FAA Position Papers - what are they?

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Well, quite simply they are a presentation of facts and data to support a client's desire to get FAA engineering buy in on some technical issue or maintenance issue that they are presented with. Effectively the DER ca assist the applicant with gathering the information, resources and data to make a cogent argument that can be presented to the applicant's local Flight Standards District Office or FSDO or to get engineering concurrence for some technical issue from the local Aircraft Certification Office or ACO.

Examples that MROTechnologies has worked on include:

1) The application of one STC'ed item (wire strike protection system) over another STC'ed item (new glass cockpit) for McDonnell Douglas 369 Series Helicopter

2) Assisting the applicant in getting an extension on the overhaul time requirement for JT-12 engines on an experimental aircraft flying low hours each year and to demonstrate an adequate maintenance program supported by lots and lots of data

3) Change from a standard lubrication product for rotrocraft transmissions to a synthetic lubricant for a S76 helicopter.

These are just a few examples but any time a client is having difficulty communicating with the FSDO or ACO a Designated Engineering Representative may be ableto help bridge the gap and get your issue(s) resolved. Note that there are no official forms signed with Position Papers. These documents only provide technical justification for why something should be allowed by the applicant and are more in the spirit of an alternate means of compliance.