Late last month MARPA filed comments with the FAA on Draft Policy Statement ANE-35.1-01-R1 Parts Manufacturer Approval (PMA) for Propeller Critical Parts and Category 1 Propeller Parts. As we previously explained on this blog, the draft language of the policy would substantially broaden the definition of “propeller critical parts,” thus rendering a significantly larger set parts subject to the requirements of 14 C.F.R. § 35.16 (without regulatory justification), which establishes the requirements for propeller critical parts. This could create several challenges for manufacturers of propeller PMAs.
MARPA’s comments noted several problems the proposed policy statement would create:
- A broadened (and unsupported by the Federal Aviation Regulations) definition of “propeller critical part”
- An undefined requirement for a “Life Management Program” that appears contrary to the Regulations
- Conflating “Critical” and “Category 1” parts such that they are all held to the same increased requirements
- Arbitrarily designates certain parts as “critical” without technical justification
- Could have the inadvertent effect of barring many PMA propeller parts from Europe.
MARPA’s comments addressed each of these issues–and more–and explained why the Draft Policy Statement should be withdrawn or at the very least amended.
MARPA is always working diligently to protect the PMA industry and advance the PMA industry’s interests, both with regulators and TC/PC holders. Our goal is to support the PMA industry–and especially our members–in every way we can, and make sure the PMA industry continues to grow and thrive. Filing comments like these to push back against potentially harmful policy is one of many things MARPA member dues go to support.
You can read MARPA’s full comments here.