21.146 and 21.147 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. Pratt & Whitney (P&W) may manufacture interface components (IC), which includes 

single articles or kits that are part of a product type certificate (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 production limitation 

record (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 

(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.
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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.

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., 
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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 maintenance review board action).

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.

The Effect of Our Decision

Our decision extends the termination date of Exemption No. 10531 to May 31, 2016 unless 

sooner superseded or rescinded.

Sincerely,

/s/

Dorenda D. Baker

Director, Aircraft Certification Service