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CMM is essential to the continued airworthiness of the aircraft.
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In the Matter of Warbelow’s Air Ventures, Inc., FAA Order No. 2000-3, Docket
No. CP97AL0012 (February 3, 2000)(IOP 19), the FAA imposed a civil penalty
on an air carrier for operating an unairworthy aircraft contrary to sections 91.7(a)
and 135.25(a)(2). Specifically, the two aircraft had been flown for almost 1,400
hours with improperly modified and repaired fuel pumps. In affirming the law
judge’s finding that the aircraft were operated in an unairworthy manner because
the fuel pumps were not in condition for safe operation, the Administrator stated:
The Romec manual for the fuel pumps provides: ‘Avoid
application of excessive torque when tightening valve cover
mounting screws. Tighten screws progressively to 29-31 lb.-
in. torque.’ (emphasis in original). Rimer did not have a copy of the
Romec manual when he modified the two fuel pumps. He did not
know the proper torque values and did not use a torque wrench. It
is undisputed that if the screws are not tightened properly the fuel
pumps may leak, resulting in a fire hazard.
In the matter of USAir, FAA Order No. 92-48, Docket No. CP91NM0183 (July 22,
1992) (IOP 20), the FAA found that USAir operated an unairworthy aircraft
contrary to section 121.153(a)(2). The aircraft had sustained damage to its nose
gear water deflector during pushback from the gate. Because the aircraft no
longer conformed to its type certificate, the Administrator affirmed the law judge’s
finding that the aircraft had been operated in an unairworthy manner.
V. CONCLUSION
Complainant requests that the FAA initiate an informal investigation and
thereafter issue an order finding that Airbus is in violation of section 21.50(b).
The Complainant has provided the Administrator with the necessary IOPs
establishing violations of section 21.50(b).
If there is any doubt about the merits of Complainant’s position, ARSA urges the
Administrator to issue an order of investigation in accordance with Part 13,
Subpart F. A formal investigation would allow the Administrator to name a
Presiding Officer, issue subpoenas, take depositions, hold an evidentiary public
hearing and issue a written report of the investigation.
ARSA urges the FAA to consider this Complaint in the broadest possible terms.
In the Association’s view, it would make little sense for the Administrator to issue
a ruling favorable to Aerotron and TPS without recognizing that the same issues
apply throughout the aviation maintenance industry. Ultimately, Complainant
requests that the Administrator enforce the ICA requirements against design
approval holders as diligently as it enforces them against maintenance providers
and operators.
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Respectfully submitted,
Marshall S. Filler
Catherine Dépret
E: msf@potomac-law.com
E: catherine@potomac-law.com
Counsel to Complainant Aeronautical Repair Station Association
Obadal, Filler, MacLeod & Klein, P.L.C.
117 North Henry Street
Alexandria, VA 22314-2903
T: 703-299-0784
F: 703-299-0254
October 3, 2003
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CERTIFICATE OF SERVICE
I, ________________________________, certify that on October ____, 2003, I
caused the executed original and one copy of the foregoing Aeronautical Repair
Station Association Part 13 Complaint on section 21.50(b) of the Federal Aviation
Regulations to be delivered via _____________________ to:
Federal Aviation Administration
Office of the Chief Counsel
800 Independence Avenue, S.W.
Washington, D.C. 20591-0004
ATTN: Enforcement Docket AGC-10
Signature
22
COMPONENT MAINTENANCE MANUAL
WITH
ILLUSTRATED PARTS LIST
Decorative Window Shade Assembly
A320-113M2165
Second Issue: JAN 10/05
25-23-08 JAN 10/05
Lou Martin & Assoc., Inc.
Component Maintenance Manual
25-23-08
Lou Martin & Assoc., Inc.
Component Maintenance Manual
25-23-08
Record of Revisions
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IR 07 DEC 04 07 DEC 04 C. MEDINA
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Lou Martin & Assoc., Inc.
Component Maintenance Manual
25-23-08
Lou Martin & Assoc., Inc.
Component Maintenance Manual
25-23-08
Record of Temporary Revisions
Temporary Page Issued By Date By
Rev No. Number Date Removed
Record of Temporary Revisions
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JAN 10/05
Lou Martin & Assoc., Inc.
Component Maintenance Manual
25-23-08
Lou Martin & Assoc., Inc.
　
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