ARSA Submits Recommendations for FAA's Proposed AMOC Guidance

The association recommends that the agency address "means of compliance" to an AD and provide FAA personnel with a more consistent and appropriate method for judging an AMOC.


ALEXANDRIA, VIRGINIA, AUGUST 17 – The Aeronautical Repair Station Association (ARSA) submitted a number of recommended changes to Federal Aviation Administration (FAA) draft Order 8110.103A, which outlines the agency’s process for issuing or denying Alternative Means of Compliance (AMOC) requests to Airworthiness Directives (ADs).

“As a member of the FAA’s Airworthiness Directive Implementation Aviation Rulemaking Committee, ARSA is committed to working with the FAA to strengthen all aspects of AD compliance, including the AMOC process,” said Sarah MacLeod, ARSA executive director.

ARSA’s proposed changes align the draft Order with the FAA’s regulatory responsibilities and ensure that AMOCs are issued only when necessary. The association also recommended that the agency address “means of compliance” to an AD and provide FAA personnel with a more consistent and appropriate method for judging an AMOC. These suggested changes to procedures would help the agency reduce the number of AMOCs, enabling more consistent and uniform compliance with established ADs.

To view ARSA’s letter to the FAA highlighting the recommended changes, visit www.arsa.org/files/ARSAComments-Order8110-103-20100806.pdf.

ARSA is an Alexandria, Virginia-based trade association that represents aviation maintenance and manufacturing companies. The association has a distinguished 25-year record of advocating for repair stations and providing regulatory compliance assistance to the industry. More information about ARSA is available at www.arsa.org.

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