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obligation of the design approval holder under section 21.50(b). The
Whitlow letter, issued by the highest-ranking career lawyer in the
FAA, did not believe the type certificate holder needed to specifically
reference the supplier’s CMM in the product’s ICAs. Indeed, it
explicitly stated that the airframe component ICAs were required to
be made available if the application for the type certificate was made
after January 28, 1981.
The FAR, the Whitlow letter and Flight Standards-initiated enforcement cases
clearly apply to maintenance performed on and off the aircraft. When
component maintenance is performed off the aircraft, the CMMs allow
maintenance providers to fulfill their regulatory obligations under Parts 43 and
145; in other words, to perform airworthy repairs. This includes (1) determining
the degree of inspection required, (2) the criteria for determining whether a
specific part may be continued in service (applicable wear tolerances) and, (3)
the specific work that must be performed before the component may be
approved for return to service. (Part 25, Appendix H, paragraph H25.3).
4. Airbus has an obligation under section 21.50(b) to provide
the ICAs for the Liebherr components
Liebherr manufactures specific components installed on the Airbus A320. It does
not to provide CMMs to duly authorized maintenance providers. Unlike Airbus,
Liebherr does not hold an FAA design approval and therefore is not bound by
section 21.50(b).
However, as the design approval holder for the A320 series aircraft, Airbus must
comply with section 21.50(b). As the Whitlow letter explicitly stated:
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The fact that [the TC holder] has historically used vendors to
supply components would not obviate its obligation to comply
with section 21.50(b); that section clearly states that the
obligation to provide [ICAs] rests with the holder of the design
approval. [The TC holder] may not avoid its obligations under
FAA regulations by entering into contracts that conflict with
the regulations. Furthermore, the fact that [the TC holder] and
some of its vendors have supplied the original owners or
operators with [ICAs] would not obviate the design approval
holder’s obligation to also provide [ICAs] “thereafter … to any
other person required to comply with any of the terms of the
[ICAs].” (emphasis added)
If this information is not contained in the AMM, the design approval holder
must ensure that the CMM is made available as required by section
21.50(b).
5. Repair stations are required to comply with the ICAs
Aerotron and TPS are certificated repair stations rated to perform maintenance,
preventive maintenance and alterations on the Liebherr air cycle machine, flow
control and check valves. Under both the current and new Part 145, Aerotron
and TPS are required to obtain and keep current the ICAs for these articles. The
repair stations’ customers include Parts 121 and 135 air carriers. Section 145.2
(and new section 145.205) directs the repair stations to follow the maintenance
manual of the air carrier when they perform work on the carrier’s behalf. With
respect to component maintenance, air carriers direct their maintenance
providers to perform the work in accordance with the manufacturer’s CMM.
The Whitlow letter concluded that FAA certificated repair stations are “other
persons required by [Chapter I of Title 14 of the CFR] to comply with any of the
terms of the instructions.” The letter correctly observed that even if the aircraft
manufacturer was not “technically” required by section 21.50(b) to provide
component ICAs (because application for the type certificate for the BAe-146
was filed prior to January 28, 1981), such a refusal was “puzzling, at best, and,
at worst, [was] an artificial obstacle to ensuring that each BAe-146 airplane
is maintained in an airworthy condition.” (emphasis added). The date
specified in section 21.50(b) presents no such restriction in this case since the
type certificate for the Airbus A320 was applied for after January 28, 1981.
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C. The Liebherr CMMs are Essential to Continued Airworthiness
1. Component maintenance instructions
Part 25, Appendix H, paragraph H25.1 (b) provides:
[I]f Instructions for Continued Airworthiness are not supplied by the
manufacturer of an appliance or product installed in the airplane,
the Instructions for Continued Airworthiness for the airplane must
include the information essential to the continued airworthiness
of the airplane. (emphasis added.)
Because Liebherr has elected not to supply CMMs to repair stations, Airbus is
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