Sturgell

MEMORANDUM **

The Restricted Category Aircraft Association (“RCAA”) petitions for review of a final order of the Federal Aviation Administration (“FAA”), which adopted a new Airworthiness Directive (“AD”) for certain Honeywell International Inc. (“Honeywell”), T53 turboshaft helicopter engines. The AD mandates reduced life limits on certain components of Honeywell’s T53 engines for all applications within the jurisdiction of the FAA. Pursuant to the AD, operators of T53 engines must also use predetermined cycle-counting methods and comply with drawdown schedules to replace components that currently exceed the new life limits.

We have jurisdiction to review RCAA’s petition under 49 U.S.C. § 46110 (a). Under the Federal Aviation Act, “[f]indings of fact by the [agency], if supported by substantial evidence, are conclusive.” 49 U.S.C. § 46110 (c). In the absence of a contrary provision in the organic statute, we review the FAA’s nonfactual determinations according to the standard provided by the Administrative Procedure Act (“APA”). See City of Sausalito v. O’Neill, 386 F.3d 1186 , 1205 (9th Cir.2004) (“Because the statutes under which [plaintiff] seeks to challenge administrative…