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required information under section 21.50(b) (IOP 12). It set forth four
requirements that a repair station must establish before CMMs would be required
to be made available from the design approval holder. Those conditions are set
forth in italics below, with the relevant facts in bold.
1. Application for the latest related type certificate (original, amended or
supplemental) was made after January 28, 1981.
The A-320 type certificate was applied for on February 7, 1984.
2. The latest related certification basis includes [section] 21.50 as
amended 09/11/80 or later (and 2X.1529 or 3x.4, as applicable, i.e.,
the certificate holder was required to develop (furnish) ICAs as part of
the certification process.
The certification basis for the A320 encompasses Part 25,
Amendments 25-1 through 25-56. Part 25, Appendix H was added to
section 25.1529 by Amendment 25-54.
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3. The requester (repair station) of the ICA is currently rated for the
product/part and is required by Chapter 1 of 14 CFR to comply with the
ICA for the product/part.
The repair stations (Aerotron and TPS) and others similarly situated
are rated to perform maintenance on the specified Liebherr
components.
4. If the ICA data requested is a CMM or specific repair
information, the CMM or repair information is referenced in
higher-level ICA (airplane or engine ICA) as the appropriate
source of information for continued airworthiness actions
It is Complainant’s understanding that the Introduction section of the
Airbus’ A320 Aircraft Maintenance Manual (AMM) states that the
AMM provides information for performing maintenance on the
aircraft including references to the CMMs of its suppliers. The
supplier CMMs contain maintenance instructions specifically
required by Part 25, Appendix H, paragraph H25.3(b).
With respect to the Liebherr flow control valve P/N 751A0000
requested by TPS, it is Complainant’s understanding that the AMM
specifically refers to the Liebherr CMM and service bulletins for this
component. AMM task 21-51-51 describes the servicing of the pack
flow control valve. Airbus identifies the component manufacturer by
referring both to the Liebherr CMM (21-51-51) and Liebherr service
bulletins (SB).8 Complainant urges the FAA to examine the A320
AMM.
However, type certificate holders should not be able to circumvent
their obligations under section 21.50(b) merely by providing remove
and replace instructions for components. Indeed, this would be
contrary to Part 25, Appendix H, paragraph H25.3(b), which also
requires information on “the degree of inspection, the applicable
wear tolerances and work recommended at these periods.”9
When a component malfunctions, one that conforms to the approved
type design must replace it. Although the replacement part can be
8 ATA chapter 21 relates to the airplane’s air-conditioning system, sub-chapter 51 relates to the
air conditioning flow and section 51 relates to airflow control.
9 Although not directly at issue in this Complaint, FAA requirements in the engine ICA rules are
even more explicit. For example, in the engine overhaul manual section, the FAA requires
disassembly information, cleaning and inspection techniques, methods of overhaul, details of all
fits and clearances, details of repair methods for worn or otherwise substandard parts and
components along with the information necessary to determine when replacement is necessary,
the order and method of assembly, etc. Similar to Part 25, Appendix H, the engine ICA rules
apply to each engine and all engine parts (Part 33, Appendix A, paragraph A33.1(b)).
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new or used, Complainant requests the FAA to take administrative
notice of the fact that rotable components are routinely repaired and
replaced several times during their useful life. Indeed, there are
approximately 4,500 repair stations in the United States and most of
them perform maintenance on components off the aircraft.
We also request administrative notice of the fact that type certificate
holders require CMMs to be prepared as a condition of product
support agreements with their suppliers. Aircraft manufacturers
certainly recognize that operators would not purchase their aircraft if
all components that malfunctioned had to be replaced with new
ones. Additionally, aircraft owners and operators require
information necessary for the economical operation of their aircraft
in their purchase agreements, including detailed maintenance
information regarding the aircraft and its installed equipment.
The agency’s deputy chief counsel has previously determined that
making the CMM’s available to authorized repair stations is an
　
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